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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Student General Assistance Provisions – Readmission for Servicemembers

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any

legal or administrative requirements that necessitate the collection. Attach a hard copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

This is a request for an extension of the current information collection. As provided by

the Higher Education Opportunity Act, the regulations state the requirements under 

which an institution must readmit servicemembers with the same academic status they

had at the institution when they last attended (or where accepted for attendance). The 

regulations require institutions to charge readmitted servicemembers, for the first 

academic year of their return, the same institutional charges they were charged for the 

academic year during which they left the institution (see section 484C of the HEA). 

The regulations are a result of regulatory review of the program regulations to provide 

benefits to students, and protect the taxpayers' interest. This request is for continued 

approval of recordkeeping requirements contained in the regulations related to the 

administrative requirements of the readmission requirements for servicemembers 

program. The information collection requirements in the regulations are necessary to 

determine eligibility to receive program benefits and to prevent fraud and abuse of 

program funds.

General Provisions: (OMB control number: 1845-0095)

Section 668.18 contains information collections requirements. Under the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3507(d)), the Department of Education is submitting a 

copy of this section to the Office of Management (OMB) for its review. 

Section 668.18 (c) – Readmission procedures

 

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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

The regulations created procedures effective August 14, 2008, that provided for the 

readmission of a student who was required to leave an institution of higher education in 

order to fulfill a service requirement in the uniformed services. An institution is not 

allowed to deny readmission under prescribed conditions.

Section 668.18(g) – Documentation

The student who wishes readmission to an institution of higher education under this 

regulatory section shall provide documentation to the designated institution office(s) 

showing they haven’t exceeded the allowed service limitations and are eligible for 

readmission. Examples of acceptable documentation are included in this regulatory

section.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new 

collection, indicate the actual use the agency has made of the information received from the 

current collection.

This is a recordkeeping requirement for the institutions. They must retain the evidence of 

eligibility for readmission under this regulation in their files to be reviewed as required 

by regulation. The returning servicemember will provide documentation to the 

institution’s designated office(s) for the institution to determine eligibility for 

readmission by evidencing the time served and the continuing eligibility of the 

servicemember for readmission. 

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis for the 

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

The examples of satisfactory documents are all paper documents provided to the 

servicemember at the completion of the tour of service that caused the enrollment 

separation. Institutions may convert the information to an electronic format for storage 

purposes but this is not a requirement.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2 above.

There is no duplication of data as a result of the collection of this information.

5. If the collection of information impacts small businesses or other small entities, describe any

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

No small businesses are impacted by this collection.

6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing 

burden.

Recordkeeping requirements are imposed to assure accountability of program participants 

for proper program administration and less frequent collection could impair 

accountability of program participants.

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, 

grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

the information’s confidentiality to the extent permitted by law.

The information collection requirements require no special circumstances.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to 

submission to OMB. Summarize public comments received in response to that notice and 

describe actions taken by the agency in response to these comments. Specifically address 

comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

Consultation with representatives of those from whom information is to be obtained or those 

who must compile records should occur at least once every 3 years – even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may

preclude consultation in a specific situation. These circumstances should be explained.

This is the 30 day comment period request. The 60 day comment period for this 

collection package to solicit comments on the current burden assigned to this regulation 

was published as Federal Register Notice, Vol. 77, page 58819, on September 24, 2012. 

No comments were received during that comment period.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

No payments or gifts will be provided to the respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

These requirements do not cover any confidential information.

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

The Department is not requesting any sensitive data.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden was 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, estimates should 

not include burden hours for customary and usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

We estimate that 2,482 servicemembers will apply for readmission under this regulation. 

We estimate that it will take each servicemember approximately 10 minutes to gather 

together the appropriate documentation to provide to the school.

We estimate the time for schools to process the information provided will be 

approximately 30 minutes per individual servicemember. 

Affected Entities and Burden:

Revised Burden Inventory

# of # of # of Hours 

Respondents Responses Burden 

Individuals 2,482 2,482 X .17 hours = 422 hours

Institutions:

Public 794 794 X .50 hours = 397 hours

Private 745 745 X .50 hours = 373 hours

Proprietary 943 943 X .50 hours = 472 hours 

Subtotal 2,482 2,256 1,242 hours

TOTAL 4,964 4,964 1,664 hours

Current Burden Inventory

# of # of # of Hours 

Respondents Responses Burden 

4,512 4,512 1,513 hours
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

Difference in Current and Revised Burden

+452 +452 +151

Annual Cost of Burden to Respondents

We estimate that the cost to the institutional respondents will be:

# of Est. $ per Est. $ 

Respondents Response Burden 

Individuals 2,482 .45 = $1,117

# of Est. $ per Est. $ 

Respondents Response Burden

Institutions:

Public 794 X $24.61 X .50 hours = $9,770

Private 745 X $24.61 X .50 hours = $9,167

Proprietary 943 X $24.61 X .50 hours = $11,604

Subtotal 2,256 $30,541

TOTAL 4,964 $31,658

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

provide information or keep records for the government or (4) as part of customary and 

usual business or private practices. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There is no additional cost burdens associated with this collection other than those listed 

in item 12

14. Provide estimates of annualized cost to the Federal government. Also, provide a description 

of the method used to estimate cost, which should include quantification of hours, operational 

expenses (such as equipment, overhead, printing, and support staff), and any other expense that 

would not have been incurred without this collection of information. Agencies also may

aggregate cost estimates from Items 12, 13, and 14 in a single table.

There are no additional costs to the Federal government as a result of the regulation.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

This request is to extend the current information collection. There has been no revision 

to the required recordkeeping of the specific readmission regulations. The changes to the 

burden hour estimates are a result of an increase in the expected number of 

servicemembers who would apply for readmission under this regulation. The increase in 

the burden hours is treated as an adjustment.

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical techniques that will be used. Provide the time 

schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

The results of the collection of information will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.
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ICRAS Tracking and OMB Number: (1459.04) 1845-0095 v2 Revised: 11/21/2012

RIN Number: XXXX-XXXX (if applicable)

The Department is not seeking this approval.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department is not requesting any exceptions to the “Certification for Paperwork 

Reduction Act Submissions” of OMB Form 83-1.