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ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A
**SUPPORTING STATEMENT**

**FOR PAPERWORK REDUCTION ACT SUBMISSION**

**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 cop y 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 section 1

. Specify the review t ype of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The College Cost Reduction and Acce ss Act of 2007 (Pub. L . No. 110
- 84) and the Higher Education Opportunity

Act of 2008 (Pub. L. No. 110

- 315) amended Section 455 of the Higher Education Act of 1965, as amended, (the HEA) (20 USC 1087(e)(m)) to provide for the forgiveness of the outstanding balance of a borrower’s William D. Ford Federal Direct Loan (Direct Loan) Program loan(s) after the borrower has made 120 on

- time, monthly pay ments under a qualifying repay ment plan after October 1, 2007 while working for a qualifying public service organi zation. Final regulations for the Public Service Loan Forgiveness (PSLF) Program were published in the Federal Register on October 23, 2008 (73 FR 63256) and were codified in 34 CFR 685.219. These regulations require a borrower to submit an application for loan forgiveness to the U.S. Department of Education (the Department). To determine whether a borrower is eligible for loan forgiveness, the Department must confirm that the borrower was emplo yed full

- time by a qualifying public service organization at the time each of the required 120 pay ments was made. Because borrowers must make 120 pay ments on or after October 1, 2007 before becoming eligible for forgiveness, the earliest that any borrower could apply

for forgiveness under PSLF would be October 1, 2017. Consequently , no loan forgiveness application fo rm is required at this time. However, as the 2017 date approaches, the Department will submit a Public Service Loan Forgiveness Application for clearance, to be included as part of the same paperwork clearance package as the Employ ment Certification. Th e Department is not making substantive changes to the forms except as follows:

 Restructuring section 3 of the form to provide discrete, yes/no questions and answers.

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A

 Adding skip logic to section 3 of the form, to making it simpler for borrowers to complete.  Modifying language on the form to emphasize key points concerning the PSLF Program.  Merging the separate instructions document into the form, itself. 2. Indicate how, by

whom, and for what purpose the information is to be used. Except for a ne w collection, indicate the actual use the agency has made of the information received from the current collection. The Department and its Direct Loan Program servicers will use the information collected on the Employ

ment Certification for Public Service Lo an Forgiveness form to determine whether a borrower has worked for a qualified employ er during the certification period and whether pay

ments made against a borrower’s outstanding Direct Loan balance were qualifying pay

ments for the purpose of the Public Service Loan Forgiveness (PSLF) program. The submission of the Employ er Certification Form prior to applying for loan forgiveness is done at the borrower’s discretion. While the Department recommends that a borrower submit the Employer Certification Form annually , the borrower could submit the form when changing jobs, or could wait until he or she is eligible to submit an application for loan forgiveness and provide all Employ ment Certifications at that time. If the borrower submits Employ ment Certificat ions prior to the submission of an application for forgiveness, the borrower’s Direct Loan servicer will retain the form on the borrower’s behalf and notify the borrower many

pay ments made during the certification period of employ ment count toward the requ ired 120 pay ments. 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 s ubmission of responses, and the basis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. Because the Emplo ym ent Certification form requires a signed certification from an authorized official of the borrower’s emplo yer, electronic submission of the Employ ment Certification is not feasible. Although this form cannot be submitted electronically, it can be downloaded and completed electronicall y using common or free software. Whi le the form cannot be submitted electronicall y, ED will continue its effort to maximize the use of available information technology in making and servicing Direct Loans when it is feasible and cost

- effective. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above.3

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A
There is no similar information already available from other sources that can be used for the purposes described in Item 2. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y 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, which is a government of a city , count y, town, township, school district, or special district with a population of less than 50,000. No small businesses are affected b y this information collection. 6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. If this collection of information were not conducted, the Department would be unable to determine whether borrowers are eligi ble for Public Service Loan Forgiveness. As explained in Item 2 of this Supporting Statement, the frequency of submission is determined b y the borrower, and may be as frequent as each time a borrower changes public service employers. If borrowers were not allowed to submit employ ment certifications until after they have made all 120 required payments and are eligible to apply for loan forgiveness, there would be a greater likelihood that borrowers would be unable to obtain the required documentation of employ ment that ended y ears in the past, and it would be more difficult for them to track their progress toward making their 120 th qualifying pay ment. Further, b y soliciting Employ ment Certification forms less frequentl y, the Direct Loan servicers would receive a large number of forms at the same time, when the first borrowers become eligible to apply for loan forgiveness in October 2017. This would lead to an increase in the time required to process borrowers’ loan forgiveness applications. In summary , if the Department did not allow for Employ ment Certification forms to be submitted annually

or more frequentl y, this would increase burden on both borrowers and the Department. 7. Explain any

special circumstances that would cause an information collec tion to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterl y;4

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A

 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 y ears;  in connection with a statistical s urvey , 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 b y OMB;
 that includes a pledge of confidentia lity 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 unnecessaril y i mpedes sharing of data with other agencies for compatib le 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. This information collection does not involve any of the above conditions. 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 5 CFR 1320.8(d), soliciting comments on the information collectio n prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken b y the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consu lt 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 an y), and on the data elements to be recorded, disclosed, or r eported. 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 y ears
– 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. ED considered comments from the public when developin g the currentl y approved form s. Furthermore, ED consulted with borrower stakeholde rs prior to entering the form into clearance, the public had a 60
- day comment period, and will have a further 30
- day comment period during which they may submit comments to the proposed form. 9. Explain any

decision to provide any

pay ment or gift to resp ondents, other than remuneration of contractors or grantees with meaningful justification
. No pay ments or gifts have been provided to respondents.5

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A 10. Describe an y 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 Sy stems of Record Notice and the date a Privacy Impact A ssessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is dee med sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. The forms include a Privacy Act Notice that (1) informs borrowers of the statutory authority for the information collection; (2) explains that the disclosure of the information is voluntary , but is required in order to qualify for a loan discharge; and (3) identifies the third parties to whom the information may be disclosed an d explains the circumstances under which those disclosures may occur. 11. Provide additional justification for an y 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 wh y 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 an y steps to be taken to obtain their consent. The form do es not require borrowers to provide any information of a sensitive nature. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affec ted public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not - for

- profit institutions, farms, state, local or tribal governments) , frequency of response, annual hour burden, and an exp lanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to ob tain 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 widel y because of differences in activity , size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.

2 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

– Sa feguarding Personally Identifiable Information, OM : 6
- 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)6

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A

 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 ROCI S IC Burden Analy sis 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 h ere. Instead, this cost should be included in Item 14. ED estimates the total annual number of respondents for this information collection to be as follows: The estimated time required to complete the forms is 0.5 hours (30 minutes). Based on one respo nse per respondent, this equates to a total estimated annual reporting burden of 61,448 hours, calculated as follows: Estimated annual number of respondents: 122,896 Number of responses per borrower: x 1 Hours per response: x 0.5 (30 minutes) Annual hour burden: 61,448 hours This revision represents a reduction of 975,375 burden hours. This reduction is the result of a re

- estimation of the number of borrowers who will submit the form in any given ye ar. The prior estimate greatl y overestimated the number of borrowers who would submit the form. There are no annual costs to respondents associated with operating or maintaining sy stems or purchasing services. 13. Provide an estimate of the total annual cost burden to respondents or record keepers resu lting 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 t o estimate major cost factors including s ys tem 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.7

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A

 If cost estimates are expected to vary widel y, agencies should pres ent 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 res pondents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is 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 provide informati on 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 : $0.00 Total Annual Costs (O&M) : $0.00

____________________ Total Annualized Costs Requested : $0.00 There are no capital/startup costs to respondents.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the metho d 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. Agencie s also may aggregate cost estimates from Items 12, 13, and 14 in a single table. There is no significant cost to the federal government related to these forms from Direct Loan borrowers, since servicers distribute and process the loan discharge application s, and ED servicers do not specificall y charge the government for distributing these forms
. 15. Explain the reasons for an y 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 materiall y 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 t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
.8

ICRAS Tracking and OMB Number: ( 1474 .0 7 ) 1845
- 0110 Revised: 10 / 15 /2014 RIN Number: N/A This revision represents a reduction of 975,375 burden hours. This reduction is the result of a re

- estimation of the number of borrowers who will submit the form in any given ye ar. The prior estimate greatl y overestimated the number of borrow ers who would submit the form. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques that will be used. Provide the time schedule for the entire projec t, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The results of this information collection 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. The Department is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperw ork Reduction Act. The Department is not requesting an y exceptions to the "Certification for Paperwork Reduction Act Submissions".