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ICRAS and OMB Number: (1400.16) 1845-0019 v.7 Revised: 6/27/2013

RIN Number: 1840-AD12 

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

FEDERAL PERKINS LOAN PROGRAM 

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.

The Higher Education Act of 1965, as amended (HEA), established the Federal Perkins 

Loan Program (Perkins Loan). The Perkins Loan program provides low cost Title IV, 

HEA loans for eligible students to pay the costs of a student's attendance at an eligible 

institution of higher education. The regulations implementing the Perkins Loan Program 

are in 34 CFR Part 674.

For the Federal Perkins Loan Program, the proposed regulations would add a new 

§674.19(f) with the heading “enrollment reporting process.” Proposed §674.19(f)(1) 

would provide that upon receipt of an enrollment report from the Secretary, an institution 

must update all information included in the report and return the report to the Secretary in 

the manner and format prescribed by the Secretary and within the timeframe prescribed 

by the Secretary. Proposed §674.19(f)(2) would provide that unless it expects to submit 

its subsequent updated enrollment report to the Secretary within the next 60 days, an 

institution must notify the Secretary within 30 days after; 1. the date the school discovers 

that a loan under title IV of the HEA was made to a student who was enrolled or accepted 

for enrollment at the institution, and the student has ceased to be enrolled on at least a 

half-time basis, 2. or failed to enroll on at least a half-time basis for the period for which 

the loan was intended, 3. or discovers that a student who is enrolled at the institution and 

who received a loan under title IV of the HEA has changed his or her permanent address. 

Because the Secretary already receives enrollment reporting information on Federal 

Perkins Loan borrowers who also have a FFEL loan or a Direct Loan, the additional 

burden associated with sending enrollment reports to institutions for the Federal Perkins 

Loan Program is only associated with those Federal Perkins Loan borrowers whose only

loan received under title IV of the HEA is a Federal Perkins Loan and who are enrolled 

on at least a half-time basis.

Under proposed §674.34, institutions that participate in the Perkins Loan program (or 

their servicers) would be required to use the same eligibility criteria that lenders and the 

Department use in the FFEL and Direct Loan programs, respectively, to define an eligible 

 

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Please limit pasted text to no longer than 3 paragraphs.
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RIN Number: 1840-AD12 

graduate fellowship program and to establish the eligibility of a Perkins Loan borrower 

for a graduate fellowship deferment. The proposed regulations would require that a 

borrower provide the institution with a statement from an authorized official of the 

borrower’s graduate fellowship program certifying a.) that the borrower holds at least a 

bachelor’s degree and b.) the borrower’s anticipated completion date of the program.

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.

There is no change to the purpose and use of the collection of information on the Perkins 

Loan program. The proposed regulations related to school enrollment status reporting to 

reflect current terminology and procedures. In addition these proposed changes to the 

Perkins reporting would make it consistent with FFEL and Direct Loan status reporting 

requirements. The proposed change to the graduate fellowship deferment serves to 

provide equitable treatment for this deferment across the Title IV, HEA loan programs.

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.

School enrollment status reports are generated by the Department six times per year and 

sent to institutions via NSLDS. Institutions open the report and subsequently provide 

status reporting data which is returned to the Department via NSLDS. The proposed 

change to the graduate fellowship deferment procedures is a manual process where the 

borrower obtains a written statement from an authorized official of the borrower’s 

graduate program certifying that the borrower already possesses a bachelor’s degree and 

the borrower’s anticipated graduation date from the graduate program.

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.

The current requirements are minimal and avoid duplication. There is no similar 

information available that can be used or modified for this purpose at this time.

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, 

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 affected by this information collection.
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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.

Absent the proposed requirement on student enrollment status information reporting for 

Perkins only borrowers, the Department would not have vital student eligibility

information regarding when a student ceased to be enrolled on at least a half-time basis, 

when a borrower failed to enroll on at least a half-time basis for the period for which the 

Perkins loan was intended, and other changes to the borrower’s enrollment status. In

addition, under this proposed requirement, the institution would provide information to 

the Department whenever a student who is enrolled at the institution and received a loan 

under Title IV of the HEA has changed his or her permanent address. The proposed 

change to the deferment of repayment for a borrower engaged in a graduate fellowship 

program requires that the same criteria used for the establishment of such a deferment 

under either the FFEL or Direct Loan program be used thus providing for equal treatment 

throughout the Title IV, HEA loan programs.

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 collection of this information will continue to be conducted in a manner that is 

consistent with the guidelines in 5 CFR 1320.6.

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 
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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.

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.

The proposed regulations were developed through the Negotiated Rulemaking process 

where the public provided its input and in consultation with schools, and a variety of 

professional associations and other interested parties. The comment period for the 

burden associated with these proposed regulations will run concurrently with the 

comment period for the proposed regulations. Although OMB has up to 60 days to 

approve the ICR, it is recommended that the public comment on the ICR within the 30 

days of the regulations publication.

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.

Privacy protected information is not being collected, rather the Department is providing 

information about students with Title IV, HEA program assistance as listed on our 

NSLDS system and the institution would be providing enrollment status information 

 

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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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about the students to the Department via NSLDS. Additionally, changes to borrower’s 

permanent address information would be provided by the institution to the Department.

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 

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.

Section 674.19 – School Enrollment Status Reporting Requirements

In the 2011 calendar year, there were 2,070,514 Federal Perkins Loan borrowers. Of the 

2,070,514 Federal Perkins Loan borrowers, 240,959 borrowers have a Federal Perkins 

Loans as the only loan received under title IV of the HEA. Of the 240,959 borrowers, 53 

percent (127,708 borrowers) were enrolled on at least a half-time basis or had recently

changed enrollment status. The Secretary will be sending enrollment reports to each of 

the institutions approximately every 60 days or 6 reports per year. We estimate that on

average the completion and submission of an enrollment report would take .05 hours (3 
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minutes) per borrower. Burden would increase by 38,312 hours (127,708 borrowers 

multiplied by .05 hours per borrower multiplied by 6 reports per year) under OMB 

Control Number 1845-0019.

For the 2011 calendar year 51 percent of the Federal Perkins loan borrowers were at 

public institutions, therefore we estimate that burden would increase for public 

institutions by 19,539 hours (38,312 multiplied by .51) under OMB 1845-0019.

For the 2011 calendar year 45 percent of the Federal Perkins loan borrowers were at 

private not-for-profit institutions, therefore we estimate that burden would increase for 

private not-for-profit institutions by 17,240 hours (38,312 multiplied by .45) under OMB 

1845-0019.

For the 2011 calendar year 4 percent of the Federal Perkins loan borrowers were at 

proprietary institutions, therefore we estimate that burden would increase for private forprofit institutions by 1,533 hours (38,312 multiplied by .04) under OMB 1845-0019.

Collectively, the proposed regulatory changes to §674.19 would increase burden by

38,312 hours under OMB 1845-0019.

Section 674.19 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 127,708 127,708 .05 hrs 38,312

Section 674.34 – Deferment of Repayment – Federal Perkins Loans

In calendar year 2011 there were 1,104 Perkins borrowers who applied for a graduate 

fellowship deferment. We estimate that on average it would take the borrower .25 hours 

(15 minutes) to obtain the certification from an authorized official of the graduate 

fellowship program and to complete and submit the Perkins loan deferment form 

multiplied by an estimated 1,104 deferment applications equals 276 hours of increased 

burden to the borrowers under OMB Control Number 1845-0019.

For the 2011 calendar year, 51 percent of the Federal Perkins loan borrowers or 563 

affected borrowers were at public institutions, therefore we estimate that burden would 

increase for public institutions and their authorized officials by 141 hours (1,104 

applications multiplied by .51 multiplied by .25 hours per certification) under OMB 

1845-0019.

For the 2011 calendar year, 45 percent of the Federal Perkins loan borrowers or 497 

affected borrowers were at private not-for-profit institutions, therefore we estimate that 

burden would increase for private not-for-profit institutions and their authorizing officials

by 124 hours (1,104 applications multiplied by .45 multiplied by .25 hours per 

certification) under OMB 1845-0019.
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For the 2011 calendar year, 4 percent of the Federal Perkins loan borrowers or 44 

affected borrowers were at proprietary institutions, therefore we estimate that burden 

would increase for private not-for-profit institutions and their authorizing officials by 11 

hours (1,104 applications multiplied .04 multiplied by .25 hours per certification) under 

OMB 1845-0019.

Collectively, the proposed regulatory changes to §674.34 would increase burden by 552

hours under OMB 1845-0019.

Section 674.34 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 2,208 2,208 .25 hrs 552

Currently Approved Numbers:

# of Respondents # of Responses Hours/Response Burden Hours

 11,486,794 11,486,794 6,208,288

New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 129,916 129,916 38,864

Revised Numbers Requested:

 11,616,710 11,616,710 6,247,152

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 
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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 

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 are no capital/startup costs to respondents, nor are there any annual costs to 

respondents associated with operating or maintaining systems or purchasing services.

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.

The cost to the federal government is minimal to the Department since School 

Enrollment Status Reporting has been occurring for many years under the title “Student 

Status Confirmation Reporting”. The proposed addition of the Perkins reporting would 

be the newly added reporting. There is little or no cost to the Department regarding the 

criteria used to determine whether a borrower in a graduate fellowship program is eligible 

for a Perkins Loan deferment since the information is provided to the institution where 

the Perkins Loan is held and the determination is made by the loan holder – the institution 

that originally provided the Perkins Loan to the borrower.

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 a revision of the current information collections. The proposed 

regulations would increase burden by 38,864 hours. Under proposed 674.19, institutions 
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participating in the Title IV, HEA programs already report student enrollment status 

information via NSLDS. The Department sends student enrollment status information 

reports to participating institution approximately every 60 days. The institution would be 

required to report data for a student for whom a Federal Perkins loan is their only Title IV 

loan (since students who also have either a FFEL or Direct Loan have been reported 

under the current FFEL and DL requirements). Under proposed 674.34, the criteria used 

to make a determination of whether a borrower in a graduate fellowship program may be 

granted a Perkins Loan deferment and so the deferment is made under the same criteria 

used for the FFEL and Direct Loan programs.

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 this 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.

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.