1

OMB Number: 1845

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- XXXX (if applicable)

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANT ELIGIBILITY REGULATIONS** 
**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 collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. The College Cost Reduction and Access Act (the CCRAA), Pub. L . 110

- 84, established the Teacher Education Assistance for College and Higher Education (TEACH) Grant Program under Part A of the Higher Education Act of 1965, as amended (the HEA). The regulations for this program are in 34 CFR 686

. The following sections of the TEACH Grant regulations are included in this information collection : 686.4, 686.11, 686.32, and 686.34. These regulations can be reviewed at 34 CFR 686

. The regulations in 686.4 require an institution that ceases to participate or becomes ineligible to participate in the TEACH Grant program during an award ye ar to report to the Department of Education within 45 day s after the effective date of the loss of eligibility

. The report must include the name of ea ch TEACH Grant eligible student, the amount of the TEACH Grant funds paid to e ach student for that award y ear, and the amount of TEACH Grant funds due each eligible student through the end of the pay ment period. Also, the institution must provide an ac counting of all TEACH Grant expenditures for that award y ear to the date of termination. The regulations in 686.11 establish that in addition to meeting the student eligibility requirements, in order to receive a TEACH Grant the applicant must submit the designated application, sign a TEACH Grant agreement to serve (this burden is captured under OMB Control Number 1845

- 0083) , and enroll in a TEACH Grant eligible institution. I n addition, the grant recipient must either maintain a cumulative grade point average of 3.25 on a 4.0 scale during each pay ment period or score above the 75 th percentile on at least one of the battery of nationally

- normed standardized test.

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

OMB Number: 1845

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- XXXX (if applicable) The regulations in 686.32 require an institution to provide initial, subsequent, and exit counseling to each TEACH Grant recipient and maintain documentation substantiating the counseling requirements

. The regulations in 686.34 require the institution to promptly provide written notification to a student requesting repay ment of any

overpayme nt that the institution does not have responsibility

to repay . The regulations also require that the institution refer the student to the Department if the student does not take positive action to promptly resolve the TEACH Grant overpay

ment. This is a r equest for an extension of the existing burden hours in OMB Control Number 1845

- 0084 which provides for program administration and is necessary to determine eligibility to receive program benefits and to prevent fraud and abuse of program funds. 2. I ndic ate how, b y 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. The TEACH Grant program is maintained at participatin g institutions of higher education. The majority

of the collection requirements are for recordkeeping at the institution. The required reporting to the Department of Education (Department) relates to ceasing participation or losing eligibility to partici pate. The recordkeeping and reporting requirements of these regulations assure accountability of program participants for proper program administration and justify the pay ment of funds by the federal government. The collection of this information aids in assuring that the Federal dollars are not lost to fraud, waste or abuse. 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or form s of information technology , e.g. permitting electronic submission 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. The required enrollment for institutions of higher education in the TEACH Grant program is done through the e

- Application process, the disbursement and overpay ment reporting is done through the Common Origination and Disbursement s ys tem. These are all electronic s ys tems operated b y the Department. 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 I tem 2 above. These regulations were created with the partici pation of affected parties who had a vested interest in avoiding duplication. The required information is not captured in any other Department s ys tem. 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 deemed3

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- XXXX (if applicable) to be one that is independently owned and operated and that is n ot 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 impacted b y this 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. The recordkeeping and reporting requirements are necessary to ensure accountability

of program participants for proper program administration and less frequent collection could impair accountabilit y 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 quarter ly ;  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 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 b y OMB;
 that includes a pledge of confidentiality that is not supported by

authority established in statute or regulation, that is not supported by disclosure an d data security policies that are consistent with the pledge, or that unnecessaril y i mpedes 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 be conducted in a manner that is consistent with the guidelines in 5 CFR 1320.5(d)(2). 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 collection prior to submission to OMB. Summarize public comments receiv ed 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 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,4

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- XXXX (if applicable) disclosure, or reporting format (if an y), 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 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. The regulations have not changed since their original development during the negotiated rulemaking and the fin al rule process. There was a request for additional information about the program received as a comment during the 60 day comment period. This is the 30 day notice to be published in the Federal Register providing the public with an addition opportunity to submit comments on the proposed burden. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

. No pay ments of gifts will be provided to the respondents. 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 I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidential ity should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement is deemed 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. A Privacy

Act Notice is included on the Free Application for Federal Student Aid (FAFSA) application form and the TEACH Grant Agreement to Serve. In both of these forms, the applicant is informed of the st atutory authority for collecting the information requested. Although the disclosure of the information is voluntary , the recipient is informed that in order to be considered for TEACH Grant funds, the information must be provided. The information provide d is used to verify the grant recipient’s identity , to determine the grant recipient’s eligibility to receive the TEACH Grant benefits, and in those cases where a TEACH Grant is converted to a Direct Unsubsidized L oan, to permit the servicing of the borrow er’s loan(s), and to locate the borrower and collect on the loan(s) if the loan(s) become delinquent or default. A listing of the persons and entities to which

2 Requests for this information are in accordance with the follow ing ED and OMB policies: Privacy Act of 1974, OMB Circular A

- 108

– Privacy Act Im plementation

– 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)5

OMB Number: 1845

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- XXXX (if applicable) the information may

be disclosed and for what purposes the information may be disclosed is also included. 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 t h e 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 Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected 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 explanation of how the burden was estimated, including identification of burden t ype: recordkee ping, 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 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 widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Gener all y, 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 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, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information collection activities should not be included here. Instead, this cost should be included in I tem 14. TEACH Grants: Section 686.4

– Ins titutional participation Burden Assessment: We anticipate a continued 17% or 97 9 of the 5,7 5 9 Title I V eligible institutions will participate in the TEACH Grant program. No institution has officially withdrawn from the program. Therefore, we are adjusting to .5% or 5 the estimated number of institutions that will cease to participate or lose eligibility to participate in the program. The program’s participation rate has been higher than estimated in the previous burden calculation. The 201 5 Fiscal Year (FY1 5 ) budget request indicates there were 33,700 TEACH Grant recipients in FY 14

. There would be an average of 34 students6

OMB Number: 1845

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- XXXX (if applicable) participating in the program at each eligible institution. To meet the reporting requir ements, we estimate that the burden associated with ceasing participation or losing eligibility would be 4 3 hours. # of Eligible Institutions 5,7 5 9 % of Institutions participating in TEACH Grant Program X .1700 # of Participating Institutions 97 9 Projected % of Institutions ceasing Partic ipation or becoming ineligible X .005 # of Affected Institutions 5 Projected # of TEACH Grant eligible Students 33 , 7 00 Divided by

# of Participating Institutions / 97 9 Average projected number of students Participating in TEACH Grant program At each Institutions 34 Average projected amount of time to report Student and funding data at 15 minutes per student record X .25 hours Burden hours per affected institutions 8 .5 hours Times the # of affected institutions X 5 Total Burden Hours 4 3 hours Affected Entities: # of # of Hours/ Total Respondent s Responses response hours Business or other for

- profits 1 1 8 .5 9 Not

- for

- profits 2 2 8 .5 17 Public institutions 2 2 8 .5 17 TOTAL 5 5 4 3

Section 686.11

– Eligibility to receive a grant There are several categories of grant recipients where the cumulative grade point average of 3.25 must be maintained for each pay ment period. Those categories are: I. The initial pay

ment period: The final cumulative high school GPA for a first term undergra duate recipient

– The TEACH eligible institution must document the student’s secondary school GPA from an LEA, an SEA or other State agency, a public or private high7

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- XXXX (if applicable)

school, or in the case of a home schooled student, obtain documentation of the secondary s chool GPA from the parent or guardian. The undergraduate cumulative GPA for either the post

- baccalaureate or graduate student recipient

– The TEACH eligible institution must document the student’s undergraduate school GPA. The transfer student cumulativ e GPA as determined by the current TEACH Grant eligible institution

– The TEACH eligible institution must document the student’s GPA based upon the method established by the institution to accept coursework completed from any prior postsecondary

instituti on that it accepts. II. Subsequent pay

ment periods: The cumulative GPA based on courses taken at the TEACH eligible institution through the most

- recently completed pay

ment period, or III. Alternatives to the cumulative GPA: Scoring above the 75 th percentile of at least one of the battery of test from a nationally

- normed standardized test, or The grant recipient is currently a teacher or retiree w ho is apply ing for a TEACH Grant to obtain a master’s degree in an eligible TEACH Grant program. Burde n Assessment: Assuming a continued 7% of FAFSA applicants in 2013

- 2014 expressing an interest in the TEACH Grant program, there would be approximately 1,483,545 applicants for the TEACH Grant. Prior data indicate that 10% or 148,355 applicants actuall y a pply . The FY 2015 Budget indicates that approximately 22.715% or 33,700 TEACH Grants were received in 2014 with an anticipated 34,116 TEACH Grant to be awarded in 2015. The burden assessment below breaks out burden attributable to applicants as well as r ecipients. Initial pay

ment period: # of Hours/ Total Respondents response hours High school GPA Applicants 13, 352 .250 3, 338 Recipients 3 , 033 .250 758 Undergraduate GPA Applicants 4 0 , 056 .017 681 Recipients 9 , 099 .017 1 5 5 Transfer student GPA Applicants 13, 352 .167 2, 230 Recipients 3 , 033 .167 5078

OMB Number: 1845

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- XXXX (if applicable) Subsequent pay

ment period: # of Hours/ Total

Respondents response hours Standardized tests Applicants 65 , 276 .017 1,1 10 Recipients 1 4 , 828 .017 252 Current Teachers/Retirees Applicants 16, 319 .167 2, 725 Recipients 3 , 707 .167 619 All recipients X .80 26 , 960 .017 458 Subtotals Applicants 1 48 , 355 10,084 Recipients 33 , 7 00 2,291 Subsequent recipients 2 6 , 96 0 458 TOTAL S 20 9, 015 12, 833 Affected Entities: # of # of Total Respondent s Responses hours I NDI VI DUALS : High School GPA Home school parents 13 13 4 INST ITUTIONS: Business or other for

- profits 10 2,0 90 12 8 Not

- for

- profits 519 1 10 , 771 6, 800 Public institutions 450 9 6 , 141 5, 901 T OTAL : 992 20 9 , 015 12, 833

Section 686.32

– Counseling requirements Ty pes of TEACH Grant counseling: In

- person: We project that an in

- person presentation (individual or group) will take approximately

.33 hours (20 minutes) per presentation. We project that 4 9 institutions new to the program will require 10 hours to develop the requir ed in

- person presentation materials that will cover the three t ypes of counseling required. We project that 9 30 participating institutions will annually update the in

- person presentation materials that will cover the three t ypes of counseling required and will require 1 hour for review and revision. Audio

- visual (A/V) presentation: W e project that the A/V presentation will take approximately

.33 hours (20 minutes) per presentation. We project that 29 institutions new to the program will require 6 hours to develop the A/V presentation materials that will cover the three t ypes of counseling required. We project that it will take 1 hour annually to review and update an A/V presentation that will cover the three ty pes of9

OMB Number: 1845

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- XXXX (if applicable) counseling required and w e project t hat 3 91 institutions will updat e such A/V presentation s. Interactive (on

- line): We project that the on

- line presentation will take approximately .33 hours (20 minutes) per presentation. We project that it will take 29 institutions new to the program wil l require 7 hours to develop the on

- line presentation that will cover the three t ypes of counseling required. We project that it will take 1 hour annually to review and update an on

- line presentation that will cover the three t ypes of counseling required and we project that 4 5 0 institutions will update such on - line counseling presentation s . Affected Entities: IN DI VI DUALS Recipient Initial counseling: We project that 20% of the 33 , 7 00 recipients or 6,740 recipients will require Initial Counseling Recipient Subsequent counseling: We project that 80% of the recipients or 26,960 recipients will need subsequent counseling in a ye ar of their TEACH Grant program participation. Recipient Exit counseling: We project that 20 % of the recipients or 6,740 recipients will need Exit counseling in a ye ar of the TEACH Grant program

. Respondents: Responses: Initial Counseling 6 , 740 Subsequent Counseling 2 6 , 960 Exit Counseling 6 , 74 0 Total # of Respondents 4 0, 44 0 x .33 hrs = 13 , 345 burden hours INST ITUTIONS In

- person counseling: 9 30 institutions Presentation review and update x 1 hour 9 30 hours Presentation development 4 9 institutions x10 hours 4 9 0 hours Providing in

- person counseling We project that 10% of the recipients will want in

- person counseling and that the counseling will average 20 minutes (.33 hours)

. 33 , 7 00 recipients x .10 3 , 37 0 x .33 hours 1,112 hours10

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- XXXX (if applicable) AV Counseling: 3 91 institutions Presentation review and update x 1 hour 3 91 hours Presentation development 29 institutions x 6 hours 1 74 hours Providing AV counseling We project that 10 % of the recipients will want AV counseling and that the counseling will average 20 minutes (.33 hours). 33 , 7 00 recipients x .10 3 , 370 x .33 hours 1,112 hours On

- Li ne Counseling: 4 50 institutions Presentation review and update x 1 hour 4 50 hours Presentation development 29 institutions x 7 hours 2 0 3 hours Providing AV counseling We project that 80 % of the recipients will want on

- line counseling and that the counseling will average 20 minutes (.33 hours). 33 , 7 00 recipients X .80 2 6 , 96 0 X .33 hours 8 , 897 hours Annual Review and Update: In

- person counseling 9 30 hours AV 3 91 hours On

- line 4 50 hours Sub

- Total 1,7 71 hours Initial Development : In

- person counseling 4 9 0 hours AV 1 74 hours On

- line 2 0 3 hours Sub

- Total 8 67 hours11

OMB Number: 1845

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- XXXX (if applicable) Actual Counseling: In

- person counseling 1,112 hours AV 1.112 hours On

- line 8,897 hours Sub

- Total 11,121 hours TOTAL 1 3 , 759 hours Affected Entities: # of # of Total Respondents Responses hours I NDI VI DUALS : 40 , 44 0 4 0, 44 0 13 , 345 INST ITUTIONS: Business or other for

- profits 10 10 1 38 Not

- for

- profits 51 9 51 9 7 , 292 Public institutions 4 50 4 50 6 ,3 29 T OTAL : 41 , 419 41 , 419 2 7 , 104

Section 686.34

– Liability for and recovery of TEACH Grant overpayments We project that . 1% of the estimated 33 , 7 00 recipients will owe a TEACH Grant overpay ment. However, all eligible institutions must have a written notice for requesting repay ment of a TEACH Grant overpay ment when a student has responsibility to repay along with notification that the student will become ineligible for additional Title I V, HEA program funds. The participating institutions m ust establish procedures to refer an overpay ment when a student fails to make satisfactory repay ment arrangements or fully repay the overpay

ment. We estimate that it will take student s .167 hours (10 minutes) to read the written notification and respond t o the TEACH Grant overpay ment notice. And we estimate that each participating institution will require .33 hours (20 minutes) to annually review the notification and make the required referrals. Affected Entities: # of # of Hours/ Tot al Respondents Responses response hours I NDI VI DUALS : 34 34

. 167 6 INST ITUTIONS: Business or other for

- profits 10 10 .33 3 Not

- for

- profits 5 19 51 9 .33 17 1 Public institutions 4 50 4 50 .33 14 9 T OTAL : 1,013 1,013 32912

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- XXXX (if applicable)
C urrent B urden A ssociated with the R egulations : # of Respondents # of Responses #Burden Hours 231,172 23 3 , 2 7 6 3 3 , 568 Revised Burden Associated with the Regulations after Review: # of Respondents # of Responses #Burden Hours 41,466 251,452 40,309 Difference: # of Respondents # of Responses #Burden Hours

- 189,706* + 18 , 176 +6 , 741 *This decrease in respondents is done to account for a mistaken multiple counting of universe of eligible and participating institutions. Staff costs at $36.55 per hour calculate to an estimated total of $1,473,294 institutional costs to review, update and develop required counseling materials. 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 I tems 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 ac count costs associated with generating, maintaining, and disclosing or providing the information. I nclude descriptions of methods used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, t he 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 testin g equipment; and acquiring and maintaining record storage facilities.
 If cost estimates are expected to vary widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting out information collectio n 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 reg ulatory

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 achiev e 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 :13

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- XXXX (if applicable) Total Annual Costs (O&M) : Total Annualized Costs Requested : There are no additional costs not identified 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 aggregat e cost estimates from I tems 12, 13, and 14 in a single table. The re is no additional cost to the Federal government

. 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 a nd 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 statut e, 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)

. This is a request for an extension of the current information collection. There has been no change to the statute or regulations for the TEACH Grant program. The upward adjustment in burden of 6,741 hours is due in part to an increase in the participatio n in the program from the prior filing based on the FY15 Budget figures for the FY14 usage data. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical techniques t hat 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 result 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. The Department is not seeking this approval. 18. Explain each exception to th e certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submission”.