Here are answers to your questions below - I have answered them in RED beneath each question.

-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Thursday, December 14, 2006 7:31 PM
To: Potter, Rachel F.; Ingalls, Katrina; Eliadis, Pam
Cc: Axt, Kathy; Carey, Sheila; Arrington, Angela
Subject: RE: OMB comments on NSLDS data system

Pam and Katrina -

We will need responses by COB Monday at the latest. OMB's review of
information collections is intended to be 60 days only - this collection
is now on day 72 and ED has had almost a month to prepare responses. We
have already granted an extension of the due date for responses and
unfortunately cannot grant other.

Best,
Rachel

-----Original Message-----
From: Ingalls, Katrina [mailto:[email protected]]
Sent: Thursday, December 14, 2006 2:30 PM
To: Eliadis, Pam
Cc: Ingalls, Katrina; Axt, Kathy; Carey, Sheila; Potter, Rachel F.;
Arrington, Angela
Subject: RE: OMB comments on NSLDS data system

Pam,

The timing is OMB's call at this point. I will be here through next
Friday and will get what you provide over to OMB. However, I want you to
know that Rachel Potter, Kathy Axt and I will all be on leave the week
between Christmas and New Year's. If your timeline is OK with Rachel - I
will get them over to Rachel at OMB and get the info put into Rocis.
Since Rachel will be out for a week - you need to realize that your
responses may not get reviewed until she gets back after the 1st.

I will put Rachel on this email so Rachel knows when you anticipate the
responses coming to her. She can get back to you if she has a problem
with this timeline. Thanks.

Katrina

-----Original Message-----
From: Eliadis, Pam
Sent: Thursday, December 14, 2006 1:03 PM
To: Ingalls, Katrina; Fontana, Matteo
Cc: Axt, Kathy
Subject: Re: OMB comments on NSLDS data system

I have put together responses for the most part. I hope to get them in
the system by mid next week as I need assistance in getting the info in.

Is this ok?
Pam
--------------------------
Sent from my BlackBerry Wireless Handheld

-----Original Message-----
From: Ingalls, Katrina
To: Eliadis, Pam; Fontana, Matteo
CC: Ingalls, Katrina; Axt, Kathy
Sent: Thu Dec 14 12:25:04 2006
Subject: FW: OMB comments on NSLDS data system

Pam and Matt,

Please let Rachel (and me) know where you are with your responses to
OMB's questions on the NSLDS questions. Thanks.

Katrina
-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Thursday, December 14, 2006 10:55 AM
To: Ingalls, Katrina
Subject: RE: OMB comments on NSLDS data system

Katrina -

What is the status of ED's response on this? Thanks.

_____

From: Potter, Rachel F.
Sent: Wednesday, November 22, 2006 1:44 PM
To: 'Ingalls, Katrina'
Cc: Axt, Kathy; Eliadis, Pam; Fontana, Matteo
Subject: RE: OMB comments on NSLDS data system

Katrina -

12/6 is fine; however, this is an extension over OMB's normal 60 day
review, so we will not be able to provide an extension any longer than
that.

As for comment #2 below, we need to know what data elements we are
granting approval for and to have a record of those approval data
elements in our files (ROCIS). We are somewhat flexible regarding the
exact format. For similar collections in the past, we have approved
screenshots or more basic documents that show the questions/ potential
responses from individuals. Again, the basic point is that we know
exactly what information we giving you approval to collect.

As for your comments on the instructions, we generally consider
instructions to be part of an approved information collection, so please
include them for the ICs for which they were inadvertently excluded. I
have opened ROCIS up for you to make those changes.

Happy Thanksgiving!

- Rachel

_____

From: Ingalls, Katrina [mailto:[email protected]]
Sent: Tuesday, November 21, 2006 12:37 PM
To: Potter, Rachel F.
Cc: Ingalls, Katrina; Axt, Kathy; Eliadis, Pam; Fontana, Matteo
Subject: RE: OMB comments on NSLDS data system

Rachel,

There are two sponsor's on this collection. Pam Eliadis (one of the
sponsor's) is here today and then is out of the office until Dec 4th.
The second sponsor, Matt Fontana, is already out on leave and will not
be back until sometime next week. It would be very helpful to both of
the sponsors to have until 12/6 to prepare the responses to your
comments. Would that be possible?

I do have a question about comment #2. I want to be able to advise Pam
and Matt on exactly what you want to fulfill this requirement. Do you
want the system specs? I just checked with Pam - and they have them -
but they are huge. She can get those for you - but will have to burn a
CD for you.

If you want a copy of the NSLDS instructions that go with those three
respondent groupings that were not included, the sponsor has told me
that these were inadvertently left out of the package but they can send
them to me to be included in Rocis. The NSLDS instructions were
already provided in ROCIS for the GA's and for the Serviced Schools -
Perkins, however, they were not included for the three other groups in
the initial package. (That was the reason for the note I put in Rocis
"There is no specific instrument that relates specifically to this group
of respondents since all respondents use the same NSLDS system".) I
inserted this note for three groups: the NON-Serviced Schools - other
data, Serviced schools - other data, and for non-serviced schools -
Perkins. Do you want the instructions added to ROCIS for these three
groups?

I appreciate your help with this package. Hope you have a good holiday.
Thanks.

Katrina

-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Friday, November 17, 2006 5:23 PM
To: Ingalls, Katrina
Cc: Rudolph, Kim
Subject: OMB comments on NSLDS data system

Katrina,

OMB has the following questions on the NSLDS collection (1845-0035).
Please respond by COB Monday 11/27. Thanks!

1. Please explain the improvements that ED envisions making with
NSLDS-II. Why does ED believe it will take more than 6 years to
implement NSLDS-II(the previous terms, which envisioned NSLDS-II were
issued in 10/03 and the supporting memo included with this submission
states that the changes will not be ready for a minimum of 3 years from
now - 11/09)?

The improvements to NSLDS (formally known as NSLDS-II) has now been rolled into the Department's Target State Vision. The implementation of the Department's Target State Vision includes re-engineering NSLDS, including the process and content of data collected. The work surrounding the Target State Vision not only includes NSLDS, but other major Federal Student Aid Systems in order to create an Enterprise Information System. In order to most effectively build the Enterprise System, the Department is analyzing its current processes, both its acquisition strategy and data flow processes. As the Department begins reviewing data flow processes, it will examine in detail the data collected today and the data needed in the future in order to improve business processes and oversight. Focus on creating unique aid, organization and borrower identifiers will further improve the oversight and confirmation of cost estimates and obligations. The improved data flows will enable the Department to capture the data needed, at the appropriate times, that is easily tracked through the Department's systems and aid life cycle.

Yes, there are other systems that collect similar data. As OMB knows, a lot of data is captured by NSLDS, but NSLDS doesn't capture the sufficient loan level detail to be able to summarize it into the same data provided to LaRS (for example, actual interest rates and borrower payments). Similarly, the Guaranty Agency Financial Report (GAFR) that is collected monthly and stored in FMS, also collects summarized data, but again NSLDS doesn't capture the sufficient loan level detail to be able to summarize it and match the data on the GAFR. Finally, the Debt Collection System collects some of the same information provided to NSLDS when loans are assigned the the Department for collection, but again not all necessary data is captured.

As mentioned in number 1 above, the Department is currently planning an Enterprise Information System as part of its Target State Vision. As we analysis current data flows, we will identify data that will and will not be needed at a loan-level detail, as well as, determine how to remove or reduce redundant data. Our plan is for the Target State Vision to enable for reasonability of the data reported that will continue to be collected at the summary level. The reasonability results will be used to both inform audits and reviews, as well as, to inform the Department of the accuracy of the data collected about federal obligations.

4. ED has submitted this collection as a revision. Please describe
the program changes you are proposing from the currently approved
version of this collection. What are the new data elements you are
proposing to collect?

There has been little change over the past three years of data collected in NSLDS, we continue to collect the same data elements. Due to the Higher Education Reconciliation Act (HERA), NSLDS has added a new loan type, two new Grant Types and plans to add additional Teacher Loan Forgiveness data. However, this has had minimal impact to the suppliers of data. As mentioned in number 1 and 3 above, when planning the Enterprise Information System, we do plan on changing the data collected that could have a much larger impact. But this change will not take place for several more years.

5. In term of burden, how much more burden (in terms of hours/
minutes) do the new data elements impose on respondents? How does that
compare overall to the increase of 5,024 annual responses? That is, we
would like an explanation for ED's request for a burden reduction
-44,872 hours, while the number of responses and data elements are
increasing.

Although the respondents have increased over time, we have seen a huge increase in the number of respondents using servicers to compile and send data. Also, the respondents have moved away from creating and mailing tapes to sending the data electronically. By using servicers, the time spent to create and send data by respondents has been transferred to a third party that have more advanced technical capabilities. Further, the creation of tapes to send data is a long process that has been replaced with electronic means.

Rachel F. Potter
Office of Information and Regulatory Affairs Office of Management and
Budget
Tel: (202) 395-5887
Fax: (202) 395-6974
<mailto:[email protected]>