ss 0047 2008

ss 0047 2008.pdf

Health Professions Student Loan (HPSL) Program and Nursing Student Loan (NSL) Program: Administrative Requirements (Regs. & Policy)

OMB: 0915-0047

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Health Professions Student Loan (HPSL) Program And Nursing Student Loan (NSL) Program
Administrative Requirements (Regulations and Policy)
Supporting Statement
A.

Justification

1.

Circumstances of Information Collection

This is a request for approval for an extension without change of the information collections
approved under OMB No. 0915-0047 for the administrative regulatory requirements under the
Health Professions Student Loan (HPSL) Program and the Nursing Student Loan (NSL)
Program. The expiration date for the current approval is 10/31/08 and no changes have been
made to the regulatory requirements.
The HPSL program, authorized by sections 721-735 of the Public Health Service (PHS) Act (42
USC 292q-292y), provides long-term, low-interest loans to students attending schools of
medicine, osteopathic medicine, dentistry, veterinary medicine, optometry, podiatric medicine,
and pharmacy. The NSL Program, authorized by sections 835-842 of the PHS Act (42 USC
297a-i), provides long-term, low-interest loans to students who attend eligible schools of nursing
in programs leading to a diploma in nursing, an associate degree, a baccalaureate degree, or a
graduate degree in nursing. Participating HPSL and NSL schools are responsible for
determining eligibility of applicants, making loans, and collecting monies owed by borrowers on
their outstanding loans. Schools are required to: (1) invest their HPSL and NSL funds and return
earnings from the investments to the HPSL and NSL funds; (2) identify and return to the
Department excess cash from the HPSL and NSL funds; and (3) determine the ability to collect
of defaulted loans and, for loans determined to be uncollectible, either obtain approval to write
off the loans or reimburse the fund for the amount that remains uncollected on the loans. The
governing regulations for the HPSL program are §§ 57.201-57.218 and the NSL program are §§
57.301-57.318.
Approval is requested for the following information collections and regulatory requirements.
RECORDKEEPING REQUIREMENTS
§ 57.206(b)(2) and 57.306(b)(2)(ii), Documentation of Cost of Attendance - In the selection of
qualified applicants, the school must document criteria used for determining reasonable costs
necessary for the student's attendance at the school.
§ 57.208(a) and 57.308(a), Promissory Note - Each HPSL or NSL loan must be evidenced by a
properly executed promissory note in a form approved by the Secretary, and the school must
safeguard the note against fire, theft, and tampering.
§ 57.210(b)(1)(i) and 57.310(b)(1)(i), Documentation of Entrance Interview - The school must
conduct and document the entrance interview with the borrower prior to disbursing HPSL/NSL
funds, to inform him/her of the rights and responsibilities associated with receiving the funds.

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§ 57.210(b)(1)(ii) and 57.310(b)(1)(ii), Documentation of Exit Interview - The school must
conduct and document the exit interview with the borrower, or if borrower terminates studies
without advance notice, the school must document attempts to inform the borrower of the
substance of the exit interview and to secure required information from the borrower by mail.
§ 57.215(a) & (d) and 57.315(a)(1) & (a)(4), Program Records - The school must maintain
records relating to the operation of its HPSL or NSL funds.
§ 57.215(b) and 57.315(a)(2), Student Records - Approved student applications, documentation
of financial need records, and copies of financial aid transcripts must be retained by the school
for 5 years after a student ceases to be a full-time student.
§ 57.215(c) and 57.315(a)(3), Repayment Records - Repayment records for each borrower must
be retained for at least 5 years from the date of retirement of a loan.
REPORTING REQUIREMENTS
§ 57.206(a)(2) and 57.306(a)(2), Student Financial Aid Transcript (Disclosure) - An applicant
who has previously attended an institution of higher education must submit a financial aid
transcript.
§ 57.208(c), Loan Disclosure Requirements (Disclosure) - The school must disclose loan
information to students who receive HPSL loans at the onset of their studies and prior to the
completion or termination of their studies.
§ 57.210(b)(1)(i) and 57.310(b)(1)(i), Entrance Interview (Disclosure) - The school must conduct
the entrance interview with the borrower prior to disbursing HPSL/NSL funds, to inform him/her
of the rights and responsibilities associated with receiving the funds.
§ 57.210(b)(1)(ii) and 57.310(b)(1)(ii), Exit Interview (Disclosure) - The school must conduct
the exit interview with the borrower, or if borrower terminates studies without advance notice,
the school must attempt to inform the borrower of the substance of the exit interview and to
secure required information from the borrower by mail.
§ 57.210(b)(1)(iii) and 57.310(b)(1)(iii), Notification of Repayment (Notification) - The school
must notify the borrower in writing of the impending repayment obligation at least twice during
the grace period.
§ 57.210(b)(1)(iv) and 57.310(b)(1)(iv) - Notification during Deferment (Notification) - The
school must notify the borrower in deferment status in writing of the impending repayment
obligation 1 to 3 months prior to the expiration of the approved period of deferment.
§ 57.210(b)(1)(vi) and 57.310(b)(1)(vi) - Notification of Delinquent Accounts (Notification) The school must make at least four attempts to contact the borrower regarding past due
payments, prior to the loan becoming 120 days past due.

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§ 57.210(b)(1)(x) and 57.310(b)(1)(x) - Credit Bureau Notification (Notification) - The school
must become a member of a credit bureau and notify the credit bureau of accounts past due by
more than 120 days.
§ 57.210(b)(4)(i) and 57.310(b)(4)(i), Write-off of Uncollectible Loans (Reporting) - If a school
wishes to request the Department's approval to write off an uncollectible loan, it must do so
within 30 days of determining that the loan is uncollectible.
§ 57.211(a) and 57.311(a), Disability Cancellation (Reporting) - The Secretary will cancel a
student borrower's indebtedness if found to be permanently and totally disabled, on
recommendation of the school and as supported by whatever medical certification the Secretary
may require.
§ 57.312(a)(3), Evidence of Educational Loans (Disclosure) - Borrowers must provide evidence
of loans for which they are requesting partial payment for service in a health professional
shortage area. Under this regulatory section, there have been no repayment activities reportable
for NSL since 1982 when the provision was phased out due to lack of Federal funding.
§ 57.215(a)(2) and § 57.315(a)(1)(ii), Administrative Hearings (Reporting) - A school which
fails to comply with reporting requirements relating to the operation of its program, and is
therefore subject to termination, may submit a request for formal hearing which contains a
statement of material, factual issues in dispute.
§ 57.216a(d) and 57.316a(d), Administrative Hearings (Reporting) - A school which fails to
comply with requirements to reduce its default rates may submit a request for formal hearing
which contains a statement of material, factual issues in dispute.
2.

Purpose and Use of Information

These information collections and record keeping requirements are essential for assuring that
borrowers are fully informed of the terms and conditions of their loans and are aware of their
rights and responsibilities, and that schools know the history and status of each loan account, that
they pursue aggressive collection efforts, and maintain adequate records for audit and assessment
purposes. The reporting and recordkeeping requirements are to ensure compliance with the
authorizing legislation. Schools must maintain adequate records of loan accounts for audit and
assessment purposes, and pursue aggressive collection efforts to reduce default rates.
3.

Use of Improved Information Technology

Schools use automated systems and may select whatever information technology they have
available to maintain all records associated with the regulations.

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4.

Efforts to Identify Duplication

The information requested is unique to the HPSL and NSL program requirements. These
requirements will not result in duplication of reporting since schools would not be reporting this
kind of information elsewhere.
5.

Involvement of Small Entities

This activity does not involve small businesses or other small entities.
6.

Consequences If Information Collected Less Frequently

The information is collected at specified critical intervals of the program and, consequently,
could not be collected less frequently without detriment to the success of the program and the
financial interest of the Federal Government.
7.

Consistency With the Guidelines in 5 CFR 1320.5(d)(2)

Under P.L. 103-43 the HPSL statute allows for a 10-25 year repayment period at the discretion
of the institution (see Sec 134 General Provisions (a)(3)(B)), excluding periods of student status
and eligible deferment activities. As a result, student records and repayment records that are part
of the loan collections process must be retained for the appropriate repayment period. In
addition, the regulations require that student repayment records be retained for 5 years after
repayment of the loan.
8.

Consultation Outside the Agency

The notice required by 5 CFR 1320.8(d) was published in the Federal Register on July 23, 2008
(73 FR 42582-42583). No comments were received.
The following HPSL and NSL schools were contacted by program staff regarding various
aspects of the HPSL and NSL programs. They report no problems and there are no unresolved
issues.
Health Professions Student Loan Contacts
1.

Ann Wilson
Bursars Office
University of Oklahoma Health Sciences Center
P.O. Box 26901
Oklahoma City, Oklahoma 73190
(405) 271-2680

2.

Nancy Martorano
Director of Financial Aid
Philadelphia College of Osteopathic Medicine

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School of Osteopathy
4170 City Avenue
Philadelphia, Pennsylvania 19131
(215) 871-6173
Nursing Student Loan Contacts
1.

Ann Wilson
Bursars Office
University of Oklahoma Health Sciences Center
P.O. Box 26901
Oklahoma City, Oklahoma 73190
(405) 271-2680

2.

Stacey Mathews
Director of Financial Operations
Student Loan Office
University of Mississippi
Medical Center
2500 North State Street
Jackson, Mississippi 39216-4505
(601) 984-1035

9. Remuneration of Respondents
Respondents will not be remunerated.
10.

Assurance of Confidentiality

Several records systems were established for the HPSL and NSL Programs, which cover the
kinds of records maintained by the schools under these regulations. The system numbers are 0915-0038, and 09-15-0039.
11.

Questions of a Sensitive Nature

There are no questions of a sensitive nature.
12.

Estimates of Annualized Hour Burden

The reporting and recordkeeping burden is as follows:

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RECORDKEEPING REQUIREMENTS
Regulatory/section requirements

Number of
Record keepers

HPSL Program:
57.206(b)(2), Documentation of
Cost of Attendance
57.208(a), Promissory Note
57.210((b)(1)(i), Documentation of
Entrance Interview
57.210(b)(1)(ii), Documentation of
Exit Interview
57.215(a)&(d), Program Records
57.215(b), Student Records
57.215(c), Repayment Records
HPSL Subtotal
Regulatory/section requirements

Hours per year Total Burden
Hours

432
432

1.17
1.25

505
540

432
*472

1.25

540

0.33
10
10
18.75
..............

156
4,720
4,720
8,850
20,031

*472
*472
*472
472
Number of
Record keepers

Hours per year Total Burden
Hours

NSL Program:
57.306(b)(2)(ii), Documentation of
300
0.3
90
Cost of Attendance
57.308(a), Promissory Note
300
0.5
150
57.310(b)(1)(i), Documentation
of
300
0.5
150
Entrance Interview
57.310(b)(1)(ii), Documentation of
*435
0.17
74
Exit Interview
57.315(a)(1)&(a)(4), Program
*435
5
2,175
Records
57.315(a)(2), Student Records
*435
1
435
57.315(a)(3), Repayment Records
*435
2.51
1,092
NSL Subtotal
435
..............
4,166
Total for HPSL and NSL
907
..............
24,197
*Includes active and closing schools.
HPSL data includes active and closing Loans for Disadvantaged Students (LDS) program
schools.

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REPORTING REQUIREMENTS
Regulatory/section requirements

HPSL Program:
57.206(a)(2), Student
Financial Aid Transcript
57.208(c), Loan
Information Disclosure
57.210(b)(1)(i), Entrance
Interview
57.210(b)(1)(ii), Exit
Interview
57.210(b)(1)(iii), Notification
of Repayment
57.210(b)(1)(iv), Notification
During Deferment
57.210(b)(1)(vi), Notification
of Delinquent Accounts
57.210(b)(1)(x), Credit
Bureau Notification
57.210(b)(4)(i), Write-off of
Uncollectible Loans
57.211(a) Disability
Cancellation
57.215(a)(2), Administrative
Hearings
57.215(a)(d), Administrative
Hearings
HPSL Subtotal

Number of
Respondents

Responses
per
Respondent

4,600

1

432
432
*472

Total
annual
responses

Hours
per
response

Total
hour
burden

4,600

.25

1,150

68.73

29,692

.0833

2,473

68.73

29,692

0.167

4,959

12

5,664

0.5

2,832

30.83

14,552

0.167

2,430

24.32

11,479

0.0833

957

10.28

4,853

0.167

811

8.03

3,790

0.6

2,274

20

1.00

20

3.0

60

10

1

10

.75

8

0

0

0

0

0

0
7,854

0
..........

0
104,352

0
........

0
17,954

*472
*472
*472
*472

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REPORTING REQUIREMENTS Continued
Regulatory/section requirements

Number of
Respondents

Responses
per
Respondent

4,100

1

300
*435

NSL Program:
57.306(a)(2), Student
Financial Aid Transcript
57.310(b)(1)(i), Entrance
Interview
57.310(b)(1)(ii), Exit
Interview
57.301(b)(1)(iii), Notification
of Repayment
57.310(b)(1)(iv), Notification
During Deferment
57.310(b)(1)(vi), Notification
of Delinquent Accounts
57.310(b)(1)(x), Credit
Bureau Notification
57.310(b)(4)(i), Write-off of
Uncollectible Loans
57.311(a), Disability
Cancellation
57.315(a)(1)(ii),
Administrative Hearings
57.316(a)(d), Administrative
Hearings
NSL Subtotal
Total for HPSL and NSL
Total Burden Hours for HPSL
and NSL for Reporting and
Recordkeeping

Total
annual
responses

Hours
per
response

Total
hour
burden

4,100

0.25

1,025

23.51

7,053

0.167

1,178

3.77

1,640

0.5

820

6.18

2,688

0.167

449

0.65

283

0.083

24

4.61

2,006

0.167

335

8.3

3,611

0.6

2,167

20

1.0

20

3.5

70

10

1.0

10

0.8

8

0

0

0

0

0

0
6,605

0
..........
..........

0
21,411

0
........
........

0
6,076

*435
*435
*435
*435

14,459

125,763

*Includes active and closing schools.
RECORDKEEPING REQUIREMENTS Basis for Burden:
The estimates of burden for the schools are for the maintenance of required records on the
history and status for each loan account.
The total burden for the HPSL and NSL schools is 48,227 hrs.

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24,030
48,227

13. Estimates of Annualized Cost Burden to Respondents
There are no maintenance or operating costs. Respondents maintain the required information for
their own purposes and the reports are generated automatically. The computers used to generate
the reports have been acquired for usual and customary school operations.
14.

Estimates of Annualized Cost to the Government

The total cost to the Federal Government to perform the review of requests for cancellation is
$7,240.
Disability Cancellations (.1 FTE @ $72,400 = $7,240)
15.

Changes in Burden

There are currently 52,690 hours in the inventory for the HPSL/NSL regulatory requirements.
This submission is for approval of 48,227 total burden hours, for a decrease of 4,463 hours.
The decrease in the estimate of burden hours is due to a decrease in the number of participating
schools since the last approval. The overall result is a program adjustment with a decrease of
4,463 hours in the annual estimate of burden.
16.

Time Schedule, Publication and Analysis Plans

There are no plans for tabulation, statistical analysis or publication of the information maintained
by the schools.
17. Exemption for Display of Expiration Date
No exemption is being requested.
18. Certifications
This information fully complies with the guidelines in 5 CFR 1320.9. The certifications are
included in this package.

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