SUPPORTING STATEMENT
Information Collections Under the Proposed Regulations Governing the Student Assistance General Provisions.
A. Justification
1. Necessity of Information Collected
The General Provisions regulations revise current regulations in the areas of program administration.
These proposed regulations are a result of regulatory review of the program regulations to reduce administrative burden for program participants, provide benefits to Title IV, HEA program recipients, and protect the taxpayers' interest. This request is for approval of reporting requirements contained in the attached proposed regulations related to the General Provisions administrative requirements for the Title IV, HEA programs. The information collection requirements in these proposed regulations are necessary to determine eligibility to receive program benefits and to prevent fraud and abuse of program funds.
General Provisions: (OMB control number: 1845-0022)
Sections 668.14, 668.43, 668.46, 668.190, 668.191, 668.209, 668.210, 668.211, and 668.212 contain information collection requirements. Under the Paperwork Reduction Act of 1995 (44 U.S.C. 3507(d)), the Department of Education is submitting a copy of these sections to the Office of Management (OMB) for its review. We are proposing the following changes to those sections:
Section 668.14 – Program participation agreement.
Peer to peer file sharing/copyrighted materials - §668.14(b)(30).
The proposed regulations in §668.14(b)(30) require an institution, as a condition of participation in a title IV, HEA program, to agree that it has developed and implemented plans to effectively combat the unauthorized distribution of copyrighted material by users of the institution’s network without unduly interfering with the educational and research use of the network.
The proposed regulation requires an institution, in consultation with the chief technology officer or other designated officer of the institution, to the extent practicable, offer legal alternatives to illegal downloading or otherwise acquiring copyrighted material, as determined by the institution. The proposed regulations would also require that institutions (1) periodically review the legal alternatives for downloading or otherwise acquiring copyrighted material and (2) make the results of the review available to their students through a Web site and/or other means.
Teach-out plans - §668.14(b)(31).
The proposed regulations in §668.14(b)(31) are amended to require an institution to submit a teach-out plan to its accrediting agency whenever (1) the Department or their accrediting agency initiates an LS&T, or an emergency action against the institution, as required by statute; (2) the institution’s State licensing or authorizing agency revokes the institution’s license or legal authorization to provide an educational program; (3) the institution intends to close a location that provides 100 percent of at least one program; or (4) the institution otherwise intends to cease operations.
Section 668.43 – Institutional information.
Plans for improving academic programs - §668.43(a)(5)(iv).
The proposed regulation in §668.43(a)(5)(iv) amends the information about the academic program that the institution must make readily available to enrolled and prospective students about any plans by the institution for improving any academic program at the institution. An institution would be allowed to determine what a “plan” is, including when a plan becomes a plan.
Services and facilities for student with disabilities - §668.43(a)(7).
The proposed regulation in §668.43(a)(7) changes the phrase “any special facilities and services” to “the services and facilities,” and replaces the phrase “disabled students” with “students with disabilities.” The proposed changes would also clarify that a description of services and facilities for students with disabilities must also contain the services and facilities available for students with intellectual disabilities.
Unauthorized distribution of copyrighted materials - §668.43(a)(10).
The proposed regulations in §668.43(a)(10) requires information regarding institutional policies and sanctions related to the unauthorized distribution of copyrighted material be included in the list of institutional information provided upon request to prospective and enrolled students. This information must (1) explicitly inform enrolled and prospective students that unauthorized distribution of copyrighted material, including peer-to-peer file sharing, may subject a student to civil and criminal liabilities; (2) include a summary of the penalties for violation of Federal copyright laws; and (3) delineate the institution’s policies with respect to unauthorized peer-to-peer file sharing, including disciplinary actions that are taken against students who engage in illegal downloading or unauthorized distribution of copyrighted materials using the institution’s information technology system.
Section 668.46 – Institutional security policies and crime statistics.
Annual security report – missing student notification policy - §668.46(b).
The proposed regulations in §668.46(b) require an institution to include its missing student notification policy and procedures in its annual security report. The missing student notification policy announcement would be required beginning with the annual security report distributed by October 1, 2010.
Hate crime reporting - §668.46(c)(3).
The proposed regulations in §668.46(c)(3) add the crimes of “larceny-theft,” “simple assault,” “intimidation,” and “destruction/damage/vandalism of property” to the crimes that must be reported in hate crime statistics. Additionally, the proposed regulations update the definitions of the terms “Weapons: carrying, possessing, etc.,” “Drug abuse violations,” and “Liquor law violations” which are excerpted from the Federal Bureau of Investigation’s Uniform Crime Reporting Program, to reflect changes made by the FBI to these definitions in 2004.
Timely warning and emergency notification - §668.46(e).
The proposed regulations in §668.46(e) clarify the difference between the existing timely warning requirement and the new requirement for an emergency notification policy. While a timely warning must be issued in response to specific crimes, an emergency notification is required in the case of an immediate threat to the health or safety of students or employees occurring on campus. The proposed language would clarify that an institution that follows its emergency notification procedures is not required to issue a timely warning based on the same circumstances; however, the institution must provide adequate follow-up information to the community as needed.
Emergency response and evacuation procedures - §668.46(g).
The proposed regulations in §668.46(g) outline the elements that an institution must include in its statement of policy describing its emergency response and evacuating procedures in its annual security report. They include the procedures to immediately notify the campus community upon the confirmation of a significant emergency or dangerous situation involving an immediate threat occurring on the campus.
A description of the process that the institution will use to (1) confirm that there is a significant emergency or dangerous situation, (2) determine the appropriate segment or segments of the campus community to receive a notification, (3) determine the content of the notification, and (4) initiate the notification system.
A statement that the institution will, without delay, and taking into account the safety of the community, determine the content of the notification and initiate the notification system, unless issuing the notification will, in the professional judgment of responsible authorities, compromise efforts to assist a victim or to contain, respond to, or otherwise mitigate the emergency.
A list of the titles of the persons or organizations responsible for carrying out the actions proposed.
Procedures for disseminating emergency information to the larger community.
Procedures for testing its emergency response and evacuation procedures on at least an annual basis with at least one test per calendar year, and be documented, including a description of the exercise, the date, time, and if it was announced or unannounced.
Missing student notification - §668.46(h).
The proposed regulation in §668.46(h) implements the new statutory requirements, specifying that a statement of policy regarding missing student notification for students residing in on-campus student housing facilities.
The proposed regulation further requires an institution to advise students who are under 18 and not emancipated that if the student is missing it will notify a custodial parent or guardian in addition to any contact person designated by the student. All students must also be advised that, regardless of whether they name a contact person, the institution must notify the local law enforcement agency that the student is missing, unless the local law enforcement was the entity that determined the student to be missing.
Sections 668.190, 668.191, 668.209, 668.210, 668.211, and 668.212 - Electronic Processes.
The proposed regulations would eliminate the need to request a loan record detail report by providing that the report will be sent electronically to the institution as part of a package notifying the institution of its official cohort default rate. The institution would have five business days, from the transmission date of the package as posted on the Department’s Web site, to report any problem with receiving that transmission. If the institution reports a problem within the five-day period, and the Department agrees that the institution did not cause the problem, we will extend the adjustment, challenge, and appeal, deadlines and timeframes to account for retransmitting the package after the problem is resolved. The timeframes for the adjustments, challenges, and appeals, are reflected in 668.190(b) and 668.191(b).
The subpart M provisions in proposed 668.186, and the provisions for adjustments, challenges, and appeals in the related sections, would also be reflected in the following parallel provisions in subpart N: 668.209, 668.210, 668.211, and 668.212.
2. Purpose and Use of Information Collected
General Provisions:
The information collected and reported in Subparts B and D of Part 668 – Student Assistance General Provisions will continue to be used for program participation and for student consumer information purposes. The information collected and reported in Subparts M and N of Part 668 – Student Assistance General Provisions will continue to be used for institutions to appeal their cohort default rates. The information collected and reported will continue to be used as necessary in the calculation of cohort default rates. If we did not require the collection and reporting of information in Subparts B and D, we would not be able to conform the participation agreements with the statute, nor would we be providing the required disclosures to prospective and enrolled students. If we did not require the collection and reporting of information in Subparts M and N, we would not be able to calculate cohort default rates, nor would institutions be able to submit an appeal or make adjustments.
3. Consideration of Improved Information Technology
General Provisions:
We propose to maximize the use of available technology by providing electronic loan record detailed reports to institutions should they wish to make an appeal of their cohort default rate or request a correction to their default data. Under the proposed regulations this information will be automatically provided to the institution and not as a result of a request made by the institution to the Department.
4. Efforts to Identify Duplication
A thorough review of procedures indicates that current requirements are minimal and avoid duplication. This review was done in conjunction with affected parties who have a vested interest in eliminating duplication.
5. Burden Minimization as Applied to Small Business
No small businesses are impacted by this collection.
6. Consequences of Less Frequent Data Collection
Recordkeeping requirements are imposed to assure accountability of program participants for proper program administration and less frequent collection could impair accountability of program participants.
Special Circumstances Governing Data Collection
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. Consultation Outside the Agency
The Notice of Proposed Rulemaking (NPRM) will be published in the Federal Register for comment.
9. Payments or Gifts to Respondents
No payments or gifts will be provided to the respondents.
10. Assurance of Confidentiality
A Privacy Act Notice is included on the Application Form and Promissory Note. In this notice, the borrower is informed of the statutory authority for collecting the information requested. Although disclosure of the information is voluntary, the borrower is informed that in order to be considered for Perkins Loan, FFEL, or Direct Loan Program funds, the information must be provided. The information provided is used to verify the borrower's identity, to determine the borrower's eligibility to receive a Perkins Loan, FFEL, or Direct Loan Program loan and benefits, to permit the servicing of the borrower'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 the information may be disclosed and for what purposes the information may be disclosed is also included.
11. Questions of Sensitive Nature
The Department is not requesting any sensitive data.
12. Annual Hour Burden for Respondents/Recordkeepers.
General Provisions:
Section 668.14 – Program participation agreement.
Peer to peer file sharing/copyrighted materials - §668.14(b)(30).
Under this proposed regulation, institutions would be required to develop and implement policies to effectively combat the unauthorized distribution of copyrighted materials by users of the institution’s computer network. We estimate that the average burden to meet the proposed requirements will be 16 hours of additional development, implementation, and evaluation to comply with the proposed regulations in §668.14(b)(30).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X 16 hours = 32,880
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X 16 hours = 27,920
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X 16 hours = 30,320
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 91,120
Teach-out plans - §668.14(b)(31).
Under this proposed regulation, an institution would be required to develop and submit for approval by its accrediting agency, a teach-out plan whenever an eligible and participating institution wants to teach-out students at a school which is closing or has otherwise ceased to operate. We estimate that a proprietary institution will develop a teach-out plan for submission and approval will increase burden by 10 hours per plan to comply with the proposed regulations in §668.14(b)(31).
Affected Entity:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
16 X 10 hours = 160
Total # of Respondents: Total Responses: Total Burden Hours
16 16 160
Section 668.43 – Institutional information.
Plans for improving academic programs - §668.43(a)(5)(iv).
The proposed regulation amends the information that an institution is required to disclose to prospective students and enrolled students to include institutional plans for improving academic programs at the institution. We estimate that the average burden to meet the proposed requirements will be 968 hours of additional development, implementation, and evaluation to comply with the proposed regulations in §668.43(a)(5)(iv).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X .17 hours = 349
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X .17 hours = 297
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X .17 hours = 322
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 968
Services and facilities for student with disabilities - §668.43(a)(7).
The proposed changes clarify that a description of services and facilities for students with disabilities that is provided to enrolled and prospective students must also contain services and facilities available for students with intellectual disabilities.
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1 X .17 hours = 0
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
60 X .17 hours = 10
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
200 X .17 hours = 34
Total # of Respondents: Total Responses: Total Burden Hours
261 261 44
Unauthorized distribution of copyrighted materials - §668.43(a)(10).
Most of the burden related to the prevention of unauthorized distribution of copyrighted materials is in §668.14(b)(30) where the institution’s plan is developed and implemented. This section of the proposed regulations requires the institution to provide a statement of the institution’s policies and sanctions for unauthorized distribution of copyrighted materials and unauthorized peer-to-peer file sharing. That statement includes civil and criminal penalties that students would be subject to, for violations of Federal copyright laws.
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X .25 hours = 514
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X .25 hours = 436
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X .25 hours = 474
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 1,424
Section 668.46 – Institutional security policies and crime statistics.
Annual security report – missing student notification policy - §668.46(b).
Beginning with the annual security report distributed by October 1, 2010, the proposed regulations require a statement of policy regarding missing student notification procedures. We estimate that the proposed requirements will increase burden by 456 hours to comply with the proposed regulations in §668.46(b).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X .08 hours = 164
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X .08 hours = 140
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X .08 hours = 152
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 456
Hate crime reporting - §668.46(c)(3).
Under the proposed regulations, an institution must report, by category of prejudice, crimes reported to local police agencies or to a campus security authority that manifest evidence that the victim was intentionally selected because of the victim’s actual or perceived race, gender, religion, sexual orientation, ethnicity, or disability.
We estimate that the proposed requirements will increase burden by 5,695 hours to comply with the proposed regulations in §668.46(c)(3).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X 1 hour = 2,055
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X 1hour = 1,745
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X 1 hour = 1,895
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 5,695
Timely warning and emergency notification - §668.46(e).
Under the proposed regulations, if there is an immediate threat to the health or safety of students or employees occurring on campus, an institution must follow its emergency notification procedures. An institution that follows its emergency notification procedures is not required to issue a timely warning based on the same circumstances; however, the institution must provide adequate follow-up information to the community as needed.
We estimate that the proposed requirements will increase burden by 1,424 hours to comply with the proposed regulations in §668.46(e).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X .25 hours = 514
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X .25 hours = 436
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X .25 hours = 474
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 1,424
Emergency response and evacuation procedures - §668.46(g).
The proposed regulations in §668.46(g) outline the elements that an institution must include in its statement of policy describing its emergency response and evacuating procedures in its annual security report. A description of the process that the institution will use to (1) confirm that there is a significant emergency or dangerous situation, (2) determine the appropriate segment or segments of the campus community to receive a notification, (3) determine the content of the notification, and (4) initiate the notification system. The emergency response and evacuation procedures also includes a list of the titles of the persons or organizations responsible for carrying out the actions proposed, as well as procedures for disseminating emergency information to the larger community. In addition, the procedures will include testing its emergency response and evacuation procedures on at least an annual basis with at least one test per calendar year, and be documented, including a description of the exercise, the date, time, and if it was announced or unannounced.
We estimate that the proposed requirements will increase burden by 11,390 hours to comply with the proposed regulations in §668.46(g).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
2,055 X 2 hours = 4,110
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,745 X 2 hours = 3,490
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X 2 hours = 3,790
Total # of Respondents: Total Responses: Total Burden Hours
5,695 5,695 11,390
Missing student notification - §668.46(h).
The proposed regulation in §668.46.(h) implements the new statutory requirements, specifying that a statement of policy regarding missing student notification for students residing in on-campus student housing facilities. The proposed regulation further requires an institution to advise students who are under 18 and not emancipated that if the student is missing it will notify a custodial parent or guardian in addition to any contact person designated by the student. All students must also be advised that, regardless of whether they name a contact person, the institution must notify the local law enforcement agency that the student is missing, unless the local law enforcement was the entity that determined the student to be missing.
We estimate that the proposed requirements for institutions with on-campus housing will increase burden by 2,423 hours to comply with the proposed regulations in §668.46(h).
Affected Entities:
Private – for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
62 X .67 hours = 42
Private – not-for-profit institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,658 X .67 hours = 1,111
Public institutions:
# of institutions Average # hrs of addt’l burden Burden Hours
1,895 X .67 hours = 1,270
Total # of Respondents: Total Responses: Total Burden Hours
3,615 3,615 2,423
Sections 668.190, 668.191, 668.209, 668.210, 668.211, and 668.212 - Electronic Processes.
We estimate that the burden associated with appealing cohort default rates will decrease as a result of the proposed regulation eliminating the need for institutions to request their loan record detail report.
Affected Entities:
INSTITUTIONS:
483 appeals X 1.5 hours = 725 hour decrease in burden
(Ties to Team II)
Respondents, Responses and Burden Hours:
# of Respondents # of Responses #Hrs/Response #Hrs
Burden
483 483 1.5 -725
(Ties to Team II)
General Provisions:
Section 668.14 – Program participation agreement.
Peer to peer file sharing/copyrighted materials - §668.14(b)(30).
We estimate the cost to implement effective plans to combat unauthorized duplication of copyrighted materials to be $9,112,000.
5,695 institutions X 16 hours of research, development and implementation X $100 per hour programming time = $9,112,000.
Teach-out plans - §668.14(b)(31).
We estimate the cost of development of required teach-out plans to be $16,000.
16 plans X 10 hours X $100 per hour = $16,000.
Section 668.43 – Institutional information.
Plans for improving academic programs - §668.43(a)(5)(iv).
We estimate that there will be no substantive additional cost associated with the implementation of this proposed regulation and the required announcement of the institution’s plans for academic program improvement.
Services and facilities for student with disabilities - §668.43(a)(7).
We estimate that there will be no substantive additional cost associated with the implementation of this proposed regulation and the required announcement of the institution’s programs, services and facilities for students with intellectual disabilities.
Unauthorized distribution of copyrighted materials - §668.43(a)(10).
We estimate that there will be no substantive additional cost associated with the implementation of this proposed regulation and the required announcement of the institution’s policies on the copying and distribution of copyright protected materials. The substantive cost is accounted for in §668.14(b)(30).
Section 668.46 – Institutional security policies and crime statistics.
Annual security report – missing student notification policy - §668.46(b).
We estimate that there will be no substantive additional cost associated with the implementation of this proposed regulation and the required announcement about missing student notification.
Hate crime reporting - §668.46(c)(3).
We estimate the cost of for reprogramming the security reporting to include hate crime data to be $569,500.
5,695 institutions X 1 hour X $100 per hour for programming = $569,500.
Timely warning and emergency notification - §668.46(e).
We estimate that there will be no substantive additional cost associated with the implementation of this proposed regulation on timely warnings and emergency notification.
Missing student notification - §668.46(h).
We estimate that of the 3,615 institutions of higher education with on-campus housing, that it will take each .67 hours at $100 per hour for a total estimated cost of $242,205 to comply with the proposed regulations.
Sections 668.190, 668.191, 668.209, 668.210, 668.211, and 668.212 - Electronic Processes.
There are no costs to the Institution for providing the loan record detail report.
TOTAL OF BURDEN INCREASES:
# of Respondents # of Responses # Hours
Burden
44,240 44,240 114,379
Summary of Current Burden Inventory:
Respondents, Responses and Burden Hours:
# of Respondents # of Responses #Hrs
Burden
409,364 245,368 1,191,391
Revised Burden Inventory:
Respondents, Responses and Burden Hours:
# of Respondents # of Responses #Hrs
Burden
453,604 289,608 1,305,770
13. Start-Up Cost Burden to the Respondents
There are no start-up costs associated with these proposed regulatory changes.
14. Estimated Annual Cost to the Federal Government
There are no additional costs to the Federal government as a result of the final regulations.
15. Reasons for Changes to Burden Hour Estimated
These changes to the burden estimates are as a result of the proposed regulations to implement the statutory changes made by the Higher Education Opportunity Act (HEOA) (Pub. L. 110-315) to the Higher Education Act of 1965, as amended (HEA).
Below is a summary of the changes in burden hours:
Respondents, Responses and Burden Hours:
Section 668.14 – Program participation agreement.
Peer to peer file sharing/copyrighted materials - §668.14(b)(30).
# of Respondents: # of Responses: #Hours
Burden
5,695 5,695 91,120
Teach-out plans - §668.14(b)(31).
# of Respondents: # of Responses: # Hours
Burden
16 16 160
Section 668.43 – Institutional information.
Plans for improving academic programs - §668.43(a)(5)(iv).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 968
Services and facilities for student with disabilities - §668.43(a)(7).
# of Respondents: # of Responses: # Hours
Burden
261 261 44
Unauthorized distribution of copyrighted materials - §668.43(a)(10).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 1,424
Section 668.46 – Institutional security policies and crime statistics.
Annual security report – missing student notification policy - §668.46(b).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 456
Hate crime reporting - §668.46(c)(3).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 5,695
Timely warning and emergency notification - §668.46(e).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 1,424
Emergency response and evacuation procedures - §668.46(g).
# of Respondents: # of Responses: # Hours
Burden
5,695 5,695 11,390
Missing student notification - §668.46(h).
# of Respondents: # of Responses: # Hours
Burden
3,615 3,615 2,423
Sections 668.190, 668.191, 668.209, 668.210, 668.211, and 668.212 - Electronic Processes.
# of Respondents # of Responses #Hrs/Response # Hours
Burden
483 483 1.5 -725
GRAND TOTAL:
# of Respondents # of Responses # Hours
Burden
44,240 44,240 114,379
Summary Current Burden Inventory:
Respondents, Responses and Burden Hours:
# of Respondents # of Responses #Hrs
Burden
409,364 245,368 1,191,391
Revised Burden Inventory:
Respondents, Responses and Burden Hours:
# of Respondents # of Responses #Hrs
Burden
453,604 289,608 1,305,770
16. Collection of Information with Published Results
The results of the collection of information will not be published.
17. Approval to Not Display Expiration Date
ED is not seeking this approval.
18. Exception to the Certification Statement
ED is not requesting any exceptions to the "Certification for Paperwork Reduction Act Submissions".
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | I.R.G. |
| Last Modified By | Authorised User |
| File Modified | 2009-10-09 |
| File Created | 2009-10-09 |