Ss_1845-0002(11-5-2010)

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION

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 copy of the appropriate section of each statute and regulation mandating or
authorizing the collection of information.
In order to manage the Title IV, HEA assistance programs, authorized by the Higher Education Act of 1965, as
amended (HEA); 20 U.S.C. 1070 et seq., Federal Student Aid (FSA) must electronically transact business with the
following FSA systems and institutions that include, but are not limited to the following:
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Common Origination and Disbursement (COD) system

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Central Processing (CPS) system

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Electric Campus-Based (eCB) system

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National Student Loan Data System (NSLDS)

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Financial Management System (FMS)

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Common Services for Borrowers (CSB)

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Debt Management Collection System (DMCS), under CSB

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Direct Loan Servicing System (DLSS), under CSB

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Title IV Additional Servicers (TIVAS)

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Access Information Management System (AIMS)

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Postsecondary Educational Participants System (PEPS)

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Institutions of higher education that participate in Title IV, HEA assistance programs.

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Third-party servicers that provide services to eligible institutions of higher education.

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State scholarship agencies

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Guaranty agencies for the Federal Family Education Loan (FFEL) Program or their third-party servicers

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Lenders for the Federal Family Education Loan (FFEL) Program or their third-party servicers

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Others approved by the U.S. Department of Education

The U.S. Department of Education, FFEL lenders and their third-party servicers, guaranty agencies and their thirdparty servicers, Title IV Additional Servicers (TIVAS), local educational agencies (LEAs), public secondary
schools, private secondary schools, State agencies and their third-party servicers, and institutions of higher
education and their third-party servicers use the Student Aid Internet Gateway (SAIG) to electronically transmit and
receive data with the Department’s contracted processors for Title IV, HEA assistance programs. The entities
described above (the entities) that need access to the SAIG and online FSA systems must enroll with Federal
Student Aid through the SAIG Participation Management System, at the https://fsawebenroll.ed.gov Web site, or by
using the paper SAIG Enrollment Form, to establish a location, called a Destination Point (TG Number/Mailbox),
from which to transact business electronically with Federal Student Aid.

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In order to protect privacy information contained in the Federal Student Aid systems, FSA has established security
procedures that include requiring the entities that need access to FSA systems to designate individuals to serve as a
Primary Destination Point Administrator (Primary DPA) in order to conduct transactions on behalf of the entities.
Once a Primary DPA is established, he or she may enroll additional Destination Point Administrators (DPA’s) for
selected electronic services and for access to Federal Student Aid systems.
Before a Primary DPA is granted access to the SAIG, the individual must enroll with Federal Student Aid by
providing his or her name, date of birth, address, e-mail address, telephone number, Social Security Number, certain
confidential information that only the Primary DPA knows, the name of the entity the Primary DPA represents and
by indicating the specific services the entity wishes to participate in through the Primary DPA.
Most of the enrollment process can be completed from the https://fsawebenroll.ed.gov Web site; however,
enrollment is not considered complete until FSA receives a hard-copy certification page signed by the Primary DPA
and the entity’s chief operating officer authorized to enter into written agreements, for the entity, signs the Primary
DPA’s enrollment agreement. Only the Primary DPA may enroll additional organizational members and select the
specific services to be conducted by each of those individuals. Each Primary DPA that enrolls other DPA’s must
provide the same personally identifiable information about each of those individuals that he or she provided (e.g.,
name, Social Security Number, etc.).
An enrolled Primary DPA is able to –
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Electronically exchange files of financial aid data

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Access services of the Federal Direct Loan Program

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Perform data transmissions for the electronic Campus-Based (eCB) programs for Federal Work-Study
(FWS), Federal Supplemental Educational Opportunity Grant (FSEOG) and the Federal Perkins Loan
program

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Access Grant services of the Federal Pell Grant program, the Iraq Afghanistan Service Grant program, the
ACG/National SMART Grant programs, and the TEACH Grant program

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Access the Central Processing System (CPS) database or Web-based systems through FAA Access to CPS
Online

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Access the Campus-based system through the Fiscal Operations Report and Application to Participate
(FISAP) Online

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Access the National Student Loan Data System (NSLDS) and receive cohort default rate (eCDR)
notification packages

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Access the Lender Reporting System (LaRS) to send financial reporting information to Federal Student
Aid’s Financial Management System (FMS)

With access to FSA systems, a Primary DPA can –
• Complete and send electronic initial and renewal financial aid (FAFSA) applications to the CPS
• Receive electronic Institutional Student Information Records (ISIRs) from the CPS
• Send electronic corrections of applicant data to the CPS
• Exchange payment and required reporting information from the Federal Pell Grant program, the Iraq
Afghanistan Service Grant program, the ACG/National SMART Grant programs, and the TEACH Grant
•
•

program
Receive Electronic Statements of Accounts (ESOA) from the Federal Pell Grant Program
Exchange data with the Federal Direct Loan Program to originate loans; draw down, disburse, and
reconcile loan funds; and report student status.

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•
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Exchange data with the NSLDS
Receive eCDR Rate Reports from Default Management

For the 2011-2012 Award Year, we are providing an Enrollment Form designed for the convenience of Local
Educational Agencies and Secondary Schools to enroll in the SAIG. The new version of enrollment form for the
Local Educational Agencies, as well as the enrollment form for State Scholarship and Grant Agencies are
streamlined versions of the enrollment form designed for Post Secondary Schools and Servicers, containing only the
questions that are appropriate for each group.
On November 29, 1996, the Secretary published final regulations in the Federal Register (61 FR 60603) that
required institutions to participate in the electronic processes identified by the Secretary in order to improve the
administration and delivery of FSA program funds to students and institutions and to protect Federal fiscal interests.
Institutions must use software developed by the institution, or its vendor, in accordance with the specifications
provided by the Secretary in the regulations. The Secretary believes that the savings and benefits from these
electronic business processes are more than offset by any necessary initial investments by both the U.S. Department
of Education and by institutions.

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.
The Participant Management System manages a participant database, which is a collection of data from the SAIG
Enrollment Form. The enrollment process enables entities to receive, transmit, view, and update student financial
aid data available through the SAIG Mailbox system and other FSA online Web services (e.g. NSLDS online and
FAA Access). The enrollment form is available on the Internet at https://fsawebenroll.ed.gov. Information collected
via the enrollment form is used to assign entities a SAIG Mailbox ID (TG Number) and associate the application
services selected to that entity and its Primary DPA, as well as its non-Primary DPAs.

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.
The enrollment process for electronic services and access to FSA systems is on the Internet, and the design of the
Web site is based on the SAIG Enrollment Form (paper). Customers can enroll and change services via the SAIG
enrollment Web site at https://fsawebenroll.ed.gov. This Web site reduces and virtually eliminates paper collection
for enrollment (the paper enrollment form and process will continue to be available upon request for entities having
difficulties accessing the Internet). Entities may use the Web enrollment process to complete and submit
applications to participate in the FSA electronic services currently available. The U.S. Department of Education is
sensitive to the concerns of entities and individuals regarding the security of their application data. Users will be
prompted to enter confidential authentication identifiers in order to validate their identity before being allowed to
change or update FSA services. In addition, users will be advised via the Web site to check the security
configuration of their browser to ensure that the information they transmit to ED is protected.

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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 SAIG enrollment form is the only means that Title IV participating schools and other eligible entities can use to
enroll for the previously mentioned data exchange services.

5. If the collection of information impacts small businesses or other small entities (Item
8b of IC Data Part 2), describe any methods used to minimize burden.
No small businesses are affected by this information collection.

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.
If collection is not conducted, no new participants will be able to enroll for electronic services. Existing participants
will not be able to change their existing services, including deactivating individuals who no longer need access to
the services, or who are no longer employed.

7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
The collection of this information will be conducted in a manner that does not involve any of the guidelines in:

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Requiring respondents to report information to the agency more often than quarterly.
N/A – Respondents report as needed.
Requiring respondents to prepare a written response to a collection of information in fewer than 30
days after receipt of it.
N/A – Respondents report as they need to enroll or make changes to an enrollment.
Requiring respondents to submit more than an original and two copies of any document.
N/A – Only the originals are submitted.
Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid,
or tax records for more than 3 years.
The Office of Inspector General periodically audits schools. Schools must keep copies of the
participation information with signatures for review as well as the FSA User Statement with
original signature. These documents are required to protect the security of the FSA’s systems of
records.
In connection with a statistical survey, that is not designed to produce valid and reliable results that
can be generalized to the universe of study.
N/A – These data are not collected to conduct statistical surveys.
Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.
N/A – These data are not collected to conduct statistical surveys.

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•

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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 which unnecessarily impedes sharing of data with other agencies for compatible
confidential use.
N/A – Does not meet any of the above-mentioned criteria.
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 SAIG Enrollment Form collects Social Security Number, date of birth, and mother's maiden
name from every Destination Point Administrator. Two of these identifiers (Social Security
Number and date of birth) are used to authenticate the customer when they request a password
reset from the SAIG/CPS Technical Support Help Line. Electronic authentication is now done
through Security Architecture (SA) and users are required to enter their FSA User ID to use
protected pages on the Web enrollment site.

8. If applicable, provide a copy and identify the date and page number of publication in
the Federal Register of the agency’s notice, 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 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.
FSA consults with all applicable application systems during the requirements phase to solicit comments and
suggestions for improving the enrollment form. These meetings address problems and enhancements to the
existing form. FSA has enhanced the enrollment form to simplify the enrollment process for all participating
institutions. A 60-day and 30-day federal register notice will be published seeking public comment.
PUBLIC COMMENTS RECEIVED IN RESPONSE TO THE 60-DAY FEDERAL REGISTER
NOTICE
The secretary invited comments on the Notice of Proposed Information Collection Request published on
August 24, 2010 and we received seven comments from one respondent during the 60-day open comment
period.
Summary of Comments Received:

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a)

On the “Federal Student Aid System Access Enrollment Form for FAFSA Completion Tracking” form,
one commenter asked us to revise the phrase, on page 2, “In order to obtain information on Free
Application for Federal Student Aid (FAFSA) submission for students affiliated with an organization,
the organization must enroll to participate in the U.S. Department of Education’s Student Aid Internet
Gateway (SAIG).” to read as “In order to obtain information on a Free Application for Federal Student
Aid (FAFSA) submission by a consumer, the organization must enroll to participate in the U.S.
Department of Education’s Student Aid Internet Gateway and complete this form.”
• Changes: While the Department does consider applicants to be potential consumers, the term
consumer in this case has a broader intent than is intended in this form, which is designed for
a particular population defined as applicants. We did look at the sentence cited and
determined a better update would be to add an “s” to the word “submission”. The sentence
will now read “In order to obtain information on Free Application for Federal Student Aid
(FAFSA) submissions for students affiliated with an organization, the organization must
enroll to participate in the U.S. Department of Education’s Student Aid Internet Gateway
(SAIG).”
b) On the “Federal Student Aid System Access Enrollment Form for FAFSA Completion Tracking” form,
the same commenter asked us to change the instructions in Step 1, page four, to require all
“participants” fill out a complete form. We believe the instructions are complete and do require the
necessary information to validate and identify applicants or returning users.
• Changes: None.
c) On the “Federal Student Aid System Access Enrollment Form for FAFSA Completion Tracking” form,
the same commenter asked us to delete Question 1 of page 5 and require the applicant list the full legal
name in Question 2. We considered this, but truncating to a maximum of 40 characters in question 2
allows our system to identify the institution against other systems which do contain the full legal
identification without loss of security.
• Changes: None.
d) The same commenter repeated those requests for page 13 of the Form for Postsecondary Educational
Institutions, Guaranty Agencies, Title IV Additional Servicers and Lenders. We applied the same
consideration and reached the same conclusion.
• Changes: None.
e) This same commenter objected to the request for Mother’s Maiden name as a question and asked it be
replaced by a security password. This information is not requested for security purposes, but for
identification purposes.
• Changes: None.
f) On the “Federal Student Aid System Access Enrollment Form for FAFSA Completion Tracking” form,
the same commenter asked that, on page 9, above the second signature block, we add the word “also”
in the bold text “If you are an authorized representative, acting on behalf of another organization, you
must also read and sign this certification.” We consider the text sufficient as is.
• Changes: None.
g) The same commenter stated his belief that the burden was overestimated and provided thoughts on
how to better estimate the burden. We believe the criteria we applied, based on historical data, have
led us to a reasonable estimation of the burden.
• Changes: None.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.

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The Department of Education does not allow any payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
The confidentiality of the data on the enrollment form is discussed in the enrollment procedures. The citations that
authorize the collection of the information are Executive Order 9397 and Executive Order 13478.

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.
There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement
should :
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Indicate the number of respondents, frequency of response, annual hour
burden, and an explanation of how the burden was estimated. 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.

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If this request for approval covers more than one form, provide separate hour
burden estimates for each form and aggregate the hour burdens in item 16 of
IC Data Part 1.

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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.

Frequency of response when an institution wants to enroll or change services.
Based on intrinsic and past experience in completing enrollment forms, we estimate that it takes a respondent
approximately 20 minutes (.33 hours) to complete the online enrollment form and 40 minutes (.66 hours) to
complete a paper enrollment form and, as noted earlier, nearly all enrollments are completed via the Web (97%).
Breakdown by respondent type for the Postsecondary Educational Institutions, Institutional Third-Party

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Servicers, FFELP Guaranty Agencies and Guaranty Agency Servicers, Title IV Additional Servicers (TIVAS),
FFELP Lenders and Lender Servicers Enrollment Form (reference as PSEI), the State Scholarship and Grant
Agencies Enrollment Form (reference as SSGA), and the U.S. Department of Education’s Federal Student Aid
System Access Enrollment Form For FAFSA Completion Tracking For Local Educational Agencies, Public
Secondary Schools, Private Secondary Schools, State Agencies and Guaranty Agencies (reference as LEA):
Business or other for-profit institutions:
.33 hours x 8,565 new (PSEI) web enrollments = 2,826 hours
.33 hours x 8 new (SSGA) web enrollments = 3 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.66 hours x 243 new (PSEI) paper enrollments = 160 hours
.66 hours x 0 new (SSGA) paper enrollments = 0 hours
.66 hours x 0 new (LEA) paper enrollments = 0 hours
2,826 + 3 + 160 = 2,989 is the total annual hour burden
Subtotal of Respondents, Responses and Burden Hours for Business or Other For-Profit
# of Burden Hours
2,826 + 3 + + 160 + 0 = 2,989

# of Respondents/Responses
8,565 + 8 + 243 = 8,816
Not-for-profit Institutions:

.33 hours x 3,953 new (PSEI) web enrollments = 1,304 hours
.33 hours x 4 new (SSGA) web enrollments = 2 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.66 hours x 112 new (PSEI) paper enrollments = 74 hours
.66 hours x 0 new (SSGA) paper enrollments = 0 hours
.66 hours x 0 new (LEA) paper enrollments = 0 hours
1,304 + 2 + 74 + 0 = 1,380 is the total annual hour burden
Subtotal of Respondents, Responses and Burden Hours for Not-For-Profit
# of Burden Hours
1,304 + 2 + 74 = 1,380

# of Respondents/Responses
3,953 + 4 + 112 = 4,069
State, Public Institutions:

.33 hours x 3,953 new (PSEI) web enrollments = 1,304 hours
.33 hours x 4 new (SSGA) web enrollments = 2 hours
.33 hours x 20 new (LEA) web enrollments = 7 hours
.66 hours x 112 new (PSEI) paper enrollments = 74 hours
.66 hours x 0 new (SSGA) paper enrollments = 0 hours
.66 hours x 0 new (LEA) paper enrollments = 0 hours
1,304 + 2 + 74 + 0 = 1,380 is the total annual hour burden

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Subtotal of Respondents, Responses and Burden Hours of State and Public
# of Burden Hours
1,304 + 2 + 7 + 74 = 1,387

# of Respondents/Responses
3,953 + 4 + 20 + 112 = 4,089

Subtotal of Respondents and Burden Hours for All Institutions
# of Burden Hours
2,989 + 1,380 + 1,387 = 5,756

# of Respondents/Responses
8,816 + 4,069 + 4,089 = 16,974

Total Annual hour burden for the year ending Dec 2009:
.33 hours x 16,507 new web enrollments = 5,447 hours
.66 hours x 467 new paper enrollments = 309 hours
5,447 + 309 = 5,756 is the total annual hour burden
Total Respondents, Responses and Burden Hours
# of Respondents
16,507 + 467=16,974

# of Responses
16,507 + 467=16,974

# of Burden Hours
5,447 + 309 = 5,756

The annualized cost to respondents was estimated using the above figures to complete a form and an average yearly
salary of $35,360 ($17.00 per hour) for a Financial Aid Administrator (derived average salary from two recent FAA
job postings on www.careerbuilder.com).
5,756 hours (calculated above) x $17.00 per hour = $97,852 annualized cost.

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.)
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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.

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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 economic or regulatory impact analysis

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associated with the rulemaking containing the information collection, as
appropriate.
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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.
Total Annualized Capital/Startup Cost
Total Annual Costs (O&M)
:

:

Total Annualized Costs Requested

:

____________________

There are no start-up costs.

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 following is a breakdown of estimated costs to the Federal government to produce, process, and update the
2011-2012 Student Aid Internet Gateway Enrollment Form. The estimated costs are based on the actual costs
incurred for the most recent completed cycle year.
a.

Projected Cost for the Virtual Data Center (VDC) to host Participation Management

The VDC hosts the Web servers on which the Web enrollment form runs. Part of the cost listed below includes
hosting costs of the database at the Pearson Data Center.
FY 2009
For costs incurred to house the
Web servers at the VDC

$44,265

b. Projected Cost for Development/Annual Rollover Updates
$457,625
c.

Projected Cost to provide Maintenance/System Support
$672,178

d. Projected Processing Cost
Enrollment Processing

$286,682

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Total Costs

$1,460,750

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data
Part 1 Form.
An adjustment of an additional 5,315 responses and 1,743 hours occurred due to an increase in the number of
institutions using the web-based reporting form. While the creation of respondent-focused forms is expected to
result in a respondent burden savings, the actual burden reduction cannot be determined until after the new
streamlined forms have been implemented.

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.
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 OMB expiration date will be displayed on the form together with the standard request for comments.

18. Explain each exception to the certification statement identified in the Certification of
Paperwork Reduction Act.
There is no exception to the certification.

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