Justification - Forbearance 9.14.11 - 2

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1.  Need for Information Collection

The National and Community Service Act of 1990, as amended, provides that individuals who enroll in an approved national service position are eligible for a postponement on the repayment of any qualified student loan they have, which temporarily suspends their obligation to make loan payments while they are earning a minimal living allowance in their national service position.

A2.  Indicate how, by whom, and for what purpose the information is to be used.

Officials use the Forbearance Request for National service Form, or its electronic versions, to certify that AmeriCorps members are eligible for forbearance based on their enrollment in a national service position. AmeriCorps members use the form, or its electronic equivalents, to request a forbearance.

 

 A3.  Minimize Burden: Use of Improved Technology to Reduce Burden

Currently, about two-thirds of the forbearances are requested and processed electronically. The Corporation expects the use of paper forms to continue to decrease over the next few years.

A4.  Non-Duplication

This information is not being requested by any other means.

 

A5.  Minimizing for economic burden for small businesses or other small entities.

Only AmeriCorps members and certifying officials fill out this form or its electronic versions and forward the forms to the loan holders who process the requests.

A6.  Consequences of the collection if not conducted, conducted less frequently, as well as any technical or legal obstacles to reducing burden.

 

The law states that for every term of service qualified student loans are eligible for mandatory forbearance. If this data were not collected the loan holder would have no reason to put the loan in forbearance based on national service and could require the borrower to continue to make payments while serving and earning a meager living allowance.

A7.  Special circumstances that would cause information collection to be collected in a manner requiring respondents to report more often than quarterly; report in fewer than 30 days after receipt of the request; submit more than an original and two copies; retain records for more than three years; and other ways specified in the Instructions focused on statistical methods, confidentially, and proprietary trade secrets.

There are no special circumstances that would require the collection of information in any other ways specified.

A8.  Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice. Summarize comments received and actions taken in response to comments. Specifically address comments received on cost and hour burden.

The 60 day Notice soliciting comments was published on Thursday, May 5, 2011 on page 27673. The 30 Day Notice soliciting comments to OMB was published on Friday, July 15, 2011 on page 41769. The Corporation received no responses to the Notices.

 

 A9.  Payment to Respondents

There are no payments or gifts to respondents.

  

A10.  Assurance of Confidentiality and its basis in statute, regulation, or agency policy.

Confidentiality of information supplied by respondents is ensured by the Privacy Act. A Privacy Act Notice appears on the form.

A11.  Sensitive Questions

 

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

The estimate of burden hours for respondents to complete the form is a total of 40,000 minutes (667 hours), 9 minutes for AmeriCorps members to complete their section x 4,000 forms = 36,000 minutes, and 1 minute for schools or loan holders to complete their section x 4,000 forms = 4,000 minutes.

A13. Cost burden to the respondent

None.

 

A14. Cost to Government

There are no additional costs to the Government.

A15. Reasons for program changes or adjustments in burden or cost.

Change due to adjustment. The burden for this ICR has decreased because we have a more accurate estimate of how many students and institutions use the electronic and paper forms. 

 A16.  Publication of results

Not applicable because the responses to this information collection will not be published. 

 

A17.  Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

The Corporation requests that the expiration date not be displayed. OMB approved a similar request the last time the Corporation revised the voucher form.

System constraints make it difficult to revise the hard-coded dates on the online versions in a timely manner, which may give rise to considerable confusion among members and institutions who mistake it for the award’s expiration date.

 

 A18.  Exceptions to the certification statement

No exceptions are requested.

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