Justification - interest_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, requires that the Corporation pay, on behalf of AmeriCorps members, all or a portion of the interest accruing during their service period, if their loans were in forbearance and if they successfully complete their term of service. This payment is in addition to their education award. The intention is to keep the qualified student loan debt of members from increasing as a result of their national service. The percentage of accrued interest the Corporation pays is determined by a formula based on the member’s term of service.

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

AmeriCorps members use the form, or its electronic equivalents, to request a payment of accrued interest on qualified student loans and to authorize the release of loan information to the National Service Trust; schools and lenders verify eligibility for the payments; and both parties verify certain legal requirements.

 

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

Currently, about two-thirds of the interest payments are requested and processed electronically. The Corporation expects the use of paper forms to continue to decrease over the next few years and will continue to promote payments through Electronic Funds Transfers via the US Treasury, which now comprise about 70% of award payments.

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 their schools or student loan holders fill out this form or its electronic version. The form requests only the most pertinent information not available to the Trust elsewhere. Schools and loan holders complete the forms in order to receive payments.

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

 

If this data were not collected the Corporation would not know the amount of the interest payment, how or where to disburse AmeriCorps members’ payments, nor how to assess a request’s eligibility.

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 27672. The 30 day Notice soliciting comments 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 667 hours, 1 minute for AmeriCorps members to complete their section x 4,000 forms = 67 hours, and 9 minutes for schools or loan holders to complete their portion x 4,000 forms = 600 hours.

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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