suppstatptA_2014-2015_FISAP_031313[1]

OMB Number: 1845-0030 Revised: 03/13/2013

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 hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information, or you may provide a valid URL link or paste the applicable section¹. Specify the review type of the collection (new, revision, extension, reinstatement with change, reinstatement without change). If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.

Administrative Requirements and Legislative Authority for the Fiscal Operations Report and Application to Participate (FISAP) and the Reallocation Form

FISAP

The Higher Education Opportunity Act (HEOA) (P.L. 110-315) was enacted on August 14, 2008 and reauthorizes the Higher Education Act of 1965 (HEA), as amended. It requires participating Title IV institutions to apply for funds and report expenditures for the Federal Perkins Loan (Perkins), the Federal Supplemental Educational Opportunity Grant (FSEOG) and the Federal Work-Study (FWS) Programs on an annual basis.

The data submitted electronically in the Fiscal Operations Report and Application to Participate (FISAP) is used by the Department of Education (the Department) to determine the institution’s funding need for the award year and monitor program effectiveness and accountability of fund expenditures. The data is used in conjunction with institutional program reviews to assess the administrative capability and compliance of the applicant. There are no other resources for collecting this data. Sections of the Higher Education Act of 1965, as amended, that govern these programs can be found at http://www2.ed.gov/about/offices/list/ope/library.html.

The legislative authority governing the application for the distribution of Perkins funds is 20 U.S.C. 1087bb (34 CFR 673.3); for FWS funds it is 42 U.S.C. 2752 (34 CFR 673.3); and for FSEOG funds it is 20 U.S.C. 107b-3 (34 CFR 673.3).

The legislative authority governing the annual report on the uses made of funds provided under the previous sections is (20 U.S. C. 1094) enacted October 3, 1980, P.L. 96-374, sec. 451(a), 94 Stat. 1451; amended April 7, 1986, P.L. 99-272, sec. 16034, 100 Stat.356; amended October 17, 1986, P.L. 99-498, sec. 487(a), 100 Stat. 1486.

Reallocation Form

The HEA requires that if an institution anticipates not using all of its allocated funds for the Perkins, FWS, and FSEOG programs by the end of an award year, it must specify the anticipated remaining unused amount to the Secretary, who reduces the institution’s allocation accordingly. Unused amounts are reported in Section A of the Reallocation Form.

The HEA also requires the Secretary to reallocate these unexpended funds before the appropriations expire on September 30, immediately following their release in this form. The data collected in Section B provides the minimum information needed by the Secretary to determine a fair and equitable distribution of supplemental FWS allocations for the purpose of furthering the program’s community service goals.

Changes being made to the FISAP and Reallocation Form Collections

The forms and instructions are rolled over annually to accommodate the next cycle. The deadline dates and award year references are being updated.

In addition to annual award year and date references, significant changes are being made to three key areas as explained below.

• Part I, Section A, item 5. Additional Institutions
  
  

This item was formerly identified as “Additional Locations.” However, we have discovered an unintended misuse of terminology which resulted in some schools incorrectly interpreting this item and providing incorrect information. This item is to be used by an institution that is reporting, on one FISAP, information for not only itself but also for other institutions that, while having different OPEIDs are under the same administrative control or ownership as he reporting institution.

We have changed the eCB system to require less data entry by institutions by using technology to gather existing data electronically from other sources.

• Part II, Section D and F, Non-Traditional Calendar Enrollment Information
  
  

A non-traditional calendar means a school admits a new group of students monthly, or more frequently, into a majority of its eligible programs—even if those students enroll on a quarter, trimester, or semester basis. Currently the FISAP only requests “non-traditional” schools to provide undergraduate enrollment.

At one time this was appropriate because a non-traditional school’s level of degree tended to range from certificates to associate degrees or to other undergraduate credentials. However, there are now institutions offering programs above the undergraduate level using non-traditional calendars. In order for these schools to accurately represent their graduate enrollment on the FISAP form, we are expanding Lines 9-22 of Part II, Section D to include columns (c) and (d), for graduate enrollment.

This change was discussed with OMB staff on 11/26/2012 with concurrence received on 11/30/2012.

• Part VI, Section A, Distribution of Program Recipients and Expenditures by Type of Student
  
  To provide for more precise statistical analysis, the income grid in this section has been expanded to include $10,000 increments over the current $60,000 limit up to $100,000 and over, and for Undergraduate Dependent students $5,000 increments over the current $20,000 up to $40,000 and over.
  
  There is minimal additional burden to schools as these expanded fields have the same edits as the existing fields where data is required and a null value is not accepted.
  
  This change was requested by OMB staff during the previous year review of this data collection. Discussions were held 8/21/2012 with concurrence on 8/24/2012.
  
  

There are no data items being changed on the Reallocation Form.

In addition to annual award year and date references, the FISAP Instructions are being updated to correct some minor typographical errors and clarify instructions as described by part:

FISAP Instructions Part	Description
Introduction	Page iii – Provided additional information concerning Additional Institutions. Page v – Updated Campus-Based deadline dates and funding schedule.
Part I	Section A. Field 1(a) – Explained need for additional information if the school is a new applicant for 2014-2015 but its students were included in a FISAP filed by a different school last year. Section A. Field 5 – Revised Additional Institution data entry information.
Part II	Section A. Introduction – Added note to explain that if a school’s Program Participation Agreement does not reflect eligibility for a specific Campus-Based program; data cannot be entered to request funds for that program. Section C. Field 6 - Provided additional information concerning Waiver of the FWS/FSEOG institutional-share requirement for Title III/V Schools. Section D. Fields 7 & 8 – Provided clarification that High School students who are also enrolled in postsecondary classes are not “regular” students and are not to be reported as enrolled for the purposes of the FISAP. Section D. Fields 9-21 – Provided clarification concerning enrollment information for a school with a non-traditional calendar
Part III	No changes.
Part IV	No changes.
Part V	No changes.
Part VI	No changes.

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.

FISAP

The relative institutional financial need, which is the basis for computing by formula the amount of funds needed by each institution to operate one or more of the Campus-Based Programs during the application year, is determined by the data reported in the form. The data is used to assess program effectiveness and accountability of fund expenditures under the previously cited authority. In addition, the data is used in conjunction with institutional program reviews to help assess the administrative capability of the applicant and enforce compliance.

1. Application data provides a standard measure of institutional need used to distribute a level of funds for institutions requesting participation in one or more of the Campus-Based Programs.
   
   

2. Application data provides a data base that is sufficient, comprehensive and reliable to calculate annual funding formulas based on verifiable data input.
   
   

3. Expenditure data is used to calculate past utilization of funds awarded for assessment of penalties, recovery of unexpended funds, and close-out of awards.
   
   

4. Data regarding Perkins Loan collection activities are used to compute institutional cohort default rates, compile the Federal Perkins Loan Status of Default (Orange Book), and to track issuance of Perkins Loan cancellations for teaching; military; volunteer; law enforcement and corrections officer; child, family and early intervention; nurse and medical technician; pre-K or child care; public defender; fire fighter; Tribal College faculty; librarian; and speech pathology services.
   
   

5. Data is maintained and made readily available to Department staff and other agencies for analysis, historical research, budget evaluations, audits, program reviews, and OIG inquiries.
   
   

6. The eCB system processes all FISAP on the Web information in real-time into the database. Institutions with outstanding (required) hard-copy signature forms are automatically identified to withhold funding until the forms have been received and validated.
   
   

7. The data collected is used to identify poorly administered operations that may require on-site monitoring, additional training of staff, or termination of funding in extreme cases.
   
   

The information collected in this submission enables the Department to comply with legislation that authorizes and appropriates funds for the Campus-Based Programs.

Reallocation Form

The unexpended funds reported in the Reallocation Form are distributed by the Department as supplemental awards to qualifying institutions in accordance with provisions of the HEA. FWS funds will be awarded to eligible institutions that used at least seven percent of their total FWS funds to compensate students employed as reading tutors to children or in family literacy activities as part of their community-service activities. Because FWS reallocated funds are distributed on a fair-share basis, institutions must have a fair-share shortfall to receive these funds. Institutions use the reallocated (supplemental) funds to compensate students employed in community service. Legislation requires the unexpended funds to be reported and redistributed. Collection of this information maximizes utilization of the appropriated funds, provides financial aid to needy students, and results in the Department’s compliance with the reallocation provisions of the HEA.

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.

For the upcoming award year, institutions will continue to use the Department’s electronic services to participate in the Title IV Programs. Institutions participating in the Campus-Based Programs must submit FISAP and campus-based funds reallocation data through eCB at https://cbfisap.ed.gov. The certification signature page is printed locally from eCB.

eCB processing of both the FISAP and the Reallocation Form has eliminated printing costs, distribution, expense, data entry time, and reduced the cycle time and input errors. This process reduces institutional burden by using three years of information already contained in the database to provide institutional characteristics to verify funding levels and reduce the number of staff necessary to process the information.

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.

FISAP

No other agency or system collects the information needed to determine the allocation of campus-based funds.

It had been anticipated that some Perkins data could be retrieved from NSLDS. However, as currently designed, it does not collect Perkins interest data and the timing of the submission of Perkins data to the Department through NSLDS and the manner in which it is collected limit its use as a substitute for Perkins reporting on the FISAP.

Section A of the Perkins Loan Report (FISAP, Part III) contains 89 cells of data. Section C contains 28 data cells. NSLDS does not contain sufficient historical information to populate the cells in these two sections which require data to be cumulative from the beginning of an institution’s participation in Perkins. Section B of the Perkins Loan Report has 15 data cells. Two cells (loans advanced to students during the report year and principal and interest repaid by the borrowers for the same year) could conceivably be populated with data from NSLDS. Sections D and E contain Perkins cohort default rate data, which is not currently available from NSLDS. Review of the data needed for completion of the five sections of the Perkins Loan Report and the data available in NSLDS concludes that NSLDS data will not currently provide data that is compatible with either the historical or annual data collected on the FISAP.

FSEOG overpayment data is collected in NSLDS, but no FSEOG disbursement data is collected. No FWS data is collected in NSLDS.

NSLDS does not and cannot collect data that would sufficiently correspond to the type of data required from the FISAP for items such as annual award calculations, cohort default rate calculations, cumulative collections data, and prior year account reconciliation data. At this time, institutions will continue to be required to provide FISAP data in order for the Department to carry out required functions such as the calculation of allocations and Perkins cancellation reimbursements.

Reallocation Form

Similar information as is collected on the Reallocation Form is not available at the time it is needed. The Department must rely on the information being required by institutions at the end of each award year (June 30). The reporting and redistribution must be complete prior to September 30, or the authority to obligate these funds will expire.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entity may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not-for-profit enterprise that is independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less than 50,000.

The collection of this information does not involve small businesses or other small entities. Information is collected from Title IV eligible schools only.

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.

FISAP

If the FISAP data collection were not conducted or conducted less frequently, the Department would not be in compliance with authorizing legislation or appropriation legislation which requires annual distribution of appropriated funds on the basis of an annual application from eligible institutions.

Reallocation Form

If the data collection on the Reallocation Form were not conducted or conducted less frequently, the authority to redistribute the excess funds would expire on September 30 and the Department would not meet the legislative requirement to reallocate funds.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• 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 that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• 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.

There are no special circumstances inconsistent with these guidelines.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as 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.

FISAP

Campus-Based staff members in both operations and policy areas provide presentations and support for national and regional conferences. During these activities, staff members take all comments, recommendations, and suggestions made by institutions for use in determining the need for improvement or change to existing policies and procedures.

Frequent communication with institutions by our Call Center and Campus-Based staff provides additional information on the data being collected and on problems with electronic processing requirements. Comments from schools are shared with staff members and frequently included as possible upgrades to existing procedures. Institutions continue to report favorably about the ease in completing and submitting the data electronically.

The Department’s OMB clearance process allows further opportunity for comment on the FISAP through an announcement in the Federal Register at the onset of the clearance process. The Department accepts public comments on the FISAP during a 60-day time period. Revisions are made to the documents as deemed necessary based on the comments. An additional 30-day comment period is provided through another announcement in the Federal Register. Historically, institutions rarely submit comments on the FISAP. The Campus-Based Programs have been in operation for more than 40 years, and completion of the annual FISAP is a common practice for institutions.

Reallocation Form

The reporting of unexpended funds by institutions participating in the Campus-Based Program is required by the HEA. Institutions submit part of this information annually in the FISAP at a later date. The collection of this data is frequently discussed a financial aid conferences, and the financial aid community provides unsolicited comments through their contacts with our Call Center and Campus-Based staff members.

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

There are no payments or gifts to respondents other than the allocation of Federal funds that result from the information collected.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that authorizes the pledge of confidentiality should be provided.² If the collection is subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state that the Department makes no pledge about the confidentially of the data.

The Department makes no pledge about the confidentiality of the data.

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.

No questions of a sensitive nature are asked.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents by affected public type (federal government, individuals or households, private sector – businesses or other for-profit, private sector – not-for-profit institutions, farms, state, local or tribal governments), frequency of response, annual hour burden, and an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. 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.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCIS IC Burden Analysis Table. (The table should at minimum include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)

• 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.

FISAP

The FISAP data collection is composed of six parts. Part I is the institution’s identification. Part II is the application for funds. Part III is the Federal Perkins Loan Report. Part IV is the FSEOG Report. Part V is the FWS Report. Part VI is the Program Summary. The range of time required to complete the various parts of the form depends on several variables: (1) the number of programs in which respondents are currently participating; (2) whether the respondent is a “first-time” or “continuing” applicant; and (3) the type of institution.

Burden hours for new schools are minimal since they are only required to complete the first two parts (Identifying Information, Certification and Warning; and the Application to Participate).

Proprietary institutions use less time to prepare the FISAP than public and private institutions. A random sampling of institutions revealed that proprietary institutions were more likely to use servicers to prepare their FISAP. Since servicers prepare FISAPS in volume, they tend to keep their computerized data systems updated, and have totally encompassed the Department’s electronic processes into their systems which results in less FISAP preparation time.

Most public and private institutions have restructured their data collection processes so that information is readily accessible to complete the FISAP electronically. Identifying information is pre-populated on the FISAP from prior year data and common mathematical computations are automatically displayed, which reduces institutional burden. Data entry and process edits notify users of erroneous data entry or potential data issues. This assists the data entry, reduces review time, and also reduces institutional burden.

The matrix below shows the respondent participation from the most recent FISAP submission (October 1, 2012) in the various parts of the submission. The total amounts shown by institutional type are unduplicated counts. The part breakdowns under each category of Institution are duplicated counts, based on the variables described above.

FISAP Respondent Type by Part	Estimated Number of Respondents	Estimated Person Hours per Respondent-Reporting	Estimated Person Hours per Respondent-Record Keeping	Total Hours	Total Hours (AVG Person hrs x Resp)
Public
Parts I & II - Application	1549	2.0	2.0	4.0
Part III - Federal Perkins Loan	748	4.0	4.0	8.0
Part IV - FSEOG	1526	2.0	2.0	4.0
Part V - FWS	1496	2.0	2.0	4.0
Part VI - Summary	1538	2.0	2.0	4.0
	Total Number Respondents	Total Hours per Respondent-Reporting	Total Hours per Respondent-Record Keeping	Total Hours per Respondent	Total Annual Burden Hours - All Respondents
Total FISAP Respondents - Public Schools	1549	12.0	12.0	24.0	37,176
Proprietary
Parts I & II - Application	1057	2.0	2.0	4.0
Part III - Federal Perkins Loan	194	3.0	3.0	6.0
Part IV - FSEOG	976	1.0	1.0	2.0
Part V - FWS	503	1.0	1.0	2.0
Part VI - Summary	976	1.0	1.0	2.0
Total	1057	8.0	8.0	16.0	16,912
Private (Non-Profit)
Parts I & II - Application	1457	3.0	3.0	6.0
Part III - Federal Perkins Loan	998	4.0	4.0	8.0
Part IV - FSEOG	1319	1.0	1.0	2.0
Part V - FWS	1360	2.0	2.0	4.0
Part VI - Summary	1419	1.0	1.0	2.0
Total	1457	11.0	11.0	11.0	32,054
	Total Number Respondents	Total Avg. Hours per Respondent-Reporting	Total Avg. Hours per Respondent-Record Keeping	Total Avg. Hours per Respondent	Total Annual Burden Hours - All Respondents
Total FISAP Respondents -Proprietary & Private (Non-Profit) Schools	2514	9.5	9.5	19.0	47,766

Because both the FISAP and the Reallocation form contain separate Paperwork Burden Statements that contain an estimated average number of hours for completion, the complex averages demonstrated above for the FISAP have been combined into the total annual burden hours for all respondents and divided by the total number of respondents. The estimated average number of hours for completion of the FISAP has been calculated to be 20.91 hours per respondent.

	Total Number Respondents	Total Annual Burden Hours - All Respondents	Total Burden Hours per Each Respondent (84942/4063)
FISAP Total	4063	84942	20.91

Reallocation Form

The Reallocation Form data collection is composed of two sections. Section A requests unexpended allocation figures for the Campus-Based Programs. Section B requests information regarding supplemental FWS funds. The range of time required to complete the two sections of the form depends on these variables: (1) the number of programs in which respondents are currently participating; and (2) whether or not an institution requests supplemental funds for community service activities.

The following matrix shows the respondent participation from the most recent Reallocation Form submission (August 17, 2012) in the two sections of the form. The amounts shown are unduplicated counts.

Reallocation Form by Respondent Type	Estimated Number of Respondents	Estimated Person Hours per Respondent-Reporting	Estimated Person Hours per Respondent-Record Keeping	Total Hours	Total Hours (AVG Person hrs x #Resp)
Public
Section A	28	.5	.5	1.0
Section B	34	.5	.5	1.0
	Total Number Respondents	Total Hours per Respondent - Reporting	Total Hours per Respondent - Record Keeping	Total Hours per Respondent	Total Annual Burden Hours - All Respondents
Total Reallocation Respondents - Public Schools	62	1.0	1.0	2.0	124
Proprietary
Section A	74	.5	.5	1.0
Section B	6	.5	.5	1.0
Total	80	1.0	1.0	2.0	160
Private (Non-Profit)
Section A	30	.5	.5	1.0
Section B	23	.5	.5	1.0
Total	53	1.0	1.0	2.0	106
	Total Number Respondents	AVG Total Hours per Respondent - Reporting	AVG Total Hours per Respondent - Record Keeping	AVG Total Hours per Respondent	Total Annual Burden Hours - All Respondents
Total Reallocation Respondents - Proprietary & Private (Non-Profit) Schools	133	1.0	1.0	2.0	266

Because both the FISAP and the Reallocation form contain separate Paperwork Burden Statements that contain an estimated average number of hours for completion, the complex averages demonstrated above for the Reallocation Form have been combined into the total annual burden hours for all respondents and divided by the total number of respondents. The estimated average number of hours for completion of the Reallocation Form has been calculated to be 2.0 hours per respondent.

	Total Number Respondents	Total Annual Burden Hours - All Respondents	Total Burden Hours per Each Respondent (84942/4063)
Reallocation Form Total	195	390	2.0

Total Burden FISAP and Reallocation Forms

The combined total for the FISAP and Reallocation Form has an estimated total of 4258 respondents with a total annual burden of 85,322 hours. We’ve used the Census Bureau National Industry-Specific Occupational Employment Wage Estimate for Educational Services (NAICS 611300 Colleges, Universities, and Professional Schools, Occupation Code 13-119) of $25.48 per hour, the estimated total to all respondents of $2,174,260.

The matrix below shows the combined totals for the separate data provided in the FISAP and Reallocation data matrices above as well as the estimated Hour-Burden Salary Cost to respondent institutions.

Summary of Burden FISAP & Reallocation (1845-0030)
		Program Change
	Requested	Due to New Statute	Due to Office Discretion	Due to Adj. in Office Estimate	Change Due to Potential Violation	Currently Approved
Annual Number of Responses
FISAP-Public	1,549
FISAP-Proprietary & Non-Profit	2,514
Reallocation Form-Public	62
Reallocation Form- Proprietary & Non-Profit	133
Total	4,258	0	0	0	0	4,258
Annual Hour Burden
FISAP-Public	37,176
FISAP-Proprietary & Non-Profit	47,766
Reallocation Form-Public	124
Reallocation Form- Proprietary & Non-Profit	266
Total	85,322	0	52,371	0	0	32,961
Annual Salary Cost
FISAP-Public	$947,244
FISAP-Proprietary & Non-Profit	$1,217,078
Reallocation Form-Public	$3,160
Reallocation Form- Proprietary & Non-Profit	$6,778
Total	$2,174,260	0	$2,174,260	0	0	0

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.)

• 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.

• 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 associated with the rulemaking containing the information collection, as appropriate.

• 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. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost :      

Total Annual Costs (O&M) :      

____________________

Total Annualized Costs Requested :      

The nature of business for Title IV institutions (the respondents) is such that purchases of equipment and provision of services that are required for electronic processing of the FISAP and Reallocation form are a part of their customary and usual business practice. They are the type of equipment and services normally necessary to successfully operate any educational entity.

The requirement to transmit the FISAP and Reallocation Form data electronically through eCB is not considered an increase in burden for most institutions. Because thousands of institutions are already participating in other Title IV, they would have access to the Internet (web) in order to do business with the Department.

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 matrix below describes the separate costs for the FISAP and the Reallocation Form and the combined total annual cost to the Federal Government of $2,600,735.00.

FISAP
FISAP Cost for Development of eCampus-Based FISAP on the Web Many tasks must be performed in order to develop the FISAP on the Web and make it available to campus-based participants. Some of the major costs include the costs for contractor services, the development of web server programs, the Technical Reference, documents for posting on the web (i.e. Electronic Announcements), and the FISAP Form and Instructions Booklet. The amount below reflects the cost all of these campus-based programs to the Department. There are no funds designated for Development at this time.
Total	$0
FISAP Publication and Distribution Costs The FISAP on the Web cost is replacing the old Publication & Distribution Cost calculation because it is no longer needed.
Total	$0
FISAP Operations & Maintenance Contract Costs Collabralink 3130 Fairview Park Drive Suite 800 Falls Church, VA 22042 The cost of collecting and maintaining the data is justified because FISAP data is made available to, and widely used, throughout the Department for analysis, historical research, budget evaluations, audits, program reviews, OIG inquiries, etc. In addition, the information collected justifies institutional funding for the next award period. The current annual O&M costs for the eCB system include the FISAP and Reallocation forms as well as the TCLI Directory*, Work Colleges Application and Expenditure forms**, and the CTP-Intellectual disabilities form***. *The TCLI Directory is a separate data collection with OMB control number 1845-0077. **The number of schools participating in the Work Colleges program is static at 7 participants. There is no OMB control number for this data collection. ***The CTP is a separate data collection with OMB control number 1845-0113. Note: Annual O&M Contract cost - $1,402,344 = monthly cost $116,862 allotted as: FISAP (8 months) = $934,896 Reallocation (1 month) = $116,862 TCLI Directory (1 month) = $116,862 Work Colleges (1 month) = $116,862 CTP-Intellectual Disabilities (1 month) = $116,862
Total (8 months)	$934,896
FISAP Staffing Operations and Overhead Costs A staff of 7.75 FTE’s is required for the operation of the campus-based programs and the eCB system. This includes the FISAP and Reallocation forms as well as the TCLI Directory, Work Colleges Application and Expenditure forms, and the CTP-Intellectual disabilities form as footnoted on page 18. As the driving force in these operations, the FISAP is the instrument by which institutions request campus-based funding and report program expenditures. The FISAP provides the data that is required to perform a variety of processes such as funding calculations, program compliance, analysis, customer service, information publication and distribution, accounting and fund control, etc. The types of program staff include managers, accountants, financial management specialists, technicians, systems analysts, and clerical staff. Using the Salary Table 2012-DCB Effective January 2012, the average hourly wage of the current staff composition is $46.94. Note: The total amount of annual salaries devoted eCB activities is divided as: Reallocation (3 staff @ 120 hrs ea x $46.94) = $16,899.30 TCLI Directory (1 staff @ 80 hrs x $46.94) = $3,755.40 Work Colleges (1 staff @ 160 hrs x $46.94) = $7,510.80 CTP-Intellectual Disabilities (1 staff @ 160 hrs x $46.94) = $7,510.80 FISAP (Total salaries less Reallocation, TCLI Directory, Work Colleges, CTP-Intellectual Disabilities) = $1,318,425.70
Yearly Staff Costs	$1,318,425.70
FISAP Yearly Overhead Costs A standard budget estimate of 16% was used to determine the overhead costs of staff operations including such items as equipment, utilities, work materials, etc. ($1,318,425.70 x 16% = $210,948.11)
Yearly Overhead Costs	$ 210,948.11
Total Staff and Overhead Costs	$1,529,373.81

Reallocation Form
Reallocation Form Publication and Distribution Publication and distribution cost to the campus-based programs has been eliminated. The conversion to the eCampus-Based FISAP on the web has transferred all costs, including software production and distribution, into the overall contract for services made by the Department.
Total	$0
Reallocation Form Operations & Maintenance Contract Costs Collabralink 3130 Fairview Park Drive Suite 800 Falls Church, VA 22042
Total (1 month)	$ 116,862.00
Reallocation Form Staffing Operations and Overhead Costs A staff of 3 is required for the operation of the campus-based programs Reallocation process. While the FISAP is the instrument by which institutions request campus-based funding and report program expenditures, the Campus-Based Reallocation Form is used to provide information that is needed prior to the annual submission of the FISAP. The 3 program staff members include managers, accountants and systems analysts. Of that staff, each of the three employees worked 120 hours per year on the Reallocation process for a total of 360 hours worked for the office. This process takes approximately two half-months to complete for a yearly cost of $16,899.30 (120 hours x 3 employees x $46.94 average hourly rate).
Yearly Staff Costs	$ 16,899.30
Reallocation Form Yearly Overhead Costs A standard budget estimate of 16% was used to determine the overhead costs of staff operations including such items as equipment, utilities, work materials, etc. ($16,899.30 x 16% = $2,703.89)
Yearly Overhead Costs	$ 2,703.89
Total Staff and Overhead Costs	$ 19,603.19

FISAP and Reallocation Form Combined Total Cost to Federal Government
Cost for Development of eCB FISAP on the Web	$ 0.00
O&M Costs to the Federal Government	$1,051,758.00
Staff Operations and Overhead Costs	$1,548,977.00
Total	$2,600,735.00

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in burden result from re-estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the reporting universe). Program changes result from a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes should be disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours, responses and costs (if applicable).

The total annual reporting and record keeping hour burden changed from the current OMB inventory of 32,961 to 85,332 (an increase of 52,371 hours) due to an increase in the number of fields on the form, a change in the composition of respondents from the different types of Title IV institutions on various sections of the forms. These are consider a program change.

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.

This information collected on the FISAP and the Reallocation form is not collected for statistical publication

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 Department is not seeking this approval.

18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

There are no exceptions to the certification statement.

1 Please limit pasted text to no longer than 3 paragraphs.

2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)

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