Guaranty Agencies Security Self-assessment and attestation

Forms and Documents

Document Name	Status
Security Self-assessment template Form and Instruction	New
Security Self-assessment template Form and Instruction	New
Emergency clearance memo GA IT security self-assessment.pdf Supplementary Document	2015-07-13
Attestation Statement for FSA IT Security Self Assessment.pdf Supplementary Document	2015-07-13
Emergency Clearance GA Security Self Assessment Supporting Statement.docx Supporting Statement A	2015-07-13

IC Document Collections

IC ID	Document Title	Status
217443	Security Self-assessment template Form and Instruction	New
217442	Security Self-assessment template Form and Instruction	New

ICR Details

OMB Control No: 1845-0134	ICR Reference No: 201507-1845-003
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: ED/FSA	Agency Tracking No:
Title: Guaranty Agencies Security Self-assessment and attestation
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 07/20/2015
OIRA Conclusion Action: Approved without change	Conclusion Date: 07/28/2015
	Date Received in OIRA: 07/13/2015
Terms of Clearance: This collection is approved for six months under emergency processing. If the Department chooses to use this past its expiration date, they will be required to submit the information collection under the full normal Paperwork Reduction Act process.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2016	6 Months From Approved
Responses	28	0	0
Time Burden (Hours)	8,848	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The E-Government Act (Public Law 107-347) passed by the 107th Congress and signed into law by the President in December 2002 recognized the importance of information security to the economic and national security interests of the United States. Title III of the E-Government Act, entitled the Federal Information Security Management Act (FISMA) requires each federal agency to develop, document, and implement an agency-wide program to provide information security for the information and information systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other source. FISMA, along with the Paperwork Reduction Act of 1995 and the Information Technology Management Reform Act of 1996 (Clinger-Cohen Act), explicitly emphasizes a risk-based policy for cost-effective security. FSA is initiating a formal assessment program of the Guaranty Agencies that will ensure the continued confidentiality and integrity of data entrusted to FSA by students and families. The assessment will identify security deficiencies based on the Federal standards described in the National Institute of Standards and Technology (NIST) publications. The comprehensive self-assessment links all questions with a NIST control. This collection of information impacts 28 independently owned Guaranty Agencies (GAs) dispersed throughout the U.S. Each agency is under signed agreement with the Department of Education to service Federal Family Education Loans that have been turned over from the lending institutions to the GAs for the purpose of student loan collections.

Emergency Justfication: This is a request for an emergency clearance to enable Federal Student Aid (FSA) to ensure that all data collected and managed by Guaranty Agencies (GAs) in support federal student financial aid programs is secure. FSA is initiating a formal assessment program for ensuring the GAs have security protocols in place to protect the confidentiality and integrity of data entrusted to FSA by students and families. This assessment is designed to identify security deficiencies based on the federal standards described in the National Institute of Standards and Technology publications.

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Authorizing Statute(s): US Code: 20 USC 1078 Name of Law: Higher Education Act of 1965, as amended
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Security Self-assessment template	NA	Security Self-assessment template and attestation
Security Self-assessment template	NA	Security Self-assessment template

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	28	0	0	28	0	0
Annual Time Burden (Hours)	8,848	0	0	8,848	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a program change resulting in a new collection. The increase in burden is due to a program change based on agency discretion. There are 28 respondents requiring an estimated 316 hours each to complete the required self-assessment for a total of 8,848 burden hours.

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Annual Cost to Federal Government: $213,000

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 07/13/2015

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