Data Challenges and Appeals Solution (DCAS)

Forms and Documents

Document Name	Status
DCAS Institutional Challenges to Completers List Form and Instruction	New
DCAS Institutional Challenges to Completers List Form and Instruction	New
DCAS Institutional Challenges to Completers List Form and Instruction	New
Signed emergency clearance request memo.pdf Supplementary Document	2015-09-16
Emergency Clearance DCAS Supporting Statement A 9 16 2015.docx Supporting Statement A	2015-09-16

IC Document Collections

IC ID	Document Title	Status
218198	DCAS Institutional Challenges to Completers List Form and Instruction	New
218197	DCAS Institutional Challenges to Completers List Form and Instruction	New
218195	DCAS Institutional Challenges to Completers List Form and Instruction	New

ICR Details

OMB Control No: 1845-0137	ICR Reference No: 201509-1845-004
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: ED/FSA	Agency Tracking No:
Title: Data Challenges and Appeals Solution (DCAS)
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: 10/15/2015
OIRA Conclusion Action: Approved without change	Conclusion Date: 10/15/2015
	Date Received in OIRA: 09/21/2015
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	04/30/2016	6 Months From Approved
Responses	1,029,889	0	0
Time Burden (Hours)	175,081	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: This is a request for an emergency clearance approval for the Data Challenges and Appeals Solution (DCAS), a new system that will allow institutions to challenge their self-reported data as well as Department calculated metrics. The system will ultimately provide for the receipt, processing, data storage and archiving of data challenges received from institutions for challenges of Gainful Employment (GE) metrics, Cohort Default Rates (institutional and programmatic), and Disclosure Rates and Metrics. This request is for a new collection for the first phase of DCAS, the institutional challenge to the GE completers list provided to institutions by the Department of Education. The other aspects of DCAS will be made functional and available to institutions in stages, to allow for full development and testing, through subsequent system releases.

Emergency Justfication: The Data Challenges and Appeals Solution (DCAS) is a new system that will allow institutions to challenge their self-reported data as well as Department calculated metrics. The system will ultimately provide for the receipt, processing, data storage and archiving of data challenges received from institutions for challenges of GE metrics, Cohort Default Rates (institutional and programmatic), and Disclosure Rates and Metrics. An emergency clearance approval for the use of the system described below due to the following conditions: •The Department’s contracting process experienced a seven month setback when a contractor solicitation had to be cancelled and re-issued. In order to allow the challenge and appeal process to be implemented on time, the system must be able to accept challenges to the completer lists by November 9, 2015. •The Department believes that students will be harmed if there is a delay in implementing the challenge process which will ultimately delay the issuance of final rates. The schedule is to have the final rates published and available to disclose to students by January 2017. •Trends in graduates’ earnings, student loan debt, defaults, and repayment underscore the need for the Department to act swiftly. The Gainful Employment accountability framework takes into consideration the relationship between total student loan debt and earnings after completion of a post-secondary program. •The Gainful Employment regulation was issued after both negotiated rulemaking and notice-and-comment procedures. The full challenge and appeals process is already detailed at 34 CFR 668.405 and 668.406. Burden calculations were likewise already promulgated. Stakeholders and other interested parties have already had significant opportunities to give input on the process.

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Authorizing Statute(s): US Code: 20 USC 1001, 1002, 1088, 1094 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: 3

IC Title	Form No.	Form Name
DCAS Institutional Challenges to Completers List	NA	DCAS screen shots completer list correction
DCAS Institutional Challenges to Completers List	NA	DCAS screen shots completer list correction
DCAS Institutional Challenges to Completers List	NA	DCAS screen shots completer list correction

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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	1,029,889	0	0	1,029,889	0	0
Annual Time Burden (Hours)	175,081	0	0	175,081	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 an emergency request for a new information collection for the Data Challenges and Appeals Solution (DCAS). This program change is due to the establishment of a consolidated system for institutions to submit regulatory requirements to capture required data collections and appeals. This is the first stage of the system. This change is due to the implementation of regulations. The Department requests the transfer of the the 1,029,899 responses and respondents and the 175,081 hours from 1845-0123 to this new 1845-NEW collection request.

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Annual Cost to Federal Government: $4,200,000

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: 09/21/2015

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