2014-2015 Supporting Statement A_1845_0002_122613

ICRAS Tracking and OMB Number: (1383.26) 1845-0002

Revised: 12/23/2013

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 section 1. 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.
In order to manage the Title IV, HEA assistance programs, authorized by the Higher Education Act of 1965, as
amended (HEA); 20 U.S.C. 1070 et seq., Federal Student Aid (FSA) must electronically transact business with the
following FSA systems and institutions that include, but are not limited to the following:
•

Common Origination and Disbursement (COD) system

•

Central Processing System (CPS)

•

Electric Campus-Based (eCB) system

•

National Student Loan Data System (NSLDS)

•

Financial Management System (FMS)

•

Debt Management Collection System (DMCS)

•

Total and Permanent Disability (TPD)

•

Federal Loan Servicers

•

Access Information Management System (AIMS)

•

Postsecondary Educational Participants System (PEPS)

•

Institutions of higher education that participate in Title IV, HEA assistance programs.

•

Third-party servicers that provide services to eligible institutions of higher education.

•

State Scholarship and Grant Agencies

•

Guaranty Agencies (GAs) for the Federal Family Education Loan (FFEL) Program or their third-party
servicers

•

Lenders for the Federal Family Education Loan (FFEL) Program or their third-party servicers

•

Others approved by the U.S. Department of Education

The U.S. Department of Education, FFEL lenders and their third-party servicers, Guaranty Agencies and their thirdparty servicers, Federal Loan Servicers (FLS), local educational agencies (LEAs), public secondary schools, private
secondary schools, State agencies and their third-party servicers, and institutions of higher education and their thirdparty servicers use the Student Aid Internet Gateway (SAIG) to electronically transmit and receive data with the
1

Please limit pasted text to no longer than 3 paragraphs.

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

Revised: 12/23/2013

Department’s contracted processors for Title IV, HEA assistance programs. The entities described above (the
Entities) that need access to the SAIG and online Federal Student Aid (FSA) systems must enroll with FSA through
the SAIG Participation Management System, at the https://fsawebenroll.ed.gov Web site, or by using the paper
SAIG Enrollment Form, to establish a location, called a Destination Point (which is identified by a TG Number),
from which to transact business electronically with FSA.
In order to protect privacy information contained in the FSA systems, FSA has established security procedures that
include requiring the Entities that need access to FSA systems to designate individuals to serve as a Primary
Destination Point Administrator (Primary DPA) in order to conduct transactions on behalf of the Entities. Once a
Primary DPA is established, he or she may enroll additional Destination Point Administrators (Non-Primary DPA’s)
for selected electronic services and for access to FSA systems.
Before a Primary DPA is granted access to the SAIG, the individual must enroll with FSA by providing his or her
name, date of birth, address, e-mail address, telephone number, Social Security number, certain confidential
information that only the Primary DPA knows, the name of the Entity the Primary DPA represents and by indicating
the specific services the Entity wishes to participate in through the Primary DPA.
Most of the enrollment process can be completed from the https://fsawebenroll.ed.gov Web site; however,
enrollment is not considered complete until FSA receives a hard-copy certification page signed by the Primary DPA
and the Entity’s chief operating officer authorized to enter into written agreements for the Entity, signs the Primary
DPA’s enrollment agreement. Only the Primary DPA may enroll additional organizational members and select the
specific services to be conducted by each of those individuals. Each Primary DPA that enrolls other Non-Primary
DPA’s must provide the same personally identifiable information about each of those individuals that he or she
provided (e.g., name, Social Security number, etc.).
An enrolled Primary DPA is able to –
•

Electronically exchange files of financial aid data

•

Access services of the Federal Direct Loan Program

•

Perform data transmissions for the electronic Campus-Based (eCB) programs for Federal Work-Study
(FWS), Federal Supplemental Educational Opportunity Grant (FSEOG) and the Federal Perkins Loan
program

•

Access Grant services of the Federal Pell Grant program, the Iraq and Afghanistan Service Grant program,
and the Teacher Education Assistance for College and Higher Education (TEACH) Grant program

•

Access the Central Processing System (CPS) database or Web-based systems through FAA Access to CPS
Online

•

Access the Campus-based system through the Fiscal Operations Report and Application to Participate
(FISAP) Online

•

Access the National Student Loan Data System (NSLDS) and receive cohort default rate (eCDR)
notification packages

•

Access the Lender Reporting System (LaRS) to send financial reporting information to Federal Student
Aid’s Financial Management System (FMS)

•

Access to online NSLDS Enrollment Reporting (formerly SSCR) function for updating student enrollment
and Gainful Employment data and Gainful Employment rates.

•

Access to COD Website to create and modify loan and disbursement data or receive Electronic IncomeBased Repayment (IBR)/Pay As You Earn/Income-Contingent Repayment (ICR) Plan Request

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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Revised: 12/23/2013

Re-disclose student’s Free Application for Federal Student Aid (FAFSA) filing status to a state, local, or
private entity designated by the Secretary of Education per written agreement.

With access to FSA systems, a Primary DPA can –
• Complete and send electronic initial and renewal financial aid (FAFSA) applications to the CPS
• Receive electronic Institutional Student Information Records (ISIRs) from the CPS
• Send electronic corrections of applicant data to the CPS
•
•
•
•
•

Exchange payment and required reporting information from the Federal Pell Grant program, the Iraq and
Afghanistan Service Grant program, and the TEACH Grant program
Receive Electronic Statements of Accounts (ESOA) from the Federal Pell Grant Program
Exchange data with the Federal Direct Loan Program to originate loans; draw down, disburse, and
reconcile loan funds; and report student status.
Exchange data with the NSLDS
Receive eCDR Rate Reports from Default Management

For the 2014-2015 Award Year, we revised the Postsecondary Educational Institutions, Institutional Third-Party
Servicers, FFELP Guaranty Agencies and Guaranty Agency Servicers, Federal Loan Servicers, FFELP Lenders and
Lender Servicers Enrollment Form to allow Lenders and their Servicers to enroll for COD Online access in order to
have completed electronic IBR/Pay As You Earn/ICR Repayment Requests transferred to the FFELP
Lender/Servicers. Also, the participation agreement in the SAIG Application for State Grant Agencies Form was
revised to establish the conditions under which the Department will permit the disclosure of certain data received or
generated by the Department concerning FSA applicants. The forms were revised to better describe the SAIG
enrollment process and the key personnel involved in the process as well as to accommodate annual rollover
changes (i.e. new award years).
On November 29, 1996, the Secretary published final regulations in the Federal Register (61 FR 60603) that
required institutions to participate in the electronic processes identified by the Secretary in order to improve the
administration and delivery of FSA program funds to students and institutions and to protect Federal fiscal interests.
Institutions must use software developed by the institution, or its vendor, in accordance with the specifications
provided by the Secretary in the regulations. The Secretary believes that the savings and benefits from these
electronic business processes are more than offset by any necessary initial investments by both the U.S. Department
of Education and by institutions.

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.
The Participant Management System manages a participant database, which is a collection of data from the SAIG
Enrollment Form. The enrollment process enables entities to receive, transmit, view, and update student financial aid
data available through the SAIG Mailbox system and other FSA online Web services (e.g. NSLDS online and FAA
Access). The enrollment form is available on the Internet at https://fsawebenroll.ed.gov. Information collected via
the enrollment form is used to assign entities a SAIG Mailbox (which is identified by a TG Number) and associate
the application services selected to that entity and its Primary DPA, as well as its Non-Primary DPAs.

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

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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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.
The enrollment process for electronic services and access to FSA systems is on the Internet, and the design of the
Web site is based on the SAIG Enrollment Form (paper). Customers can enroll and change services via the SAIG
enrollment Web site at https://fsawebenroll.ed.gov. This Web site reduces and virtually eliminates paper collection
for enrollment (the paper enrollment form and process will continue to be available upon request for entities having
difficulties accessing the Internet). Entities may use the Web enrollment process to complete and submit
applications to participate in the FSA electronic services currently available. The U.S. Department of Education is
sensitive to the concerns of entities and individuals regarding the security of their application data. Users will be
prompted to enter confidential authentication identifiers in order to validate their identity before being allowed to
change or update FSA services. In addition, users will be advised via the Web site to check the security
configuration of their browser to ensure that the information they transmit to ED is protected.

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.
The SAIG enrollment form is the only means that Title IV, HEA participating schools and other eligible entities can
use to enroll for the previously mentioned data exchange services.

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.
No small businesses are affected by this information collection.

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.
If collection is not conducted, no new participants will be able to enroll for electronic services. Existing participants
will not be able to change their existing services, including deactivating individuals who no longer need access to
the services, or who are no longer employed by an Entity.

7. Explain any special circumstances that would cause an information collection to be conducted
in a manner:
The collection of this information will be conducted in a manner that does not involve any of the guidelines in:



requiring respondents to report information to the agency more often than quarterly;
N/A – Respondents report as needed.

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002



Revised: 12/23/2013

requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;
N/A – Respondents report as they need to enroll or make changes to an enrollment.



requiring respondents to submit more than an original and two copies of any document;
N/A – Only the originals are submitted.



requiring respondents to retain records, other than health, medical, government contract,
grant-in-aid, or tax records for more than three years;
The Office of Inspector General periodically audits schools. Schools must keep copies of the
participation information with signatures for review as well as the FSA User of Electronic
Services Statement with original signature. These documents are required to protect the security
of the FSA’s systems of records.



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;
N/A – These data are not collected to conduct statistical surveys.



requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
N/A – These data are not collected to conduct statistical surveys.



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.
The SAIG Enrollment Form collects the Social Security number, the date of birth, and the
mother's maiden name from every Destination Point Administrator. Two of these identifiers
(Social Security number and date of birth) are used to authenticate the customer when they request
a password reset from the SAIG/CPS Technical Support Help Line. Electronic authentication is
now conducted through the Access and Identify Management System (AIMS) and users are
required to enter their FSA User ID to use protected pages on the Web enrollment site.

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,

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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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.
FSA consults with all applicable application systems during the requirements phase to solicit comments and
suggestions for improving the enrollment form. These meetings address problems and enhancements to the
existing form. FSA has enhanced the enrollment form to simplify the enrollment process for all participating
institutions.
A 60-day Federal Register notice was published and public comments were received on the participation
agreement in the SAIG Application for State Grant Agencies. In summary, the comments requested expanding
the types of organizations that LEA’s could re-disclose FAFSA information. In responses, Federal Student Aid
explained that the language in the current participation agreement already included many of the organizations
noted by the commenter and any other organizations could be considered in the future. There is no change to
the cost or burden hour calculation based on the comments. A 30-day Federal Register notice will be published
allowing for additional public comment.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration
of contractors or grantees with meaningful justification.
The Department of Education does not allow any payments or gifts to respondents.

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 confidentiality of the data on the enrollment form is discussed in the enrollment procedures. The citations that
authorize the collection of the information are Executive Order 9397 and Executive Order 13478.

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.
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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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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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.
There are no questions of a sensitive nature.

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.

Frequency of response when an institution wants to enroll or change services.
Based on intrinsic and past experience in completing enrollment forms, we estimate that it takes a respondent
approximately 20 minutes (.33 hours) to complete the online enrollment form, and 40 minutes (.66 hours) to
complete a paper enrollment form, as noted earlier, nearly all initial enrollments are completed via the Web (94%).
We also estimate that it takes a respondent approximately 10 minutes (.16 hours) to complete online enrollment
updates and 15 minutes (.25 hours) to complete a paper enrollment update and 70 % of enrollment updates are
completed via the Web.
The following is a breakdown of the amount of reporting burden by respondent type for the Institutions of Higher
Education, Institutional Third-Party Servicers, FFELP Guaranty Agencies and Guaranty Agency Servicers,
Federal Loan Servicers(FLS), FFELP Lenders and Lender Servicers Enrollment Form (reference as PSEI), the
State Scholarship and Grant Agencies Enrollment Form (reference as SSGA), and the U.S. Department of
Education’s Federal Student Aid System Access Enrollment Form For FAFSA Completion Tracking For Local

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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Educational Agencies, Public Secondary Schools, Private Secondary Schools, State Agencies and Guaranty
Agencies (reference as LEA):
Business or other for-profit institutions:
.33 hours x 14,012 new (PSEI) web enrollments = 4,624 hours
.33 hours x 0 new (SSGA) web enrollments = 0 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.16 hours x 2,188 update (PSEI) web enrollments = 350 hours
.16 hours x 0 update (SSGA) web enrollments = 0 hours
.16 hours x 0 update (LEA) web enrollments = 0 hours
.66 hours x 76 new (PSEI) paper enrollments = 50 hours
.66 hours x 0 new (SSGA) paper enrollments = 0 hours
.66 hours x 0 new (LEA) paper enrollments = 0 hours
.25 hours x 924 update (PSEI) paper enrollments = 231 hours
.25 hours x 0 update (SSGA) paper enrollments = 0 hours
.25 hours x 0 update (LEA) paper enrollments = 0 hours
4,624 + 350 + 50 + 231 = 5,255 is the total annual hour burden
Subtotal of Respondents, Responses and Burden Hours for Business or Other For-Profit
# of Respondents/Responses

# of Burden Hours

14,012 + 2,188 + 76 + 924 = 17,200

4,624 + 350 + 50 + 231 = 5,255

Not-for-profit Institutions:
.33 hours x 6,467 new web enrollments = 2,134 hours
.33 hours x 0 new (SSGA) web enrollments = 0 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.16 hours x 1,010 update web enrollments = 161 hours
.16 hours x 0 update (SSGA) web enrollments = 0 hours
.16 hours x 0 update (LEA) web enrollments = 0 hours
.66 hours x 35 new paper enrollments = 23 hours
.66 hours x 0 new (SSGA) web enrollments = 0 hours
.66 hours x 0 new (LEA) web enrollments = 0 hours
.25 hours x 426 update paper enrollments = 107 hours
.25 hours x 0 update (SSGA) web enrollments = 0 hours
.25 hours x 0 update (LEA) web enrollments = 0 hours
2,134 + 161 + 23 + 107 = 2,425 is the total annual hour burden

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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Subtotal of Respondents, Responses and Burden Hours for Not-For-Profit
# of Respondents/Responses

# of Burden Hours

6,467 + 1,010 + 35 + 426 = 7,938

2,134 + 161 + 23 + 107 = 2,425

State, Public Institutions:
.33 hours x 6,456 new (SSGA) web enrollments = 2,130 hours
.33 hours x 0 new (SSGA) web enrollments = 0 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.16 hours x 1,010 update (SSGA) web enrollments = 162 hours
.16 hours x 0 update (SSGA) web enrollments = 0 hours
.16 hours x 0 update (LEA) web enrollments = 0 hours
.66 hours x 35 new (SSGA) paper enrollments = 23 hours
.66 hours x 0 new (SSGA) web enrollments = 0 hours
.66 hours x 0 new (LEA) web enrollments = 0 hours
.25 hours x 426 update (SSGA) paper enrollments = 107 hours
.25 hours x 0 update (SSGA) web enrollments = 0 hours
.25 hours x 0 update (LEA) web enrollments = 0 hours
2,130 + 162 + 23 + 107 = 2,422 is the total annual hour burden
Subtotal of Respondents, Responses and Burden Hours of State and Public
# of Respondents/Responses

# of Burden Hours

6,456 + 1,010 + 35 + 426 = 7,927

2,130 + 162 + 23 + 107 = 2,422

FAFSA Completion Program Data:
.33 hours x 75 new web enrollments = 25 hours
.33 hours x 0 new (SSGA) web enrollments = 0 hours
.33 hours x 0 new (LEA) web enrollments = 0 hours
.16 hours x 0 update web enrollments = 0 hour
.16 hours x 0 update (SSGA) web enrollments = 0 hours
.16 hours x 0 update (LEA) web enrollments = 0 hours
.66 hours x 0 new paper enrollments = 0 hours
.66 hours x 0 new (SSGA) web enrollments = 0 hours
.66 hours x 0 new (LEA) web enrollments = 0 hours
.25 hours x 0 update paper enrollments = 0 hours

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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.25 hours x 0 update (SSGA) web enrollments = 0 hours
.25 hours x 0 update (LEA) web enrollments = 0 hours
25 + 0 = 25 is the total annual hour burden
Subtotal of Respondents, Responses and Burden Hours of FAFSA Completion Program
# of Respondents/Responses

# of Burden Hours

75 + 0 + 0 + 0 = 75

25 + 0 + 0 + 0 = 25

Subtotal of Respondents and Burden Hours for All Institutions
# of Respondents/Responses

# of Burden Hours

17,200 + 7,938 + 7,927 + 75 = 33,140

5,255 + 2,425 + 2,422 + 25 = 10,127

Total Annual hour burden for the year ending Dec 2012:
.33 hours x 27,010 new web enrollments = 8,913 hours
.16 hours x 4,207 update web enrollments = 673 hours
.66 hours x 147 new paper enrollments = 97 hours
.25 hours x 1,776 update paper enrollments = 444 hours
8913 + 673 + 97 + 444 = 10,127 is the total annual hour burden
Total Respondents, Responses and Burden Hours for New Web and Paper Enrollments
# of Respondents
27,010 + 147 = 27,157

# of Responses
27,010 + 147 = 27,157

# of Burden Hours
8,913 + 97 = 9,010

Total Respondents, Responses and Burden Hours for Update Web and Paper Enrollments
# of Respondents
4,207 + 1,776 = 5,983

# of Responses
4,207 + 1,776 = 5,983

# of Burden Hours
673 + 444 = 1,117

The annualized cost to respondents was estimated using the above figures to complete a form and an average yearly
salary of $44,100 ($21.20 per hour) for a Financial Aid Administrator (derived average salary from two recent FAA
job postings on www.careerbuilder.com).
10,127 hours (calculated above) x $21.20 per hour = $214,692 annualized cost.

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

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

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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

:

There are no start-up costs.

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 following is a breakdown of estimated costs to the Federal government to produce, process, and update the
2012-2013 Student Aid Internet Gateway Enrollment Form. The estimated costs are based on the actual costs
incurred for the most recent completed cycle year.
a.

Projected Cost for the Virtual Data Center (VDC) to host Participation Management

The VDC hosts the Web servers on which the Web enrollment form runs. Part of the cost listed below includes
hosting costs of the database at the Pearson Data Center.
FY 2012For costs incurred to house the
Web servers at the VDC

$48,370

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

b.

Revised: 12/23/2013

Projected Cost for Development/Annual Rollover Updates
$500,059

c.

Projected Cost to provide Maintenance/System Support
$734,507

d.

Projected Processing Cost

Enrollment Processing

$313,265

$1,596,201
Total Costs

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 SAIG Application for State Grant Agencies Form was revised to create a two-part form. The first part is the
SAIG Enrollment application and the second part is the new Participation Agreement which establishes the
conditions under which the Department will permit the disclosure of certain data received or generated by the
Department concerning FSA applicants. The Institutions, Third-Party Servicers, Guaranty Agencies, Federal Loan
Servicers, Lenders Enrollment Form was revised to allow Lenders and their Servicers to enroll for COD Online
access in order to receive completed electronic IBR/Pay As You Earn/ICR Repayment Request. Additionally, all
forms were revised to accommodate annual rollover changes (i.e. new award years).
The program change for this collection includes the annual burden as estimated to be 10,127 hours, based on 33,140
forms processed from January – December 2012. The current OMB inventory of 7,962 hours was based on 25,757
of the respondents enrolling in 2011. The number of respondents increased by approximately 28% for a total of
33,140 respondents.
This results in an increase of 2,165 hours to the OMB inventory due to the increase in new enrollments.
Additionally, the expansion of the system access, as noted in Item 1, is expected to increase system usage.

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.

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ICRAS Tracking and OMB Number: (1383.26) 1845-0002

Revised: 12/23/2013

Results of this collection of information will not be published.

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 OMB expiration date will be displayed on the form together with the standard request for comments.

18. Explain each exception to the certification statement identified in the Certification of
Paperwork Reduction Act.
C. It reduces burden on small entities – This information collection does not impact small entities.
F. It indicates the retention periods for recordkeeping requirements – This information collection does not have
recordkeeping requirements.
I. It uses effective and efficient statistical survey methodology – The data on this information collection is not
collected to conduct statistical surveys.

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