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pdfSUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE
PAPERWORK REDUCTION ACT AND 5 CFR 1320
A.
1.
Justification
Circumstances of the Information Collection: The Department of Justice Attorney
Student Loan Repayment Program (ASLRP) is an agency recruitment and retention
incentive program based on 5 U.S. C. S 5379, as amended, and 5 CFR Part 537. The
Department selects participants during an annual open season each spring. Any
Department of Justice employee serving in or hired to serve in an attorney position may
request consideration for the ASLRP. The number of requests varies from year to year.
The vast majority of submissions are from current DOJ employees; however, we estimate
that we also receive about 10 requests annually from incoming hires. Initial acceptance
of ASLRP funding triggers a three-year service obligation to the Department. Each year,
subject to availability of funds, the Department selects attorneys for participation on a
competitive basis and renews current beneficiaries in the second and third year of their
service obligations. ASLRP benefits are paid directly to the loan holder, not to the
individual attorney. To receive ASLRP benefits, the attorney must qualify, the attorney's
student loans must qualify, and all statutory and regulatory requirements must be met.
Attorneys who do not complete their service obligation must repay the Department for
all funds received through the ASLRP, unless a waiver of indebtedness is approved.
2.
Purpose for collection of information: The main purpose for collecting the information
is to establish the terms under which a DOJ attorney receives a student loan repayment
benefit under the Attorney Student Loan Repayment Program. The information
collected is used to determine eligibility, as a basis for payroll actions and to identify
and validate qualifying Federal student loans.
3.
Use of Automated, Electronic, Mechanical or Other Technological Collection
Techniques: The application forms and the service agreement form are available on the
Office of Attorney Recruitment and Management (OARM) website in form-fillable PDF
format, which may be digitally signed and submitted electronically. Applicants are able
to complete and forward the necessary documentation directly from their computers.
One hundred percent of the applicants for the benefits available under this Program will
complete their applications electronically. Federal law and regulations require DOJ to
validate student loans to ensure they qualify for this program: individuals requesting
participation must submit relevant supporting documents (e.g., loan payment history,
evidence of good standing, the type of loan, the loan balance, and other relevant
information) for each existing federal student loan.
4.
Efforts to Identify Duplication: There is no evidence of duplication from available
sources. Similar information is not available.
5.
Impact on Small Business and Small Entities: There is no impact on small business or
entities.
6.
Consequences if Information is Collected Less Frequently: The ASLRP selection process
is conducted once a year. Current ASLRP recipients (employees entering the second or
third year of an existing service agreement) who seek renewal of benefits must submit
their documentation by March 31st. Employees and incoming hires seeking to participate
in the ASLRP must submit their paperwork to their hiring components in April. This is the
manner in which the Department determines eligibility for the receipt of ASLRP benefits.
7.
Special Circumstances: The initial ASLRP request consists of three discrete sections: (1)
administrative eligibility information for the requesting individual; (2) relevant student
loan documentation; and (3) the individual's justification for selection. The first two
sections are retained by OARM and are reviewed to establish eligibility. The third
section is reviewed by five separate senior career officials ("the ASLRP Panel") who are
not co-located. There is insufficient funding to award benefits to all eligible requesters;
accordingly, the five-member Panel selects recipients each year. Selectees may renew
their benefits for an additional two years without further Panel review by submitting an
annual renewal request. Due to other duties, this group cannot meet for joint review,
which takes between 20-30 hours annually to complete. Electronic submission
facilitates the distribution of the Justification portion to the selecting officials for review
via a secure shared drive (Share Point).
8.
Outside Consultation: Prior to initial implementation in 2002, the agency consulted
with the Department of State, which had a similar program, to identify best practices
and take advantage of lessons learned regarding availability of data, frequency of
collection, the clarity of instructions and record keeping, disclosure, or reporting format,
and on the data elements to be recorded, disclosed, or reported. After analyzing the
statutory and regulatory requirements, several Program options were developed and
briefed to Department leaders along with recommended courses of action. A final
version was discussed with representatives from OPM prior to implementation. The
agency is part of an interagency working group that regularly assesses government-wide
issues associated with federal student loan repayment programs. The Program is
reviewed and updated annually for compliance with all regulatory provisions
implemented by OPM. The 30-day federal register notice has been published in the
federal register for public comments and no comments were received.
9.
Payment or Gift: Not applicable.
10.
Assurance of Confidentiality: The information collected is used within the agency by
employees with a need to know to determine program eligibility, to process payroll
actions, and to identify and validate qualifying Federal student loans. Disclosure of
identifiable information, including truncated Social Security Numbers, may be made to
the DOJ Office of the Inspector General and the DOJ Office of Professional Responsibility
to determine eligibility for awards, the Internal Revenue Service for tax withholding
purposes, the National Finance Center for payroll action, and lending or educational
institutions to identify and validate qualifying Federal student loans. ASLRP records are
maintained pursuant to approved records retention schedules. Effective in 2017, ASLRP
requests will be stored in a Department of Justice, Office of Attorney Recruitment and
Management (OARM) computer file. Hard copy records from preceding years are
maintained in secured files pursuant to applicable DOJ records retention policy
containers in a secured workspace not accessible to the public or DOJ employees
without the need to access the information in the course of official duty. This
information may also be used by the Department of Justice for other lawful purposes,
including law enforcement and litigation. In addition, these records, or information
therein, may also be used within the Department of Justice for study purposes, such as
projection of staffing needs, and/or creation of non-identifiable statistical data for
reports to other Federal agencies and Congress.
11.
Justification for Sensitive Questions: Documentation of the individual's qualifying federal
student loans is required to determine statutory and regulatory eligibility. Disclosure of
the individual's truncated SSN is mandatory since it is the identifier used by the DOJ's
Office of the Inspector General and Office of Professional Responsibility when reviewing
candidates for award approval. The use of the truncated SSN is necessary because of the
large number of present and former employees and applicants who have identical names
and birth dates, and whose identities can be distinguished only by the SSN. It is used
primarily to identify an employee's personnel, leave, and pay records and to relate one to
the other. It also may be used by the Department of Justice to identify and validate
qualifying Federal student loans. Disclosure of the truncated SSN is required to ensure
that servicing Human Resources Offices can identify the proper recipient in order to effect
a pay transaction. Student loan repayments are a form of incentive award: gross awards
are subject to federal and state taxes and withholdings and are considered income to the
employee. Although NFC and IRS regulations require use of the complete SSN to identify
the taxpayer, that information is independently available to recipients' finance staffs and
is not collected by OARM in managing the ASLRP. The application does not pose any other
questions of a sensitive nature except to request that the applicant voluntarily identify
personal characteristics, i.e., gender, race/national origin). Applicants are advised that the
provision of this information is entirely voluntary, is not provided to the selecting Panel,
is used only by OARM to compile Program statistical data, and that failure to respond has
no effect on their request for consideration.
12. Estimates of Hour Burden:
The Department anticipates that on a yearly basis, about 275 respondents will complete
the initial ASLRP application (new request). Of those, we estimate approximately 10
respondents are incoming hires (individuals who have accepted an offer of employment)
seeking benefits effective upon employment. The remaining 265 respondents are
current DOJ employees. It is estimated that each new application will take two (2) hours
to complete. This time estimate is reflects an increase (from 1 hour to 2 hours)
associated with the preparation of a justification statement for benefits by individuals
submitting initial requests. In addition, each year the Department expects to receive
approximately 110 applications from current employees (attorneys and law clerks)
requesting renewal of the benefits they received in previous years. We estimate that
each renewal application will take approximately 20 minutes to complete.
We calculate the estimated public burden associated with this collection, based solely
on initial requests submitted by individuals who have accepted an offer of employment
but not yet entered on duty, as 20 hours. The burden hours for collecting respondent
data, 20 hours, is calculated as follows: 10 new respondents x 2 hours = 20 hours.
When we include current employees as well as incoming hires, the estimated burden
associated with this collection is 586 hours, 40 minutes. The burden hours for collecting
respondent data, 586 hours, 40 minutes, are calculated as follows: 275 new respondents
x 2 hours = 550 hours, plus 110 renewing respondents x 20 minutes = 36 hours, 40
minutes.
ICR Summary of Burden: (Excluding current employees - Including only incoming hires)
Program
Change Due
to New
Statute
Program
Change Due
to Agency
Discretion
Change Due
to
Adjustment
in Agency
Estimate
Change due
to Potential
Violation of
the PRA
Previously
Approved
10
0
0
-10
0
20
20
0
0
+10
0
20
0
0
0
0
0
0
Requested
Annual
Number of
Responses
Annual Time
Burden (Hr)
Annual Cost
Burden ($)
ICR Summary of Burden: (lncluding all requests — employees and incoming hires)
Program
Change Due
to New
Statute
Program
Change Due
to Agency
Discretion
Change Due
to
Adjustment
in Agency
Estimate
Change due
to Potential
Violation of
the PRA
Previously
Approved
385
0
0
-90
0
475
587
0
0
+262
0
325
0
0
0
0
0
0
Requested
Annual
Number of
Responses
Annual Time
Burden (Hr)
Annual Cost
Burden ($)
13.
Estimates of the Total Cost Burden: $650.00
14.
Estimate of Annualized Cost to the Federal Government: $650.00
15.
Program Changes or Adjustments: The forms have been revised to eliminate
redundancy and streamline processing. Collection of the individual’s social security
number (SSN) has been modified to collect only a truncated SSN in lieu of the complete
SSN previously approved. The application forms and the service agreement form have
been converted to a fully form-fillable PDF format, which may be digitally signed and
submitted electronically.
16.
Publishing Information: This information is used internally for selecting recipients of
the Department's attorney student loan repayments and will not be published
17.
Display of Expiration Date for OMB Approval: OARM will display the OMB number and
expiration date on the instructions and on the electronic application.
18.
Certification for Paperwork Reduction Act Submission: OARM is not seeking any
exception to the certification statement identified in Item 19 of the Form 83-1.
Collections for Information Employing Statistical Methods: This information collection
does not employ statistical methods.
Director, Office of Attorney Recruitment and Management
Authorizing Official
| File Type | application/pdf |
| Author | Willis, Deana (OARM) |
| File Modified | 2017-02-21 |
| File Created | 2017-02-16 |