2019 Justification - Forbearance

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1. Need for Information Collection

Section 428 of the Higher Education Act of 1965, as amended, provides mandatory forbearance on qualified student loans for individuals serving in a national service position for which the borrower receives a national service educational award.

A2. Indicate how, by whom, and for what purpose the information is to be used.

Officials use the Forbearance Request for National Service Form, or its electronic versions, to certify that AmeriCorps members are eligible for forbearance based on their enrollment in a national service position. AmeriCorps members use the form, or its electronic equivalents, to request a forbearance from the loan holder.

 

 A3. Minimize Burden: Use of Improved Technology to Reduce Burden

Currently, about two-thirds of the forbearances are requested and processed electronically. CNCS expects the use of paper forms to continue to decrease over the next few years.

A4. Non-Duplication

This information is not being requested by any other means.

 

A5. Minimizing for economic burden for small businesses or other small entities.

Only AmeriCorps members and certifying officials fill out this form or its electronic versions and forward the forms to the loan holders who process the requests.

A6. Consequences of the collection if not conducted, conducted less frequently, as well as any technical or legal obstacles to reducing burden.

 

For every term of service, qualified student loans are eligible for mandatory forbearance. If this data were not collected, the loan holder would not have the information to put the loan in forbearance based on national service and could require the borrower to continue to make payments while serving.

A7. Special circumstances that would cause information collection to be collected in a manner requiring respondents to report more often than quarterly; report in fewer than 30 days after receipt of the request; submit more than an original and two copies; retain records for more than three years; and other ways specified in the Instructions focused on statistical methods, confidentially, and proprietary trade secrets.

There are no special circumstances that would require the collection of information in any other ways specified.

A8. Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice. Summarize comments received and actions taken in response to comments. Specifically address comments received on cost and hour burden.

The 60-day Notice soliciting comments was published on Tuesday, June 11, 2019 on page 27095. CNCS received no comments.

 

 A9. Payment to Respondents

There are no payments or gifts to respondents.

  

A10. Assurance of Confidentiality and its basis in statute, regulation, or agency policy.

Confidentiality of information supplied by respondents is ensured by the Privacy Act. A Privacy Act Notice appears on the form.

A11. Sensitive Questions

 

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

An estimated 11,000 respondents will take 10 minutes each to complete the form, resulting in 1,833 total burden hours.

A13. Cost burden to the respondent

None.

 

A14. Cost to Government

Cost	Pay Band	Salary*	% of Effort	Fringe if applicable	Total Cost to Government
Federal Oversight	NY02	55,000.00	0.0334		1,837.00

A15. Reasons for program changes or adjustments in burden or cost.

CNCS seeks to revise the burden hour information to reflect the increased electronic volume of this form.  

 A16. Publication of results

Not applicable because the responses to this information collection will not be published. 

 

A17. Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

CNCS requests that the expiration date not be displayed. OMB approved a similar request the last time CNCS revised this form. System constraints make it difficult to revise the hard-coded dates on the online versions in a timely manner, which may give rise to considerable confusion among members and institutions who mistake it for the award’s expiration date.

 

 A18. Exceptions to the certification statement

No exceptions are requested

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