20200110 Justification - Interest1

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1. Need for Information Collection

The National and Community Service Act of 1990, as amended, requires that CNCS pay, on behalf of AmeriCorps members, all or a portion of the interest accruing during their service period, if their loans were in forbearance and if they successfully complete their term of service. This payment is in addition to their education award. The intention is to keep the qualified student loan debt of members from increasing as a result of their national service. The percentage of accrued interest CNCS pays is determined by a formula based on the member’s term of service.

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

AmeriCorps members use the form, or its electronic equivalents, to request a payment of accrued interest on qualified student loans and to authorize the release of loan information to the National Service Trust; schools and lenders verify eligibility for the payments; and both parties verify certain legal requirements.

 

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

Currently, about two-thirds of the interest payments are requested and processed electronically. CNCS expects the use of paper forms to continue to decrease over the next few years and will continue to promote payments through Electronic Funds Transfers via the US Treasury, which now comprise about 70% of award payments.

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 their schools or student loan holders fill out this form or its electronic version. The form requests only the most pertinent information not available to the Trust elsewhere. Schools and loan holders complete the forms in order to receive payments.

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

 

If this data were not collected CNCS would not know the amount of the interest payment, how or where to disburse AmeriCorps members’ payments, nor how to assess a request’s eligibility.

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

The estimate of burden hours for respondents to complete the form is a total of 1,100 hours. 13,200 respondents will take five minutes to complete the form, resulting in a total burden of 66,000 minutes or 1,100 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	0.042		2,310.00
Total					2,310.00

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

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

 A16. Publication of results

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 the voucher 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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