Conflicting Interests Certification for Proprietary Schools Only (VA Form 22-1919)

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Form VA Form 22-1919 Conflicting Interests Certification for Proprietary Schools Only	Form	Modified	Repair queued
Form VA Form 22-1919 Conflicting Interests Certification for Proprietary Schools Only	Form	Modified	Repair queued
2020-18742.pdf	Supplementary Document	Uploaded 2020-08-27	Repair queued
2020-13371.pdf	Supplementary Document	Uploaded 2020-06-22	Repair queued
2020 SUPPORTING STATEMENT.docx	Supporting Statement A	Uploaded 2020-06-22	Repair queued

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
28934	Conflicting Interests Certification for Proprietary Schools Only	Form	Modified	Conflicting Interests Certification for Proprietary Schools Only
28934	Conflicting Interests Certification for Proprietary Schools Only	Form	Modified

ICR Details

OMB Control No: 2900-0657	ICR Reference No: 202006-2900-003
Status: Historical Active	Previous ICR Reference No: 201612-2900-002
Agency/Subagency: VA	Agency Tracking No: VBA-EDU-NK
Title: Conflicting Interests Certification for Proprietary Schools Only (VA Form 22-1919)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 03/25/2021
Retrieve Notice of Action (NOA)	Date Received in OIRA: 10/02/2020
Terms of Clearance: VA is encouraged to consider the use of this form within the broader context of faithful execution of 38 USC 3683. In doing so, VA should consider 1. The practical utility and burden of what information should be collected directly from VA and SAA employees versus from senior school officials, 2. What information the school officials reasonably have access to, and 3. Communicating to schools, VA employees, and SAA employees what expectations, if any, exist related to changes in information currently collected on a one-time basis.

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	03/31/2024	36 Months From Approved	03/31/2021
Responses	336	0	202
Time Burden (Hours)	56	0	34
Cost Burden (Dollars)	0	0	0

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Abstract: VA uses data from the VA Form 22-1919 to ensure that proprietary schools comply with the law, in order to prevent erroneous VA education benefit payments, and it prohibits VA employees from receiving any services from private for-profit schools.

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Authorizing Statute(s): US Code: 38 USC 3683 Name of Law: Conflicting Interest
  

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
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 37498	06/22/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 18742	08/26/2020
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
Conflicting Interests Certification for Proprietary Schools Only	VA Form 22-1919	Conflicting Interests Certification for Proprietary Schools Only

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ICR Summary of Burden

table that charts list 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	336	202	0	134	0	0
Annual Time Burden (Hours)	56	34	0	22	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: The slight increase in the annual reporting burden from 34 hours to 56 hours is as a result of an increase in approvals received by the SAA and/or VA from ‘2017 through ‘2019.

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Annual Cost to Federal Government: $1,946

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     Yes

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? No

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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: 10/02/2020

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