1845-0022 Supporting Statement General Provisions non-GE Final Rule 2023 FINAL (3)

Tracking and OMB Number: (XX) 1845-0022 Revised: 10/18/2023

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Student Assistance General Provisions

1. Explain the circumstances that make the collection of information necessary. What is the purpose for this information collection? Identify any legal or administrative requirements that necessitate the collection. Include a citation that authorizes the collection of information. 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, list the sections with a brief description of the information collection requirement, and/or changes to sections, if applicable.

On January 18, 2022, the Department convened a negotiated rulemaking committee, the Institutional and Programmatic Eligibility Committee, to consider proposed regulations for the Federal Student Aid programs authorized under title IV of the Higher Education Act of 1965, as amended, (HEA). Through the Notice of Proposed Rulemaking (NPRM), docket number ED-2022-OPE-0062, the Secretary proposes new regulations to promote transparency, competence, stability, and effective outcomes for students in the provision of postsecondary education. The NPRM, published May 19, 2023 (Vol. 88, No. 97, pages 32300-32511), included proposed regulations on five topics--Financial Value Transparency and Gainful Employment (GE), Financial Responsibility, Administrative Capability, Certification Procedures, and Ability to Benefit. Some of those topics were covered under the information collection 1845-0022 as published in the NPRM. The NPRM has been divided into two separate Final Rules. The burden that covered the GE portion of the information collection originally submitted in the NPRM was cleared through a separate filing under the 1845-0022 information collection under the GE Final Rule published October 10, 2023.

The Financial Responsibility, Administrative Capability, Certification Procedures, and Ability to Benefit Final Rule makes changes to the information collection 1845-0022 – Student Assistance General Provisions. This information collection request only covers the Final Rule provisions for the Financial Responsibility, Administrative Capability, and Certification Procedures which includes some burden for the information collection 1845-0022 that was published in the NPRM.

Section 668.14-Program participation agreement.

In § 668.14, the Final Rule requires institutions that are provisionally certified and that are determined to be at risk of closure to submit an acceptable teach-out plan or agreement to the Department, the State, and the institution’s recognized accrediting agency.

Section 668.15-Factors of financial responsibility.

The Final Rule simplifies the regulations by consolidating the financial responsibility requirements for changes in ownership under proposed part 668, subpart L and removing and reserving current § 668.15.

Section 668.16-Standards of administrative capability.

The Final Rule adds standards in the administrative capability regulations at § 668.16 that will ensure that institutions can appropriately administer the title IV, HEA programs. In § 668.16(h) the Final Rule requires institutions to provide adequate financial aid counseling and financial aid communications to advise students and families to accept the most beneficial types of financial assistance available to enrolled students that includes clear information about the cost of attendance, sources and amounts of each type of aid separated by the type of aid, the net price, and instructions and applicable deadlines for accepting, declining, or adjusting award amounts. In § 668.16(p) the Final Rule strengthens the requirement that institutions must develop and follow adequate procedures to evaluate the validity of a student’s high school diploma.

Section 668.23-Compliance audits and audited financial statements.

In § 668.23(d)(2)(ii) the Final Rule adds new language that will require a domestic or foreign institution that is owned directly or indirectly by any foreign entity to provide documentation stating its status under the law of the jurisdiction under which it is organized.

Section 668.171 General.

The Final Rule amends § 668.171(f) by adding several new events to the existing reporting requirements and expanding others. These events must be generally reported generally no later than 10 days following the event. Additionally, the Final Rule amends § 668.171(g) by adding language which will require a public institution to provide to the Department a letter from an official of the government entity or other signed documentation acceptable to the Department.

This request is to revise the current information collection to include these new regulatory requirements.

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 revisions to §§ 668.14, 668.16, 668.23, and 668.171 will provide the Department with crucial information to determine if an institution continues to meet the eligibility requirements of the regulations and should remain an eligible participant in the title IV, HEA student financial aid programs.

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 information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Please identify systems or websites used to electronically collect this information. Also describe any consideration given to using technology to reduce burden. If there is an increase or decrease in burden related to using technology (e.g. using an electronic form, system or website from paper), please explain in number 12.

There are no prohibitions to the use of technology in providing the required information to the Department.

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.

This information is not duplicated on any other information collection.

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.

The Department does not believe the regulations will adversely impact any institution that may meet the small entity designation. The use of the electronic means to meet the regulations would mitigate any burden of providing the required information.

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 the requirements in these regulations do not occur, the Department will lack crucial information to protect the integrity of the title IV, HEA programs and to protect students and taxpayers abusive behaviors.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• 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;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• 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.

This information collection does not require any of the noted special circumstances.

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.

Include a citation for the 60 day comment period (e.g. Vol. 84 FR ##### and the date of publication). Summarize public comments received in response to the 60 day notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. If only non-substantive comments are provided, please provide a statement to that effect and that it did not relate or warrant any changes to this information collection request. In your comments, please also indicate the number of public comments received.

For the 30 day notice, indicate that a notice will be published.

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, 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.

The Department developed these proposed regulations after conducting negotiated rulemaking with affected entities and other interested parties. The public comment period for this information collection ran concurrently with the Notice of Proposed Rulemaking.

There were no specific comments related to the burden for this information collection. No changes have been made to the estimated burden.

8. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.

No payments or gifts will be provided to respondents.

8. 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.¹ 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 confidentiality of the data. If no PII will be collected, state that no assurance of confidentiality is provided to respondents. If the Paperwork Burden Statement is not included physically on a form, you may include it here. Please ensure that your response per respondent matches the estimate provided in number 12.

There are no assurances of confidentiality provided to States regarding this information.

8. 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. 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 in this collection.

8. Provide estimates of the hour burden for this current information collection request. The statement should:

• Provide an explanation of how the burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. Address changes in burden due to the use of technology (if applicable). Generally, estimates should not include burden hours for customary and usual business practices.

• Please do not include increases in burden and respondents numerically in this table. Explain these changes in number 15.

• 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. 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 this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burden in the table below.

• Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. Use this site to research the appropriate wage rate. 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. If there is no cost to respondents, indicate by entering 0 in the chart below and/or provide a statement.

This burden estimate change only covers the non-GE portion of the burden originally submitted in the NPRM. The burden that covered the GE portion of that originally submitted in the NPRM was cleared through a separate, filing under the 1845-0022 information collection under the GE Final Rule published October 10, 2023.

Section 668.14-Program participation agreement.

The Final Rule amends the new paragraph (e) which outlines a non-exhaustive list of conditions that the Department may opt to apply to provisionally certified institutions. The Final Rule requires that institutions at risk of closure submit an acceptable teach-out plan or agreement to the Department, the State, and the institution’s recognized accrediting agency. The Final Rule requires that institutions at risk of closure submit an acceptable records retention plan that addresses title IV, HEA records, including but not limited to student transcripts, and evidence that the plan has been implemented, to the Department. The Final Rule requires that an institution at risk of closure that is teaching out, closing, or that is not financially responsible or administratively capable, will release holds on student transcripts. Other conditions for institutions that are provisionally certified and may be applied by the Secretary are also identified.

The Final Rule regulatory language in § 668.14 will add burden to all institutions, domestic and foreign. The change in § 668.14(e) will require provisionally certified institutions at risk of closure to submit to the Department acceptable teach-out plans, and acceptable record retention plans. For provisionally certified institutions at risk of closure, are teaching out or closing, or are not financially responsible or administratively capable, the proposed change requires the release of holds on student transcripts.

We believe that this type of update will require 10 hours for each institution to provide the appropriate material, or required action based on the proposed regulations. As of January 2023, there were a total of 863 domestic and foreign institutions that were provisionally certified. We estimate that of that figure 5% or 43 provisionally certified institutions may be at risk of closure.

We estimate that it will take private non-profit institutions 250 hours (25 x 10 = 250) to complete the submission of information or required action.

We estimate that it will take proprietary institutions 130 hours (13 x 10 = 130) to complete the submission of information or required action.

We estimate that it will take public institutions 50 hours (5 x 10 = 50) to complete the submission of information or required action.

The estimated § 668.14(e) total burden will be 430 hours with a total rounded estimated cost for all institutions of $20,663 (430 x $48.05 rounded) under OMB Control Number 1845-0022.

Section 668.15-Factors of financial responsibility.

This section is being removed and reserved.

With the removal of regulatory language in Section 668.15 the Department will remove the associated burden of 2,448 hours under OMB Control Number 1845-0022.

Section 668.16-Standards of administrative capability.

The Department amends § 668.16 to clarify the characteristics of institutions that are administratively capable. The Final Rule amends § 668.16(h) to require institutions to provide adequate financial aid counseling and financial aid communications to advise students and families to accept the most beneficial types of financial assistance available to enrolled students. This will include clear information about the cost of attendance, sources and amounts of each type of aid separated by the type of aid, the net price, and instructions and applicable deadlines for accepting, declining, or adjusting award amounts. Institutions will also have to provide students with information about the institution’s cost of attendance, the source and type of aid offered, whether it must be earned or repaid, the net price, and deadlines for accepting, declining, or adjusting award amounts.

The Final Rule amends § 668.16(p) which will strengthen the requirement that institutions must develop and follow adequate procedures to evaluate the validity of a student’s high school diploma if the institution or the Department has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education. The Department updates the references to high school completion in the current regulation to high school diploma which will set specific requirements to the existing procedural requirement for adequate evaluation of the validity of a student’s high school diploma.

The Final Rule’s regulatory language in § 668.16 will add burden to all institutions, domestic and foreign. The proposed changes in § 668.16(h) would require an update to the financial aid communications provided to students.

We believe that this update will require 8 hours for each institution to review their current communications and make the appropriate updates to the material based on the proposed regulations.

We estimate that it will take private non-profit institutions 15,304 hours (1,913 x 8 = 15,304) to complete the required review and update.

We estimate that it will take proprietary institutions 12,032 hours (1,504 x 8 = 12,032) to complete the required review and update.

We estimate that it will take public institutions 14,504 hours (1,813 x 8 = 14,504) to complete the required review and update.

The estimated § 668.16(h) total burden is 41,840 hours with a total rounded estimated cost for all institutions of $2,010,412 (41,840 x $48.05).

The changes in § 668.16(p) will add requirements for adequate procedures to evaluate the validity of a student’s high school diploma if the institution or the Department has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education.

We believe that this update will require 3 hours for each institution to review their current policy and procedures for evaluating high school diplomas and make the appropriate updates to the material based on the proposed regulations.

We estimate that it will take private non-profit institutions 5,739 hours (1,913 x 3 = 5,739) to complete the required review and update.

We estimate that it will take proprietary institutions 4,512 hours (1,504 x 3 = 4,512) to complete the required review and update.

We estimate that it will take public institutions 5,439 hours (1,813 x 3 = 5,439) to complete the required review and update.

The estimated § 668.16(p) total burden is 15,690 hours with a total rounded estimated cost for all institutions of $753,905 (15,690 x $48.05 rounded).

The total estimated increase in burden for § 668.16 is 57,530 hours with a total rounded estimated cost of $2,764,317 to OMB Control Number 1845-0022.

Section 668.23-Compliance audits and audited financial statements.

The Final Rule adds § 668.23(d)(2)(ii) that will require that an institution, domestic or foreign, that is owned by a foreign entity holding at least a 50 percent voting or equity interest to provide documentation of its status under the law of the jurisdiction under which it is organized, as well as basic organizational documents. The submission of such documentation will better equip the Department to obtain appropriate and necessary documentation from an institution which has a foreign owner or owners with 50 percent or greater voting or equity interest which would provide a clearer picture of the institution’s legal status to the Department, as well as who exercises direct or indirect ownership over the institution. 

The Final Rule’s regulatory language in § 668.23(d)(2)(ii) will add burden to foreign institutions and certain domestic institutions to submit documentation, translated into English as needed.

We believe this reporting activity will require an estimated 40 hours of work for affected institutions to complete.

We estimate that it will take private non-profit institutions 13,520 hours (338 x 40 = 13,520) to complete the required documentation gathering and translation as needed.

We estimate that it will take proprietary institutions 920 hours (23 x 40 = 920) to complete the required footnote activity.

The estimated § 668.23(d)(2)(ii) total burden is 14,440 hours with a total rounded estimated cost for all institutions of $693,842 (14,440 x $48.05).

The total estimated increase in burden for § 668.23 is 14,440 hours with a total rounded estimated cost of $693,842 to OMB Control Number 1845-0022.

Section 668.171 General.

The Final Rule amends § 668.171(f) by adding several new events to the existing reporting requirements, and expanding others, that must be reported generally no later than 21 days following the event. Implementation of the reportable events will make the Department more aware of instances that may impact an institution’s financial responsibility or stability. The final rule’s reportable events are linked to the financial standards in § 668.171(b) and the financial triggers in § 668.171 (c) and (d) where there is no existing mechanism for the Department to know that a failure or a triggering event has occurred. Notification regarding these events will allow the Department to initiate actions to either obtain financial protection, or determine if financial protection is necessary, to protect students from the negative consequences of an institution’s financial instability and possible closure.

The Final Rule amends § 668.171(g) by adding language which wwill require an insittutions seeking eigiblilty as a public institution for the first time, as part of a request to be recognized as a public institution following a change in ownership, or otherwise upon request by the Department to provide to the Department a letter from an official of the government entity or other signed documentation acceptable to the Department. The letter or documentation must state that the institution is backed by the full faith and credit of the government entity. The final rule applies similar amendments to apply to foreign institutions.

The Final Rule regulatory language in § 668.171(f) will add burden to institutions regarding evidence of financial responsibility. The regulations in § 668.171(f) will require institutions to demonstrate to the Department that it met the triggers set forth in the regulations. We estimate that domestic and foreign, have the potential to hit a trigger that will require them to submit documentation to determine eligibility for continued participation in the title IV programs. The overwhelming majority of reporting will likely stem from the mandatory triggering event on gainful employment programs that are failing with limited reporting under additional events.

We believe that this documentation and reporting activity will require an estimated 2 hours per institution.

We estimate it will take private non-profit institutions 100 hours (50 institutions x 2 hours = 100) to complete the required documentation and reporting activity.

We estimate that it will take proprietary institutions 1,300 hours (650 institutions x 2 hours = 1,300) to complete the required documentation and reporting activity.

The Final Rule’s regulatory language in § 668.171(g) will add burden to public institutions regarding evidence of financial responsibility. The regulations in § 668.171(g) will require institutions to demonstrate to the Department that the public institution is backed by the full faith and credit of the government entity. We believe that this document filing would be done by the majority of the public institutions upon recertification of currently participating institutions.

We estimate that 36 public institutions (two percent of the currently participating public institutions) will be required to recertify in a given year. We further estimate that it will take each institution 5 hours to procure the required documentation from the appropriate governmental agency for a total of 180 hours (36 institutions x 5 hours = 180 hours).

The total estimated increase in burden for § 668.171 is 1,580 hours with a total rounded estimated cost of $75,919 to OMB Control Number 1845-0022.

The total estimated increase to OMB Control Number 1845-0022 for §§ 668.14, 668.15, 668.16, 668.23, and 668.171 is 5,230 respondents, 9,002 responses, and 71,532 hours with a total rounded estimated cost of $3,437,114.00.

This is added to the current burden assessment of 789,349 respondents, 1,352,836 responses, and 2,514,148 hours, for new totals for OMB Control Number 1845-0022 of 794,579 respondents, 1,361,838 responses and 2,585,680 burden hours.

Estimated Annual Burden and Respondent Costs Table

Information Activity or IC (with type of respondent)	Number of Respondents	Number of Responses	Average Burden Hours per Response	Total Annual Burden Hours	Estimated Respondent Average Hourly Wage	Total Annual Costs (hourly wage x total burden hours)
Individual	N/A	N/A	N/A	N/A	N/A	N/A
For-Profit Institutions	1,504	2,828	See above	18,078	$48.05	$868,648.00
Private Institutions	1,913	3,373	See above	34,097	$48.05	$1,638,361.00
Public Institutions	1,813	2,801	See above	19,357	$48.05	$930,104.00
Annualized Totals	5,230	9,002		71,532		$3,437,114.00
Current Totals	789,349	1,352,836		2,514,148
New Grand Total	794,579	1,361,838		2,585,680		$124,241,925.00

Please ensure the annual total burden, respondents and response match those entered in IC Data Parts 1 and 2, and the response per respondent matches the Paperwork Burden Statement that must be included on all forms.

8. 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 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 is no additional cost.

8. 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.

There is no additional cost to the Federal government.

8. 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).

Provide a descriptive narrative for the reasons of any change in addition to completing the table with the burden hour change(s) here.

	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate
Total Burden		+71,532
Total Responses		+9,002
Total Costs (if applicable)

This request is to revise the currently approved information collection. These changes are due to the final regulations offered through program change.  Sections 668.14, 668.15, 668.16, 668.23, and 668.171 has the estimated burden of 71,532 hours for 9,002 responses from 5,230 institutions.  This final rule covers these sections of the information collection requirement and we are requesting an increase in respondents, responses and hours from the previous overall burden.

8. 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.

This information collection will not be published.

8. 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 Department is not seeking this approval.

8. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

The Department is not requesting any exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83-I.

1 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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