Process for FSA ID Account Creation for Individuals without a Social Security Number in Connection with Person Authentication Service (PAS)

Forms and Documents

Document Name	Status
Process for FSA ID Account Creation for Individuals without a Social Security Number in Connection with Person Authentication Service (PAS) Form and Instruction	New
1845-NEW FSA ID Non SSN Supporting Statement emergency 20231207.docx Supporting Statement A	2023-12-07
PAS Emergency Clearance Memo final 20231219 rev.docx Supplementary Document	2023-12-20

IC Document Collections

IC ID	Document Title	Status
263814	Process for FSA ID Account Creation for Individuals without a Social Security Number in Connection with Person Authentication Service (PAS) Form and Instruction	New

ICR Details

OMB Control No: 1845-0179	ICR Reference No: 202312-1845-004
Status: Active	Previous ICR Reference No:
Agency/Subagency: ED/FSA	Agency Tracking No: ED-2023-SCC-0216
Title: Process for FSA ID Account Creation for Individuals without a Social Security Number in Connection with Person Authentication Service (PAS)
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 12/20/2023
OIRA Conclusion Action: Approved with change	Conclusion Date: 12/20/2023
	Date Received in OIRA: 12/20/2023
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2024	6 Months From Approved
Responses	3,500	0	0
Time Burden (Hours)	1,155	0	0
Cost Burden (Dollars)	0	0	0

---

Abstract: Applicants, parents, and borrowers establish an FSA ID, which includes a username and password. The FSA ID is used for the purposes of verifying the identity of the user; allowing users to establish an account with FSA; safeguarding their personally identifiable and financial information; signing applications and loan related documents; providing users access to their information and applications; allowing users to customize or update their accounts with FSA; renewing or revoking a users account with FSA; and supporting the Federal Student Aid Information Center (FSAIC) help desk functions. The specific questions that applicants are asked to answer in the FSA ID creation process are described separately in the Creating FSA-ID document, which explains the use of the questions in the application. As part of the standard process, users information is matched with information from the Social Security Administration (SSA) to confirm their SSA status. In the event of individuals who do not have a SSN to match, they are instructed to the contact the Department and provide one of the following documents (U.S. State/Territory Drivers License; U.S. State or City Identification Card; Foreign Passport; Municipal identification card; Community ID; or a Consular identification card) and a signed attestation of their identity under the penalty of perjury, as instructed by the Privacy Act. This collection provides the process and application that individuals without a SSN may use to acquire an FSA ID to access the statutory and regulatory benefits of the Title IV, HEA student financial assistance programs.

Emergency Justfication: If the Department were required to put the collection through the normal clearance process, we would be unable to implement this critical change by the launch of the 2024-25 FAFSA form, which would result in no access to the FAFSA application for individuals who need to get an FSA ID without a Social Security Number. Any delay in getting access to the FAFSA form would increase the potential for public harm through delayed access to student financial aid and the possibility of decreasing the likelihood of postsecondary enrollment. As a result, in order to meet the late-December, 2023 form launch, the Department is requesting that OMB approve the collection associated with non-Social Security Number FSA ID account creation process using the emergency clearance procedures.

---

Authorizing Statute(s): PL: Pub.L. 116 - 91 6 Name of Law: FUTURE Act
  

Citations for New Statutory Requirements: PL: Pub.L. 116 - 91 6 Name of Law: FUTURE Act

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

---

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

IC Title	Form No.	Form Name
Process for FSA ID Account Creation for Individuals without a Social Security Number in Connection with Person Authentication Service (PAS)	N/A	N/A

---

ICR Summary 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	3,500	0	3,500	0	0	0
Annual Time Burden (Hours)	1,155	0	1,155	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This new request for approval of this collection is due to legislative changes under the FAFSA Simplification Act of 2020. New legislative language require the development of a process to allow individuals with no SSN to contribute to applications for student financial assistance programs. This process supplements the currently approved FSA ID account creation process which is a result of the Departments action to improve user access and security of systems that include personal and financial information used to determine federal student aid eligibility. We anticipate a single response from 3,500 respondents at 20 minutes a response for a total burden of 1,155 hours annually.

---

Annual Cost to Federal Government: $500,000

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.     No

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.     No

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

---

Common Form ICR:  No

---

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: 12/20/2023

---