Supporting Statement (Req for OMB Approval - 1105-0086)_

SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL UNDER THE PAPERWORK
REDUCTION ACT AND 5 CFR 1320
A.
1.

Justification
Circumstances of the Information Collection: The Department of Justice Attorney
Student Loan Repayment Program (ASLRP) is an agency recruitment and retention
incentive program based on 5 U.S. C. § 5379, as amended, and 5 CFR Part 537. The
Department selects participants during an annual open season each spring. Any
Department of Justice employee serving in or hired to serve in an attorney position may
request consideration for the ASLRP. The number of requests varies from year to year.
The majority of submissions are from current DOJ employees; however, we average 21
requests annually from incoming hires.
Initial acceptance of ASLRP funding triggers a three-year service obligation to the
Department. Each year, subject to availability of funds, the Department selects attorneys
(current employees and incoming hires) for participation on a competitive basis and
renews current beneficiaries (all of whom are DOJ employees) in the second and third
year of their service obligations. ASLRP benefits are paid directly to the loan holder, not
to the individual attorney. To receive ASLRP benefits, the attorney must qualify, the
attorney's student loans must qualify, and all statutory and regulatory requirements must
be met. Attorneys who do not complete their service obligation must repay the
Department for all funds received through the ASLRP, unless a waiver of indebtedness is
approved.

2.

Purpose and Use of the Information: The main purpose for collecting the information is
to establish the terms under which a DOJ attorney or incoming DOJ attorney hire receives
a student loan repayment benefit under the Attorney Student Loan Repayment Program.
The information collected is used to determine eligibility, as a basis for payroll actions
and to identify and validate qualifying Federal student loans. The Office of Attorney
Recruitment and Management (OARM), which manages the Attorney Student Loan
Repayment Program, has the authority to ask for this information pursuant to 5 U.S.C.
§301, and 28 C.F.R. Part 0.15(b)(2). This information can be shared in accordance with
routine uses as published in system of record notice JMD-024, Attorney Student Loan
Repayment Program Applicant Files, 71 FR 64740 (11-03-2006), as modified by 82 FR
24147(5-25-2017) (See https://www.govinfo.gov/content/pkg/FR-2017-05-25/pdf/201710780.pdf).

3.

Use of Automated, Electronic, Mechanical or Other Technological Collection
Techniques: All ASLRP application forms are available on the Office of Attorney
Recruitment and Management (OARM) website in form-fillable PDF format, which may
be digitally signed and submitted electronically. Applicants are able to complete and
forward the necessary documentation directly from their computers. One hundred
percent of the applicants for the benefits available under this Program will complete their
applications electronically. Federal law and regulations require DOJ to validate student
loans to ensure they qualify for this program: individuals requesting participation must
submit relevant supporting documents (e.g., evidence the loan is in good standing, the

type of loan, the loan balance, account holder, and other relevant information) for each
existing federal student loan.
4.

Efforts to Identify Duplication: OARM is the only office within DOJ that collects this data.
There is no evidence of duplication from available sources. Similar information is not
available.

5.

Impact on Small Business and Small Entities: There is no impact on small business or
entities.

6.

Consequences if Information is Collected Less Frequently: The ASLRP selection process
is conducted once a year. Current ASLRP recipients (employees entering the second or
third year of an existing service agreement) who seek renewal of benefits must submit
their documentation by March 31st. Current employees and incoming hires seeking to
participate in the ASLRP must submit their paperwork to their hiring components in April.
This is the manner in which the Department determines eligibility for the receipt of ASLRP
benefits and selects recipients.

7.

Special Circumstances: The initial ASLRP request consists of administrative eligibility
information for the requesting individual; relevant student loan documentation; and the
individual's justification for selection. The first two sections are retained by OARM and
are reviewed to establish eligibility. The third section is reviewed by five separate senior
career officials ("the ASLRP Panel") who are not co-located. There is insufficient funding
to award benefits to all eligible requesters; accordingly, the five-member Panel selects
recipients each year. Selectees may renew their benefits for an additional two years
without further Panel review by submitting an annual renewal request. Due to other
duties, this group cannot meet for joint review, which takes approximately 20 hours
annually to complete. Electronic submission facilitates the distribution of the Justification
portion to the selecting officials for review via a secure shared drive (Share Point).

8.

Outside Consultation: In addition to the 30-day and 60-day Federal Register notices and
the comment process, when establishing the Program in 2002, DOJ consulted with the
Department of State, which had a similar program, to identify best practices and take
advantage of lessons learned regarding availability of data, frequency of collection, the
clarity of instructions and record keeping, disclosure, and reporting format, and on the
data elements to be recorded, disclosed, or reported. After analyzing the statutory and
regulatory requirements, several Program options were developed and briefed to
Department leaders along with recommended courses of action. A final version was
discussed with representatives from OPM prior to implementation. The Program is
reviewed and updated annually for compliance with all regulatory provisions
implemented by OPM and, as appropriate, policy changes are promulgated to ensure the
Program continues to meet the Department’s needs. The 30-day federal register notice
has been published in the federal register for public comments and no comments were
received.

9.

Payment or Gift: If selected to participate in the ASLRP, an individual may receive up to
$6000 a year for up to three years in loan repayment incentives paid directly to the loan
holder.

10.

Assurance of Confidentiality: There are no assurances to the respondent since
submission of this information is entirely voluntary. However, personal identifiers are
collected only to issue benefit payments. The information collected is used within the
agency by employees with a need to know to determine program eligibility, to process
payroll actions, and to identify and validate qualifying Federal student loans. Disclosure
of identifiable information, including truncated Social Security Numbers, may be made to
the DOJ Office of the Inspector General and the DOJ Office of Professional Responsibility
to determine eligibility for awards, the Internal Revenue Service for tax withholding
purposes, the National Finance Center for payroll action, and lending or educational
institutions to identify and validate qualifying Federal student loans. ASLRP records are
maintained pursuant to approved records retention schedules. Since 2017, ASLRP
requests have been stored in a Department of Justice, OARM, computer file. Hard copy
records from preceding years are maintained in secured files pursuant to applicable DOJ
records retention policy containers in a secured workspace not accessible to the public or
DOJ employees without the need to access the information in the course of official duty.
This information may also be used by the Department of Justice for other lawful purposes,
including law enforcement and litigation pursuant to system of record notice JMD-024,
Attorney Student Loan Repayment Program Applicant Files, 71 FR 64740 (11-03-2006), as
modified by 82 FR 24147 (5-25-2017) (See https://www.govinfo.gov/content/pkg/FR2017-05-25/pdf/2017-10780.pdf). In addition, these records, or information therein, may
also be used within the Department of Justice for study purposes, such as projection of
staffing needs, and/or creation of non-identifiable statistical data for reports to other
Federal agencies and Congress.

11.

Justification for Sensitive Questions: Documentation of the individual's qualifying federal
student loans is required to determine statutory and regulatory eligibility. Disclosure of
the individual's truncated SSN is mandatory since it is the identifier used by the DOJ's
Office of the Inspector General and Office of Professional Responsibility when reviewing
candidates for award approval. The use of the truncated SSN is necessary because of the
large number of present and former employees and applicants who have identical names
and birth dates, and whose identities can be distinguished only by the SSN. It is used
primarily to identify an employee's personnel, leave, and pay records and to relate one to
the other. It also may be used by the Department of Justice to identify and validate
qualifying Federal student loans. Disclosure of the truncated SSN is required to ensure
that servicing Human Resources Offices can identify the proper recipient in order to effect
a pay transaction. Student loan repayments are a form of incentive award: gross awards
are subject to federal and state taxes and withholdings and are considered income to the
employee. Although NFC and IRS regulations require use of the complete SSN to identify
the taxpayer, that information is independently available to recipients' finance staffs and
is not collected by OARM in managing the ASLRP. The application does not pose any other
questions of a sensitive nature except to request that the applicant voluntarily identify
personal characteristics, i.e., gender, race/national origin. Applicants are advised that the
provision of this information is entirely voluntary, is not provided to the selecting Panel,
is used only by OARM to compile Program statistical data, and that failure to respond has
no effect on their request for consideration.

12.

Estimates of Hour Burden:
The Department anticipates that on a yearly basis, about 150 respondents will complete
the initial ASLRP application (new request). Of those, we average 21 requests from
respondents who are incoming hires (individuals who have accepted an offer of
employment) seeking benefits effective upon employment. The remaining 129
respondents are current DOJ employees.
We calculate the estimated public burden associated with this collection, based solely on
initial requests submitted by individuals who have accepted an offer of employment but
not yet entered on duty, as 42 hours. The burden hours for collecting respondent data,
42 hours, is calculated as follows: 21 new respondents x 2 hours = 42 hours.

ICR Summary of Burden: (Excluding current employees - Including only incoming hires)
Program
Change Due to
New Statute

Program
Change Due
to Agency
Discretion

Change Due
to
Adjustment
in Agency
Estimate

Change due
to Potential
Violation of
the PRA

Previously
Approved

21

0

0

+11

0

10

42

0

0

+22

0

20

0

0

0

0

0

0

Requested

Annual
Number of
Responses
Annual Time
Burden (Hr)

Annual Cost
Burden ($)

13.

Estimates of the Total Cost Burden: $0

14.

Estimate of Annualized Cost to the Federal Government: $0

15.

Program Changes or Adjustments: Estimate of public burden and cost to government
refined based on experience.

16.

Publishing Information: This information is used internally for selecting recipients of the
Department's attorney student loan repayments and will not be published

17.

Display of Expiration Date for OMB Approval: OARM will display the OMB number and
expiration date on the forms for the electronic application.

18.

Certification for Paperwork Reduction Act Submission: OARM is not seeking any
exception to the certification statement identified in Item 19 of the Form 83-1.

19.

Collections for Information Employing Statistical Methods: This information collection
does not employ statistical methods.

__________________________________
Eleanor Carpenter
Director, Office of Attorney Recruitment and Management
Authorizing Official