Supporting Statement Part A

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SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
Certification and Application for Public Service Loan Forgiveness

    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.

The Department of Education (Department) is requesting an emergency clearance for a revision to an existing information collection. The Department provides this form, 1845-0110 Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application form, which is used by student loan borrowers to apply for Public Service Loan Forgiveness (PSLF). Borrowers complete this form to have their qualifying employment certified and their progress toward forgiveness recorded in our system. They are encouraged to submit this form annually but are only required to submit it at the point that they have reached the requisite 120 qualifying months of repayment. As further explained below, final regulations for the William D. Ford Federal Direct Loan Program published on October 31, 2025, require changes be made to the language and instructions provided on the form. In order for this form to be made available for public use by the effective date of the regulations, July 1, 2026, the Department is requesting an emergency approval of these changes.  
On March 7, 2025, President Trump signed an executive order titled Restoring Public Service Loan Forgiveness (E.O. 14325) making individuals employed by organizations whose activities have a substantial illegal purpose ineligible for PSLF. 
The Department held public hearings on April 29 and May 1, 2025, and engaged in the negotiated rulemaking process by convening a committee of higher education stakeholders and experts in July of 2025. On August 18, 2026, the Department published a Notice of Proposed Rulemaking (FR 90 FR 40154) and collected public comments on the proposed regulations until September 17, 2025. 
As explained in the Final Regulations published on October 31, 2025 (90 FR 48966), 34 CFR 685.219(i) requires an update to the currently approved Public Service Loan Forgiveness Certification and Application, OMB # 1845-0110. The only updates to the form are: 1) To comply with E.O. 14325, the revision of the existing certification language to include an attestation statement, under penalty of perjury, that the employer has not engaged in any activity that has a substantial illegal purpose on or after July 1, 2026; 2) References to the updated list of eligible loan repayment plans for PSLF, as outlined in the OBBBA; and 3) Updates to the Privacy Act Statement to reflect the most current System of Records Notice (SORN) published by the Department. We also provide the definitions of what constitutes an activity that could result in a finding that the employer has a substantial illegal purpose. The attached redlined version of the draft form is included with this package and shows line-by-line revisions.  
Further explained in the Final Regulations, the Department does not believe this new certification will require an increase to burden of the form or change the number of anticipated responses or respondents. The availability of this certification and new regulatory requirements are in effect as of July 1, 2026.
The One Big Beautiful Bill Act (OBBA) signed into law on July 4, 2025 also made statutory changes that indirectly impact this collection effective July 1, 2026. Changes include the creation of a new PSLF qualifying repayment plan (the Repayment Assistance Plan) that will be available as of July 1, 2026 and the sunset of existing PSLF eligible repayment plans (SAVE, PAYE, ICR) by July 1, 2028. These changes made to qualifying PSLF repayment plans are referenced on the PSLF Form but do not impact the data collected by the form and therefore require simple content updates for borrower awareness.  
Currently, while seeking an emergency approval of 1845-0110, FSA is preparing the form for the full PRA clearance process. FSA plans to open the 60-day public comment period for this collection following the approval of the emergency clearance. This also allows public availability of the updated form at the same time as the new PSLF rule is effective. 
    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 Department and its Direct Loan Program servicers use the information collected on the consolidated Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application form to determine whether a borrower has worked for a qualified employer during the certification period and whether payments made against a borrower’s outstanding Direct Loan balance were qualifying payments for the purpose of the PSLF program or TEPSLF program. General information about the PSLF/TESPLF program is available at studentaid.gov/publicservice. And the application is available electronically and can be electronically submitted at studentaid.gov/pslf. A physical version of the form can be printed in a pdf format at https://studentaid.gov/forms-library/. 
    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.

As discussed in item 2, studentaid.gov/pslf allows for the completion of the form(s) online and electronic direct submission to the PSLF servicer if the borrower opted for their employer to provide a digital signature. If they do not request a digital signature, the pre-filled form is produced as a pdf that the borrower can upload through the loan servicer’s website. 
 
When a borrower uses the online form flow, their employer eligibility data is gathered and pre-populated on the form from the Department’s employer database. If an employer is not in the database, the borrower is notified and the form is not produced until an employer eligibility review has been performed. This reduces the instances of forms being produced with conflicting or incomplete data. 

    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. 

There is no similar information available from other sources that can be used for the purposes described in question 2. Additionally, the regulations require a borrower to submit an application to determine eligibility to participate in the PSLF program.
    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.

No small businesses are affected by this information collection.

    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.

Absent this collection of information, the Department would not have sufficient or accurate information required to make eligibility determinations for the reconsideration opportunity authorized for these borrowers.
As explained in Question 2 of this Supporting Statement, the frequency of submission of the Employment Certification Form is determined by the borrower and may be as frequent as the borrower determines necessary.   
If borrowers were not allowed to submit employment certifications until after they have made all 120 required payments and are eligible to apply for loan forgiveness, there would be a greater likelihood that borrowers would be unable to obtain the required documentation of employment that ended years in the past, and it would be more difficult for them to track their progress toward making their 120th qualifying payment. 
Further, by soliciting the Employment Certification section of the application less frequently, the Direct Loan servicers would receive a large number of forms at the same time, which would lead to delays in processing borrowers’ loan forgiveness applications. 
If the Department did not allow for Employment Certification section of the form to be submitted annually or more frequently, this would increase burden on borrowers and delay the Department’s determination of the borrower’s eligibility for Public Service Loan Forgiveness. 
The Application section of the form, however, is submitted when the borrower believes that he or she qualifies for forgiveness and wants to request that forgiveness.  If the borrower has not already done so, the borrower must submit Employment Certifications that cover the period or periods of time during which the borrower made the necessary payments. 
    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 involve any of the above conditions.

    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.

This is a request for an emergency clearance, not to exceed 180 days, of the information collection process to allow the Department to collect information from borrowers to determine eligibility for PSLF reconsideration. 

A request for this emergency clearance has been sent to the Federal Register and the emergency clearance package will be submitted to OMB as soon as the emergency notice publishes.

The Department plans to make the collection available for public comment, as part of the full PRA clearance process, by opening the 60 day comment period following the emergency clearance approval and prior to the expiration of the emergency clearance period.
 

    9. 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 have been provided to respondents.

    10. 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.

The collection will include a Privacy Act Statement that (1) informs borrowers of the statutory authority for the information collection; (2) explains that the disclosure of the information is required in order to qualify for loan forgiveness and the general servicing of federally-held loans; and (3) explains that further disclosure will only occur with the prior written consent of the borrower or under the routine uses for which the information may be disclosed, and identifies the circumstances under which those disclosures may occur. The information will be held within the System of Records Notice, entitled “Common Services for Borrowers (CSB)” (18-11-16), as published in the Federal Register on 04/22/26.

    11. 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.

The form does not require borrowers to provide information of a sensitive nature.

    12. 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.

The Department continues to estimate the time required to complete the collection of information at 0.5 hours (30 minutes) per request. Based on one response per respondent, this equates to a total estimated annual reporting burden of 456,867 hours, calculated as follows:

Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application 
Estimated annual number of respondents: 
 
913,713 
Number of responses per borrower: 
x 
1 
Hours per response: 
x 
         0.5 
Annual hour burden: 
 
456,857 hours 


There are no annual costs to respondents associated with operating or maintaining systems or purchasing services. 

Estimated Annual Burden and Respondent Costs Table

The costs are based on the May 2020 median wage for all occupations as noted here: https://www.bls.gov/oes/current/oes_nat.htm#00-0000


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.

    13. 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 are no capital/startup costs to respondents.

    14. 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 significant cost to the federal government related to these forms from Direct Loan borrowers, since servicers distribute and process the loan discharge applications, and the Department’s servicers do not specifically charge the government for distributing these forms. 
    15. 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). 



Program Change Due to New Statute
Program Change Due to Agency Discretion
Change Due to Adjustment in Agency Estimate
Total Burden



Total Responses



Total Costs (if applicable)




This request does not request changes to the approved burden.

    16. 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.

The results of this information collection will not be published.

    17. 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.

    18. 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".