20200110 Justification - Payment1a

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1. Need for Information Collection

The National and Community Service Act of 1990, as amended, provides a national service education award to individuals who complete a term of service in an approved national service position. These education awards can be used to repay qualified student loans and to pay for the cost of attending qualified post-secondary educational institutions. The form is used to collect information necessary for disbursing payments as detailed in 42 USC §12602 through §12604.

A2. Indicate how, by whom, and for what purpose the information is to be used.

Individuals using a Segal AmeriCorps Education Award use the form, or its electronic equivalent, to authorize a payment from their education award account, schools and lenders verify eligibility for the payments, and both parties verify certain legal requirements.

 

 A3. Minimize Burden: Use of Improved Technology to Reduce Burden

Currently, about two-thirds of the education award payments are requested and processed electronically. CNCS expects the use of paper forms to continue to decrease over the next few years and will continue to promote payments through Electronic Funds Transfers via the US Treasury, which now comprise about 88% of award payments.

A4. Non-Duplication

This information is not being requested by any other means.

 

A5. Minimizing for economic burden for small businesses or other small entities.

Only Individuals using a Segal AmeriCorps Education Award and their schools or student loan holders fill out this form or its electronic version. The form requests only the most pertinent information not available to the Trust elsewhere. Schools and loan holders complete the forms in order to receive payments.

A6. Consequences of the collection if not conducted, conducted less frequently, as well as any technical or legal obstacles to reducing burden.

 

If this data were not collected CNCS would not know how or where to disburse payments, nor how to assess a request’s eligibility under the National and Community Service Act of 1990, as amended.

A7. Special circumstances that would cause information collection to be collected in a manner requiring respondents to report more often than quarterly; report in fewer than 30 days after receipt of the request; submit more than an original and two copies; retain records for more than three years; and other ways specified in the Instructions focused on statistical methods, confidentially, and proprietary trade secrets.

There are no special circumstances that would require the collection of information in any other ways specified.

A8. Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice. Summarize comments received and actions taken in response to comments. Specifically address comments received on cost and hour burden.

The 60-day Notice soliciting comments was published on Tuesday, June 18, 2019 on page 28284. CNCS received no comments.

 

 A9. Payment to Respondents

There are no payments or gifts to respondents.

  

A10. Assurance of Confidentiality and its basis in statute, regulation, or agency policy.

Confidentiality of information supplied by respondents is ensured by the Privacy Act. A Privacy Act notice appears on the form.

A11. Sensitive Questions

 

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

The estimate of burden hours for respondents to complete the form is a total of 13,500 hours. This estimate of burden hours accounts for section A and B of the manual payment form.

• 1/2 minute for AmeriCorps members to complete their section x 162,000 forms = 81,000 minutes or 1,350 hours

• 4 1/2 minutes for schools or loan holders to complete their portion x 162,000 forms = 729,000 minutes or 12,150 hours

A13. Cost burden to the respondent

None.

 

A14. Cost to Government

Cost	Pay Band	Salary*	% of Effort	Fringe if applicable	Total Cost to Government
Federal Oversight	NY02	56,000.00	0.084		4,704.00
	NY03	70,000.00	0.084		5,880.00
	NY03	70,000.00	0.084		5,880.00
	NY03	79,000.00	0.084		6,636.00
Total					23,100.00

A15. Reasons for program changes or adjustments in burden or cost.

CNCS seeks only to revise the burden hour information to reflect the increased electronic volume of this form.

 

 A16. Publication of results

Not applicable because the responses to this information collection will not be published. 

 

A17. Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

CNCS requests that the expiration date not be displayed. OMB approved a similar request the last time CNCS revised this form.

Several years ago, when a prior version did include the expiration date, CNCS was contacted by hundreds of members whose awards were not due to expire for several years because they thought the form’s expiration date was the date their award expired. We have not had this confusion with subsequent versions, which do not include the expiration date.

In addition, system constraints make it difficult to revise the hard-coded dates on the online versions in a timely manner, which may give rise to considerable confusion among members and institutions due to the display of a date indicating the ICR has expired.

 

 A18. Exceptions to the certification statement

No exceptions are requested

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