SSA Ed Award Final Rule

Corporation for National and Community Service (AmeriCorps)

Education Award Transfer Forms

OMB Control Number 3045-0136

Justification – Part A Supporting Statement

 

The National and Community Service Act as amended by the Edward M Kennedy Serve America Act, 25 U.S.C. 12501 et seq., (NCSA) establishes the National Service Trust, which is an account from which AmeriCorps pays education awards to eligible AmeriCorps participants (i.e., members) and interest on qualified student loans for AmeriCorps members during their terms of service in approved national service positions. The NCSA authorizes AmeriCorps members to transfer all or part of an education award, with limitations on who can transfer the award and who can receive the transferred award. This information collection is associated with a rulemaking and implements provisions of 42 U.S.C. 12604(f) concerning award transfers.

• This is a Revision to an Existing Collection. The currently approved information collection is due to expire on 1/31/2024.

• The forms used for this information collection are the following, but only the first two are affected by the changing regulation:

  • Transfer Application Form,

  • Award Transfer Acceptance Form,

  • Award Transfer Rescind Form, and

  • Award Transfer Revoke Form.

• Changes to the forms are:

  • Transfer Application Form:

    • State that an award may be transferred to no more than two individuals - this is a result of changing regulations, as the current regulations allow the transfer to only one individual,

    • State that a transfer may be declined in part or in full or revoked in part or in full - this is also the result of changing regulations, which allow part of an education award to be rejected, and

    • Delete the portion of the form requiring request of a waiver to re-transfer – changing regulations eliminate the need for a waiver to re-transfer.

    • Removal of a provision relating to individuals who began service after 2009 – no longer needed.

  • Award Transfer Acceptance Form:

    • Revisions to indicate that step-children and step-grandchildren may accept the transfer of an education award – changing regulations allow step-children and step-grandchildren to accept transferred awards.

• No changes to burden estimates are occurring.

• Respondents include AmeriCorps members who want to transfer or revoke the transfer of their education awards and transfer recipients who want to accept or rescind acceptance of the transferred education award.

1. Need & Method for the Information Collection

This information collection is necessary to identify when AmeriCorps members would like to transfer or revoke the transfer of their education awards, determine their eligibility to transfer the awards, determine whether the designated recipient is eligible to receive the transferred award and whether the recipient accepts the award and if they later rescind their acceptance.

2. Use of the Information

AmeriCorps uses these forms to verify members’ eligibility to request a transfer of an education award and the eligibility of the person designated to receive the transferred award, and to determine whether the person designated to receive the award accepts the award. If so, then AmeriCorps uses the information from the Award Transfer Acceptance Form to establish a Trust account for the transfer recipient. AmeriCorps uses the Award Transfer Revoke Form and Award Transfer Rescind Form to carry out members’ directions in situations where the members would like to revoke or rescind transfer of their education award.

 

 3.  Use of Information Technology

AmeriCorps accepts members’ and award transfer recipients’ responses electronically via the My AmeriCorps portal, AmeriCorps’ secure online member account management system. If members or award transfer recipients are unable to apply or respond on-line, they can use the hard copy forms and instructions to submit their application.

4.  Non-Duplication

There are no other sources of information by which AmeriCorps can meet the purposes described in response to Question 2 (above).

 

5.  Minimizing Burden on Small Businesses

This collection of information does not impact small businesses because they are not eligible to apply for or receive award transfers.

6.  Less Frequent Collection

 

The information is collected only at the initiation of AmeriCorps members or recipients. If this information collection were conducted less frequently, AmeriCorps would be unable to identify members who desire to and are qualified to transfer their awards or those who desire to and are qualified to accept transfer of the award in accordance with the provisions of 42 U.S.C 12604(f).

7.  Paperwork Reduction Act Guidelines

This collection does not involve any special circumstances that would require respondents to submit multiple copies of the document, retain records, or be conducted in any other of the listed manners.

8.  Consultation and Public Comments

AmeriCorps requested comments on this information collection as part of the proposed rule publication, at 88 FR 1021 (January 6, 2023), but received no comments in response. AmeriCorps also accepts input on an ongoing basis from any individual filling in the forms who would like to comment on any aspect of the form.

 

9.  Gifts or Payments

The agency is not proposing to provide any incentive (monetary or non-monetary) to potential respondents to obtain their information or to encourage respondents to provide the requested information.

10. Privacy and Confidentiality

Information provided by this collection will be held solely by AmeriCorps member, award transfer recipients, and AmeriCorps staff. Confidentiality of information supplied by respondents is ensured by the Privacy Act. A Privacy Act notice appears on the forms.

11. Sensitive Questions

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

12. Burden Estimate

The total number of respondents is 900 and includes AmeriCorps members and recipients of transferred education awards.

The estimated respondent burdens and labor costs are shown in the following table.

Estimation of Respondent Burden
Number of respondents	900
Responses per respondent (annually)	1
Number of responses	900
Hours per response	0.083333 (5 minutes)
Total estimated hours (number of responses multiplied by hours per response)	75
Cost per hour (hourly wage)	$58.72
Annual public burden (estimated hours multiplied by cost per hour)	$4,404

Note: The cost per hour is based on the Office of Personnel Management(OPM) General Schedule (GS) hourly rate of $43.10 for a GS-12, step 5, employee (for calendar year 2022 for the rest of the U.S.) plus the 36.25% civilian personnel full fringe benefit rate from OMB memorandum M-08-13 ($43.10 + $15.62 = $58.72, rounded to the nearest dollar).

Annual Responses and Burden with Changes:

	Requested	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
Annual Number of Responses for this IC	900	N/A	N/A	N/A	N/A	900
Annual IC Time Burden (Hour)	75	N/A	N/A	N/A	N/A	75
Annual IC Cost Burden (Dollars)	0	N/A	N/A	N/A	N/A	0

Burden per Response:

	Time Per Response	Hours	Cost Per Response
Reporting	5 minutes	0.0833333	0
Record Keeping	0	0	0
Third Party Disclosure	0	0	0
Total	5 minutes	0.0833333	0

Annual Burden:

	Annual Time Burden (Hours)	Annual Cost Burden (Dollars)
Reporting	75	0
Record Keeping	0	0
Third Party Disclosure	0	0
Total	75	0

13. Estimated Nonrecurring Costs.

This information collection does not impose any annual cost burden on respondents, as the respondents are members and recipients of transferred education awards that may complete the forms either online or by hard copy. No capital and start-up costs are expected.

14. Estimated Cost to the Government

The annual cost of this information collection to AmeriCorps is $3,708. This annual cost is salary expense for the AmeriCorps staff who assist respondents and process the requests for transfers, revocations of transfers, acceptances of transfers, and rescissions of accepted transfers. We estimate that approximately 3 staff will assist with these efforts. We are using an average GS-12 salary, Step 10 (similar to average of NY-4/NY-3) at $49.44/hour, and average of 25 hours/staff member.

The federal government employee salary information was obtained from OPM’s 2022 Salary Table for the Rest of the U.S. (RUS) at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2022/RUS_h.pdf and includes a 1.5 multiplier to account for the costs of benefits.

15. Reasons for Changes

AmeriCorps is updating its regulations regarding education awards and made substantive changes that affect the Transfer Application Form and Award Transfer Acceptance Form, but no change to responses or burden hours is expected.

16. Publicizing Results

AmeriCorps will not publish responses to this information collection.

17. OMB Not to Display Approval

AmeriCorps will display the expiration date of OMB’s approval.

18. Exceptions to “Certification for Paperwork Reduction Submissions”

There are no exceptions because this information collection:

• Is necessary for the proper performance of agency functions;

• Avoids necessary duplication;

• Reduces burden on small entities;

• Uses plain, coherent, and unambiguous language that is understandable to respondents;

• Will be implemented consistent and compatible with current reporting and recordkeeping practices;

• Indicates the retention periods for recordkeeping requirements;

• Informs respondents of the information called for under 5 CFR 1320.8(b)(3) about:

  • Why the information is being collected;

  • Use of the information;

  • Burden estimate;

  • Nature of response (voluntary, required for benefit, or mandatory);

  • Nature and extent of confidentiality; and

  • Need to display current valid OMB control number;

• 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;

• Uses effective and efficient statistical survey methodology (if applicable); and

• Makes appropriate use of information technology.

19. Surveys, Censuses, and Other Collections that Employ Statistical Methods

This request does not include surveys or censuses and does not use statistical methods.

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