Rachel,
This is in reply to your January 10, 2007 e-mail
to Katrina Ingalls concerning the FFELP Consolidation Loan Application and
Promissory Note (OMB #1845-0036).
#1 (number of responses for the Loan
Verification Certificate). The Department has reviewed your comments and
we agree that the math used in #12 of the Supporting Statement is probably
incorrect, and is also unnecessarily complicated. (The same calculation
was used in previous submissions for the Direct Consolidation Loan Application
and Promissory Note forms and was simply carried over here.) If we are
simply trying to determine the average annual reporting hour burden for the Loan
Verification Certificate, then it seems to us that the simplest approach would
be to multiply the total number of LVCs (2,943,000) by the time needed to
complete an LVC (0.15 hours). This results in a total annual reporting
hour burden of 441,450 hours. This is very close to the result obtained by
using the average number of responses as determined by your option (a) in the
formula shown in the supporting statement:
7,000 respondents x 420
average respondents x 0.15 hours = 441,000 total hours
I will update #12
in the supporting statement to reflect a revised calculation of the burden for
the LVC using your option (a). I will also update the
83-I.
#2 (SSA verification). The planned agreement with SSA is not
expected to be implemented for at least two years. Therefore, we will
delete the borrower authorization related to SSA verification.
Finally,
please note that we received comments from NCHELP and Texas Guaranteed during
the 30-day comment period for this collection. We have tentatively
accepted the majority of the form changes that were suggested and are now
waiting for our Office of the General Counsel to give final approval of these
changes. Once I have approval from OGC, I will provide you with copies of
the comments, our responses, and the final revised forms. I hope to be
able to provide these documents no later than next week.
Please let me
know if you have any questions.
Jon Utz
Policy Liaison and
Implementation
Federal Student Aid
U.S. Department of
Education
-----Original
Message-----
From: Ingalls, Katrina
Sent: Thu
1/11/2007 9:59 AM
To: Utz,
Jon
Cc: Ingalls, Katrina; Axt,
Kathy
Subject: FW: Problem with
FFELP Consolidation App & Promissory Note #1845-0036
Jon,
Here
are the OMB comments on your package. Please get responses back to Rachel as
soon as possible. Unless you disagree with Rachel's suggestion on #1,
please change the supporting statement part A (and 83I) accordingly and send
Rachel and me the revised supporting statement. (I would ask that you
update Edics with the changes also when they are completed.) Call if you
have questions. Thanks.
Katrina
-----Original
Message-----
From: Potter, Rachel F. [mailto:Rachel_F._Potter@omb.eop.gov]
Sent:
Wednesday, January 10, 2007 5:49 PM
To: Ingalls, Katrina
Cc: Arrington,
Angela; Axt, Kathy
Subject: RE: Problem with FFELP Consolidation App &
Promissory Note #1845-0036
Katrina -
Attached below are two
OMB comments on this collection. As soon as we receive your responses, we
can conclude review.
1. The number of responses for the Loan
Verification Certificate is currently an average of the average number of
responses for the top 5 lenders (approximately 382,570 responses each) and the
other lenders (approximately 147 responses each). I believe that the
math is incorrect here, because rather than averaging the two responses here you
then sum them and divide by 7,000 again. The average number of responses
should be either:
a) the total number of responses (2,943,000) divided by
the number of respondents (7,000). This would result in 420 responses.
OR
b) a weighted average of the responses by type of lender, which would
result in 124,361 responses. [((.65*382,570)+(.35*147))/2=124,361]
Given
the large disparity in responses, the weighted average is probably more
appropriate. Please update the supporting statement to reflect the change
to the table and to the burden. You will also need to update the burden in
ROCIS.
2. The Department has rejected NCHELP's suggestion that
the following language be deleted from the form: "
H. I authorize the
Department and its agent(s) to verify my Social Security Number with the Social
Security Administration (SSA) and if the number on my loan record is incorrect,
then I authorize SSA to disclosure my correct Social Security Number to these
parties.
What is the status of ED obtaining an agreement with SSA to
conduct this verification? Please provide an estimated date when ED plans
to begin conducting this verification. It is not appropriate for the Dept.
to obtain this authorization unless this activity is not imminently
pending.
_____
From: Ingalls, Katrina [mailto:Katrina.Ingalls@ed.gov]
Sent:
Tuesday, January 09, 2007 1:14 PM
To: Potter, Rachel F.
Cc: Ingalls,
Katrina; Arrington, Angela; Axt, Kathy
Subject: FW: Problem with FFELP
Consolidation App & Promissory Note #1845-0036
Rachel,
I
wanted to follow up with you on the status of the review of this
collection. As you will recall, there was a problem with the certification
page not being complete and we had to resubmit this on the 13th of
December. I am still puzzled about how this happened - but I want to check
with you to see what timeframe you anticipate for clearance of this package -
given the circumstances (and the fact that the package was over at OMB for 60
days on 12/26/06). Do you consider that 12/13 is the beginning of the 60
days allocated to OMB - or are you able to shorten the review somewhat given the
circumstances? I know that the program will be anxious for clearance as soon as
possible for this form. Please let me know when we might expect your comments on
this package. Thanks.
Katrina
-----Original
Message-----
From: Ingalls, Katrina
Sent: Wednesday, December 13, 2006
12:17 PM
To: 'Potter, Rachel F.'
Cc: Arrington, Angela; Rudolph, Kim;
Ingalls, Katrina; Axt, Kathy
Subject: RE: Problem with FFELP Consolidation
App & Promissory Note #1845-0036
Rachel,
I cannot
understand how this could have happened since I have a copy of the certification
page that I copied off when I completed the collection and the certification was
complete. At any rate, I have just completed the collection again under
ICR Ref. NO 200612-1845-001and it will be resubmitted today as soon as Angela
gets a chance to sign off on the package.
Thanks.
Katrina
-----Original Message-----
From: Potter,
Rachel F. [mailto:Rachel_F._Potter@omb.eop.gov]
Sent:
Tuesday, December 12, 2006 5:33 PM
To: Ingalls, Katrina
Cc: Arrington,
Angela; Rudolph, Kim
Subject: Problem with FFELP Consolidation App &
Promissory Note
Katrina,
In reviewing 1845-0036, it has
come to my attention that Education has not completed the necessary
certifications for this collection - see screenshot below. At this point,
this is not an edit we (or you) can make in ROCIS and our only option is to
return this collection to you as improperly submitted. Fortunately, the
expiration date for this collection is 12/31/06, so if you immediately resubmit
the collection to us, Education will not be at risk of either incurring a
violation or being forced to stop collecting the information.
We
are looking into whether future upgrades to ROCIS will force the agency to
certify before submission is even possible, but at this point we have been asked
to manually review every collection for incomplete certifications. Let me
know if you have any
questions.
Rachel
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