Emergency Memo

UNITED STATES DEPARTMENT OF EDUCATION

April 26, 2021
MEMORANDUM
TO:

Lindsay Abate
Office of Management and Budget Desk Officer

FROM:

Beatriz Ceja
Senior Director, Institutional Service

RE:

Emergency request for Paperwork Reduction Act (PRA) approval

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR
1320, ED requests that the following collection of information, Required Proprietary
Institution Certification Form, be processed in accordance with section 1320.13
Emergency Processing. ED has determined that this information must be collected prior to
the expiration of time periods established under Part 1320, and that this information is
essential to ED’s ability to effectively implement ARP and address the economic
disruption posed by the Novel (new) Coronavirus (“2019-nCoV”).
Section 2003(4) of ARP (ARP (a)(4)) 1 provides funding for proprietary institutions of
higher education (IHEs), to be used solely to make financial aid grants directly to students,
which may be used for any component of the student’s cost of attendance or for emergency
costs that arise due to the coronavirus, such as tuition, food, housing, health care (including
mental health care) or child care. This collection includes required certifications that must
be completed by proprietary institutions seeking funding under this section.
If this emergency collection is not approved, the Department will be unable to issue these
awards in a timely manner. Due to the heightened risk associated with proprietary
institutions, the Department has determined that it is necessary to obtain these additional
certifications prior to making further awards under the (a)(4) funding stream. Without
approval of the Required Proprietary Institution Certifications form, the Department will
be forced to delay making ARP (a)(4) awards to these institutions. Delay of ARP (a)(4)
awards would be particularly problematic, as Congress has designated these funds as being
solely directed to emergency financial aid grants to students at these institutions. Thus,
1

Because ARP section 2003(4) is governed in part by the Coronavirus Response and
Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260) section 314
(a)(4), we refer to this program herein as “ARP (a)(4)”.
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www.ed.gov
The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by
fostering educational excellence and ensuring equal access.

without emergency approval, many students will be left without funding to address key
financial needs, such as for emergency costs that arise due to coronavirus, or unmet
financial needs for food, housing, health care, mental health care, or child care. Delay of
funding to these students could contribute to the systemic increase in dropout and
withdrawals of college students that have taken place as a result of 2019-nCoV, having
life-altering impacts on the students who are forced to disrupt or permanently change their
educational plans.
Given the short timeframe, ED is unable to consult with the public prior to issuing the
form. However, ED has ample experience designing other similar forms in a way that is
clear and minimizes burden. We estimate that the form will require 30 minutes per
applicant to complete.
The Department is requesting an emergency clearance from OMB by May 7 and will
publish an emergency notice with a 60 day comment period as required by 5 CFR
1320.8(d) to solicit public comments on the regular information collection.

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