Information Collection Package Submission Guidelines
- Process for Preparing an Information Collection Approval Package
- Guidelines for Preparing the Supporting Statement
Process for Preparing an Information Collection Approval Package
Every information collection approval request submission, whether for a new collection or to extend or revise an existing collection, must include two hard copies of the following.
Order of IC Package
* Emergency ICP Request Memo
- Completed OMB 83-I form
- Supporting Statement and Burden Grid
- Copy of any forms, surveys, scripts, screens, etc. used in the collection of information
- Copy of the 60-day Federal Register notice
- Copies of any pertinent statutes or regulations, which reference collection requirements or provide guidance on what or how information should be collected.
- Copies of any pertinent handbooks, manuals or other program instructional materials.
- Copies of reports
- 30-day Federal Register Notice
Additionally an electronic copy of the supporting statement should be included or e-mailed. A more detailed explanation of each item in a standard information collection request package is provided below.
Each information collection approval request package should include a completed OMB 83-I form (http://www.whitehouse.gov/omb/inforeg/83i-fill.pdf). All fields with the exception of field 9, Keywords, should be completed
All eighteen questions of the supporting statement should be answered in whole. It is not acceptable to take the responses to questions from previous submissions and cut and paste them in the new submission. OMB expects the response to each question to be well thought out and understandable by the average member of the public.
- If the agency is a partner in the Service Center Initiative a 19th question must be answered.
- If the collection involves statistical methods, Section B with an additional five questions must be answered.
Copies of the forms used to collect information should be provided. The form must include the OMB approval number and a standard burden statement as follows.
According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 05nn nnnn. The time required to complete this information collection is estimated to average ____ minutes/hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
A copy of the 60-day Federal Register notice must be attached. Reference to the date of publication and page number should be included in the response to question 8 of the supporting statement.
Any statutes or regulations discussing the Department's/Agency's authority to establish and/or collect information in conjunction with program operations must be provided. Any instructional, outreach or other materials relevant to the collection, its purpose, etc. would also be appropriate to include. If the collection is a result of a rulemaking action, the draft rule must be attached to the information collection.
The general chronology for preparing an information collection approval request submission varies from organization to organization depending on the number of reviews and other factors. In general, the first step is to publish your Federal Register notice. While you can talk in some generality in the abstract section of the notice, the estimate of burden and respondents needs to be fairly accurate. This means you may need to do some research prior to finalizing the notice in order to justify and have confidence in your estimates. Once the notice is published, a 60 (calendar) day period must pass.
During the 60-day comment period, you may be preparing your supporting statement and assembling the back-up materials (items 3-5). When the comment period concludes, you will need to document whether comments were received in the response to question 8 of the supporting statement.
When the package has been prepared and the OMB 83-I has been signed, the information collection approval request package is forwarded to the Information Management Division (IMD) within the Office of the Chief Information Officer (OCIO). A minimum of two weeks should be allowed for the review and processing of a package. After someone in OCIO signs off on the package, two copies are forwarded to OMB who then has 60 days to review and approve or disapprove the submission.
Guidelines for Preparing the Supporting Statement
The supporting statement of an information collection package consists of responses to 18 (sometimes 23) standard questions established by the Office of Management and Budget (OMB). The supporting statement is the heart of the package and serves as the formal mechanism for justifying the need and practical utility for imposing reporting and recordkeeping burden on the public.
The supporting statement is a public document and should be written in a manner that provides the average person with an understanding of why information must be collected from them and what use USDA will make of the information. The entire information collection package is entered into a docket library at OMB when it is submitted and is available to the public upon request for their review.
The guidelines provided in this document are meant to assist the author of a package in developing the supporting statement. Some general comments are offered as well as question by question guidelines. The standards that OMB is holding the Department to continually increase. By following the guidance below, an agency may minimize the delays in obtaining approval. However, as every information collection is unique in some way, there are no exact recipes or guarantees.
- All supporting statement responses should be written in plain English with acronyms, programs, organizations, etc. fully spelled out. No level of program understanding should be assumed. Remember these documents are for the public.
- Please do not use N/A as a response to any question. If you feel a question does not apply, answer appropriately in a full sentence. For example, a good response to the question:
- "Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees." would be:
- "There are no plans to provide any payments or gifts to respondents."
- While there are specific questions that must be answered, if it helps the reader understand the context around the information collection or, in the case of a revision, if regulatory or other program changes are the catalyst for the information collection package, an Introduction section may precede the actual questions and responses.
Justification (Questions and Responses)
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
The response to this question should cover the need for the information collection. Specific references to statutes, executive orders, regulations, notices, directives, or other relevant documents that the agency feels directs them to collect the information should be cited (and included as attachments to the package). After reading this response, the reader should have a full understanding of why the government must collect the information described.
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 bulk of the narrative in the supporting statement should go into the responses for questions 1 and 2. Question 2 must address the many characteristics of the information collection including:
- What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)
- From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.
- What will this information be used for - provide ALL uses?
- How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)?
- Does the respondent have multiple options for providing the information? If so, what are they?
- How frequently will the information be collected?
- Will the information be shared with any other organizations inside or outside USDA or the government?
- If this is an ongoing collection, how have the collection requirements changed over time?
Ultimately, the justification for collecting information must provide an explanation of the practical utility. Just because there is a need (refer to question 1) doesn't mean the agency has a definite plan for using the information. Furthermore, it is not acceptable to speak in broad terms when describing the use. For example, to say the collection of information is necessary to "ensure compliance" or "for program evaluation" is too general. Specific examples of how certain information will be used to determine compliance or what area of a program is being evaluated and how the information collected will enable that evaluation to occur is required.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The response to this question should address any automated or electronic methods (i.e., telephonic ordering, web-based applications) that are used, or are planned for use in the near future, to collect information. (Note: Facsimile transmission of information does not count toward the use of automated, electronic, or mechanical collection techniques.)
Specifically, the agency should address plans to offer an electronic alternative for respondents in conjunction with the Government Paperwork Elimination Act (GPEA). The response for the transaction should be consistent with the agency's plans to comply with GPEA as documented in its most recent GPEA Progress Report. If an agency does not currently offer an electronic alternative, a description of plans to move in that direction, with a timeline, should be included. If the collection is not being considered for electronic delivery, a detailed justification of this decision must be provided. A reference to the specific ongoing or planned initiative documented in the agency's eGovernment Tactical Plan should also be provided to ensure program activities are properly integrated with GPEA and other eGovernment plans.
Please note that forms or other collection instruments, and instructions for their use, that will be offered electronically on the Internet must be approved by OMB before they are posted. Copies of both the forms and the instructions should be included as attachments to the supporting statement.
The response to this question should be consistent with the information provided in field 13(b)(1) of the OMB 83-I form.
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.
The response to this question should address duplication of information collected from other sources within USDA, from other government sources, and from outside sources. If you think it might appear to the reader that the collection is duplicative of another collection effort, explain the circumstances that make the collection unique and necessary. If you are aware that information is collected elsewhere in the government (e.g., SSN) then the response should include a description of why it would be necessary to collect it from a member of the public again.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
The response to this question should be consistent with the information provided in field 5 of the OMB 83-I. If there are special provisions related to the information collection that affect small businesses, please describe those in this response.
6. Describe the consequence 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.
The response to this question should address the impact on the agency's mission if the collection is not conducted or is conducted less frequently. This explanation may include justification such as an inability to deliver program benefits, an inability to measure agency progress against Government Performance and Results Act (GPRA) performance objectives (state the specific objectives), or the timely implementation of a new program.
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 that 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 which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
- requiring respondents to submit proprietary trade secret, 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.
The response to this question should include an answer for each of the eight subparts. Please do not indicate "N/A" for any response. Rather, answer appropriately in a full sentence. If the answer to any subpart is "yes", then a full explanation of the circumstances surrounding the collection should be provided.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, 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.
The response to this question should include a full citation for the 60-day Federal Register notice and include a specific statement as to whether any comments were received. If comments were received, they should be enumerated along with an explanation of what response the agency took to the comments. It is helpful to attach copies of the correspondence, or other mechanism of communication, received from the public.
The response should also include a reference to three individuals or organizations who are either respondents or interested parties in the collection that have been consulted about the burden estimate and other characteristics (i.e., frequency, clarity of instructions) of the collection. The reference should include a phone number for OMB to use in case contact with the public is desired. This requirement especially applies to collections which have been ongoing for more than three years.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
If the agency plans to provide a payment or gift to respondents a thorough explanation, including justification for this action, description and monetary value of the item, and basis for the decision to take such action must be provided.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
If the agency has unique confidentiality policies or other privacy policies apply, they should be cited and discussed in terms of what protections will be provided to respondents.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This 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.
This question pertains primarily to issues of race/ethnicity, disability, and other private issues such as social security number. It is not impossible to obtain OMB approval to collect this type of information, but the explanation for what it is needed for and how it will be used (reflecting back to the response to question 2) must be very sound. For information collections involving questions of race/ethnicity, the agency should ensure that the OMB Standards for the Classification of Federal Data on Race and Ethnicity are followed. Furthermore, reflecting back to the response provided in question 4, an explanation of why the agency cannot obtain the desired information - such as SSN - from another source should be included.
12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.
This is a two part question and both parts must be addressed.
A) Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
This response must be detailed enough for the reader to understand how the agency developed the burden estimates - e.g., sources of data, changes in program requirements. It is not necessary to indicate collection instrument by collection instrument how the estimated response time was derived; however, a general statement on how those numbers were developed is necessary. Whenever there is more than one source of burden - i.e., multiple forms, surveys, recordkeeping requirements - the agency should use a burden table or grid to show the burden estimate for each collection requirement (forms or non-forms). At a minimum, the table or grid should include columns for:
- description of the collection activity,
- corresponding form number (if applicable),
- number of respondents,
- number of responses annually per respondent,
- total annual responses (columns c x d)
- estimated hours per response
- total annual burden hours (columns e x f)
Only the columns corresponding to the number of annual responses and the total annual burden hours should be totaled. NOTE: The number of respondents affected by the collection (and recorded in field 13(a) of the OMB 83-I) does not equal the sum of the number of respondent's column. The number of respondents is the actual number of individuals the collection is estimated to impact in a given year.
Recordkeeping burden should be addressed separately and should include columns for:
- description of recordkeeping activity,
- number of recordkeepers
- annual hours per recordkeeper
- total annual recordkeeping hours (columns b x c)
In calculating a total burden amount, the total annual burden hours should be summed with the total annual recordkeeping hours.
In developing burden estimates, there are several considerations which should also be taken into account.
- In complex collections, the burden estimate may need to be calculated separately for different categories of respondents (e.g., loan applicant versus a bank versus an appraiser or the public and a contractor performing a survey for an agency). A single grid can still be used for this, but some narrative should be provided to describe the burden estimation approach used for each group of respondents.
- The burden estimate may need to account for different methods of collecting the same information. For example, if a form previously (and currently) available in hard copy format is now available on the Internet and the capability also exist to submit the information to the agency electronically, then separate burden calculations for submission of the same information should be included to reflect the different time requirements associated with each method of collection. This can also be included, with proper notations in the description column, in the same table or grid, as long as detailed narrative explaining the duplication is provided in the response.
- If the agency does not offer other methods for reporting required information other than physically visiting a field or headquarters office, then the agency must include round trip travel time in the burden estimate. If multiple collection options are offered, then travel time should be calculated for only the percentage of responses that the agency feels will result from a physical visit to an office.
B) Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.
The estimate of annualized cost to respondents is a theoretical cost accounting for the idea that the respondent's time spent complying with the information collection request is worth something - i.e., time is money. The total burden hours should be multiplied against an average hourly wage rate for the respondent universe. Minimum wage may be used, but only if that wage is reasonable for the class of respondent affected. An explanation of the wage rate used should be provided and the source, if applicable, cited. If multiple respondent groups exist, then the burden hours for each group should be factored against an appropriate hourly wage rate and summed.
13. Provide estimates 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 estimates 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.
While the response to part two of question 12 dealt with a theoretical cost of the respondent's time, this question and its response should address the ACTUAL cost a respondent must bear as a result of the information collection. In most situations, this will be zero; however, the agency should consider all aspects of the information collection to determine if any equipment, software, or services must be procured by the respondent in order to provide the agency with the information requested.
If the agency does not feel there are any costs of this nature, the following response should be provided.
"There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection."
14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.
The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:
- employee labor and materials for developing, printing, storing forms
- employee labor and materials for developing computer systems, screens, or reports to support the collection
- employee travel costs
- cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information
- employee labor and materials for collecting the information
- employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information
This information is best summarized in a table or grid. When costs for employee time are being described, a separate table or grid entry should be noted for each different grade/step category involved in the collection activity. For example, if a GS-11 field employee spends 15 minutes processing an application and a GS-13 analyst at headquarters spends 30 minutes evaluating the application before approving or disapproving the request, these two separate activities and the associated time/costs should be calculated separately.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.
This response should address any changes from the previous approval of the collection. If no changes have been made then the following statement would be appropriate.
"There are no changes to the information collection since the last OMB approval."
If there are changes, then either a summary of those changes or a table describing each change should be included. The response should be detailed enough for the reader to track the reason for changes from the previously approved burden amount to the current burden request. Changes must be described as either 1) program changes - changes that were implemented proactively by the agency (e.g., a regulatory change which eliminated or added reporting/recordkeeping requirements; a change in frequency of collection; a change in the method of collection) regardless of whether or not the changes were directed by legislation or 2) adjustments - changes due to things not necessarily in the agency's control (e.g., a change in the number of respondent, a change in program funding levels) or changes in the burden estimation approach (e.g., addition of a form currently in use, but not previously approved; a change in a burden estimate, changes due to previous miscalculations in the burden estimate).
If the information collection approval request is a reinstatement, then the current approved burden will be zero. The change in burden reflected in field 13(e) of the OMB 83-I should represent the entire burden request (carried down from field 13(c) of the OMB 83-I). This amount represents a program change because the agency is reinstating the collection. The response, however, should also include additional narrative to explain the changes, if any, in the collection between the current burden request and the last approved burden amount. In preparing this portion of the response, the guidelines in the previous paragraphs should be followed.
16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.
If the agency plans on performing certain analyses and developing statistics, reports, or other items summarizing the results of the collection activity, the response should describe each of these plans including a timeframe for development and publication. The response should clearly state whether the information will be distributed internally or externally.
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.
Before responding to this question, the author should determine whether the agency plans to include an expiration date of the information collection approval on the form. This is not to be confused with other dates printed on the form such as the form creation date or the last revision date.
If the agency prefers not to print the expiration date of OMB approval, then a statement such as the one provided below should be included followed by an explanation of why the agency feels it would be inappropriate to display the expiration date.
"The agency is seeking approval to not display the OMB expiration date on the (forms/surveys/questionnaires) associated with this information collection."
If the agency does plan to print the expiration date of OMB approval on all forms/surveys/questionnaires, then a statement such as the one below would be appropriate.
"The agency plans to display the expiration date for OMB approval of the information collection on all instruments."
18. Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."
A. Certification Statement
The certification statement is provided on the second page of the OMB 83-I. The author of the information collection supporting statement and the signor of the OMB 83-I should read the statement provisions to ensure that there are no exceptions. If there are exceptions, a detail justification of each should be provided.
If there are not exceptions to the certification statement, the following response would apply:
"The agency is able to certify compliance with all provisions under Item 19 of OMB Form 83-I."
B. Collections of Information Employing Statistical Methods
The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked "Yes", responses to the following questions should be included in the Supporting Statement to the extent that it applies to the methods proposed. If there are no statistical methods involved, a response stating this should be provided. NOTE: All information collections involving surveys or questionnaires, regardless of whether or not statistical methods are used, is subject to a review by the National Agricultural Statistics Service (NASS). NASS is viewed by OMB as an in-house source of expertise in survey development, sampling frame development, and survey methods. Their suggestions and comments should be strongly considered in preparing the information collection approval request. Please coordinate with Ginny McBride (720-5778) of that agency to arrange for this review to occur prior to submitting the information collection for agency and Departmental processing.
1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.
The response should describe the respondent universe and how that universe was or will be selected. The method of sampling should also be explained. With respect to the response rate, the narrative should cover the actual percentage response rate that is anticipated. Collections anticipating a response rate less than 75% will not be forwarded to OMB. Additionally, the agency should describe the efforts that will be undertaken to ensure a high response rate including pre-survey telephone calls or correspondence, post-mailing reminders, etc. If correspondence will be used to boost the response rate, copies of all letters, telephone scripts or other materials should be included in the package. If the collection has been conducted previously, then a summary of that activity should be provided including the response rate achieved.
2. Describe the procedures for the collection of information including:
- Statistical methodology for stratification and sample selection,
- Estimation procedure,
- Degree of accuracy needed for the purpose described in the justification,
- Unusual problems requiring specialized sampling procedures, and
- Any use of periodic (less frequent than annual) data collection cycles to reduce burden.
The response should include an answer to each of the subparts of this question. Where the collection is considered ongoing - i.e., has been conducted previously and is continuing for the foreseeable future - a description of any changes that have been made in the procedures or statistical methodology of the collection since the last approval should be discussed.
3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.
This question is somewhat redundant to a portion of question B1. The response to B1 can be repeated for this question; however, a more thorough discussion of what the agency's plan of action for dealing with non-response must be provided. If the collection is categorized as qualitative and does not necessarily employ a sampling frame or other proven statistical methods, then an explanation of exactly what practical utility the collection will have for the agency must be discussed. This discussion should include a listing of the specific uses the agency will plans for the data collected.
4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.
The response should fully describe any planned tests of the collection including who is in the test sample, how they were chosen, what evaluation criteria for the test will be or were used, and specific comments from the participants of the test. If applicable, a summary of how the collection instrument or statistical methods were changed as a result of the test phase should be provided.
5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.
Include all individuals who have contributed to or commented on the survey, sample frame, statistical methods or other aspects of the collection. Make sure that the representatives of NASS are referenced or the submission will be returned to the agency for this review to occur.