SUPPORTING STATEMENT FOR REQUEST FOR OMB
APPROVAL UNDER THE PAPERWORK REDUCTION ACT AND 5 CFR 1320
A. Justification
Circumstances of the Information Collection: Pursuant to 28 C.F.R. § 0.15, the Deputy Attorney General of the United States Department of Justice has the responsibility for administering the "Attorney General's recruitment program for Honors law graduates and judicial law clerks." This includes hiring third-year law students, graduate law students and judicial law clerks for full-time employment following graduation or completion of a clerkship, and primarily second-year law students for summer employment. This program has been in existence for 51 years and is considered the Federal Government's premier legal recruitment program. The Department of Justice hires approximately 130 third-year law students/graduate law students/judicial law clerks and 100 second-year law students through these programs each year. The Department of Justice is the largest legal employer in the country and receives approximately 5000 applications for these positions annually.
The Deputy Attorney General has delegated the responsibility for administering these programs to the Director, Office of Attorney Recruitment and Management (OARM), pursuant to 28 C.F.R. § 0.15(c) and 0.15(e). OARM, together with Department representatives who make the ultimate hiring decisions, has designed and developed electronic applications, submitted through the Internet, for both the Attorney General’s Honors Program (Honors) and Summer Law Intern Program (Summer) to collect the information considered essential to make informed hiring decisions about applicants. This information is collected for in-house use only. Any identifier (e.g., Social Security number) is collected only to prevent duplicate applications or to prevent any one candidate from apply to both Programs at the same time. (A candidate who is eligible to apply to one Program is not eligible for the other.) Use of such an identifier also ensures that candidate information can only be accessed by that candidate. Race/Gender/National Origin information and identification of a disability are collected on a volunteer basis and are eliminated from the application before it is forwarded to the components that are considering the candidate for employment. Disability information is used to make appropriate accommodations for individuals’ who need such accommodations (e.g., sign interpreters for the deaf).
2. Purpose and Use of the Information: The electronic applications provide detailed instructions for completing the applications and explain specific Program requirements. The instructions provided on the applications also include eligibility criteria, Program deadline dates, and interview information. The OARM web page (www.usdoj.gov/oarm) provides substantive information about each of the Programs, including an “Application Checklist” for both the Honors and Summer Programs, that explains what information an applicant will need when he/she completes his/her application. Provision of this detailed information provides an educational tool for candidates and greatly reduces the number of telephone inquiries to OARM for program details, resulting in substantial savings of OARM staff time.
The electronic applications consist of form fill-able screens on which the applicant provides information about his/her participation in law school activities/components (e.g., law review, moot court, special awards, and class rank). If the applicant is a judicial law clerk or a graduate law student, he/she must provide specific information about the clerkship or graduate law program. The applicant also lists a supervisor’s name, organization/firm, and telephone number for all past and present legal employment. This is crucial since reference numbers are not included in the resume builder section of the application, and components must make telephone reference checks before extending an offer of employment.
These applications are vitally important to the Department. The Department employs many more attorneys than any other federal agency. Consequently, recruiting and hiring the highest caliber legal staff is of the utmost importance. The Department's chief competitors for the nation's best legal talent are the country's finest private law firms and corporations. In order to be competitive with private-sector employers, we must operate within similar recruitment time frames. This dictates that the programs have an early deadline date, typically in mid-September each year - a month after most law schools begin their academic year. To encourage the maximum number of applicants to the program, it is crucial that the Department has an application form that provides the concise information needed to evaluate the thousands of applications it receives each year in a timely manner.
There is no existing source for collecting the information requested on the application. For example, resumes do not always provide the information needed to determine if a candidate is eligible. In addition, resumes do not follow a standard format that allows for swift review or data input of the information on the application. (The input of certain data from the application is critical to the successful operation of the Programs. This data generates status/rejection e-mails for each applicant and numerous statuses and statistical reports for the Department.)
Standard Forms (SF) 171 and (OF) 612 do not lend themselves to collection of the information needed by a legal employer. For example, class rank, participation in law review, participation in moot court or legal clinical programs, current classes, volunteer activities and externships do not logically fall into any existing SF-171 or OF-612 category. The depth of information needed by a legal employer would not be available for all applicants. Many excellent applicants would be overlooked, or disadvantaged in conveying their unique qualifications. Furthermore, much of the SF-171 and the OF-612 information is irrelevant to a legal employer. Determining an applicant's eligibility based on an SF-171 or OF-612 would result in a cumbersome, if not impossible, review process.
OARM reviews application to make certain that applicants are eligible before forwarding the applications to the participating components. (This fall, OARM reviewed approximately 5000 Honors and Summer Program applications in less than one and one-half weeks.) The electronic application designed by OARM lends itself to the efficient evaluation of each application to ensure that the candidate is eligible, as well as to accurate and efficient data transfer. The application solicits the necessary information while streamlining the process, thereby encouraging the largest pool of applicants possible.
After OARM reviews the applications, the components participating in the programs conduct a more detailed screening to select applicants for interviews. Since this review process requires some subjective determination, more organized information leads to more informed decisions. These decisions must be made in a very short time to allow OARM and the Conference Center Staff sufficient time to schedule the interviews. Anything that slows down the screening, processing or scheduling of interviews seriously undermines the Department's ability to compete for the nation's top law students. This information is collected for in-house use only. Any identifier (e.g., Social Security number) is collected only to prevent duplicate applications or to prevent any one candidate from apply to both Programs at the same time. (A candidate who is eligible to apply to one Program is not eligible for the other.) Use of such an identifier also ensures that candidate information can only be accessed by that candidate. Race/Gender/National Origin information and identification of a disability are collected on a volunteer basis and are eliminated from the application before it is forwarded to the components that are considering the candidate for employment. Disability information is used to make appropriate accommodations for individuals’ who need such accommodations (e.g., sign interpreters for the deaf).
If an Honors Program candidate is selected for an interview(s) with one or more participating component, the candidate travels to Washington, DC for his/her interview (approximately 600 annually) at the Department’s expense. In order to obligate the costs of the candidates travel, M&IE, and/or hotel accommodations so they may be reimbursed, the Department is required to prepare travel authorizations for each candidate; hence, candidates selected for interview must complete a Travel Survey form. The principal purpose for collecting the information on this form is to prepare the authorization, schedule travel and/or hotel accommodations and schedule to interview(s) during a three week period (last week of October, first two weeks of November. Disclosure of the of the Social Security Number is mandatory because it is required for the travel authorization form. The use of the Social Security Number is necessary to distinguish candidates who have identical names and whose identities may only be determined by the Social Security Number. This form is provided on our web site.
In order for the Department to reimburse candidates for expenses incurred while traveling to their interview, candidates must complete a Reimbursement Form. The principal purpose for collecting the information of this form is to reimburse travel, M&IE, and/or hotel accommodation expenses. The information collected on the form is necessary to match it to the candidate’s travel authorization and the required documentation submitted by the candidate. The use of the Social Security Number is necessary to distinguish candidates who have identical names and whose identities may only be determined by the Social Security Number. This form is provided on our web site.
Use of Automated, Electronic, Mechanical or Other Technological Collection Techniques: In the fall of 2002, OARM introduced a fully electronic data collection system. Candidates enter information pertinent to legal employment (e.g., class rank, participation in law review, moot court or legal clinics, undergraduate major) on 14 electronic screens. The data is then certified and submitted into a database for OARM review and transmission to the components that consider the candidates for legal employment. The candidate is automatically notified by e-mail that his/her application has been received when he/she certifies and submits his/her electronic application.
Efforts to Identify Duplication: OARM is the only office within the Department that collects this data.
Impact on Small Business and Small Entities: There is no impact on small business or entities.
Consequences if Information is Collected Less Frequently: The Honors and Summer Law Intern Programs are only conducted once per year. It is the only way the Department hires entry-level attorneys. Students hired under the Summer Program may be "funneled" (hired directly after serving as a Summer Law Intern) into the Honors Program. Thus, this Program is equally vital to the Department. To eliminate this once-a-year cycle would eliminate one entire year of entry-level attorney and law student hiring, seriously curtailing the effective operations of the Department's litigating divisions. The Department depends on these programs to hire the high caliber attorneys required to conduct the Department's important legal work.
Special Circumstances: There are no special circumstances identified in the instructions that apply to this information collection.
Outside Consultation: There have been no 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 record keeping, or reporting format, and on the data elements to be recorded, disclosed, or reported. No other agency runs a recruiting or hiring program comparable to the Department's program.
Moreover, it must be again stressed that this application form is: (1) submitted voluntarily; (2) submitted only once a year by students/judicial law clerks who will be in this applicant pool only once; and (3) the information sought only relates to the hiring criteria established as an internal matter by Department of Justice (DOJ) personnel. Full consultation has been made with DOJ legal personnel on the data to be recorded, disclosed, or reported.
9. Payment or Gift: There will be no payment or gift to the respondents.
Assurance of Confidentiality: There are no assurances to the respondent since submission of this information is entirely voluntary. However, identifiers (e.g., Social Security number) are collected only to prevent duplicate applications or to prevent a candidate from applying to both Programs and to obligate/reimburse candidates for travel expenses. It also allows the candidate to access his/her information during the course of the hiring process.
Justification for Sensitive Questions: The application does not pose questions of a sensitive nature except for the request that the applicant identify personal characteristics, i.e., gender, race/national origin, disability status (if applicable). It is made clear to the applicant that the provision of this information is entirely voluntary, and that the information will be used by OARM to compile Program statistical data.
Estimates of Hour Burden: Applications to the Department's Honors and Summer Law Intern vary from year to year. We received approximately 5000 in 2006. The demand for law school graduates in the private sector has not affected the quality of candidates applying to the Department’s hiring programs. The Department continues to attract a significant number of high caliber applicants to the programs compared to the number of positions available.
In 2006, approximately 3000 candidates applied to the Honors Program, and approximately 2000 candidates applied to the Summer Program. As stated in the “Public Reporting Burden” on both applications, it is estimated that the electronic application takes approximately 15-20 minutes to complete and submit. It is further estimated that it takes an average of an additional 45 minutes to review the instructions, search existing data sources, gather and maintain the data needed, and complete and review the information collected. This is an ample time estimate, based upon a sample respondent survey. In addition, approximately 600 applicants will complete the Travel Survey and the Reimbursement form. Each form will take approximately 10 minutes to complete. Thus, the annual burden would be 5200 hours based on 5000 applicants (the average number of applications received in the last five years) x 1 response hour (estimated time to collect the appropriate information and complete the Program application) and time 200 hours for 600 candidates to complete two additional forms x 20 minutes (10 minutes for each of the forms).
13. Estimates of the Total Cost Burden: There are no costs to the respondents since the data is collected electronically.
Estimate of Annualized Cost to the Federal Government: The annualized cost to the Department for the electronic applications is approximately $54,000. This consists of $31,000 paid to Avue Technologies Corporation for the development and management of the electronic application and data system and $23,000 in man hours to review and process of the applications received.
Program Changes or Adjustments: This is a program change resulting from an agency action to extend the information collection for another three years.
16. Publishing Information: This information is used internally for hiring entry-level attorneys and legal interns and will not be published.
Display of Expiration Date for OMB Approval: OARM will display the OMB number and expiration date on the instructions and on the electronic application.
Certification for Paperwork Reduction Act Submission: OARM is not seeking any exception to the certification statement identified in Item 19 of the OMB Form 83-I.
Collections for Information Employing Statistical Methods: This information collection does not employ statistical methods.
_________________________________________________________________
Louis DeFalaise
Director, Office of Attorney Recruitment and Management
Authorizing Official
| File Type | application/octet-stream |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |