Supporting Statement DS3036 and DS3037

4

SUPPORTING STATEMENT FOR

PAPER REDUCTION ACT SUBMISSION

Recording, Reporting, and Data Collection Requirements Under 22 CFR Part 62, The Exchange Visitor Program -- Student and Exchange Visitor Information System (SEVIS); OMB No. 1405-0147, Forms DS-7000 (SEVIS), DS-3036, DS-3037.

A. JUSTIFICATION

1. The Bureau of Educational and Cultural Affairs of the US. Department of State (DOS) administers the Exchange Visitor Program (J-Visa) under the provisions of the Mutual Educational and Cultural Exchange Act of 1961 (MECEA), as amended (Public Law 87-256, 22 U.S.C. 2451 et seq.). This program enables U.S. Government agencies and public and private organizations to conduct a variety of educational and cultural exchange activities.

2. This collection of information utilizes the SEVIS electronic application (DS-7000) and two forms: DS-3036 - Exchange Visitor Program Application

DS-3037 - Update of Information on Exchange Visitor Program Sponsor.

The Exchange Visitor Program Application and the Update of Information on Exchange Visitor Program Sponsor provides a means for interested organizations to apply for designation by the Department of State to become a sponsor and to enable designated sponsors to keep the Department abreast of changes in their exchange program and to request DS-2019 Forms and brochures which are needed to administer their program. Without theses forms and the information they provide the activities conducted under the Exchange Visitor Program could not continue.

2. The Exchange Visitor Program Application (DS-3036) is used by United States Government agencies and public and private organizations to apply to the Department of State to become designated to administer an exchange program. Approximately 150 applications are received each year. The information provided is used to determine whether the interested organization meets the requirements to receive designation as a sponsor and, if approved, to create a database entry for tracking purposes. The Update of Information on Exchange Visitor Program Sponsor (DS-3037) is used by the approximately 1460 designated sponsors to notify the Department of any changes in the address, telephone numbers, fax numbers, etc. of the organization, and to request an allotment of forms, program brochures and changes in the Responsible or Alternate Responsible Officers appointed to administer the program.

3. The Department incorporated Forms DS-3036 and DS-3037 electronically into the Student and Exchange Visitor Information System (SEVIS) in 2003 when this system was put in place. SEVIS, an electronic data collection system, is administered by the Department of Homeland Security. It was developed to meet the legislative mandate established by Subtitle D, Section 641 of the Illegal Immigrant Reform and Immigrant Responsibility Act of 1996 (IIRIRA) (P.L. 104-208), and became operational in 2002 to collect and submit information on non-immigrants entering the United States on F, J, and M visas. Mandatory national implementation of the System began in 2003.

Because of the requirements for sponsors to provide originally signed or notarized copies of documents on the establishment and operation of their proposed exchange programs, the application process (Form DS-3036) is handled partly electronically and partly in paper form. The application form is completed on-line. This serves as a notification and tracking system for new applications. Once submitted on line, a paper copy of the complete application with all required signed and notarized documents must be sent to the Department in paper form. It is expected that when the collection of electronic signatures and official documents is in place in SEVIS, this process will also move to a completely electronic format. This will enable the Department of State to better serve the public and will reduce administrative and financial burdens for the reproduction costs and time necessary to collect and process information. The ability to provide information electronically has reduced the administrative and financial burdens on the1460 sponsors in notifying the Department of changes in their programs and in ordering forms and other supplies. It has also decreased the Department’s response time in serving the public.

4. There is one form per potential sponsor for the Application and approximately two forms filed by currently designated sponsors annually. This information is not otherwise available.

5. This collection does not have significant economic impact on small business entities.

6. If the collection of information is not conducted, the Department could not administer the Exchange Visitor Program. There would be no means to designate new sponsors or provide essential support to current sponsors to administer exchange programs.

7. There are no special circumstances for this collection.

8. The Department published a 60-day notice in the Federal Register to solicit public comments on February 26, 2007. We received one comment which addressed the overall Exchange Visitor Program and not the specific forms. As an application for designation, redesignation and amendment used solely by the Department, the Department does not consult with outside persons on the frequency of collection. Legislation mandates sponsors to apply for redesignation every two years.

9. Respondents are not provided with any gifts or payments.

10. The information collected on the business operations of an organization is considered proprietary and therefore determined to be confidential in nature.

11. There are no questions of a sensitive nature included in the data required.

12. The number of responses for the Form DS-3036 is approximately 150 annually. The respondents complete the form if they wish to be considered for designation as an Exchange Visitor Program sponsor. This form takes approximately one hour to complete and the annual burden is estimated to be 150 hours.

Form DS-3037 is used by designated sponsors to notify the Department of any changes in contact information for the sponsor and to request a change in Responsible or Alternate Responsible officers on their exchange program. This form takes approximately 20 minutes to complete. It is estimated that approximately 1460 respondents will submit 2 requests annually for a total 2,920 submissions. The annual burden for this form is approximately 973 hours.

Form DS-7000, the SEVIS Electronic Application, includes all Department record keeping, reporting and data collection information required under 22 CFR Part 62 and the many functions performed through SEVIS by program sponsors. A detailed breakdown of the respondents, number of responses, and burden figures are attached in table format. Please see Attachment 1 for a detailed burden accounting of data collection and reporting activities conducted through SEVIS. Please see Attachment 2 for Non-SEVIS recordkeeping and data collection activities. Respondents for this application include designated program sponsors, applicants (potential sponsors), host families, exchange visitors, foreign government entities, Congressional offices and U.S. medical facilities, yielding an estimated total of 190,200 respondents per year. The annual number of responses is approximately 1,620,375. The total aggregate annual hour burden is estimated to be 1,215,281 hours. The total annual cost to respondents is estimated to be, $20,569,070. The table below shows the aggregate burden figures for all requirements under 22 CFR Part 62.

Component	Respondents	Responses	Annual hour burden	Annual Cost burden
SEVIS	1500	23,530	17,646 hours	$168,620
Non-SEVIS	190,000	1,596,847	1,197,635 hours	$20,400,450
Totals:	190,200*	1,620,375	1,215,281 hours	$20,569,070

(* There is an overlap of respondents for SEVIS and Non-SEVIS component.)

13. Both Forms DS-3036 and DS-3037 are available on-line and are transmitted electronically to the Department. There is a filing fee of $799.00 for the review and evaluation of an application for designation as an Exchange Visitor Program sponsor (DS-3036). The estimated annual burden cost to respondents for this form would be $119,850 (150 x $799). This figure is included as part of the SEVIS burden in #12.

14. The cost incurred by the Department is the time of staff necessary to review and analyze requests and in maintaining information in office files and databases.
The estimated cost to the Federal Government is approximately $51,484.20. This estimate is based on the number of responses (DS-3036 – 150; DS-3037 - 2920), the average hourly processing time (DS-3036 - 4 hours; DS-3037 – 20 min.), and the average hourly salary (GS-13/5 $44.00; GS-9/5 $25.00). For Form DS-3036, 150 respondents times 4 hours equals 600, times $44.00, equals $26,400.00. For Form DS-3037, 2920 respondents times 20 minutes equals 973, times $25.00, equals $24,325.00. The printing costs equal $759.20 ($0.26 per response times 2920 responses). $26,400.00 plus $24,325.00 plus $759.20 yields a total cost burden of $51,484.20.

15. The change in burden hours reflects the addition of the category of intern and additional reporting of information and gathering of supporting documentation necessary for compliance with regulatory changes adopted in 1993 (22 CFR Part 62). The decrease in responses is a result of more accurate record keeping due to full implementation of the SEVIS system since the last submission, which also resulted in a decrease in cost burden.

16. The Department will not publish the collected information.

17. The Department will display the OMB expiration date.

18. The Department is not requesting any exceptions to the certification.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.