Justification for Change

JUSTIFICATION FOR CHANGE

The proposed changes are outlined as follows for the DSS Form 232

(DSS uses web-based system to collect information):

Change 1

Personnel Security Investigation (PSI) projections totals will be collected for a three year period (e.g., 2009, 2010, and 2011) instead of a five year period through a web-based system.

Section A Section B

Facility Name DoD Component Projections

Facility Security Officer Fiscal SSBI Secret Secret PR Conf Conf PR

(FSO) Name Year

FSO E-mail Address 2009

CAGE Code 2010

2011

Section C Non-DoD Component Projections

General Comments: Fiscal SSBI Secret Secret PR Conf Conf PR

Comments concerning FY 2009: Year

Comments concerning FY 2010: 2009

Comments concerning FY 2011: 2010

2011

Trustworthiness Investigation Projections

Fiscal SSBI NACLC NAC

Year

2009

2010

2011

OMB No.: 0704-0417 Expiration Date: 03/31/2008

The public reporting burden for this collection of information is estimated to average 80 minutes 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.

Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden to Department of Defense, Washington Headquarters Service, Executive Service Directorate, Information Management Division (0704-0417), 1155 Defense Pentagon, Washington, DC 20301-1155. Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply if a valid OMB control number is not displayed.

Section A will be pre-populated with specific facility data elements and only if incorrect, will the respondent provide any response.

Section B, the respondent will select the DoD components/non-DoD components requiring clearance (see change 2 below) and then provide for each DoD component/non-DoD component their best numeric projection estimates for 2009-2011 by type of personnel security investigation.

For trustworthiness investigations which require background investigations, but not for clearances, the respondent will provide their total numeric estimates for 2009-2011. The respondent will not be asked to identify the DoD or non-DoD components (government customer) for the trustworthiness investigations.

The respondent will also be asked to select all that apply from a list of data elements to describe the methodology/data source the respondent used for his/her estimates (see change 3 below).

Change 2

a. Respondents will select all that apply from a list of DoD components and a list of non-DoD components that are a primary government contract activity or government customer for the PSI requirements for their respective cleared facilities.

“Select All That Apply” List of DoD Components (or their subordinate elements) for which the Respondent has Clearance Requirements

DARPA - Defense Advanced Research Projects Agency

DCAA - Defense Contract Audit Agency

DCMA - Defense Contract Management Agency

DIA - Defense Intelligence Agency

DISA - Defense Information Systems Agency

DLA - Defense Logistics Agency

DSCA - Defense Security Cooperation Agency

DSS - Defense Security Service

DTRA - Defense Threat Reduction Agency

MDA - Missile Defense Agency

NATO - North Atlantic Treaty Organization

NGA - National Geospatial Intelligence Agency

NSA - National Security Agency

OSD - Office of the Secretary of Defense

U.S. Air Force

U.S. Army

U.S. Navy

U.S. Marine Corps

Other DoD – (all other DoD activities)

“Select All That Apply” List of Non-DoD Components (or their subordinate elements) for which the Respondent has Clearance Requirements

Dept of Agriculture

Dept of Commerce

Dept of Education

Dept of Health and Human Services

Dept of Homeland Security

Dept of Interior

Dept of Justice

Dept of Labor

Dept of State

Dept of Transportation

Dept of Treasury

Environmental Protection Agency

Federal Communications Commission

Federal Reserve System

Foreign Government

Government Accountability Office

General Services Administration

National Aeronautics and Space Administration - NASA

Nuclear Regulatory Commission

National Science Foundation

Small Business Administration

U.S. Agency for International Development

U.S. International Trade Commission

U.S. Trade Representative

Other Non-DoD (only if they come under one of the existing agency agreements under the National Industrial Security Program with DoD above)

b. Respondents will then provide their best numeric estimate of the PSI projections for the respective DoD or non-DoD components that they selected (see change 1 above).

This change is needed as this is one indicator of many used in determining reimbursable PSI expenses.

Change 3:

a. Respondents will select all that apply from a list of choices for the methodology/data sources they used to make their PSI projections. Respondents will also be able to provide text comments.

“Select All That Apply” List of Methodologies Used to Make Projections

Average over a 3 year period

Average over a 5 year period

Current contracts requiring cleared personnel

Projected contracts requiring cleared personnel

Historical business data for this company

Projected business plan data for this company

Strategic plan for this company

Human Resources / Personnel data

Statistical modeling

Other

DSS is asking for the methodology/data sources to provide a better understanding of how cleared contractors arrive at their PSI projections and calculate their submissions. This information will assist DSS in the analysis of the PSI projections.

DSS calculates that these combined changes will increase the individual response time to 80 minutes per respondent instead of the previously approved 75 minutes per respondent. The decrease in information requested because of change #1 offsets change #2 and #3 except for an additional 5 minutes per response.

DSS will reflect these changes in the next submission of the DSS collection 0704-0417.

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