April 2008
SUPPORTING STATEMENT
2700-0054
Modifications Related to Engineering Change Proposals, NFS 1843
A. Justification.
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection.
This collection is required to ensure engineering changes are made quickly and in a cost-effective manner. Proposals supporting such change orders contain detailed information which enables the Government to obtain the best goods and services for the best prices. The requirement for them is 48 CFR Part 1843.
2. Indicate how, by whom, how frequently, and for what purpose the information will
be used. Except for a new collection, indicate the actual use the agency has made of the
information received from the current collection.
NASA procurement and technical personnel use the information to manage the contract and to arrive a fair price for engineering changes made during contract performance. Change proposals are submitted whenever a change order results in an increase or decrease to the contractor’s cost to perform the contract. Without change orders, NASA would often be unable to obtain the best goods and services at the best prices.
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. Also describe any consideration of using information
technology to reduce burden.
NASA encourages the use of computer technology when preparing change proposals. NASA does not prescribe a format for submission, and most contractors have cost collection systems which are utilized for proposal preparation. Also, NASA participates in Federal efforts to extend the use of information technology to more Government processes via the Internet.
4. Describe efforts to identify duplication.
NASA procurement procedures are continually being reviewed to eliminate duplication and other inefficiencies. Each engineering change is unique and the information required in an ECP is not available elsewhere. There is no duplication of information.
5. If the collection of information impacts small businesses or other small entities (Item five of form OMB 83-I, the Paperwork Reduction Act Submission form), describe any methods used to minimize burden.
Small businesses may receive engineering changes and may be required to submit a proposal in response. The cost of preparing an ECP is included in the proposal and is reimbursable under the contract.
6. Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Absence of change proposals would often render NASA unable to fulfill its mission.
7. Explain any special circumstances that would cause an information collection to be
conducted in certain manners (as listed).
None
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 before submission to OMB.
April 18, 2008; Page 21160
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
None
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy.
The confidentiality of this data is governed by statues, the Freedom of Information Act, and contract clauses. NASA’s adherence to the NASA FAR Supplement ensures that right in data and proprietary information are protected.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
No sensitive questions are involved.
12. Provide estimates of the hour burden of the collection of information.
No. of Respondents |
Annual No. of Responses |
Hours per Response |
TOTAL HOURS |
150 |
1 |
30 |
4500 |
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers
resulting from the collection of information.
There is no cost burden to respondents or record-keepers, as costs related to the collection of this information are reimbursed by the Federal Government.
14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses, and any other expense that would not have been incurred without this collection of information.
150 ECPs received. Estimated hours to review each ECP is 10. Annual cost to NASA is 1,500 hrs. or $67,500. This estimate is calculated by determining the average costs (GS-13 at $45/hr) for hours taken by procurement and technical personnel to compile and analyze the data in the reports and proposals.
15. Explain the reasons for any program changes or adjustments reported in Items
13 or 14 of the OMB Form 83‑I.
There were no significant changes.
16. For collections of information intended for publication, outline plans for
tabulation and publication.
Not applicable
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display may be inappropriate.
Approval Expiration Date may be displayed.
18. Explain each exception to the certification statement identified in item 19, “Certification for paperwork Reduction Act Submissions” of OMB Form 83-I.
Not applicable.
B. Collections of Information Employing Statistical Methods
Not Applicable.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | Paul Brundage |
| Last Modified By | Walter Kit, DSc |
| File Modified | 2008-10-09 |
| File Created | 2008-10-09 |