VMLRP Supporting Statement Final

National Institute of Food and Agriculture

U.S. Department of Agriculture

OMB No. 0524-0046

Nomination Form of Veterinary Shortage Situations for the Veterinary Loan Repayment Program (VMLRP)

SUBJECT: Supporting Statement for Paperwork Reduction Act Submission for the Nomination Form of Veterinary Shortage Situations for the Veterinary Loan Repayment Program (VMLRP)

A. JUSTIFICATION

1. CIRCUMSTANCES MAKING COLLECTION OF INFORMATION NECESSARY

In January 2003, the National Veterinary Medical Service Act (NVMSA) was passed into law adding section 1415A to the National Agricultural Research, Extension, and Teaching Policy Act of 1997 (NARETPA). This law established a new Veterinary Medicine Loan Repayment Program (7 U.S.C. 3151a) authorizing the Secretary of Agriculture to carry out a program of entering into agreements with veterinarians under which they agree to provide veterinary services in veterinarian shortage situations.

The purpose of the program is to assure an adequate supply of trained food animal veterinarians in shortage situations and provide USDA with a pool of veterinary specialists to assist in the control and eradication of animal disease outbreaks.

The National Institute of Food and Agriculture (NIFA) will designate geographic and practice areas that have a shortage of food supply veterinarians in order to carry out the VMLRP goals of strengthening the nation’s animal health infrastructure and supplementing the Federal response during animal health emergencies. NIFA will carry out NVMSA by entering into educational loan repayment agreements with veterinarians who agree to provide veterinary services in veterinarian shortage situations for a determined period of time.

Before NIFA educational loan repayment agreements can be issued, certain nomination information is required from State animal health officials. This information is obtained via a VMLRP Veterinarian Shortage Situation Nomination Form. Because the nominations submitted are reviewed by peer panelists, it is particularly important that the information be provided in a standardized fashion to ensure equitable treatment for all.

2. HOW, BY WHOM, AND PURPOSE FOR WHICH INFORMATION IS TO BE USED

NIFA will publish a solicitation (in the Federal Register and on the NIFA website) for the veterinarian shortage situations. State animal health officials will submit the necessary information to NIFA using the Veterinarian Shortage Situation Nomination form.

NIFA will convene a panel of food supply veterinary medicine experts from Federal and state agencies, as well as institutions receiving Animal Health and Disease Research Program funds under section 1433 of NARETPA, who will review the nominations and make recommendations to the NIFA Program Manager.

3. USE OF IMPROVED INFORMATION TECHNOLOGIES

NIFA will provide this form on its website as a PDF-fillable form and a Microsoft Word document when the solicitation for VMLRP Veterinarian Shortage Situations is published in the Federal Register. Submissions will be accepted via email to a dedicated mailbox ([email protected]).

4. EFFORTS TO IDENTIFY DUPLICATION

This is the only loan repayment program for NIFA. There is no similar information available which can be used or modified to meet the information needs of this program. The information requested is specific to the program and need only be submitted when nominating a position for a veterinarian shortage situation for the Veterinary Medicine Loan Repayment Program.

5. METHODS TO MINIMIZE BUDGET OF SMALL BUSINESSES OR ENTITIES

Small Businesses are not impacted by this information collection.

6. CONSEQUENCE IF INFORMATION COLLECTION WERE LESS FREQUENT

State animal health officials submit VMLRP Veterinarian Shortage Situation Nomination Forms, only when NIFA requests nominations for a designated veterinarian shortage situation. NIFA will normally request submission of nominations on a biennial basis; however, NIFA reserves the right to solicit veterinarian shortage situations every year or every three years, as appropriate. The submission of information must be timely in order to receive nominations in NIFA, properly screen nominations, and to accomplish steps to establish and carry out the evaluation process.

7. SPECIAL CIRCUMSTANCES FOR INFORMATION COLLECTION

 Requiring respondents to report information to the agency more often than quarterly:

The agency does not require respondents to report information on a quarterly basis but rather on a situational basis.

 Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

USDA does not require 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;

USDA does not require 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;

The agency usually does not require respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years following completion of a service agreement.

 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;

This information collection does not include statistical surveys.

 Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

This information collection does not require the use of 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;

This information collection does not require 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.

 Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it instituted procedures to protect the information’s confidentiality to the extent permitted by law.

This information collection does not require respondents to submit proprietary trade secret, or other confidential information.

8. FEDERAL REGISTER NOTICE

The notice for this proposed information collection appeared in the Federal Register on Thursday, July 9, 2009 (74 FR 32788). NIFA received 22 comments, however none of these addressed the collection instrument or estimated burden. Comments are published on www.regulations.gov and also have been attached as a supplementary document to these supporting statements. The summary of these comments and any actions taken are also attached as a supplementary document. One additional comment was received during the 30 day notice published on May 4^th, 2010 (75 FRN 23664).

CONSULTATIONS WITH PERSONS OUTSIDE THE AGENCY

NIFA solicited stakeholder input at a public meeting on Monday, September 15, 2008, and through written comments. In addition, NIFA is working with the NIH DLR to provide certain administrative services and support.

9. DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES

The agency does not provide payment or gift to respondents.

10. CONFIDENTIALITY PROVIDED TO RESPONDENTS

The information collection will be handled in accordance with the Freedom of Information Act and the Privacy Act.

11. QUESTIONS OF A SENSITIVE NATURE

None of the information requested on the VMLRP Veterinarian Shortage Situation Nomination Form is of a sensitive nature.

12. ESTIMATE OF BURDEN

It is estimated that it will take approximately two hours to complete the PDF-fillable form with checkboxes and text-limiting fields to minimize the overall burden.

ANNUALIZED COSTS TO RESPONDENTS

Based on the median salary of a state government employed veterinarian of $70,000 or an hourly wage of $33.65, NIFA estimates the total annual cost burden to respondents for the value of their time to complete and submit a nomination to be $17,969 ($33.65 x 534).

Form	No. of Respondents	Annual Frequency per Response	Total Annual Responses	Hours per Response	Total Hours
VMLRP Veterinarian Shortage Situation Nomination	60	1-8 average of 4	240	2.0	480

The median salary was derived from PayScale (http://www.payscale.com/research/US/Job=Veterinarian/Salary).

13. CAPITAL/STARTUP COSTS

There are no capital or startup costs for this activity.

14. ANNUALIZED COST TO THE FEDERAL GOVERNMENT

The staffs responsible for processing applications are full-time employees ranging in grade levels GS-9 and GS-15.

Job Title	Action	Hourly Pay*	Time per Action	Total per Nomination	Total for Nominations
Program Assistant, GS-9	Evaluates nomination for preliminary review	$28.04	1 hour	$28.04	$7,487
Program Manager, GS-15	Evaluates nominations, coordinates panel members, makes final designations of shortage situations	$67.21	10	$672.10	$179,451
TOTALS			11 hours	$683.57	$186,938

*A step 5 was used in determining the hourly pay for the grade level.

15. REASONS FOR CHANGE IN BURDEN

The burden was changed from 228 to 480 as result of adjusting the method for how the allocated shortage area nominations are made in each state.

In its consideration of fair, transparent, and objective approaches to allocating shortage area nominations to each state, NIFA determined that the best approach would be base the number of nominations on “Livestock and Livestock Products Total Sales ($)” (LPTS) and “Land Area (acres)” (LA) rather than allocate the same number of nominations (2) to every state.  NIFA believes these two unbiased composite variables account for a significant proportion of several of the most relevant factors influencing veterinary service need and risk.

 

The total number of nominations allocated to each state is based on its quartile ranking in terms of LPTS and LA.  The lists of LPTS and LA are divided into quartiles and each state then received the number of designated shortage situations corresponding to the number of the quartile in which the state falls.  Thus a state that falls in the second quartile for LA and the third quartile for LPTS will be invited to submit up to five designated shortage situations (2 + 3).  This transparent computation was made for each state thereby giving a range of 2 to 8 designated shortage situations, contingent upon each state’s quartile ranking for the two variables.

 “Special Consideration Areas” include any State or Insular Area not reporting data, and/or reporting less than $1,000,000 in annual LPTS, and/or possessing less than 500,000 LA.  One nomination is allocated to any State or Insular Area classified as a Special Consideration Area.

NIFA emphasizes that shortage nomination allocation is merely intended to broadly balance number of certified shortage situations across states.  No state will be given a preference for placement of awardees and awards will be made based strictly on the peer review panel’s assessment of the quality of the match between the knowledge, skills, and abilities of the applicant and the attributes of the specific shortage situation applied for.

16. TABULATION, ANALYSIS AND PUBLICATION PLANS

USDA has no plans to publish information collected.

17. SEEKING APPROVAL TO NOT DISPLAY OMB APPROVAL DATE ON FORMS

The VMLRP Veterinarian Shortage Situation Nomination Form will display the OMB control number and burden statement.

18. EXCEPTION(S) TO THE CERTIFICATION STATEMENT (19) ON OMB 83-I

USDA claims no exceptions to the certification statement 19 on OMB 83-I.

6