Supporting Statement SF-15 083110

Supporting Statement for Paperwork Reduction Act Submission

Standard Form (SF 15)

Under the provisions of the Paperwork Reduction Act of 1980 (title 44, U.S. Code, Chapter 35), the Office of Personnel Management (OPM) is submitting to the Office of Management and Budget (OMB) a request for the continued use of the SF 15, Application for 10-Point Veteran Preference, which gathers information to support applicant claims for veterans’ preference.

A. Justification for Standard Form 15

1. Veterans’ preference is established by the Veterans Preference Act of 1944, as amended, and is now codified in various provisions of title 5, United States Code (U.S.C.). By law, veterans who are disabled or who served on active duty in the Armed Forces during certain specific time periods or in military campaigns are entitled to preference over others in hiring from competitive lists of eligibles. Specifically, 5 U.S.C. 2108 and 3309 identify those persons eligible for 10-point veterans’ preference. Consequently, a veteran must be informed of his or her rights and provided with a procedure for securing these rights.

2. OPM and agency examining offices use the information from the SF 15, including supporting documentation, to determine if the applicant for a Federal job is eligible for the type of 10-point preference he or she is claiming. Without this information, officials would not know how to adjudicate the claim, because there are seven different types of claims and required documentation varies accordingly. The submission of documents alone without the SF 15 would not satisfy this need.

The SF 15 is used to permanently document the veteran’s claim in the veteran’s Official Personnel Folder upon appointment. This is especially important in Reduction in Force (RIF) actions where veterans’ preference comes into play with regard to retention and in certain types of appointment actions, such as Veterans Recruitment Appointments.

3. Electronic alternatives to the SF 15 would not be cost-effective because of the amount of information that is actually collected. The supporting documentation that must be submitted with the SF 15 provides most of the information agencies use to adjudicate veterans’ preference. The information may come from the military, the Department of Veterans Affairs (DVA), the courts, or hospitals, as appropriate. The form will be available on OPM’s website in PDF fillable format.

4. Items 1 – 5 are also found on the Optional Application for Federal Employment form, OF 612, and, Declaration for Federal Employment form, OF 306. These forms are generally used later in the application process before an applicant is actually appointed. Items 1 – 5 must be repeated, because in many cases the applicant applies for a job by forwarding only the employment application. When this occurs and the individual indicates that he or she is eligible for 10-point veterans’ preference, the applicant must provide the SF 15 and supporting documentation. An applicant may also submit a certificate (letter) from DVA determining eligibility for a 10-point preference. We must have a means of identifying the material submitted to the examining office holding the employment application. These items aid in this identification process. The duplicate information is for identification purposes only

If the documentation submitted is inadequate, the examining office must then contact the DVA or the appropriate branch of the Armed Forces. Items 6 – 9 are required by these organizations to identify the individual concerned.

Items 12 – 14 are necessary because they are self-eliminating questions. The answers will indicate whether the candidate needs to complete the rest of the form.

5. The collection of information does not impact small businesses or other small entities; the collection is from individuals only.

6. Veterans’ preference is a factor considered in Federal hiring. Federal agencies will not be able to grant the veterans’ preference benefit established by statute if the information is not collected. The collection usually occurs once; however, if applicants are applying for numerous positions, they usually submit photocopies of the SF 15 and documentation.

7. There are no special reporting or recordkeeping requirements that increase the burden on applicants.

8. In the 60-Day Notice, we proposed to submit to the Office of Management and Budget a request for clearance of an expiring information collection instrument and invited comments on the SF 15. The notice was reported on June 14, 2010, at 75 FR 33657. At that time, OPM invited public comment on the need for information, its practical utility, the accuracy of OPM’s burden estimate, and ways to minimize that reporting burden. OPM received comments from one agency. The agency comments focused on changes to the form which are outside the scope of this notice for extension.

9. No payment or gift is made to respondents.

10. The Privacy Act Statement printed on the form identifies limitations on disclosure. The Privacy System of Records covering this information is OPM Government 5: Recruiting, Examining, and Placement Records.

11. Questions 12, 13, and 14, concerning marital status, are of a personal nature. The law clearly provides that the marital status of spouses, widows, widowers, and mothers of veterans is required in order to determine preference eligibility. Therefore, if application is made for spouse, widows, widowers, or mother’s preference, the adjudicator must know the applicant’s marital status.

12. No statistics are kept on the number of SF 15’s completed or received by agencies during the application process. The SF-15 is available on OPM’s website as a fillable downloadable form. This provides an easier mechanism to access, complete, and print the form when applying for federal employment. The number of 10-point veterans hired by the Federal Government has increased in each succeeding year. In order to make the most accurate estimate possible of the burden to the public in completing this form, we use CPDF data for 10-point veterans hired. The CPDF data indicated that, during fiscal year 2009, there were at least 18,418 forms submitted (based upon 10-point veterans’ preference individuals hired) and it took 10 minutes to complete the form. This provided the estimated annual burden of 3,070 hours.

13. There is no cost to respondents for the collection of information or its recordkeeping.

14. As discussed above, statistics are not kept on the number of SF-15's completed or received by agencies during the application process. The CPDF data for 10-point veterans hired indicated at least 18,418 forms were completed and processed in fiscal year 2009. We therefore calculated the approximate cost in processing these forms based upon CPDF information as the best estimate of annual usage of the SF 15 by veterans to obtain employment. This cost is calculated by processing the total forms indicated by CPDF (18,418) at a rate of $2.66 per form for a total of $48,992 plus 25% overhead ($12,248) resulting in a total cost of $61,240 to the government.

15. The reporting burden is 3,070 hours. Since OPM began providing the SF 15 in an easily accessible online version, both fillable and printable, agencies have hired greater numbers of disabled veterans into the Federal Government. The increasing use of SF 15s, and the reporting burden each successive year, is attributable to additional hiring of disabled veterans.

16. Not applicable. Information is not published.

17. Request SF-15 extended without a future expiration date. The requirements for extension are time-consuming and do not support the administrative costs associated with extending the form. OPM is responsible for substantive changes to the form driven by changes to veterans' preference law in title 5, United States Code.

18. Not applicable.

B. Collection of Information Employing Statistical Method

Not applicable