OMB - SUPPORTING STATEMENT - Faith-Based and Community Organization Survey

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION FOR USAID “FAITH-BASED AND COMMUNITY ORGANIZATION SURVEY”

1. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Center for Faith-Based and Community Initiatives (CFBCI) is committed to supporting the historic commitment from the White House and USAID to deliver high impact foreign assistance by helping USAID to expand our partnership community by building broad and deep relationships with the NGO community at large. This commitment extends beyond the NGOs with whom the Agency currently has financial relationships.

Because of a contact management system that was tied to Outlook and thus accessible only by particular individuals through their personal logins, contact details or many of these NGOs were lost during the transition from the previous Administration. Recognizing the lack of an institutional memory in managing the relationships between our office and our partner community, the CFBCI is working with the Chief Information Officer’s office and the Office of General Counsel to customize Salesforce.com in order to build a robust and long-lasting contact management system.

Having recently launched the online application, the CFBCI has now designed an optional electronic survey for the purpose of strengthening and updating our contact management system. We are requesting permission to send this optional survey to the contacts in our office’s system in order to obtain updated information on NGOs working in international development and humanitarian relief. This is the kind of information that is absolutely necessary for the Center for Faith-Based and Community Initiatives and USAID more broadly to better coordinate its work and interactions with nongovernmental organizations. More specifically, respondents are those who have previously indicated an interest in working with USAID.

We have begun to provide demonstrations of our system to USAID colleagues in offices and bureaus who also work with USAID’s partner community of nongovernmental organizations. They have universally expressed their desire to join the system in order that we can all better coordinate and make our engagements more efficient. This system, so long as it has updated information, will allow for increased efficiency and the avoidance of unnecessary and duplicative contacts with organizations. In addition, information requested on the organizations regional/country and technical sector focus will allow the Agency to better target and expand our outreach to the NGO community.

For that reason, the optional survey will request general contact and profile information for the respondent and his/her affiliated organization that will allow the Agency to better engage these entities. We ask about the organization’s annual budget and the number of paid employees, for example, in order to monitor our success in engaging a broad range of NGOs.

The survey instructions will clearly communicate that completing the survey is optional and that an NGO’s response or non-response will not have any impact – positive or negative – on its future relationship with the Agency.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The optional survey, which will be conducted electronically, will request general contact and profile information for non-governmental organizations that have previously expressed interest in USAID. USAID staff will use this updated information to better coordinate Agency interactions with these stakeholders and to ensure increased efficiency and the avoidance of unnecessary and duplicative contacts with organizations. It will also allow for more targeted outreach to NGOs based on region or sector of work. The optional survey requests general information on the budget and number of paid employees for each organization in order to monitor the Agency’s success in engaging a broad range of NGOs.

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, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The web link to the survey will be sent out via email and information will be collected entirely online, allowing for the easiest possible submission of information.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

Information on this universe of organizations and contacts is not currently collected or managed by USAID in any systematic way.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

This survey will not negatively impact small businesses or other small entities. This survey is voluntary for the respondent and the survey instructions indicate that the entity’s response or non-response will have no impact – positive or negative – on its relationship with the Agency. The survey itself only requests information that would be easily accessible to the respondent, such as basic contact information, focus and country of the organization’s work, and estimates of the number of paid employees and annual budget.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Without updated information from these organizations, USAID will continue to be duplicative in its outreach and requests for information. In addition, the optional survey will increase the efficiency of its efforts to engage a broader range of nongovernmental organizations.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare 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;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• 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;

• requiring the use of a 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; or

• requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

The optional survey will be conducted no more than once a year and should take the respondent no more than 15 minutes to fill out and submit. There is no time requirement for filling out the survey. Respondents are only asked to fill out the online survey once and no copies are required. The respondents are not required to retain records. There is no statistical survey in association with this information collection. There is no statistical data classification in association with this information collection. There is no pledge of confidentiality associated with this information collection. There is no requirement that respondents provide trade secrets or confidential information with this survey.

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 prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Notice of this Information Collection was published in the Federal Register on September 7, 2010; Volume 75; Page 54299. There were no comments received.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.

There is no payment or gift associated with this survey.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

There is no assurance of confidentiality other than the Agency Privacy Policy. The Agency Privacy Policy can be found on the USAID homepage at www.usaid.gov. In addition, USAID does comply with the Freedom of Information Act.

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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature in this optional survey.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

Number of respondents – 4,000

Frequency of response – no more than once a year

Annual hour burden – 1,000

Burden was estimated by multiplying the time for respondents to fill out the form (.25 hour) by the number of respondents (4,000).

The annual cost to respondents is zero because these are members of the public who are choosing to fill out an optional survey on their organization. In addition, the information that is requested is such that is easily accessible and would not require any additional recordkeeping or work by the organization.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

The annual cost to respondents is zero because these are members of the public who are choosing to fill out an optional survey on their organization. In addition, the information that is request is such that is easily accessible and would not require any additional recordkeeping or work by the organization.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The set-up and usage of the underlying system being used for this survey collection and the larger contact management needs cost the Agency approximately $13,000 for five users annually. This includes the adaptation and build-out of the contact management system to meet USAID needs, operations and maintenance, technical assistance, and other services. As other offices within the Agency choose to make use of the system, it will cost approximately an additional $2,600 per user per year. However, the development and actual use of the survey will not cost the Agency any additional funds.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

There are no program changes or adjustments because this is a new information collection.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

This information collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Not applicable.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

No exceptions are taken to Item 19 of Form OMB 83-I.

2. Collections of Information Employing Statistical Methods

The collection does not employ statistical methods. Since the information must be collected for specific individual organizations, statistical survey methodology is not appropriate.