FINAL SUPPORTING STATEMENT
For
NRC Form 212, “Qualifications Investigation
Professional, Technical, and Administrative Positions”
OMB Clearance No. 3150-0033
Extension Request with Burden Revision
Description of Information Collection
This form is used for investigating the qualifications of external candidates for appointment to professional, technical, and administrative positions in the Nuclear Regulatory Commission (NRC). This extension package reflects a consistent number of forms projected to be received by the NRC and no change in the burden for the next three-year clearance period.
As part of NRC’s review of the hiring process, the NRC Form 212 has been revised. The revised form will provide questions that are designed to prompt the responder to engage in a meaningful discussion. The NRC is also revising the guidance reduce the number of references required to support a hiring decision. NRC has also discontinued the NRC Form 212A and will use the revised NRC Form 212 for all positions. The current reference check forms (NRC-212 and NRC-212A) separates technical (engineers/scientists) from administrative positions. As part of a internal Lean Six Sigma (LSS) effort focused on the hiring process as well as the OPM Hiring Reform Initiative, we reviewed the form and it's intended use. With revising the questions to foster a more interactive discussion, we concluded that there is no longer the need for the two separate forms. Therefore, we are recommending that NRC-212A form, used for administrative positions, be abolished.
A. JUSTIFICATION
Need for and Practical Utility of the Collection of Information
Information requested on NRC Form 212 is used to determine the qualifications and suitability of applicants for employment in professional, technical, and administrative positions, including clerical positions, with the U.S. Nuclear Regulatory Commission. The completed form may be used to examine, rate and/or assess the prospective employee’s qualifications. The information regarding the qualifications of applicants for employment is reviewed by professional personnel of the Office of Human Resources, in conjunction with other information in the NRC files, to determine the qualifications of the applicant for appointment to the position under consideration.
2. Agency Use of Information
The NRC Form 212 is sent to former employers, supervisors, and other references indicated on job applications as a part of the investigation for suitability of external candidates for appointment to professional positions. The information obtained on NRC Form 212 is reviewed and evaluated by personnel of the Office of Human Resources in determining the qualifications of applicants for employment.
3. Reduction of Burden Through Information Technology
There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. NRC issued a regulation on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e-mail, special Web-based interface, or other means. The non-recurrence of each individual collection makes it difficult to reduce the burden through the use of technology. However, the NRC encourages the respondents to use any innovative technology which would reduce burden. It is estimated that approximately 0% of the potential responses are filled electronically.
4. Effort to Identify Duplication and Use of Similar Information
No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.
5. Effort to Reduce Small Business Burden
Information may be requested from individuals associated with small businesses; however, the amount of information requested is kept to a minimum while still allowing a full investigation.
Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently
This information has to be collected and reviewed prior to making a decision on employment eligibility.
7. Circumstances Which Justify Variation from OMB Guidelines
This request does not vary from OMB guidelines.
8. Consultations Outside the NRC
Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on April 5, 2010 (75 FR 17167). No comments were received.
9. Payment of Gift to Respondents
Not applicable.
10. Confidentiality of Information
Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
11. Justification for Sensitive Questions
Not applicable.
12. Estimate of Annualized Burden and Burden Hour Cost
Past experience indicates that it takes about 30 minutes to complete a form. The total estimated burden for the approximately 1,000 forms received annually is 500 hours (.5 hours x 1,000 forms). The estimated annual cost is $128,500 (500 hours x $257.00/hour).
13. Estimate of Other Additional Costs
Not applicable.
14. Estimate of Annualized Cost to the Federal Government
The total estimated annual cost to the Federal Government for printing, handling, reviewing, and assessing the NRC Form 212 is $128,500 (500/hours (1,000+.50/hours) x $257.00/hour). This cost is fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and 171.
15. Reasons for Change in Burden or Cost
The overall burden has increased by 200 hours from 300 to 500 hours because (1) a reduction in the number of references and (2) the combining of NRC Form 212A with NRC Form 212. Based on guidance from OPM regarding reference checks, the NRC has determined that the questions are virtually the same regardless of position; therefore the NRC will discontinue the use of NRC Form 212A. Although the burden per response will increase from 15 minutes to 30 minutes, the number of responses will decrease from an estimated 1,200 to 1,000 forms, based on the number of references required. This burden change will result in an estimated burden of 500 hours (1,000 forms X .50 hrs) at a cost of $128,500 (500 hrs X $257).
The fee rate increased from $214 per hour to $257 per hours.
16. Publication for Statistical Use
This information is not published for statistical use.
17. Reason for Not Displaying the Expiration Date
The expiration date is displayed on the form.
18. Exceptions to the Certification Statement
Not applicable.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | FINAL SUPPORTING STATEMENT |
| Author | rxp1 |
| File Modified | 0000-00-00 |
| File Created | 2021-02-01 |