3300 - Supporting Statement

SUPPORTING STATEMENT
U.S. Small Business Administration
SMALL BUSINESS ADMINISTRATION AWARD NOMINATION

A: JUSTIFICATION
1. Circumstances necessitating the collection of information
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.

Sections 4(h) and 8(b) (1) (A) (iv) of the Small Business Act l5 U.S.C. 633(h) and 637 (b) (1) (A) (iv) authorize the Administrator of the US. Small Business Administration (SBA) to recognize achievements of small businesses through appropriate events and activities. (Copies of these provisions are attached). In recognition of the small business community’s contributions to the nation’s economy and society, the President of the
United States designates one week each year as Small Business Week. Leading up to that week the U.S. Small Business Administration seeks nominations for ‘various recognition awards honoring the nation’s small business owners and entrepreneurs, and small business advocates. Recognition awards are presented by the U.S. Small
Business Administration to winners at the district, regional and national levels. Potential
award recipients are nominated by banks, Small Business Development Centers, employees, spouses, or are self-nominated. This information collection, which consists of Form 3300, Small Business Administration Award Nomination Form, and other information set out in the Awards Nominations Guidelines, (copy attached), is used to facilitate the award selection process.
2. How, by whom, and for what purpose information will be used
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 information collected is used to identify an actual or apparent conflict of interest, to verify the accuracy of the information submitted with the nomination packets, and to apply defined evaluation criteria to determine whether a nominee is eligible for a recognition award.

All nominees must be cleared by the U.S. Small Business Administration’s Office of
Equal Employment Opportunity and Office of Inspector General. These clearances are
required to verify the accuracy of the nomination packet and to preclude any potential
conflict of interest or embarrassment to the nominee, the U.S. Government or the
President of the United States. Once a nominee is cleared, the information collected is
reviewed by a panel, of SBA and non-SBA judges who evaluate nominees to determine
whether they meet the evaluation criteria outlined in the Awards Nomination Guidelines.

In addition, if a visit to the White House has been approved for the winner of a particular award, certain information collected is forwarded to the White House to be used for clearance purposes.

3. Technological collection technique
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 the burden.

The guidelines for eligibility and submission of information, as well as Form 3300 are
available online at the agency website. The form may be filled in online and downloaded
for submission or downloaded for completion, manually. At this time the agency does
not accept the form electronically; rather it is submitted along with the other requested
information, which generally includes DVDs or other hard media, in person or by mail.

4. Avoidance of Duplication
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.

Only those award nominees who have applied for, or received SBA assistance may have
previously provided some of the information requested. However, because applications
for SBA assistance are not centrally located, particularly identifying and contact information, it would be difficult to readily match up any prior particular collection of information with this collection. SEA minimizes the burden by requesting only the minimal information necessary to make informed selections.

5. Impact on small businesses or other small entities
If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-1), describe any methods used to minimize burden.

The only small businesses impacted by the collection of this information are the small businesses owned or operated by the award nominees. This information collection will not have a significant economic impact on the approximately 600 who respond to this collection of information. The information requested should be readily available from the nominees’ personal and business records. Information that may not be in those records, such as Congressional District, is also easily obtainable.

6. Consequences if collection of information is not conducted
Describe the consequence to the 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.

The information collected is required to determine whether an award nominee has an
actual or apparent conflict of interest. The information is also used to evaluate the nominations and select the winners based on the criteria outlined in the nomination guidelines. In addition, a credible recognition awards program would not be possible and the SBA would be hampered in its efforts to recognize outstanding small businesses.

7. Existence of special circumstances

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

A respondent may be required to respond to the request for the collection of information in less than thirty days only if the person who nominates the respondent does so within the thirty days prior to the due date for the completed nomination packet for the particular recognition award.

Confidential financial or personal information is requested but the Agency protects the confidentiality of the information to the extent permitted by the law. The information collected is kept in a locked area, with access restricted to a limited number of employees who are directly responsible for the award nomination process.

8. Solicitation of Public Comment

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. 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.

A request for public comment was published in Federal Register, 75 FR 26295, on May 11, 2010. The comment period ended on May 12, 2010; no comments were received.

9. Payment of gifts

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

No payment or gift will be provided to respondents for completing this information collection. However, award winners will receive some tangible item of nominal value, such as a trophy, plaque, or award certificate to commemorate their achievements.

10. Assurance of Confidentiality

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

The information may be subject to disclosure under the Freedom of Information Act and other related federal laws. SBA protects the information to the extent permitted by law. Also see number 11 below.

11, Questions of a sensitive nature

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.

Some of the information collected, such as criminal history, citizenship, and residential address may be considered sensitive or private. SBA protects the information to the extent permitted by law. The agency has a Privacy Act System of Records (SBA 28) that covers this information (see attached copy). Information regarding the Privacy Act rights as outlined in this notice is provided to respondents as part of the information collection request. The notice was last published in the Federal Register at 74 FR 14889, 14919 on April 1, 2009.

12. Estimate the hourly burden of the collection of information

Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated…

Each year, approximately 600 award nominees respond to this information collection as part of the annual recognition award program process. Respondents will spend an estimated average of 120 minutes responding to the information collection, including reading the questions, locating specific information in their business or personal files, determining their congressional district, and answering the questions. The estimated aggregate annual time burden is therefore approximately 1200 hours per year.

Generally, an administrative assistant, loan officer, Small Business Development Center personnel or the nominee will collect and submit the information. SBA estimates that the wage level of such personnel is equivalent to a GS-9 employee. As such the estimated hour cost burden is as follows:

Estimated completion time per response: 2 hours

Average hourly wage for person completing collection: $20.58

Total cost per response: $20.58 x 2 hours = $41.16

Estimated number of responses: 600

Total estimated cost burden: 600 x $41.16 = $24,696

13. Estimate the total annual cost burden for submission

Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information…

The estimated annual cost burden per respondent for submission is $4.82 (mail) or $15.00 (courier) depending on respondent’s choice of delivery. Generally approximately 500 nominees submit the information by first class mail and 100 by courier. The estimated aggregate annual cost burden is therefore $3910.00 ($4.82 x 500 = 2410) + ($15.00 x 100 = $1500.00).

14. Annualized Cost to the Federal Government

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.

The cost to the Federal Government for handling this information collection is negligible. SBA employees will review the form and manage the entire nomination and selection process as part of their regularly assigned duties.

15. Explanation of program changes in Items 13 or 14 on OMB Form 83-1

Explain reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

There are no changes or adjustments since prior submission.

16. Collection of information whose results will be published

For collection of information whose results will be published, outline plans for tabulation and publication. Address complex analytical techniques…Provide time schedules for the entire project…

Winners receive extensive local media coverage. Biographical and relevant business information pertaining to the winners will be provided to the media upon request. The estimated project schedule for the 2011 Small Business Week award program is as follows:

o Nominations will be submitted to the nearest U.S. Small Business Administration district office in the nominee’s state or district by a deadline falling between November 12, 2010 to December 10, 2010, depending upon the specific award.

o December 10, 2010: SBA district winners will be selected from multi-district states; state winners will be selected from single-district states.

o January 21, 2011: A panel of judges will select state winners from multi-district states.

o March 8, 2011: State winners will be announced.

o State and District winners will be honored some time during calendar year 2011 on dates to be determined by the district offices.

o May 2011: National winners will be announced and honored at the Small Business Week celebration. State and District winners will be honored some time during the 2011 calendar year, on dates to be determined by the district offices.

The timeline for subsequent years will be similar, with national awards being presented in either April or May depending on conference center availability.

17. Expiration date for collection of information

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

Not applicable.

18. Exceptions to certification in block 19 on OMB Form 83-1

Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission” of OMB Form 83-1.

Not applicable.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used.

Not applicable. Statistical methods will not be employed to analyze the information collected or to determine award winners.