Supporting Statement
for Information Collection Submission
9000-0159, Central Contractor Registration
A. Justification.
1. Administrative requirements. Federal Acquisition Regulation (FAR) Subpart 4.11 prescribes policies and procedures for requiring contractor registration in the Central Contractor Registration (CCR) database, as a part of the Business Partner Network (BPN) to: (1) Increase visibility of vendor sources (including their geographical locations) for specific supplies and services; and (2) establish a common source of vendor data for the Government.
2. Uses of information. Prospective contractors shall be registered in the CCR database prior to award of a contract or agreement, except in certain limited cases. Contractors are required to provide certain business information, including their Taxpayer Identification Number (TINs) and Electronic Funds Transfer (EFT) information only once into a common Governmentwide data source. The Government will use this common Governmentwide data sources to more efficiently meet the requirements of the Debt Collection Improvement Act of 1996 (Section 31001 of Public Law 104-134).
3. Consideration of information technology. We use improved information technology to the maximum extent practicable. Where both the Government agency and contractors are capable of electronic interchange, the contractors may submit this information collection requirement electronically.
4. Efforts to identify duplication. This requirement is being issued under the Federal Acquisition Regulation (FAR), which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication. The Central Contractor Registration was developed to centralize contractor information; therefore, eliminating duplicative bidder and contractor information systems and the need for multiple submissions of bidder data.
5.
If the
collection of information impacts small businesses or other entities,
describe methods used to minimize burden. The
burden applied to small businesses is the minimum consistent with
applicable laws, Executive orders, regulations and prudent business
practices.
6. Describe consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently. If the collection of contractor registration data is hampered or delayed, the Government will be creating an additional contractor database to maintain. Collection of information on a basis other than solicitation-by-solicitation is not practical.
7.
Special
circumstances for collection.
Collection is consistent with guidelines in 5 CFR 1320.6.
8. Efforts to consult with person outside the agency. A notice was published in the Federal Register at 77 FR 24713, on April 25, 2012. One respondent submitted public comments on the extension of the previously approved information collection. The analysis of the public comments is summarized as follows:
Comment: The respondent commented that the extension of the information collection would violate the fundamental purposes of the Paperwork Reduction Act because of the burden it puts on the entity submitting the information and the agency collecting the information.
Response: In accordance with the Paperwork Required Act (PRA), agencies can request an OMB approval of an existing information collection. The PRA requires that agencies use the Federal Register notice and comment process, to extend the OMB’s approval, at least every three years. This extension, to a previously approved information collection, pertains to FAR Subpart 4.11—Central Contractor Registration. The purpose of this part is to prescribe the policies and procedures for requiring contractor registration in the Central Contractor Registration (CCR) database, a part of the business partner Network (BPN) to—
(a) Increase visibility of vendor sources (including their geographical locations) for specific supplies and services; and
(b) establish a common source of vendor data for the Government.
The Government must ensure that contractors are registered in the CCR database prior to award of a contract or agreement, except in certain cases. Clause 52.204-7, Central Contractor Registration, is mandatory except in certain cases. Not granting this extension would consequently eliminate the Government’s ability to gather information about its vendor base which is used in the procurement process, and to facilitate electronic payment to vendors.
Comment: The respondent commented that the Agencies did not accurately estimate the public burden an extension of the information collection requirement would create. The respondent indicated that CCR requires extensive information about the registrant, for example executive compensation, and the time required is estimated time per response is 50 to 100 times greater than the estimate of .4526 hours per response. Response: The Federal Procurement Data System shows 193,397 unique vendors received awards in Fiscal Year (FY) 2011. For FY 2011, it is estimated that 168,646 current Government vendors received new awards, and 24,751 new vendors were awarded contracts. These vendors are required to input information in CCR in order to receive awards. In consideration of the public comment, it is estimated that for current CCR vendors, an average of 1 hour is needed to update the information in the system. For new CCR registrants, it is estimated that 3 hours will be required for each respondent to fill out the documentation in the system. An overall average of 1.2559 hours is required to review and update the documentation for current registrants and to review, prepare, and complete the registration for new registrants. This is an increase from the estimated average of .4526 hours per response. There are other OMB information collection requirements that account for the data collected in CCR. For example, OMB Control Number 9000-0177 accounts for the reporting of executive compensation. A notice was published in the Federal Register at 77 FR 22766, on April 17, 2012.
Comment: The respondent commented that the collective burden of compliance with the information collection requirement greatly exceeds the Agencies estimate and outweighs any potential utility of the extension.
Response: The Paperwork Reduction Act (PRA) was designed to improve the quality and use of Federal information to strengthen decision-making, accountability, and openness in government and society. Central to this process is the solicitation of comments from the public. This process incorporates an enumerated specification of targeted information and provides interested parties a meaningful opportunity for comment on the relevant compliance cost. This process has led to decreases in the overall collective burden of compliance for the information collection requirement in regards to the public. Based on OMB estimates, in FY 2010, the public spent 8.8 billion hours responding to information collections. This was a decrease of one billion hours, or ten percent from the previous fiscal year. In effect, the collective burden of compliance for the public is going down as the Government publishes rules that make the process less complex, more transparent, and reduces the cost of federal regulations to both the Contractor community and Government.
Comment: The respondent commented that the Government’s response to the Paperwork Reduction Act waiver for Far Case 2007-006 is instructive on the total burden for respondents.
Response: Serious consideration is given, during the open comment period, to all comments received and adjustments are made to the paperwork burden estimate based on reasonable considerations provided by the public. This is evidenced, as the respondent notes, in FAR Case 2007-006 where an adjustment was made from the total preparation hours from three to 60. This change was made considering particularly the hours that would be required for review within the company, prior to release to the Government.
The burden is prepared taking into consideration the necessary criteria in OMB guidance for estimating the paperwork burden put on the entity submitting the information. For example, consideration is given to an entity reviewing instructions; using technology to collect, process, and disclose information; adjusting existing practices to comply with requirements; searching data sources; completing and reviewing the response; and transmitting or disclosing information. The estimated burden hours for a collection are based on an average between the hours that a simple disclosure by a very small business might require and the much higher numbers that might be required for a very complex disclosure by a major corporation. Also, the estimated burden hours should only include projected hours for those actions which a company would not undertake in the normal course of business. Careful consideration went into assessing the estimated burden hours for this collection, and an upward adjustment is being to the estimated burden hours.
9. Explanation of any decision to provide any payment or gift to respondents, other than reenumeration of contractors or guarantees. Not applicable.
10. Describe assurance of confidentiality provided to respondents. The information is disclosed only to the extent consistent with prudent business practices and current regulations.
11. Additional justification for questions of a sensitive nature. No sensitive questions are involved.
12 & 13. Estimated total annual public hours and cost burden.
It is estimated that for current CCR vendors, an average of 1 hour is needed to update the information in the system. For new CCR registrants, it is estimated that 3 hours will be required for each respondent to fill out the documentation in the system. An overall average of 1.69 hours is required to review and update the documentation for current registrants and to review, prepare, and complete the registration for new registrants. FPDS shows 193,397 unique vendors who received awards in FY 2011. The previous figure of 87,677 was derived from fiscal year 2004 on the number of large and small business contractors who received new awards or orders of $25K or more in the FPDS database. For FY 2011, it is estimated that 168,646 current Government vendors received new awards, and 24,751 new vendors were awarded contracts. These are the vendors that are required to input data in CCR to in order to receive Federal contract awards. We used the number of new registrants and current registrants in CCR for FY 2011 to calculate the percentage split of new registrants and current registrants of the FY11 unique vendors awarded contracts required to enter data in CCR.
Annual Reporting Burden and Cost (Renewal)
Estimated respondents/yr. 168,646
Responses per respondent x 1
Total annual responses 168,646
Estimated hours per response x 1
Estimated cost to public $8,263,654
Annual Reporting Burden and Cost (New)
Estimated respondents/yr. 24,751
Responses per respondent x 1
Total annual responses 24,751
Estimated hours per response x 3.0
Estimated cost to public $3,638,397
It is estimated that the total population of respondents is 193,397, and the total estimated response hours is 242,899, resulting in a weighted average of 1.2559 hours per respondent for CCR reporting by current and potential federal Government vendors.
14. Estimated annual cost to the Government. Time required for Governmentwide review is estimated at 1 hour in receiving, reviewing, and analyzing the information submitted by the respondents.
Annual Reporting Burden and Cost
Respondents/yr 193,397
Reviewing time/hr x 1
Review time/yr 193,397
Average wages + overhead ($28/hr + 100% OH) x $56
Estimated cost to the Government $10,830,232
15. Explain reasons for program changes or adjustments reported in Item 13 or 14. This is an extension of a currently approved public information collection. The increase in the annual reporting burden is due to a change in the reporting size of the Federal Government vendor base in the CCR from FY 2004. There is also an upward adjustment to the estimated hours per response in consideration of the public comment. The estimated costs are increased due to an adjustment to average wage rates.
Outline plans for published results of information collections. Results will not be tabulated or published.
17. Approval not to display expiration date. Not applicable.
18. Explanation of exception to certification statement. Not applicable.
B. Collections of Information Employing Statistical Methods.
Statistical methods are not used in this information collection.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | Shari Kiser |
| Last Modified By | WilliamFClark |
| File Modified | 2013-02-15 |
| File Created | 2013-02-15 |