2013 SS 0055 with terms

SUPPORTING STATEMENT

OMB Clearance 0579-0055

REQUEST For Credit account approval

for reimbursable services

December 2013

Terms of Clearance:

This form has been made fillable and printable. APHIS was just awarded a contract for digital signature software, and the first phase of the pilot is due to be completed in August 2014. APHIS is also in the process of writing guidance procedures for digital signature use.

A. 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.

This information collection is needed to support requests for credit accounts for reimbursable overtime and import/export services and to provide information to prepare billings for such services performed. The services of an inspector to clear imported and exported commodities requiring release by Agency personnel are covered by user fees during regular working hours. If an importer/exporter wishes to have a shipment of cargo or animals cleared at other hours, such services will usually be provided on a reimbursable overtime basis, unless already covered by a user fee.

Also, the Debt Collection Improvement Act of 1996 (Public Law 104-134, Section 31001(x) of

31 U.S.C. 3332, as amended, requires that agencies collect tax identification numbers from all persons doing business with the Government for purposes of collecting delinquent debts. This is one field on the APHIS Form 192 and it must be completed before credit is extended.

APHIS is seeking OMB approval to continue use of APHIS Form 192, Application for Credit

Account.

2. Indicate how, by whom, how frequently, 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.

APHIS FORM 192, APPLICATION FOR CREDIT ACCOUNT

Requesters of APHIS’ services are usually repeat customers who request that APHIS bill them for services. This information collection is used by the Debt Management Team to conduct a credit check on prospective applicants to ensure credit worthiness prior to extending credit services.

Some of the information collected includes applicant’s name, title, billing and physical address, telephone numbers, and tax identification number or social security number. APHIS uses this information to deny credit to financially unstable customers. This form also serves as the contractual agreement with customers to pay the debts they owe APHIS.

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.

APHIS Form 192, Application for Credit Account, is now available in the APHIS Forms Library in a fillable and printable format. This will allow requester the opportunity to fill and save the form electronically. The site address is http://www.aphis.usda.gov/library/forms.

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

The information is not available until submitted by the requester. No other agency is authorized to provide this service. Therefore, there is no duplication.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information APHIS requires on the form is the minimum needed for APHIS to conduct a credit check. APHIS only collects the information once to establish credit-worthiness. If APHIS deems an applicant acceptable, APHIS does not collect any further information.

Without this information, customers, including small businesses, would have to pay each time they receive a service. Instead, for the convenience of customers with good credit, APHIS provides services as necessary and bills the customer only once a month. About 50 percent of the respondents to this information collection are small businesses.

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.

Not checking credit worthiness before extending credit could greatly increase the number of debts the Agency would incur. Since this is a full-cost recovery program, nonpaying customers would reduce funds to run the program.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

• 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 secret, 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.

No special circumstances exist that would require this collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

8. 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 record keeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, soliciting comments on the information collection prior to submission to 0MB.

APHIS conducted informal consultations, with persons for whom the Agency services, revealing no problems since this information collection has been in effect. APHIS has listed three references, as follows:

International USA-MEX, Inc.

305 Market

Laredo, TX 78044

Rudy Benavides (Telephone: 956-724-4104)

Sunburst Farms

P.O. Box 523224

Miami, FL 33152-3224

Raquel (Telephone: 305-594-4300)

International Pet Transportation

1534 Steinhart A venue

Redondo Beach, CA 90278

Diana Escandon (Telephone: 310-376-2899)

On Thursday, September 8, 2013, page 54617, APHIS published in the Federal Register, a 60-day notice seeking public comments on its plans to request a 3-year renewal of this collection of information. One comment was received from a concerned citizen about her perception of how fees are received when Government services are rendered by USDA. It had no relevance to the purpose of the collection.

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

This information collection activity involves no payments or gifts to respondents.

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

No additional assurance of confidentiality is provided with this information collection. Any and all information obtained in this collection shall not be disclosed except in accordance with

5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

This information collection activity asks no questions of a personal or sensitive nature.

12. 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.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 0MB Form 83-I.

See APHIS Form 71, Summary of Information Collection, for burden estimates.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

The cost to the public was determined by multiplying the total burden hours (56) x the wage per hour ($33.44) which equals $1,873.

$33.44 is the hourly rate derived from the U.S. Department of Labor, Bureau of Labor Statistics May 2013 Report – National Compensation Survey: Occupational Wages in the United States, Business and Financial Operations Occupations, May 2013. See http://www.bls.gov/oes/#tables.

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and startup cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There is zero annual cost burden associated with capital and start-up, operation and maintenance, and purchase of services in connection with this program.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The annualized cost to the Federal Government is estimated at $2,828. (See APHIS Form 79.)

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

This ICR Requests Change in Net Burden	This ICR Requests No Change in Net Burden

	Requested	Program Change Due to New Statute	Program Change Due to Agency Discretion	Change Due to Adjustment in Agency Estimate	Change Due to Potential Violation of the PRA	Previously Approved
Annual Number of Responses for this IC	225	0	0	93	0	132
Annual IC Time Burden (Hours)	56	0	0	23	0	33
Annual IC Cost Burden (Dollars)	0	0	0	0	0	0

The number of respondents requesting credit approval has increased from the previous information collection submission. There is an adjustment of 93 respondents causing the number of responses to increase by 93 resulting in an increase in total burden by 23 hours.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to tabulate or publish the information APHIS is collecting.

17. If seeking approval to not display the expiration date for 0MB approval of the information collection, explain the reasons that display would be inappropriate.

APHIS will display the expiration date on the form.

18. Explain each exception to the certification statement identified in the “Certification for Paperwork Reduction Act.”

APHIS certifies compliance with all provisions of the Act.

B. Collection of Information Employing Statistical Methods

Statistical methods are not used in this information collection.