SEVIS Supporting Statement (3-2014) OIRA

SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

OMB No. 1405-0147

Recording, Reporting and Data Collection Requirements – Student and Exchange Visitor Information System (SEVIS)

Forms DS-3036, DS-3037 and DS-7000

A. JUSTIFICATION

1. The Bureau of Educational and Cultural Affairs (ECA) of the U.S. Department of State administers the Exchange Visitor Program (J-Visa) under the provisions of the Mutual Educational and Cultural Exchange Act of 1961 (MECEA), also known as the Fulbright-Hays Act, as amended (Public Law 87-256. 22 U.S.C. 2451, et seq.). This program enables U.S. Government agencies and public and private organizations to conduct a variety of educational and cultural exchange activities.

This collection of information required under 22 CFR Part 62, utilizes the Student and Exchange Visitor Information System (SEVIS) (DS-7000) and two forms: DS-3036 - Exchange Visitor Program Application and DS-3037 - Update of Information on Exchange Visitor Program Sponsor.

The Exchange Visitor Program Application and the Update of Information on Exchange Visitor Program Sponsor provide a means for interested organizations to apply for designation by the Department of State to become a sponsor, for designated sponsors to keep the Department abreast of changes in their program, and to request DS-2019 forms and brochures. Without these forms and the information they provide, the activities conducted under the Exchange Visitor Program could not continue.

2. The Exchange Visitor Program Application (DS-3036) is used by United States Government agencies and public and private organizations to apply to the Department of State to become designated to administer an exchange visitor program. Approximately 60 applications are received each year. The information provided is used to determine whether the interested organization meets the requirements to receive designation as a Sponsor and, if approved, to create a database entry for tracking purposes.

The Update of Information on Exchange Visitor Program Sponsor (DS-3037) is used by the approximately 1415 designated sponsors to notify the Department of changes in the address, telephone numbers, fax numbers, etc., of the organization, and to request a change of the Responsible Officer or Alternate Responsible Officers.

3. The Department incorporated Forms DS-3036 and DS-3037 electronically into the Student and Exchange Visitor Information System (SEVIS). SEVIS is administered by the Department of Homeland Security to meet the legislative mandate established by Subtitle D, Section 641 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (P.L. 104-208).

Because of the regulatory requirements, (22 CFR 62.5(a) (d)), for sponsors to provide original signed copies of documents on the establishment and operation of their proposed exchange programs, the application process (Form DS-3036) is handled partly electronically and partly in paper form. The application form is completed online. This serves as a notification and tracking system for new applications. Once submitted online, the applicant must submit a paper copy of the complete application with all required signed documents to the Department.

4. There is one form per potential sponsor for the Application and approximately two or three update information forms filed by currently designated sponsors annually. This information is not otherwise available.

5. This collection does not have a significant economic impact on small business entities.

6. If the collection of information is not conducted, the Department could not administer the Exchange Visitor Program. We would not be able to designate new sponsors to administer exchange visitor programs. In addition, there would be no means for a designated sponsor to request forms required to administer its program or to provide the Department with essential information to maintain the Exchange Visitor Program database on existing designated sponsors.

7. There are no special circumstances for this collection.

8. The Department published a 60-day notice in the Federal Register to solicit public comments and the collection received 1 comment. The comment was determined to be not to be germane to this collection. This statement that the program costs a hundred times more than our estimate is not supported by the extensive data that we collect on this matter, and our private sector programs are supported by fees to a great extent..

In addition, the Department received 59 comments on the Teacher Rule (22 CFR Part 62.24), to which this collection is tied, with commenters addressing the following topics: Cultural component; length of teaching experience requirement; change in eligibility requirement; English proficiency requirement; program dates; exclusion of pre-kindergarten and daycare from program; program extensions; repeat participation additional information collection and fee transparency other provisions. No comments received impacted the information collected on DS-3036 DS3037 or DS 7000.

9. Respondents are not provided with any gifts or payments.

10. No promises of confidentiality are made.

11. There are no questions of a sensitive nature included in the data required.

12. The number of responses to the Form DS-3036 is approximately 60 applications annually. The respondents complete the form if they wish to be considered for designation as an Exchange Visitor Program sponsor. This form takes approximately 1 hour to complete and an additional 7 hours to gather supporting application documentation. The annual burden for this form is estimated to be 480 hours. The average sum for hourly civilian earnings is$22.50, therefore a total wage cost of $15,120.00 ($22.50 x the 1.4 multiplier based on FTE wage scales x 480 hours).

Form DS-3037 is used by designated sponsors to notify the Department of any changes in contact information for the sponsor, to request brochures, and to request a change in Responsible or Alternate Responsible officers on their exchange program. This form takes approximately 20 minutes to complete. It is estimated that approximately 1,415 respondents will submit a minimum of two requests annually for a total 2,830 submissions. The annual burden for this form is approximately 943 hours. The average mean for hourly civilian earnings is $22.50, therefore a total wage cost of $29,704.50 ($22.50 x 1.4 x 943 hours). The total hour cost burden for this collection is $15,120 (Form DS-3036) + 20,704.50 (Form DS-3037) = $44,824 (rounded).

Form DS-7000, the SEVIS Electronic Application, includes all the Department’s record keeping, reporting and data collection information required under 22 CFR Part 62 and the many functions performed through SEVIS by program sponsors. A detailed breakdown of the respondents, number of responses, and burden figures are attached in table format. Please see the attached spreadsheet (Attachment 1) for a detailed burden accounting of data collection and reporting activities conducted through SEVIS. Please see the attached spreadsheet (Attachment 2) for Non-SEVIS recordkeeping and data collection activities.

Respondents for this collection include designated program sponsors, applicants/potential sponsors, host families, exchange visitors, and U.S. medical schools, yielding an estimated total of 190,200 respondents per year.

The annual number of responses is approximately 1,569,302. The total aggregate annual hour burden is estimated to be 1,301,384 hours. The table below, which summarizes both spreadsheets (Attachments 1 and 2), shows the aggregate burden figures for all requirements under 22 CFR Part 62 for DS-7000; the total annual cost to respondents is estimated to be $19,371,520, which is based on an hourly cost burden.

Component	Respondents	Responses	Annual hour burden	Annual Cost burden
SEVIS	200	21,083	9,319 hours	$2,856,710
Non-SEVIS	190,000	1,548,219	1,292,065 hours	$16,514,810
Totals:	190,200*	1,569,302	1,301,384 hours	$19,371,520

(* There is an overlap of respondents for SEVIS and Non-SEVIS component.)

13. Both Forms DS-3036 and DS-3037 are available on-line through SEVIS and are transmitted electronically to the Department.

14. The cost incurred by the Department is the time of staff necessary to review and analyze requests and in maintaining information in office files and databases.
The estimated cost to the Federal Government is approximately $288,645.00. This estimate is based on the number of responses (DS-3036 – 60; DS-3037 – 2,830), the average hourly processing time (DS-3036 - 4 hours; DS-3037 – 20 min.), and the average hourly salary (DS-3036 - GS-13/5 $44.00 x 1.4 = $61.60; DS-3037 – GS-9 $25.00 x 1.4 = $35.00).

The wage cost for Form DS-3036 is $14,784.00 (60 respondent times 4 hours equals 240, times $61.60). There is an application fee of $3,982.00 for an organization to complete and file an application for designation as an Exchange Visitor Program sponsor (DS-3036) which results in a total cost of $238,920.00 ($3,982.00 x 60 respondents). The printing costs are $1,200.00 (60 responses x $20). The total cost for Form DS-3036 is $254,904.00 ($14,784 wages + $238,920 +$1,200 printing costs).

The wage cost for Form DS-3037 is $33,005 (1415 responses x twice 20 minutes equals 943 x $35.00 = $33,005.00). The printing costs are $735.80 (2830 responses x $0.26). The total cost for Form DS-3037 is $33,741 ($33,741 wages + $736 printing costs).

The total wage cost to the government for these forms is $288,645 ($ 254,904 DS-3036 + $33,741 DS-3037).

15. The Department has revised Form DS-3036 (page 2) to include a new certification under the Responsible Officer’s signature and has updated Office addresses. The Department has also published new rulemakings in the past three years that affect the Non-SEVIS spreadsheet. Section 62.25 (secondary school students) and section 62.32 (summer work travel) have been updated to include new collections on third party information, screening, monitoring, and reporting requirements of sponsors.

The number of responses under this entire collection has been reduced from 1,620,377 to 1,572,192 due to a decrease in the number of organizations applying for designation and a decrease in the number of designated sponsors from three years ago. The Department has also amended the annualized cost to respondents from $21,891,321 to $0. (This amount was incorrectly attributed as a cost to respondents in the last submission. It is a cost of services recovery fee and has been moved to cost to government in item 14).

16. The Department will not publish the collected information.

17. The Department will display the OMB expiration date.

18. The Department is not requesting any exceptions to the certification.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS.

This collection does not employ statistical methods.