White Paper

Request for Fast-Track Approval for Collecting Feedback
on CVE Verification Cost of Compliance: White Paper

Situation

The Department of Veterans Affairs (VA), Office of Small and Disadvantaged Business Utilization (OSDBU) requests approval for the Fast-Track process (or generic clearance) to collect program execution feedback under the Paper Reduction Act (PRA). OSDBU intends to collect information about the cost of compliance with the Veteran-Owned Small Business Verification Program from its participants.

The CVE Verification Program is ruled by Public Law (P.L.) 109-461, entitled “Veterans Benefits, Health Care, and Information Technology Act of 2006”, provides VA with unique authority for contracting with SDVOSB and VOSB.  In order to qualify for participation in the VA Veterans First Contracting Program, eligible business owners must be verified. OSDBU aims to measure the cost for small business owners to be in compliance with the Veteran-Owned Small Business Verification Program guidelines and requirements.

This information will be collected per OSDBU’s initiative and in response to feedback received from the Small Business Administration (SBA), Office of Advocacy. The SBA has reviewed VA’s proposal to amend its current regulations governing the Veteran-Owned Small Business Verification Program. VA has been required to publish an Initial Regulatory Flexibility Analysis, which analyzes the proposed rule’s likely economic impact on small businesses and discusses any significant regulatory alternatives designed to lessen those impacts.

The purpose of this information collection is to pilot test the instrument to ensure use, and to determine its validity and reliability. OSDBU’s intends to then request regular clearance and collect additional information, which will be shared with the SBA.

PRA Information Supporting the Fast-Track Process

The Fast Track Process is designed for information collections that focus on experiences of customers relating to existing or future services (FAQs for New Fast-Track Process, Point 2, page 1). Pilot tests are covered by the Fast Track Process (FAQs for New Fast-Track Process, Page 3). The Verification Cost of Compliance information collection focuses on customers’ experience when applying for the Veteran-Owned Small Business Verification Program, and will also test the collection instrument.

The hour burden estimate of the collection is 15 hours, which is considered low burden, which makes this collection eligible for the Fast Track process. OSDBU does not intend to share results with the public, but if requested, it will be indicated that these are not generalizable to the population of study, as established on the FAQs for New Fast-Track Process, Section IX, page 5.

Summary

OSDBU requests Fast-Track Process clearance for the CVE Verification Cost of Compliance survey. The intention is to pilot test the collection instrument, make appropriate improvements, and request regular clearance for the final instrument. The final data will be shared with the SBA, Office of Advocacy to amend the regulations governing the Veteran-Owned Small Business Verification Program.