G-1145 Supporting Statement 5-20-14

SUPPORTING STATEMENT FOR

E-Notification of Application/Petition Acceptance

OMB Control No.: 1615-0109

COLLECTION INSTRUMENT(S): Form G-1145

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.

On June 25, 2009, President Obama announced that within 90 days, USCIS would implement a capability for customers to stay informed on the status of their applications using technologies such as e-mail and text messages. The E-Notification of Application/Petition Acceptance, Form G-1145, is used by applicants and petitioners to provide their cell phone number and e-mail address with their application or petition if they wish to receive notification by e-mail or text messaging. Authority: Section 103(a) of the Immigration and Nationality Act (Act).

2. 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.

If an applicant or petitioner wishes to be notified via e-mail and/or text message on their cell phone that their application or petition has been accepted, they are requested to provide their e-mail address and/or cell phone number on E-Notification of Application/Petition Acceptance, Form G-1145, and attach the form to their application or petition. USCIS will use this information as permission to send the e-notification within 24 hours of receipt of the application or petition. The e-mail or text message will not be the official notification. USCIS will send the official written notification via the U.S. Postal Service. (See Form G-1145).

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.

The Form G-1145 is available online at http://www.uscis.gov/files/form/g-1145.pdf and the respondent can complete the form and save it electronically. The respondent may include this form as part of a complete application package, and USCIS does not currently have a process for electronic submission of this collection instrument. USCIS is currently working towards allowing for full electronic submission of forms, but this transformation effort will require a number of years to fully implement. This form will not be in the USCIS ELIS (Electronic Immigration System), but USCIS ELIS provides the functionality that this form currently enables. USCIS will maintain this information collection until all paper-based forms are processed in USCIS ELIS. USCIS respectfully requests a 2-year approval for the G-1145 due to the partial GPEA compliance for this form.

4. 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.

The use of this notification provides the most efficient means for collecting and processing the required data.

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

This collection of information does not have an impact on small businesses or other small entities.

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.

If the information is not collected, USCIS will not be able to notify the applicant or petitioner immediately by e-mail or text messaging that his or her application or petition had been accepted.

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

• 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.

The special circumstances contained in item 7 of the supporting statement are not applicable to this information collection.

8. If applicable, provide a copy and identify the data 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 in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

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.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On February 12, 2014 USCIS published a 60-day notice in the Federal Register at 79 FR 8470. USCIS did not receive comments after publishing that notice.

On May 12, 2014, USCIS published a 30-day notice in the Federal Register at 79 FR 26980. USCIS received one public comment submission. USCIS received one public comment submission.  The commenter raised general concerns about immigration.  USCIS provides immigration benefits as stipulated by the applicable immigration laws. 

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

USCIS does not provide payments or gifts to respondents in exchange for a benefit sought.

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

There is no assurance of confidentiality. The system of record notice associated with this information collection is DHS/USCIS/ICE/CBP-001 – Alien File, Index, and National File Tracking System of Records, November 21, 2013, 78 FR 69864 and DHS-USCIS-007 –Benefits Information System, September 29, 2008, 73 FR 56596. The associated privacy impact assessment is DHS/USCIS/PIA-016 – Benefits Processing of Applicants other than Petitions for Naturalization, Refugee Status, and Asylum (CLAIMS 3).

11. 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.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• 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 OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate*	Total Annual Respondent Cost
Individuals and Households	G-1145, E-Notification of Application /Petition Acceptance	1,180,000	1	0.05 (3 minutes)	59,000	$30.81	$1,817,790
Total		1,180,000	1	0.05	59,000	$30.81	$1,817,790

*  The above Average Hourly Wage Rate is derived from the May 2012 Bureau of Labor Statistics Mean Hourly Wage for “[Enter Occupation]”.  The wage rate of $30.81 is calculated from the base average wage rate of $22.01 times the wage rate benefit multiplier of 1.4.  The selection of “All Occupations” represents the possibility that respondents can be employed in any type of work; the collection is not targeting any specific category of employment.

13. Provide an estimate 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 estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995; (2) to achieve regulatory compliance with requirements not associated with the information collection; (3) for reasons other than to provide information or keep records for the government; or, (4) as part of customary and usual business or private practices.

There are no capital or start-up costs associated with this information collection.

14. Provide estimates of annualized cost 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. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annualized Cost Analysis:

a. Printing Cost $ 0

b. Collecting and Processing $ 55,000

c. Total Annual Cost to Government $ 55,000

Government Cost

The estimated cost to the Government is $55,000. This figure is derived based on the maintenance cost for e-mail and text message capability at $55,000.

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

(From Question 12 above)

	Program Change			Adjustment
Information Collection Instrument	Current OMB-Approved Hours Burden	New Hours Burden	Difference	Current OMB-Approved Burden Hours	New Hours Burden	Difference
Form G-1145				50,000	59,000	9,000
Total(s)				50,000	59,000	9,000

There is an increase of 9,000 total annual burden hours from the previously reported for this information collection, from 50,000 annual burden hours to 59,000. This increase may be attributed to the increase in the estimated number of respondents to this from 1,000,000 to 1,180,000, based an adjustment in agency estimates. There is no change in the information being collected.

(From Question 13 above)

	Program Change			Adjustment
Information Collection Instrument	Current OMB-Approved Burden Cost	New Cost Burden	Difference	Current OMB-Approved Burden Cost	New Cost Burden	Difference
				0	0	0
Total(s)				0	0	0

There is no change in the public cost burden previously reported for this information collection.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

USCIS does not intend to employ the use of statistics for this collection of information.

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

USCIS will display the expiration date for OMB approval of this information collection.

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

USCIS does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved with this collection.

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