DS-86 Supporting Statement (7-2014)

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Statement of Non-Receipt of a U.S. Passport

OMB Number 1405-0146
DS-0086

1. JUSTIFICATION

1. The Statement of Non-Receipt of a U.S. Passport, Form DS-0086, is used by the U.S. Department of State to collect information for the purpose of issuing a replacement passport to customers who have not received the passport for which they originally applied.

The Secretary of State is authorized to issue U.S. passports under 22 U.S.C. § 211a et seq, 8 U.S.C. § 1104, and Executive Order 11295 (August 5, 1966).  Pursuant to 22 U.S.C. § 212 and 22 C.F.R. § 51.2, only U.S. nationals may be issued a U.S. passport. 

2. The information is used by the Department of State to help ensure that no person shall bear more than one valid or potentially valid U.S. passport book and one valid passport card at any one time, except as authorized by the Department, and is also used to combat fraud and misuse. The form solicits information relating to a passport applicant’s non-receipt of the U.S. passport book and/or passport card for which he/she applied.

3. In keeping with the Office of Management and Budget’s (OMB) terms of clearance stated on the Notice of Action for the previous collection – “State should continue to work to increase the availability and ease to find this form ", the Department will make the DS-86 form available (once approved), on the Department’s website, at http://www.travel.state.gov, where it can be filled out online and printed for submission.

The DS-86 is currently sent by mail along with a pre-addressed return envelope following notice of non-receipt of an application, and is matched by the sending agency to the information provided on the previously submitted application. The current process works because the particular agency/center that sends the form is the one adjudicating the application, and will receive the returned form and any additional documents the applicant provides.  It is not practical at this time to create or modify existing systems or to accept this form on-line. The Department systems are not currently set up to accept on-line submissions directly from existing applicants, or to match on-line submissions from the public to specific applications, and cannot yet accept large downloaded files directly from the public. However, the Department is currently using available resources to work towards online submission of the DS-64 and the DS-82, which will serve a large percentage of the traveling public. Once this has been successfully accomplished, the Department will then explore options for modifying systems to include the ability to submit additional forms directly online, including the DS-86.

4. Aside from necessary basic self-identification data, the information requested does not duplicate information available elsewhere. While this information was originally required on the DS-11, it is requested again on the DS-86 in order to accurately match the DS-86 to the correct DS-11 application for proper adjudication of this form.

5. The collection of information may have a minimal impact on small businesses and other small entities if the small business representative is required to travel overseas for business. A passport is generally needed for overseas activities, and to depart from and return to the United States.

6. The information cannot be collected less frequently, as it must be collected whenever a passport is not received by an applicant. Eliminating this collection would impede prompt re-issuance of passports to applicants when the original passport is not received.

7. No such special circumstances exist.

8. The 60-day Federal Register Notice soliciting public comment was published on March 31, 2014 (Public Notice 8677, at 79 FR 18111) and closed May 30, 2014. The Department of State received no comments on the 60-day notice in the Federal Register.

9. This information collection does not provide any payment or gift to respondents.

10. No promises of confidentiality are made to respondents, other than those contained in the Privacy Act and other federal statutes.

11. The DS-86 does not ask questions of a sensitive nature. The DS-86 collection of information asks the respondent to provide a Social Security number in order to assist in establishing and verifying the applicant’s identity. The applicant’s identity must be established before a passport can be issued. Moreover, passport applicants are requested to submit their Social Security numbers with the passport application (26 U.S.C. 6039E).

12. Passport Services estimates that the average time required for this information collection is 15 (minutes) or 0.25 (hour) per response. Therefore, the estimated total annual burden for this collection is:

15,005 (number of respondents) x 15 (minutes) / 60 = 3,751 hours per year.

The estimated number of minutes required per response is based on counting the time required to search existing data sources, gather the necessary information, provide the information required, make photocopies of the front and back side of the applicant’s identification document, review the final collection, and submit the collection to Passport Services for processing. Passport Services ascertained the estimated time required to complete the applicant’s portion of the form through consultation with a small group of Consular Affairs employees to validate the time. In addition, Passport Services has increased the estimated number of minutes per response from the previous 5 minutes to 15 minutes to allow for travel time for the applicants that will travel to a local business to make photocopies of their identification document.

To estimate the cost to respondents for this form based on the hourly wage and weighted wage multiplier, the Department calculated the following:

$22.60 (mean hourly earnings based on estimated income per hour from the Bureau of Labor Statistics http://www.bls.gov/ncs/ocs/sp/nctb1475.pdf ) x 1.4 (weighted wage OMB multiplier) = $31.64 weighted wage

3,751 (annual hours) x $31.64 (weighted wage) = $118,681 (yearly hour burden cost)

13. To properly complete and submit a DS-86, “Statement of Non-Receipt of a U.S. Passport” application, an applicant must submit a clear photocopy of the front and back side of an identification containing his/her photograph as specified in the Important Notice section on page 1 of the form.

The photocopy of an identification document was requested in the Important Notice section on the previous collection for this form; however, the cost for making a photocopy was not taken into account in the previous collection. In addition, the photocopy requirement has changed to include both the front and back side of the applicant’s photo identification. It is estimated that 50% of the applicants will have access to a photocopier at no cost, while the other 50% will require travel to a local business to make the photocopies of their identification document. The cost of a black and white photocopy of an identification card is $0.44 (front and back) based on a quote from a local copier business.

While the DS-86 is submitted by mail, the cost for postage is not included in the cost to the respondent as it is attributed to the sending agency. Following non receipt of an application, the Passport agency sends the DS-86 by mail along with a pre-addressed return envelope application to allow the applicant to return the form and any additional documents without having to pay postage. The DS-86 is matched by the sending agency to the previously submitted application.

There is no application fee associated with this collection. The increase in respondent cost is due to the photocopy cost that was not included in the previous collection, and to the new requirement to copy the front and back of the applicant’s identification. Therefore, based on an estimated 0.50 of the total 15,005 respondents/year, at an average cost of $0.44 for two copies (2 @ $0.22 each), it is estimated that 7,502 (0.50 respondents) x $0.44 (2 photocopies) equals a total cost burden of $3,301 to respondents per year for a three year period.

14. The Department pays a contractor for materials and/or supplies purchase functions to produce the DS-86 form.  The estimate provided to the Department by the contractor includes cost for contractor labor, supplies, equipment, printing, materials, delivery, overhead, support staff, etc.  Using the estimated projection of 15,005 respondents per year for FYs 2015– 2017 at a cost of $15.00 per thousand, the contractor cost to the Federal Government is $225.

Also, the Department is providing the passport specialist time and salary cost which was derived using 2011 Time and Motion (T&M) Study numbers that measured processes conducted by passport specialists. This includes time spent to adjudicate specific forms.  These average times were then used to calculate a weighted average of the number of respondents (application receipts) for each form to account for differing amounts of time required to adjudicate a particular form.  For forms that were not measured during the T&M study, no adjudication time multiplier was applied to the estimated number of respondents (hence the 1.0 value assigned to the multiplier). The weighted averages were then converted into percentages and multiplied by the total estimated salary and total number of hours spent on adjudication tasks for passport specialists to arrive at the cost and time required to process each form.  The total estimated salary is based on the existing ratio of grade levels at each passport agency and locality pay; the total number of hours is adjusted to reflect time spent only on adjudicative tasks.

Therefore, the DS-86 passport specialist adjudication cost is calculated as follows:

1.0 (adjudication time multiplier) x 15,005 (respondents) / 21,765,378 (total weighted avg. of respondents, all PPT forms) x $82,165,237 (total passport specialist salary) = $56,645

Or using numbers only,

[(1.0 x 15,005) / (21,765,378)] x $82,165,237) = $56,645

With regard to the material costs (use of office supplies, printing, overhead, etc.) incurred by the passport specialist when adjudicating the DS-11, the Department has determined these costs to be negligible.

Therefore, the total cost to the Government is:

225 (contractor) + $56,645 (passport specialist adjudication) = $56,870.

15. Form projections are based on re-issue counts. This figure accounts for all actual re-issues resulting from DS-86 submissions. This forecast is affected by application address typos, theft, and fraud.

The yearly projected numbers of respondents are based on demand forecast numbers from statistical models and historical trends of form usage. The primary driver for form usage is the demand forecast for each fiscal year. The next two fiscal years’ forecasts are updated on an annual basis so that each forecast uses the most recent, relevant data to project future demand. Given the limits of statistical model forecasting, the demand projections beyond two fiscal years are considered guidance, and are not supported by full statistical modeling. Given that projected passport application (DS-11) demand is the primary driver for form usage, the demand estimate used at the time of the previous submission (2011/2012) impacts the difference between actual and proposed number of respondents.

While the historical form usage decreased from 13,413 in 2010 to 11,951 in 2012, DS-86 use is expected to increase steadily in correlation with the DS-11 application estimate through FY 2017 as shown in the Projections table below.

	Historical Form Usage
Fiscal Year	2010	2011	2012
Total Passport Application (DS-11) Receipts	14,005,102	12,028,710	12,478,407
DS-86	13,413	11,520	11,951

	Projections
Fiscal Year	FY13	FY14	FY15	FY16	FY17
Passport Applications (DS-11)	14,000,000	14,000,000	14,500,000	15,500,000	17,000,000
DS-86	13,408	13,408	13,887	14,845	16,282

The “estimated annual responses” for the previous 2011 – 2014 renewal period of 12,755 was based on 5 minutes per response, however, this amount did not allow for travel time for the percentage of applicants (.050) who need to travel to make photocopies of their identification document. The current hour burden adjustment of 3,751 annual responses per year for the 2014 – 2017 renewal cycle forecasts an additional 10 minutes of travel time, which when added to the 5 minutes required to fill the form fields, results in an average estimated total of 15 minutes per response.

In addition to general format changes, the following content changes have been made to the form:

• Page 1, Form - Added U.S. to the form title.

• Page 1, Form - Added a Social Security number field.

• Page 1, Form – Added a “Travel Date” field.

• Page 1, Form – In the “Important Notice”, revised language to read:

“This application must be accompanied by a clear photocopy of the front and back of an identification document containing your photograph.”

• Page 1, Form – In the “Important Notice”, revised language to read:

“Should you receive the document you reported as not received at a later time, report it as found and submit it for cancellation”

• Page 1, Form - The “Parent/Legal Guardian Signature” line has been changed to read “Mother/Father/Parent/Legal Guardian’s Signature”

• Page 1, Form – Following the “Mother/Father/Parent/Legal Guardian’s Signature” field, added the following in parentheses:

“(if applicant is under age 16)”

• Page 2, Instructions - Underneath the section “How to Use this Form,” added the

following:

“To determine how and when to use this form, please contact the National Passport Information Center (NPIC) at 1-877-487-2778 (TDD: 1-888-874-7793).”

16. This collection of information will not be published for statistical use.

17. The expiration date for OMB approval will be displayed.

18. No exceptions to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions” are being requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

1. This collection does not employ statistical methods.