3090-0163_Supporting Statement

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION

3090-0163, INFORMATION SPECIFIC TO A CONTRACT OR
CONTRACTING ACTION (NOT REQUIRED BY REGULATION)

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.

The General Services Administration (GSA) has various mission responsibilities related to the acquisition and provision of supplies, transportation, information technology, telecommunications, real property management, and disposal of real and personal property. These mission responsibilities generate requirements that are realized through the solicitation and award of public contracts. In Fiscal Year 2013, these contracts had values ranging from under $100 to over $300,000,000.

Most GSA procurement-related information collections are required by the Federal Acquisition Regulation (FAR) or General Services Administration Acquisition Regulation (GSAR); each clause requiring such a collection must be individually approved by the Office of Management and Budget (OMB). However, some solicitations require contractors to submit information specific to that contracting action, such as information needed to evaluate offers (e.g. specific instructions for technical and price proposals, references for past performance) or data used to administer resulting contracts (e.g. project management plans).

This information collection is currently associated with GSA’s information collection requirements contained in solicitations issued in accordance with the Uniform Contract Format under FAR Part 14, Sealed Bidding (see GSAR 514.201-1); FAR Part 15, Contracting by Negotiation (see GSAR 515.204-1); and solicitations under FAR Part 12, Acquisition of Commercial Items, when issued in accordance with the policy and procedures of FAR Part 14 and FAR Part 15 (see GSAR 512.301). This includes information collection requirements found in GSA Federal Supply Schedule (FSS) solicitations.

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.

Contracting officers use the information to evaluate offers and administer resulting contracts. Such information is also necessary for program managers to make informed decisions germane to those specialized areas.

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.

GSA uses improved information technology to the maximum extent practicable. Where both GSA and contractors are capable of electronic interchange, the contractors may submit information requirements electronically.

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.

As indicated in Question 1 above, the requirements are not mandated by regulation and usually are germane to a particular solicitation or resulting contract(s).

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

Burdens usually apply equally to large and small businesses that want to contract with GSA. Burden is kept to the minimum necessary to meet the specific objectives of a solicitation or contract.

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.

Offers could not be properly evaluated, specific program objectives would not be met, or performance could not be measured.

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;

• Prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• Submit more than an original and 2 copies of any document;

• Retain records, other than health, medical, government contracts, grant-in-aid, or tax records, for more than 3 years;

• In connection with a statistical survey, that is not designed to produce valid, reliable results that can be generalized to the universe of study;

• Require the use of a statistical classification that has not been reviewed and approved by OMB;

• Include 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

• Submit proprietary trade secrets, 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.

Upon occasion due to urgency of a procurement or when conducting an acquisition of commercial items, respondents may be requested to prepare a written response to a collection of information (response to solicitation for offers) in fewer than 30 days after receipt of the request. Respondents may also be required by contract to submit information more often than quarterly (e.g. monthly). An example of a monthly reporting requirement is a project progress plan.

8. If applicable, provide a copy and identify the date 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.

A 30 day notice was published in the Federal Register at 79 FR 42514 on July 22, 2014. No comments were received. A 60 day notice was published in the Federal Register at 79 FR 62620 on October 20, 2014.

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

GSA makes no such payments under this collection.

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

Confidentiality will be provided to contractors in accordance with prudent business practices and current regulations.

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.

No sensitive questions are involved.

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.

• 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 13.

The estimated number of respondents annually is 267,021, with one response per respondent. Each response requires 0.40 hours for a total of 106,808 hours. Time estimates are based on professional judgment. The number of respondents is based on data from the Federal Procurement Data System (FPDS) for Fiscal Year (FY) 2013, which shows GSA made approximately 64,000 new awards with 262,995 offers received. Additionally, the Federal Acquisition Service, Office of Acquisition Management, determined there were 4,026 offers received for Federal Supply Schedule (FSS) contracts; FSS offers are coded uniquely in FPDS because those contracts have standing solicitations, so they were not included in the 262,995 figure.

Estimated respondents/yr……………………………………….. 267,021

Total Responses annually………………………………………. 267,021

Estimated hours/response………………………………………. x 0.40

Estimated total burden hours……………………………………. 106,808

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers 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) 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.

Given the nature of the requests, reliable cost estimates are not available. Costs are captured in burden hours as shown in paragraph 12.

14. Provide estimates of annualized costs to the Federal Government. Also, provide a description of the method used to estimate cost, which should include qualification 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Estimate of the burden hours to the Federal Government is 66,800 hours. Reviewing and processing each response should take approximately 0.25 hours (15 minutes) per response; the total number of responses is estimated to be 267,021 each year. 267,021 responses multiplied by 0.25 hours equals 66,800 hours.

The total cost to the Government is $2,743,486, based on the 66,800 burden hours to the Government, multiplied by $41.07/hour.¹

Reviewing Time/hr 0.25 hours

Requests/year x 267,021

Review Time/year 66,800 hours

Average Cost/hr x $41.07

Total Government Cost $2,743,486

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14.

The total cost burden for Item 14 increased from $1,712,760 (2011 estimate) to $2,743,486 (2014 estimate). The following is a comparison of the total Government cost burden elements from 2011 to 2014:

• Reviewing Time/hr: This figure, 0.25 hours, is unchanged from 2011.

• Requests/year: This figure increased from 171,275 requests/year to 267,021 requests/year, based on information obtained from the Federal Acquisition Service and the Federal Procurement Data System (FPDS) for Fiscal Year 2013.

• Review Time/year: The increase from 42,819 hours/year to 66,800 hours/year is the result of the increase in the number of requests per year.

• Average Cost/hr: The current rate, $41.07/hour, is an increase over the previous rate of $40.00/hour.

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.

Results will not be tabulated or published. Data collected will be used for internal administration of contracts.

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.

GSA is not seeking such approval for this collection.

18. Explain each exception to the certification statement identified in Item 19,

“Certification for Paperwork Reduction Act Submissions”.

GSA has no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

Statistical methods are not used in this information collection.

1 GS-12, Step 5 hourly rate of $41.07 in the Washington, DC/Baltimore/Northern Virginia locality (Salary Table 2014-DCB Washington-Baltimore, DC-MD-VA-WV-PA, Effective January 2014).

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