2900-0090 justification 111215

SUPPORTING STATEMENT FOR 2900-0090, CONTINUED

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

This application (VA Form 10-7055 and the associated web form) will be here-in-after referred to as the form. The form is used to assist personnel of volunteer organizations, which recruit volunteers from their membership, and the Department of Veterans Affairs (VA) in the selection, screening and placement of volunteers in the nationwide VA Voluntary Service program. The volunteer program supplements the medical care and treatment of Veteran patients in all VA medical facilities. This form is necessary to assist in determining the suitability and placement of potential volunteers. The information is collected under the authority of 38 U.S.C. 513 and 7405(a)(1)(D). Additionally, a uniform application process and personnel file is a requirement of The Joint Commission, the accrediting body for VA medical facilities. As volunteers are consider without-compensation employees (WOC’s), Voluntary Service programs must be in compliance with the collection of this information.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

The form is used by the office representatives of voluntary organizations, by the Voluntary Service Program Manager and, as needed, by the Service in the medical facilities where the volunteer will be placed. The form is generally filled out when a person comes to a VA medical facility requesting a volunteer assignment. Selection and placement is made based upon this application. As a by-product, some of the information on the form is also used to enter the volunteer's name into an automated database through which the records of the service of individual volunteers are maintained. If this data was not collected, volunteer assignments would neither satisfy the volunteer nor the VA.

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.

To comply with the Government Paperwork Elimination Act (GPEA), and permit electronic submission of this information, the prospective volunteer has two electronic methods of expressing interest in the VA Voluntary Service program. VA made the form available through the internet in two ways.

The form (Application for Voluntary Service) is currently available in a “print and fill” mode on the 1-VA Forms Web Site http://www.va.gov/vaforms/. This enables the user to electronically retrieve the latest version of the form, fill the form electronically and either mail the form to the desired location or hand deliver it. We had hoped to re-engineer the business process so that the potential volunteer could electronically transmit a completed form to the office where they would like to volunteer. However, we developed an alternate means for prospective volunteers to express an interest in volunteering.

There are provisions on the Voluntary Service Web Site for volunteers to transmit a volunteer information request directly to the facility where they are interested in donating time. A copy of this request is also forwarded to VA Central Office for quality assurance purposes. The Voluntary Service website is http://www.volunteer.va.gov/.

4. Describe effort 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.

There is no other source to obtain the needed information, as the respondent knows this best.

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

The collection of information does not involve small business or other small entities.

6. Describe the consequences 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.

This is an application form used once per respondent.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; 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 and require the use of a statistical data classification that has not been reviewed and approved by OMB.

There are no such special circumstances.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’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 sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The notice of Proposed Information Collection Activity was published in the Federal Register on August 3, 2015 (Volume 80, Number 46105, Pages 46105-46106). We received no comments in response to this notice.

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

No payment or gift is provided to respondents.

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

Respondents are informed that the information collected will become part of the system of records identified as "Voluntary Service Records-VA" (57VA135), as set forth in the Compilation of Privacy Act Issuances via online GPO access at http://www.gpoaccess.gov/.

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; include 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. Estimate of the hour burden of the collection of information:

a. The annual turnover rate in the some 118,000 regularly scheduled volunteers on the rolls can vary considerably from year to year and is affected by the general mobility of the population, state of the economy and ages of the volunteers. The form is used only with persons interested in regular volunteer assignments (weekly/monthly); however, we estimate 32,000 applicants per year. Experience has shown that it takes approximately 15 minutes for a volunteer to complete the form. Therefore, we estimate the burden to be 8,000 hours (32,000 applicants x 0.25 hour).

b. 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 83-I.

This request covers only one form. However, this form may be the actual paper VA Form 10-7055, or an electronic application for voluntary service under the same form number (10-7055).

c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. 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.

This is estimated at $192,000 (8,000 burden hours x $24).

Source: U.S. Dept. of Labor Statistics

13. Provide an estimate of 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).

a. There is no capital, start-up, operation or maintenance costs.

b. Cost estimates are not expected to vary widely. The only cost is that for the time of the respondent.

c. There are no anticipated capital start-up cost components or requests to provide information.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation 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.

The total cost to the Federal Government of $200,554 is estimated as follows:

Postage (1,000 x $0.49): $490

Printing $800

Clerical (32,000 forms x 0.1 hour x $22.45/hour for GS 7/5) $71,840

Managerial (32,000 forms x 0.1 hour x $39.82/hour for GS 12/5) $127,424

15. Explain the reason for any program changes or adjustments reported in Items 13 or 14 of OMB 83-I

We anticipate no change in the number of respondents or burden hours.

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.

There are no plans to publish the results of the information collected.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

VA will include a valid expiration date in compliance with OMB rules.

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

There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

No statistical methods are used in this data collection.

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