3245-0360 Sbw Icr Supporting Statement 8-19=15

SUPPORTING STATEMENT

U.S. Small Business Administration

SMALL BUSINESS ADMINISTRATION AWARD NOMINATION

INFORMATION COLLECTION 3245-0360

SBA FORMS 3300-3314

AWARD NOMINATION FORM

A: JUSTIFICATION

1. Circumstances necessitating the collection of information

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.

Sections 4(h) and 8(b)(l)(A)(iv) of the Small Business Act, 15 U.S.C. 633(h) and 637(b)

(1)(A)(iv), authorize the Administrator of the U.S. Small Business Administration (SBA) to recognize achievements of small businesses through appropriate events and activities. (Copies of these provisions are attached). In recognition of the small business community's contributions to the nation's economy and society, the President of the United States designates one week each year as Small Business Week. Leading up to that week, the U.S. Small Business Administration seeks nominations for various recognition awards honoring the nation's small business owners and entrepreneurs, small business advocates, and small businesses. Recognition awards are presented by SBA to winners at the district, regional and national levels. Potential award recipients are nominated by banks, Small Business Development Centers, employees, spouses or self-nomination. This information collection, Small Business Administration Award Nomination Form, and other information set out in the Awards Nominations Guidelines, (copy attached) is used to facilitate the award selection process.

Amendments

This information collection currently consists of Form 3300, which is used to collect information on nominees for all Small Business Week related awards, and the Awards Nomination Guidelines (Guidelines). SBA has added two questions to this form. One relates to whether the nominee is presently debarred, suspended, proposed for debarment, or declared ineligible for the award of federal contracts or financial assistance. The other relates to the status of the nominee’s federal taxes.

In addition, SBA removed two questions from Form 3300 and added them to the specific award forms. Those questions involved forms of SBA funded assistance received and the percentage of ownership or stock owned in the small business.

Finally, SBA deleted from Form 3300 the question requesting place of birth, as it was unnecessary, and the question regarding Congressional District, as SBA can determine Congressional District from the address provided.

In an effort to streamline the nomination process, and reduce the burden on the responding public, SBA has also revised the Guidelines to eliminate the requirements for financial reports and created forms that are tailored to each specific award.

2. How, by whom, and for what purpose information will be used

The general public has the option to submit nominations via traditional mail or online through SBA’s nomination portal to the SBA. The SBA will use the nomination packages to select National Small Business Week winners on the state, regional or national levels.

The information collected on Form 3300 is used to identify an actual or apparent conflict of interest, to verify the accuracy of the information submitted with the nomination packets, and to apply defined evaluation criteria to each nominee's background to determine whether a nominee is eligible for a recognition award.

All nominees must be cleared by the U.S. Small Business Administration's Office of Diversity, Inclusion & Civil Rights (formerly the Office of Equal Employment Opportunity) and Office of Inspector General. These clearances are required to help verify the accuracy of the nomination packet and to preclude any potential conflict of interest or embarrassment to the nominee, the U.S. Government or the President of the United States. Once a nominee is cleared, the information collected is reviewed by a panel of SBA and non-SBA judges that evaluates nominees to determine whether they meet the evaluation criteria outlined in the Awards Nomination Guidelines.

In addition, if a visit to the White House has been approved for the winner of a particular award, certain information collected is forwarded to the White House to be used for clearance purposes.

The information collected on Forms 3301-3314, inclusive, will be used to evaluate the nominations and select the winners based on the criteria outlined in the nomination guidelines.

3. Technological collection technique

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 the burden.

The guidelines for eligibility and submission of information, as well as Forms 3300-3314 are available online at the agency website. The latter may be filled in online and downloaded for submission or downloaded for completion, manually. The agency accepts electronic submissions as well as hard copy submissions.

4. Avoidance of Duplication

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.

Those award nominees who have applied for, or received SBA assistance may have previously provided some of the information requested. However, because applications for SBA assistance are not centrally located, it is not always possible to readily match up any prior particular collection of information. In addition, it is important to obtain information that is as current as possible. SBA minimizes the burden by requesting only the minimal information necessary to make informed selections.

5. Impact on small businesses or other small entities

If the collection of information impacts small businesses or other small entities (Item 5 of

OMB Form 83-1), describe any methods used to minimize burden.

The only small businesses impacted by the collection of this information are those owned or operated by the award nominees. This information collection will not have a significant economic impact on the approximately 600 who respond to this collection of information. In any event, the information requested should be readily available from the nominees' personal and business records. Information that may not be in those records, such as Congressional District, is also easily obtainable.

6. Consequences if collection of information is not conducted

Describe the consequence to the 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.

The information collected is required to determine whether an award nominee has an actual or apparent conflict of interest. The information is also used to evaluate the nominations and select the winners based on the criteria outlined in the nomination guidelines. If the information is not provided, the Agency would be unable to vet or evaluate the nominees. In addition, a credible recognition awards program would not be possible and the SBA would be hampered in its efforts to recognize outstanding small businesses.

7. Existence of special circumstances

Explain any special circumstances that would cause an information collection to be

conducted in a manner, etc.

A respondent may be required to respond to the request for the collection of information on Form 3300 in less than thirty days only if the person who nominates the respondent nominates the respondent within the thirty days prior to the due date for the completed nomination packet for the particular recognition award.

Confidential financial or personal information is requested but the Agency can demonstrate that it will protect the confidentiality of the information to the extent permitted by the law. The information collected is kept in a locked area, with access restricted to a limited number of employees who are directly responsible for the award nomination process.

8. Solicitation of Public Comment

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. 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 , and the data elements to be recorded, disclosed, or reported.

A request for public comment was published in the Federal Register at 80 FR 34484 on June 16, 2015. The comment period ended on August 17, 2015; no comments were received.

9. Payment of gifts

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

No payment or gift will be provided to respondents for completing this information collection. However, award winners will receive some tangible item of nominal value, such as a trophy, plaque, or award certificate to commemorate their achievements.

10. Assurance of Confidentiality

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

SBA informs nominees that their information will be protected to the extent permitted by law, including the Freedom of Information Act, 5 U.S.C. 552, and the Privacy Act, 5 U.S.C. 552a.

11. Questions of a sensitive nature

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.

Some of the information collected, such as criminal history, citizenship, and residential address may be considered sensitive or private. SBA protects the information to the extent permitted by law. The agency has a Privacy Act System of Records, SBA 28 -- Small Business Person and Advocate Awards, that covers this information (see attached copy). Information regarding the Privacy Act rights as outlined in this notice is provided to respondents as part of the information collection request. The notice was last published in the Federal Register at 74 FR 14890 (April 1, 2009).

12. Estimate the hourly burden of the collection of information

Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

Each year, approximately 600 award nominees respond to this information collection as part of the annual recognition award program process. Each nominee submits Form 3300 regardless of the award, as well as the specific form that relates to the nominated award ( i.e. from the 3301-3314 series of forms). Respondents will spend an estimated average of 90 minutes responding to the information collection, including reading the questions, locating specific information in their business or personal files, determining their congressional district, and answering the questions. The burden for Form 3300 is 15 minutes and for each of the forms 3301-3314 the burden is 75 minutes. The estimated aggregate annual time burden is therefore approximately 900 hours per year.

Generally, an administrative assistant, loan officer, Small Business Development Center personnel or the nominee will collect and submit the information. SBA estimates that the wage level of such personnel is equivalent to the average wage for a GS-9 employee. As such the estimated hour cost burden: is as follows:

Average hourly wage for person completing collection: $20.32

Total cost per response: $20.32 x 1.5 hours= $30.48

Total estimated cost burden: 600 x $30.48= $18,288

13. Estimate the total annual cost burden for submission

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

resulting from the collection of information.

The estimated annual cost burden per respondent for submission is $4.82 (mail) or $15.00 (courier) depending on respondent's choice of delivery. Generally approximately 260 nominees submit the information by first class mail and 100 by courier. The estimated aggregate annual cost burden is therefore $2,753.20. ($4.82 X 260 = 1,253.20) + ($15.00 X 100 = $1500.00).

14. Annualized Cost to the Federal Government

Provide estimates of annualized costs 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.

The cost to the Federal Government for handling this information collection is negligible. SBA employees will review the form and manage the entire nomination and selection process as part of their regularly assigned duties.

15. Explanation of program changes in Items 13 or 14 on OMB Form 83-I

Explain reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1

The estimated total annual cost burden for submissions has decreased as SBA accepts online nominations. SBA also estimates a decrease in the hour burden due primarily to the elimination of the requirement to submit three years of financial statements.

16. Collection of information whose results will be published.

For collection of information whose results will be published, outline plans for tabulation and publication. Address complex analytical techniques ... Provide time schedules for the entire project.

Winners receive extensive local media coverage. Biographical and relevant business Information pertaining to the winners will be provided to the media upon request.

The estimated project schedule for the 2016 Small Business Week award program is as follows:

• Nominations will be submitted to the nearest U.S. Small Business Administration district office in the nominee's state or district by a deadline of January 11, 2016.

• April 15: State winners will be announced.

• State and District winners will be honored some time during calendar year 2016 on dates to be determined by the state or district offices.

• May 2016: National winners will be announced and honored at the Small Business Week celebration.

The timeline for subsequent years will be similar, with national awards being presented in either April or May depending on conference center availability.

17. ·Expiration date for collection of information

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

Not applicable.

18. Exceptions to certification in block 19 on OMB Form 83-I

Explain each exception to the certification statement identified in Item 19, ''Certification for Paperwork Reduction Act Submission” of OMB Form 83-1.

Not Applicable.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used.

Not applicable. Statistical methods will not be employed to analyze the information collected or to determine award winners.

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