1615-0080_Supporting Statement USCIS Case Status Online_FINAL5 27JAN2016

SUPPORTING STATEMENT FOR

USCIS Case Status Online

OMB Control No.: 1615-0080

COLLECTION INSTRUMENT(S): No Agency Form Number; File No. OMB-33

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 U.S. Citizenship and Immigration Service (USCIS) receives and adjudicates approximately 6 million petitions and applications annually from individuals and employers. After an individual submits an application for an USCIS service or benefit, the individual or organization acting on behalf of the individual will often request the status of the application or case.

USCIS Case Status Service Online permits individuals and organizations to electronically receive and view the status of their application or most current action. Users of the online service create an account (approved under OMB Control Number 1615-0122, USCIS ICAM) to identify and match the requestor with an application or case.

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.

The data entered into the Web site to create an account permits USCIS to match the requestor with the status of their application or case. The data to create an account is only entered the first time that an individual logs into the Web site. On subsequent visits the requestor needs to enter their login ID and password.

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 collection of information involves electronic responses through the Internet and USCIS Case Status Online can be accessed at https://egov.uscis.gov/casestatus/landing.do. Using a Web site to collect a minimal amount of information to identify the requestor is the most efficient and timely method for providing status information to the public. Storing a respondent’s profile reduces the public’s burden when subsequent visits are made to the system.

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 information collected is the minimal amount necessary to allow access to the respondent’s status. The information may duplicate that collected elsewhere, but it is necessary to allow a respondent to obtain the desired status update.

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.

The collection of information reduces the existing burden on small businesses and organizations that support USCIS customers through the use of technology to allow these small businesses or small entities (law firms or advocacy groups) to receive instant responses to their inquiries.

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.

Other methodologies for case status requests/inquiries include telephone calls and office visits. Telephone communications are constrained by the number of lines and staff available. Local office interaction is constrained by distance from the location handling the case, and the number of staff and hours available in the business day to respond to requests or inquiries. The time invested by an individual in telephoning a call center or visiting a local office is considerably higher than the 4 1/2 minutes. The waiting time in lines at large local offices can be measured in hours. The website information collection burden is minimal and the frequency of collection is once. The only technical obstacles to using the USCIS Case Status Online website are access to a computer and Internet; there are no legal obstacles.

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 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 October 19, 2015, USCIS published a 60-day notice in the Federal Register at 80 FR 63243. USCIS did receive two comments after publishing that notice.

Comment 1: One commenter indicating that the USCIS Case Status Online does not provide the most recent updates to an individual’s case, nor does it provide an estimated duration for processing of an individual’s case. In addition, the commenter indicated that USCIS should provide not just an estimated duration time for processing, but also identify the next step in the individual’s case processing.

USCIS Response: USCIS responded by stating that innovation, process development, and technology are critical to creating the conditions for a memorable, and transformative customer experience for USCIS’ customers. USCIS also stated that the agency strives to leverage service and technology innovations to build that experience. The current mission extends across multiple areas of technology, from the call centers to online services for all USCIS customers, resulting in several improvements, new services, and strategic shifts. The strategic use of technology and systems integration provides an enhanced experience for customers.

Comment 2: One commenter indicated that expanding the 3-day rule to 5 days would be beneficial for employers to process an E-verify query.

USCIS Response: USCIS reviewed the comment and determined the comment was outside the scope of the current extension, which is to allow USCIS to continue collecting information to allow first-time users of the USCIS Case Status Online to set up access accounts.

On January 15, 2016, USCIS published a 30-day notice in the Federal Register at 81 FR 2228. USCIS has not received any comments to date.

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

The 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 United States Citizenship and Immigration Services Benefits Information System, which was published in the Federal Register on September 29, 2008, at 73 FR 56596 (DHS/USCIS-007).

The privacy impact assessment associated with this information collection is DHS/USCIS/PIA-019(b) - Customer Relationship Interface System (CRIS) Update, August 15, 2013.

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	USCIS Case Status Online	7,020,000	1	0.075	526,500	$31.79	$16,737,435
Total		7,020,000			526,500		$16,737,435

* The above Average Hourly Wage Rate is the May 2014 Bureau of Labor Statistics average wage for “All Occupations” of $22.71 times the wage rate benefit multiplier of 1.4 (to account for benefits provided) equaling $31.79.  The selection of “All Occupations” was chosen as the expected respondents for this collection could be expected to be from any occupation.

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. Processing Cost $ 3,120

c. Total Annual Cost to Government $ 3,120

Government Cost.

The estimated cost of the program to the Government is $3,120. This figure is based on the number of hours to update the status database multiplied by average hourly rate of a GS-11 employee. This calculation is: approx. average GS-11 rate of $30 x 104 hours = $3,120

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

Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
USCIS Case Status Online	0	0	0	1,500,000	526,500	973,500
Total(s)	0	0	0	1,500,000	526,500	973,500

The reduction in the total annual hour burden is due to better estimation of the number of respondents for this collection of information. This estimate is based on USCIS experience in monitoring the system’s use during the past several years. The estimated number of respondents is derived by multiplying 135,000 weekly first-time account users by 52 weeks.

Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
USCIS Case Status Online	0	0	0	0	0	0
Total(s)	0	0	0	0	0	0

There is no change in the estimated public cost burden.

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.

This information collection will not be published for statistical purposes.

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.

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