Justification 2900-0117_82016

Supporting Statement for VA Form Letter 5-127,

Inquiry concerning Applicant for Employment

(2900-0117)

A. Justification

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

VA Form Letter 5-127 is used by VA personnel officials to verify qualifications and determine suitability of applications for VA employment. This information is obtained from individuals who have knowledge of the applicant’s past work record, performance, and character. VA Handbook 5005, part II, chapter 2, section A, paragraph 5d(3), requires verification of employment and suitability that necessitate 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 information obtained through use of VA Form Letter 5-127 is used by appointing officials in determining an applicant’s suitability and qualifications for employment. If the information were not collected, the risk of appointing unqualified or unsuitable individuals would increase.

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 use of automated collection techniques is not anticipated because responding to the collection of information is voluntary and VA needs to obtain the signature of the individual supplying the requested information.

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.

There is no duplication associated with this collection of information.

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

The impact on small businesses and other small entitles are minimized by using “standard” or data routinely maintained by health care facilities. The collection of information has been thoroughly analyzed to ensure that all requested is essential.

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.

If VA does not require this information, the risk of appointing unqualified or unsuitable individuals would increase.

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 special circumstances requiring that the collection be conducted in any manner inconsistent with 5 CFR 1320.6 guidelines.

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 agency notice was published in the Federal Register, Volume 81, Number 120, June 22, 2016, pages 40771. There were no comments received.

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

No payments or gifts to respondents have been made under this collection of information.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

We comply with the provisions of Title 38, U.S. Code 3301 and the Privacy Act of 1974, Title 5, U.S. Code 552a. In addition, the respondents have the opportunity to choose whether they want their identities revealed to the applicant. If the respondent does not want to be identified, VA personnel officials are required to comply.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), 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:

Estimate of Information Collection Burden:

1. Number of respondents is estimated at 12,500 per year.

2. Frequency of response is one time

3. Average time is 15 minutes.

4. Annual burden is 3,125 hours.

5. Annual cost to respondents $94,031.25 (3,125 hours x $ 30.09 per hour)

*Cost derived from U.S. Bureau of Labor Statistics (BLS) occupational code 13-1071, hourly means for a Human Resources Specialist.

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).

This collection does not involve a recordkeeping cost burden to respondents.

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.

Estimate of the Cost to the Federal government - $27,068

Mailing Cost $16,625

Collecting and Processing Costs $ 2,343

Analytical Cost $ 7,100

Printing and Distribution Cost $ 1,000

Total Cost $27,068

15. Explain the reason for any burden hour changes since the last submission.

There is no change in 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.

The information collected is not for publication or statistical use.

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.

VA does not wish to omit the expiration date.

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

This submission does not contain any exceptions to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Statistical methods are not applicable.