SSF3237-SupportingStatement_2016

United States Secret Service

SUPPORTING STATEMENT

OMB Control No. 1620-0002

SSF 3237

1. CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION

Information collected on Secret Service Form (SSF) 3237, U.S. Secret Service Facility Access Request, is necessary to ensure that all Secret Service contractor personnel or non-Secret Service Government employees on official business that require access to Secret Service controlled facilities in performance of official duties meet minimum-security standards prior to admission into those facilities. Authority to collect the information sought on this form is derived from Title 18 U.S.C. section 3056 and Executive Order 9397.

This collection is a revision of an approved collection. However, the revisions to the collection instrument are not due to a statutory requirement.

2. USE OF DATA

The Secret Service will use the information provided for determining suitability for admission to Secret Service controlled facilities by non-Secret Service personnel. Employees of the Security Management Division, Clearance and Access Branch, who make the determination regarding suitability for admittance, review this information.

In this current revision, the Secret Service determined that some data no longer needs to be collected from the public. One additional question was added to the collection. Please see the response to question number 15 for specific revisions to the collection instrument.

3. USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN

This form is available in electronic format. The Security Management Division will distribute this form via e-mail, if appropriate. However, because this form includes a release statement which gives the USSS permission to request personal information from third parties, pen and ink signature is required. (Due to the sensitive nature of the personal data being requested, the various Federal, State, local police, and other agencies (many of which are private sector credit bureaus, reporting agencies, etc.) require a physical, tangible signature before they will disclosure personal information.) While this form may be accessed electronically, it must be printed; it cannot be submitted electronically.

4. EFFORTS TO IDENTIFY DUPLICATION

No duplication exists, as there are no other forms or exhibits used for the purpose specified under Item 2 above. Individual requests are evaluated and rated by the USSS on the merits of the responses submitted with the request. Each request is unique. The information contained in each request relates to a particular individual’s need for access to a specific site and/or facilities, as well as access to potentially sensitive materials.

5. IMPACT ON SMALL BUSINESS

There is no substantive impact on small businesses.

6. CONSEQUENCES TO FEDERAL PROGRAMS IF COLLECTION IS NOT CONDUCTED OR IS CONDUCTED LESS FREQUENTLY

Vital work supporting Secret Service missions would unnecessarily be delayed until such time that the Secret Service could hire full time employees to carry out functions normally handled by contractor employees.

7. SPECIAL CIRCUMSTANCES

There are no special circumstances that would cause this information collection to be conducted in a manner which:

• Requires respondents to report information to the agency more than quarterly;

• Requires respondents to submit more than one original and two copies of any document;

• Requires respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

• Requires 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;

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

• 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

• Requires 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.

8. CONSULTATION WITH OUTSIDE AGENCIES, ETC.

Request for Comments [1620-0002]: Public comments were solicited through both a 60-Day Federal Register notice (dated 05/16/2016 and published in the Federal Register on May 19, 2016 (81 FR 31652), and a 30-Day Federal Register notice (dated 07/19/2016 and published in the Federal Register on July 27, 2016 (81 FR 49245). The comment period will end on August 26, 2016. As of this submission, no comments have been received regarding SSF 3237. If the Secret Service receives any comments while this collection is under review with OMB, they will be forwarded to OMB immediately.

9. EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS

There are no payments or gifts to respondents.

10. ASSURANCE OF CONFIDENTIALITY TO RESPONDENT

Confidentiality is assured under the provisions of the Privacy Act of 1974, Title 5 of the United States Code, Section 552a. It is recognized, however, that in addition to disclosures generally permitted under 5 U.S.C. 552a(b) of the Privacy Act, all or a portion of the records or information contained in this system may be disclosed outside the Department of Homeland Security (DHS) as a routine use pursuant to 5 U.S.C. 552a(b)(3), subject to certain specific conditions. This collection of information is covered under Department of Homeland Security/United States Secret Service Privacy Act System of Records 004, Protection Information System of Records (76 FR 66940).

11. ADDITIONAL JUSTIFICATION FOR QUESTIONS OF A SENSITIVE NATURE

There are questions of a sensitive nature to ensure that all government or contractor employees working within Secret Service controlled facilities meet minimum security standards prior to admission into those facilities. Authority to collect the information sought on this form is derived from Title 18 U.S.C. section 3056 and Executive Order 9397

12. ESTIMATED BURDEN OF INFORMATION COLLECTION

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 of Res-pondents*	Estimated Total Annual Res-pondent Cost
Individuals and Households	Secret Service Form (SSF) 3237, U.S. Secret Service Facility Access Request	5,000	1	15 minutes (0.25 hours)	1,250	$31.79	$39,738

*The above Average Hourly Wage Rate is the May 2014 Bureau of Labor Statistics average wage for “All Occupations” of $22.71 multiplied by the wage/benefit rate 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 from any occupation.

13. ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS

The estimated total annual cost burden to respondents is zero. There are no capital or start-up costs or operational and maintenance costs for this collection.

14. ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT

The estimated annual cost to the Federal Government associated with the review of these records is $98,325. This is based on the number of responses (5,000) that must be reviewed (x) the time to review and process each response (15 minutes or .25 hours = 1250 hours) (x) the average hourly rate of the reviewer* ($42.66) (+) a $9 fee the Government pays for each response to check each contractor’s credit history ($45,000) = $98,325.

*The average hourly rate of the Government full time equivalent (FTE) employee reviewing these forms is calculated by the employee's hourly rate of basic pay, $42.66 ($92,145/2,087 hours) for GS-13, step 1 (FTE are GS-12 or GS-13 grade; GS-13 step 1 represents the median salary (OPM: “Fact Sheet: Computing Hourly Rates of Pay Using the 2,087-Hour Divisor”).

15. REASONS FOR CHANGE IN BURDEN

There is no change in burden. This information collection is a revision of an existing collection; however for the public responder only one question was added and three questions were deleted. Along with additional verbiage on page 2 of this form, there is no change in burden to the public. Please see attached narrative of changes table for specific revisions.

16. PUBLICATION OF COLLECTION OF INFORMATION

This information collection will not be published for statistical purposes.

17. REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE

The USSS will display the expiration date for the OMB approval for this information collection.

18. EXCEPTIONS TO THE CERTIFICATION STATEMENT ON OMB FORM 83 - I

There are no exceptions to the certification statement identified in item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.

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