White Paper Justification for Non-Substantive Change

Request for Non-Substantive Change Approval
for Collecting Social Security numbers from
Non-Veteran Owners

Situation

The Department of Veterans Affairs (VA), Office of Small and Disadvantaged Utilization (OSDBU) requests approval for a non-substantive change under the Paperwork Reduction Act (PRA). The VA Form 0877 currently collects social security numbers from Veterans and Service-Disabled Veterans who have an ownership interest in companies seeking to participate in the VA’s set-aside procurement program for Veteran and Service-Disabled Veteran Owned Companies.  OSDBU now seeks to collect social security numbers from non-Veterans and spouses of deceased Veterans who have an ownership interest in companies seeking to participate in the VA’s set-aside procurement program for Veteran and Service-Disabled Veteran Owned Companies, who are currently identified on the form.  

The current version of VA Form 0877 specifically limits collection of social security numbers to only Veterans and Service-Disabled Veterans.  With the ability to collect social security numbers from all members in an applicant’s ownership structure, the VA will have access to additional resources to collect background information, from sites such as Thomson Reuters (Clear) and LexisNexis (Investigative Solutions), on businesses seeking to contract with the VA.  The VA also seeks to amend VA Form 0877 to clarify certain content on the form and to edit specific typographical errors. 

The collection of social security numbers does not impose a significant burden since the information is readily available to each business owner. There will be no additional burden to many companies, as these are owned by a single or various Veterans and Service-Disabled owners. The companies owned by non-Veterans will need to include their social security numbers to the form. Its use will be limited to the examination of individual applicants for the program. Lastly, the information is neither intended for public dissemination nor will it be used for compiling statistical data.

Summary

The VA administers a set-aside procurement program in which companies found eligible are allow to be verified and participate. To improve the integrity of the program at the earliest possible date, OSDBU requests that this process improvement be approved as a non-substantive change.