FY17 Supporting_Statement_1653_0043 170531

Supporting Statement A

Electronic Funds Transfer Waiver Request

(Form 10-002)

OMB No. 1653-0043

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 information of the vendor, sole proprietor, or individual is necessary, so that the agency can identify those payees who have been waived from receiving federal payments via Electronic Funds Transfer (EFT).

Federal regulations 31C.F.R. Part 208.4 and F.A.R. 32.11 give the Federal Government the authority to waive a vendor, sole proprietor, or individual from the EFT requirements of the Debt Collection Improvement Act (DCIA) if they meet one or more of the seven conditions.

The Office of Professional Responsibility (OPR) request waivers for payment of confidential Tort claims, filed offices with non-payroll related travel issues also request waivers, and foreign payments to companies that do not support EFT.

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 vendor, sole proprietor, or individual must submit the EFT Waiver Request Form to the Office of Acquisition. The EFT Waiver Request Form must be approved by the Office of Financial Management, Dallas Finance Center (DFC) and Burlington Finance Center (BFC) in order to be exempted and waived from the EFT requirement, so that they can receive their federal payments in the form of a paper check. The EFT Waiver Request Form shall be used by DFC and BFC to track those payees, who have been exempted and waived from the EFT requirement. In addition, a periodic compliance review will be performed by DFC and BFC to determine if the warrant for the waiver is still met.

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 this form provides the most efficient means for collecting and processing the required data. Respondents are instructed to return completed forms to the agency via U.S. mail or by facsimile to the locations provided in the instructions on the form. Electronic submission of waiver forms has been discussed but would not be completed until the database is relocated to the DHS Data Center. The collection requires signatures and USICE currently does not fully support electronic signatures to enable this option presently.

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 other similar information currently available which can be used for this purpose.

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.

When a small business or small entity would like to be waived from the EFT requirement, they can complete the EFT Waiver Request Form before finalizing their contractual agreement in procurement. The Office of Acquisition (OAQ) would provide the small business or entity with the necessary form during their contractual proceedings upon request.

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.

Failure to collect the EFT Waiver Request Form from the non-EFT vendors/payees would cause the agency to become non-compliant with the EFT requirement prescribed in the Debt Collection Improvement Act (DCIA).

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 March 24, 2017, USICE published a notice in the Federal Register at 82 FR 15063, soliciting public review and comment on the information collection for a 60 day period. USICE received no public comments. On May 31, 2017, USICE published a follow up notice in the Federal Register at 82 FR 24986 soliciting public review and comment on the information collection for an additional 30 day period.

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

USICE 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.

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 person’s form whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private included in this collection.

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.

Annual Reporting Burden:

a. Number of Respondents: 650

b. Number of Responses per each Respondent: 1

c. Total Annual Responses: 650

d. Hours per Response: 0.50 Hr. (30 min.)

e. Total Annual Reporting Burden: 325 Hr.

The projected hours per response for this collection of information were derived by first breaking the process into three basic components:

Learning about the Law and the Form: 10 Minutes

Completion of the Form: 5 Minutes

Assembling and Filing the Form: 15 Minutes

Total Hours per Response: 30 Minutes

Annual Reporting Burden

Total annual reporting burden hours is 325 Hrs. This figure was derived by multiplying the number of respondents (650) x frequency of response (1) x (0.50 hours) per response.

Annual Cost Burden

The estimated annual cost burden is $ 3,250. This estimate is based on the number of respondents (650) x number of responses (1) x hours per response (0.50) x ($10) average hourly rate;

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. Collecting and Processing: $26,000

c. Total Cost to Program: $26,000

d. Fee Charge: $0

e. Total Annual Cost to Government $26,000

Government Cost

The estimated cost of the program to the Government is calculated by subtracting the Total Cost of Program from the Fee Charge. Total Cost of Program is calculated by the estimated number of respondents filing the Electronic Funds Transfer Waiver Request (650) x (1) hour (time required to collect and process) x $40 (Suggested average hourly rate for clerical, officer, and managerial time with benefits, plus a percent for the estimated overhead cost for printing, stocking, distributing and processing of this form).

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

There is no increase or decrease in the estimated annual burden hours previously reported for this information collection.

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.

USICE does not intend to employ the use of statistics or the publication thereof for this collection of information.

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.

USICE 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.

USICE does not request an exception to the certification of this information collection.