0579-0297 2017 SS (Secure)

June 2017
SUPPORTING STATEMENT
NATIONAL VETERINARY ACCREDITATION PROGRAM APPLICATION FORM
OMB NO. 0579-0297
This is a reinstatement of a previously approved information collection with changes.
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 Animal Health Protection Act (AHPA) of 2002 is the primary Federal law governing the protection
of animal health. The AHPA is contained in Title X, Subtitle E, Sections 10401-18 of P.L. 107-171, May
13, 2002, the Farm Security and Rural Investment Act of 2002. It gives the Secretary of Agriculture broad
authority to detect, control, or eradicate pests or diseases of livestock or poultry. The Secretary may also
prohibit or restrict import or export of any animal or related material if necessary to prevent the spread of
any livestock or poultry pest or disease.
The Animal and Plant Health Inspection Service (APHIS) is the United States Department of Agriculture
(USDA) agency charged with carrying out this disease prevention mission. APHIS depends on various
approaches for disease prevention and proactive disease surveillance as effective methods for maintaining
a healthy animal population and for enhancing the United States’ ability to compete in the global market
for animal and animal product trade.
For APHIS to conduct all its disease prevention tasks, it utilizes APHIS-certified private veterinarians to
work cooperatively with Federal and State animal health authorities on the Agency’s behalf. Their
certification is obtained through the APHIS National Veterinary Accreditation Program (NVAP) which
has an application and renewal process. Title 9, Code of Federal Regulations, Part 161 prescribes the
requirements and standards for obtaining accreditation.
NVAP is a voluntary program and there are two categories of accreditation. Category I is limited in scope
to companion animals (pets) and related activities, and Category I accredited veterinarians are authorized
to participate in disease surveillance activities and to issue international health certificates and domestic
certificates for interstate movement of companion animals. Category II encompasses all animal species
and accredited activities, and Category II accredited veterinarians are authorized to participate in disease
surveillance activities and to issue international health certificates and domestic certificates for interstate
movement of all animals.
APHIS is asking OMB to reinstate and approve, for 3 years, its use of this information collection activity
to continue the NVAP program.

2. Indicate how, by whom, how frequently, 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.
APHIS uses the following information collection activities to certify private veterinarians to work on
behalf of APHIS through NVAP.
National Veterinary Accreditation Program Application Form (VS Form 1-36A), (9 CFR 161)
(Business)
APHIS uses VS Form 1-36A as the source document for certifying private veterinarian practitioners to
work cooperatively with Federal and State animal health authorities on behalf of the USDA as accredited
private veterinarians on various approaches for disease prevention and proactive disease surveillance. The
application requires the applicant’s name, name of the veterinary school or college from which the
applicant graduated and the year of graduation, the date the applicant completed veterinary accreditation
orientation, the State where the applicant completed accreditation orientation; the applicant’s business and
mailing addresses and telephone numbers (as well as home telephone number); the county where the
applicant resides, the States in which the applicant is authorized to perform accredited duties, the
applicant’s type of practice (cattle, equine, small animal), and his/her signature.
Accredited veterinarians also use the form to renew their accreditation, change their contact information
and/or accreditation category. Veterinarians who lose their accreditation also complete the form to request
reaccreditation.
Request for Appeal (9 CFR 161) (Business)
Applicants may appeal denial, revocation, or suspension of accredited status. The written appeal is
prepared in letter format and signed by the denied veterinarian.

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 VS Form 1-36A is a fillable, printable PDF document available online at the APHIS forms web site
at https://www.aphis.usda.gov/library/forms/pdf/VS_1_36A.pdf. A completed form can be printed,
signed, and mailed to the appropriate APHIS Area office.
The application is also fileable online if the accredited veterinarian has gone through the Level 1
e-authentication process and his/her record is linked to an e-authentication account. If so, the accredited
veterinarian may apply for renewal, change of category, and/or and change of contact online via the VS

Process Streamlining (VSPS) system (https://vsapps.aphis.usda.gov/vsps/public/Login.do).
Requests for appeal may be completed electronically and emailed to APHIS.

4. Describe efforts to identify duplication. Show specifically why any similar information already
available cannot be used or modified for use for the purpose described in item 2 above.
APHIS is the only Federal agency that operates a national veterinary accreditation program. The
information the agency collects is not available from any other source.

5. If the collection of information impacts small businesses or other small entities, describe any
methods used to minimize burden.
APHIS has determined that 100% of the respondents to this information collection are small businesses.
The burdens described in Question 2 above are the absolute minimum processes for gathering the
information required to establish or determine accreditation eligibility.

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.
APHIS relies upon APHIS-certified private veterinarians who work cooperatively with Federal and State
animal health authorities on the Agency’s behalf to conduct disease prevention tasks. If information from
accredited veterinarians was collected less frequently or not collected, APHIS would lose access to
professional and demographic data for more than 100,000 cooperators, and APHIS coverage of
veterinary, plant, and agricultural activities would be proportionately reduced.
APHIS programs for the eradication and prevention of the spread of animal diseases, many of which also
affect humans, rely almost exclusively on the vigilance of accredited veterinarians for their success. The
agency’s timely knowledge of the species categories and professional activities of accredited veterinarians
in the NVAP enable APHIS to tailor and target training materials, notifications, and calls for emergency
response assistance to the accredited veterinarians who need the information or are in the best position to
assist the United States Government.
Lastly, nearly all export documentation for animals or animal products require the signature of an
accredited veterinarian. Without the services of NVAP veterinarians, the United States export trade of
animal and animal products would be severely restricted, costing United States businesses and local
governments hundreds of millions of dollars of lost trade and revenue.

7. Explain any special circumstances that require the collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5.
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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

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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.

No special circumstances exist that would require this information collection to be conducted in a manner
inconsistent with the general guidelines in 5 CFR 1320.5.

8. 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 form, and on the data elements to be recorded, disclosed, or reported. If
applicable, provide a copy and identify the date and page number of publication in the Federal
Register of the agency's notice, soliciting comments on the information collection prior to
submission to OMB.
APHIS engaged in productive consultations with the following individuals:
Dr. James Casey
8301 Frostwood Drive
Laurel, MD 20724
301-725-4371
Dr. Karen Matlock
S. Flower Mound Animal Hospital
2570 Northshore Blvd, Suite 100
Flower Mound, TX 75028
972-724-7297
Dr. Kevin Gibbs
Family Pet Clinic of Grapevine
303 W. Northwest Highway, Suite A
Grapevine, TX 76051
817-488 - 4618
On Monday, January 23, 2017, APHIS published in the Federal Register on pages 7787 and 7788 a
60-day notice seeking public comments on its plans to request a 3-year renewal of this collection of
information. No comments from the public were received.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of
contractors or grantees.
This information collection activity involves no payments or gifts to respondents other than paying for
services provided not directly connected with this information collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
No additional assurance of confidentiality is provided with this information collection. However, the
confidentiality of information is protected under 5 U.S.C. 552a. In addition, USDA-APHIS System of
Records Notice (SORN) 2 covers this information collection.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior
or 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.
This information collection activity will ask no questions of a private or sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of
respondents, frequency of response, annual hour burden, and an explanation of how the burden
was estimated.
•Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. 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.
See APHIS Form 71. Burden estimates were developed from discussions with veterinarians applying for
entry in the NVAP.
•Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories.
APHIS estimates the total annualized cost to these respondents to be $575,294.34. APHIS arrived at this
figure by multiplying the hours of estimated response time (11,901 hours) by the estimated average
hourly wage for a veterinarian ($48.34) as determined by the U.S. Department of Labor, Bureau of Labor
Statistics website at https://www.bls.gov/oes/current/oes291131.htm.

13. Provide estimates 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). The cost estimates 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.
No annual cost burden is associated with capital and start-up costs, operation and maintenance
expenditures, and purchase of services.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the
method used to estimate cost and any other expense that would not have been incurred without this
collection of information.
See APHIS Form 79. The annualized cost to the Federal government is estimated at $1,600,535.37.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the
OMB Form 83-1.

Requested
Annual Number of
Responses
Annual Time
Burden (Hours)

Program
Change Due to Change Due to
Program
Change Due to Adjustment in
Potential
Change Due to
Agency
Agency
Violation of the
New Statute
Discretion
Estimate
PRA

Previously
Approved

23,801

23,801

0

11,901

11,901

0

With this reinstatement, there is a program change resulting in +23,801 total annual responses and
+11,901 total burden hours. The burden “Request for Appeal” was inadvertently not included in the
previous submission. It adds one 1 response and 1 hour to the information collection.

16. For collections of information whose results are planned to be published, outline plans for
tabulation and publication.
APHIS has no plans to publish information it collects in connection with this program.

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.
APHIS will display the information collection expiration date on the VS Form 1-36A.

18. Explain each exception to the certification statement identified in the "Certification for
Paperwork Reduction Act."
APHIS can certify compliance with all provisions of the Act.

B. Collections of Information Employing Statistical Methods
There are no statistical methods associated with the information collection activities used in this program.