2700-0089 Supporting Statement 091817

SUPPORTING STATEMENT

OMB Control No. 2700-0089

(2017)

Reports Requested for Contracts

with an Estimated Value Greater Than $500,000

TYPE OF ACTION: Extension.

A. Justification.

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

This information collection is required by the NASA FAR Supplement (NFS). NASA is required to monitor contract performance in support of NASA’s mission and in accordance with contractual requirements. This information collection focuses on miscellaneous reports/information collected from NASA contractors when the contract value is greater than $500,000.

This information collection does not include financial, property, and patent/data/copyright reports. Those reports are covered by separate OMB approved information collections.

2. Indicate how, by whom, how frequently, and for what purpose the information will be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

NASA contractors support authorized programs and projects, and the scope of that support is documented in each contract’s Statement of Work. Although there may be some similarity between contracts, each contract is unique and has its own reporting requirements. Some reporting requirements are routine and some reports are required only if and when specific events occur, such as a mishap report in the wake of a safety event. Consequently, this information collection addresses miscellaneous reporting requirements and the corresponding burden on contractors to submit the reports.

NASA’s technical program and contract management personnel use this information to effectively manage and administer contracts, measure the contractor’s performance, evaluate contractor management systems, ensure compliance with mandatory public policy provision, evaluate and control costs charged against contracts, detect and minimize conditions conducive to fraud, waste and abuse, and to form a database for general overview reports to the Congressional and Executive Branches. Without this information, NASA would not be able to gain the insight into contractor activity required to effectively manage and meet NASA mission requirements.

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. Also describe any consideration of using information technology to reduce burden.

NASA encourages the use of computer technology and is participating in Federal efforts to extend the use of information technology to more processes via the Internet. NASA accepts and encourages submission of reports via electronic means.

4. Describe efforts to identify duplication.

NASA procurement procedures are continually reviewed to identify duplication of effort and other inefficiencies. This information collection supports contracts valued at $500,000 and greater. Information collected through this information collection is not duplicated within NASA.

5. If the collection of information impacts small businesses or other small entities (Item five of form OMB 83-I, the Paperwork Reduction Act Submission form), describe any methods used to minimize burden.

Small businesses and other small entities are impacted to the extent that they are awarded contracts in excess of $500,000. Because the reports are required to support activity under the contract, it is necessary to require the reports of all NASA contractors regardless of size status. All contractors are reimbursed for preparation and submission of reports in accordance with contract terms, thereby minimizing the cost burden to all. The burden on small business is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.

If any restrictions were placed on the collection of information, NASA would not be able to effectively manage its contracts, thereby compromising its ability to meet its mission requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner.

NASA does not anticipate circumstances arising that would cause information to be collected in a manner that requires explanation of special circumstances.

8. If applicable, provide a copy and identify the date 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 before submission to OMB.

The 60-day notice was published in the Federal Register on July 6, 2017: (82 FR 31354). No comments were received from the public.

The 30-day notice was published in the Federal Register on October 2, 2017: (82 FR 45905). No comments were received from the public.

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

NASA does not provide gifts or payments to respondents, other than reimbursement for preparation and submission of reports in accordance with contract terms.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Reports governed by this information collection do not generally contain confidential information, and generally become the property of NASA. Therefore, there is no assurance of confidentially. However, to the extent that reports contain personally-identifiable or proprietary information that is subject to the Privacy Act, the information will be protected as required by the Privacy Act.

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.

Questions of a sensitive nature, as indicated above, will not be asked.

12. Provide estimates of the hour burden of the collection of information.

Category of Respondents	Number of Respondents Submitting Reports	Number of Reports Submitted per Respondent	Response Time (minutes)	Total Annual Burden Hours
Private Sector	218	2	420 minutes (7 hours)	3052

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.

The estimated annual contractor cost is calculated by multiplying the estimated number of hours in submitting reports (3052) by an estimated rate of $59.00 per hour (skill level comparable to GS-12, step 5, on Federal pay scale), totaling $180,068, i.e., 90,350 + O/H (.3645 (90,503)) = 123,283/2087 = $59.07 per hour. It should be noted that contractors are reimbursed by the Government for the preparation of reports produced under cost-type contracts and that the contractor has included the cost of reports required under fixed-price contracts in the total price of the contract.

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, and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to NASA for the review of reports under this ICR is $180,940. This estimate is calculated by multiplying the number of reports, 436, by an average 5 hours of Government review time, at an average rate of $83 (GS-14, Step 5, pay scale) totaling $180,940, i.e., 126,958 + O/H (.3645 (126,958)) = 173,234/2087 = $83 per hour x 5 hours per report x 436 reports = $180,940.

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

There are no program changes or adjustments.

16. For collections of information intended for publication, outline plans for tabulation and publication.

Various levels of vendor information will be available to the public via NASA’s NAIS on-line system. However, sensitive information is not intended for publication.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display may be inappropriate.

NASA seeks OMB approval not to display the PRA Statement with the associated expiration date. There is no form associated with this collection. The PRA statement is not included in the solicitation or contract. It is very common in most FAR and NASA FAR Supplement collections that the PRA statement is not shown.

18. Explain each exception to the certification statement identified in item 19, “Certification for Paperwork Reduction Act Submissions” of OMB Form 83-1.

N/A

B. Collections of Information Employing Statistical Methods.

NASA will not employ statistical methods.

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