SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
9000-0157, Architect-Engineer Qualifications
(SF-330)
Justification.
Administrative requirements. This is a request to renew an existing information collection requirement concerning 9000-0157, Consolidated Form for Selection of Architect-Engineer Contracts. FAR Part 36 is the reference point for the form.
The Standard Form 330 accomplishes the following:
Expands
essential information about qualifications and experience data
including:
An organizational chart of all participating firms and key personnel.
For all key personnel, a description of their experience in 5 relevant projects.
A description of each example project performed by the project team (or some elements of the project team) and its relevance to the agency’s proposed contract.
A matrix of key personnel who participated in the example projects. This matrix graphically illustrates the degree to which the proposed key personnel have worked together before on similar projects.
Reflects current architect-engineer disciplines, experience types and technology.
Permits limited submission length thereby reducing costs for both the architect-engineer industry and the Government. Lengthy submissions do not necessarily lead to a better decision on the best-qualified firm. The proposed Standard Form 330 indicates that agencies may limit the length of firm’s submissions, either certain sections or the entire package. The Government’s right to impose such limitations was established in case law (Coffman Specialties, Inc., B-284546. N-284546/2, 2000 U.S.Comp.Gen.LEXIS 58, May 10, 2000).
Facilitates electronic usage by organizing the form in data blocks.
This information collection, in compliance with 40 U.S.C. 541-544, is necessary for the selection of qualified architect-engineer contractors.
2. Uses of information. Standard Form 330, Part I is used by all Executive agencies to obtain information from architect-engineer firms interested in a particular project. The information on the form is reviewed by a selection panel composed of professionals and assists the panel in selecting the most qualified architect-engineer firm to perform the specific project. The form is designed to provide a uniform method for architect-engineer firms to submit information on experience, personnel, and capabilities of the architect-engineer firm to perform along with information on the consultants they expect to collaborate with on the specific project.
Standard Form 330, Part II is used by all Executive agencies to obtain general uniform information about a firm’s experience in architect-engineering projects. Architect-engineer firms are encouraged to update the form annually. The information obtained on this form is used to determine if a firm should be solicited for architect-engineer projects.
3. Consideration of information technology. We use improved information technology to the maximum extent practicable. Where both the Government agency and contractors are capable of electronic interchange, the contractors may submit this information collection requirement electronically. The Standard Form 330 was designed to facilitate electronic usage by organizing the form in data blocks.
4. Efforts to identify duplication. This requirement is being issued under the Federal Acquisition Regulation (FAR) which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication.
If the collection of information impacts small businesses or other entities, describe methods used to minimize burden. The burden applied to small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices. The revenue information is primarily used to evaluate a firm’s capacity to perform a contract in the required time period, by comparing the estimated contract amount to the firm’s annual volume of work. Revenue for each recent year is more detailed than for this purpose. Further, the 4 and 5-year-old revenue information is not very meaningful. The 3-year basis for annual average revenue also correlates with the period used in defining the small business size standard for architect-engineer firms.
6. Describe consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently. Collection of information on a less frequent basis is not practical. The information is needed to select an architect-engineer firm for a contract.
7. Special circumstances for collection. Collection is consistent with guidelines in 5 CFR 1320.6.
8. Efforts to consult with persons outside the agency. A notice was published in the Federal Register at 82 FR 17664 on April 12, 2017. A 30-day notice published in the Federal Register at 82 FR 46991 on October 10, 2017. Three comments were received.
Comment: The respondent commented that the assumption listed on the current SF 330 of twenty-nine hours per response under Annual Reporting Burden is unrealistic.
Response: Twenty-nine hours is the average amount of time to read and prepare information on a company’s Qualifications-Based Selection purposes. The estimate considered the amount of time a simple or standard disclosure might require in response to non-complex qualifications-based selection synopsis, in some cases by businesses with limited experience, as well as the time that might be required for a very complex disclosure by a major corporation. In addition, the estimated burden hours include only projected hours for those actions which a company would not undertake in the normal course of business. Maintaining information and references on work they have performed in the past are considered actions undertaken in the normal course of business.
Careful consideration went into assessing the estimated burden hours for this collection, and the collection requirements at FAR Part 36 remains the same. There is no change to the estimated number of hours per response associated with this request for extension; rather, the estimated number of responses was reduced based on data available Federal Procurement Data System (FPDS) regarding awards in Fiscal Year (FY) 2016. The public burden hours have been reduced due to the reduction in the number of new Architectural Services contracts awarded in FY 2016 listed in FPDS.
Comment: The respondent commented that firms have raised a broader issue regarding how data is reported on the SF 330. There is a concern that reporting current projects that are already reported in the Federal Procurement Data System (FPDS) creates a duplicative reporting burden on the firms.
Response: Firms are able to tailor their responses on the SF 330. This allows them to present to the Government their firm in the best possible light when they are responding to solicitations. This flexibility allows firms to include information that is not captured by FPDS which may give them a competitive advantage over their peers when they are responding to an opportunity.
Comment: The respondent commented that there are places within the SF 330 form that need either additional clarification or potential restructuring. They are as follows:
a. Add to Part I, Section B, a field for the Data Universal Numbering System (DUNS) number to be provided optionally. Many agencies require the respondents DUNS numbers enable government selection officials to search the Past Performance Information Retrieval System (PPIRS) for the respondent’s past performance information. Because a single firm may have past performance information stored under multiple DUNS numbers, respondents should be encouraged, but not required to list multiple DUNS numbers that will enable the government to find additional relevant information in the PPIRS. In some cases, larger firms have multiple office locations with multiple DUNS numbers and it can be inefficient for a contracting officer to look through the DUNS numbers of firms that are unconnected to the project.
b. In section E, member firms commented on ambiguous language in the request. There was a recommendation to remove the parenthetical instruction from Part I Section E.19(3)- “(Brief scope, size, cost, etc.).” Here the term “scope” is redundant with the main instruction to provide a “Brief description” while the term “size” is ambiguous or inapplicable in many cases. In some cases, it can be overly burdensome to provide cost information on the Section E.19 “Relevant projects.”
c. Section F.25(3) also has an ambiguous use of “scope” that needs to be further clarified. Is this term meant to define the firm or does it describe the prime or subcontract work? The lack of clarity regarding the nature of the requirement forces firms to submit extraneous information that adds a burden on the submitter, while also increasing contracting officer’s review of extraneous information that firms submit in an effort to “cover their bases.”
d. The Section G instructions should be changes to allow respondents to exclude subconsultant staff from the required table. Some member firms believe that Section G incentivizes respondents to propose the same staff who worked on the projects cited in Section F. This incentive motivates prime respondents to avoid new term partners, thus reducing available opportunities for small and disadvantaged businesses to team with strong primes.
e. In Part II, firms request that codes be expanded past the current twenty-one line limit. The limit creates difficulty for firms to accurately reflect capabilities when business systems are organized around a broader set of discipline codes.
Response: The five suggestions referenced by the respondent will be forwarded to subject matter experts to review and determine the feasibility of making changes to the SF 330.
9. Explanation of any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. Not applicable.
10. Describe assurance of confidentiality provided to respondents. This information is disclosed only to the extent consistent with prudent business practices and current regulations.
11. Additional justification for questions of a sensitive nature. No sensitive questions are involved.
Estimated total annual public hour burden.
Subject matter experts have determined that the public reporting burden for this collection of information is estimated to average 29 hours (25 hours for Part I and 4 hours for Part II) per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Because of the tailoring required by the form for each project submittal, there are virtually no savings in burden hours by repeat submittals. The number of new Architectural Services contracts (NAICS code 541310) awarded in FPDS-NG for FY 2016 was 3,256. The annual reporting burden is estimated as follows:
Annual Reporting Burden
Respondents......................................3,256
Responses per year x 4
Total annual responses..........................13,024
Review time per response x 29*
Total burden hours.............................377,696
Average wages + overhead .................... x $64.00**
Total cost to the public...................$24,172,544
*25 hours for Part I and 4 hours for Part II.
**Based on the OPM GS-13/step 5 salary ($46.60 an hour) plus 36.25 percent burden, rounded to the nearest dollar, or $64 an hour. The burden rate used is that mandated by OMB memorandum M-08-13 for use in public-private competition, as updated by OMB for the current year. Reference Salary Table 2017-GS, Effective January 2017, found at www.opm.gov).
13. Estimated total annual public cost burden. We estimate no annual cost burden other than the burdens shown in Items 12 and 14.
14. Estimated cost to the Government. We estimate 4 hours total for Standard Form 330, Part I and 1 hour total for Part II. This estimate is based on a review panel of 4 persons at the GS 13 level.
Total responses...............................13,024
Review hours per response .x 4*
Total burden hours............................52,096
Average wages + overhead ...................x $64.00**
Total Government cost.....................$3,334,144
*Based on a review panel of 4 persons (4 hours total for Part I and 1 hour total for Part II.
****Based on the OPM GS-13/step 5 salary ($46.60 an hour) plus 36.25 percent burden, rounded to the nearest dollar, or $64 an hour. The burden rate used is that mandated by OMB memorandum M-08-13 for use in public-private competition, as updated by OMB for the current year. Reference Salary Table 2017-GS, Effective January 2017, found at www.opm.gov).
15. Explain reasons for program changes or adjustment reported in Item 13 or 14. The public burden hours and responses have increased due to an increase in the number of new Architectural Services contracts awarded in FY 2016, listed in FPDS-NG.
16. Outline plans for published results of information collection. Results of this information collection will not be published.
17. Approval not to display expiration date. Not applicable.
18. Explanation of exception to certification statement. No applicable.
B. Collections of Information Employing
Statistical
Methods.
Statistical methods are not used in this information collection.
| File Type | application/msword |
| Author | CurtisEGlover |
| Last Modified By | SYSTEM |
| File Modified | 2017-12-13 |
| File Created | 2017-12-13 |