Supporting Statement G-1450 (2017)- 12-1-2017 -clean

SUPPORTING STATEMENT FOR

USCIS Electronic Payment Processing

OMB Control No.: 1615-0131

COLLECTION INSTRUMENT(S): G-1450

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 Immigration and Nationality Act of 1952 (INA), as amended, provides for the collection of fees at a level that will ensure recovery of the full costs of providing adjudication and naturalization services, including services provided without charge to asylum applicants and certain other immigrant applicants (see INA section 286(m), 8 U.S.C. 1356(m)). The authorizing regulations for USCIS fees are 8 CFR 103.7(b)(1)(i). The INA provides that the fees may recover administrative costs as well. The fee revenue collected under section 286(m) of the INA remains available to the Department of Homeland Security (DHS) to provide immigration and naturalization benefits and ensures the collection, safeguarding, and accounting of fees by the United States Citizenship and Immigration Services (USCIS) (See INA section 286(n), 8 U.S.C. 1356(n)).

The Government Paperwork Elimination Act (GPEA), Public Law 105-277, 44 U.S.C. 3504 (1998) requires federal agencies to use and accept electronic signatures, where practicable, when conducting official business with the public. In addition, Congress passed the E-Government Act of 2002, Public Law 107-347, 44 U.S.C. §§ 101, 3501, 3541, and 3601 notes (2002), to promote the use of the Internet and emerging technologies within and across Government agencies, provide citizen-centric Government information and services, reduce costs and burdens for businesses and other Government entities, promote access to high quality Government information and services across multiple channels, and transform agency operations by utilizing, where appropriate, best practices from public and private sector organizations. The Department of Treasury’s pay.gov payment processing system will be utilized to facilitate electronic payments.

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 information collected on the form G-1450 will allow the agency to collect credit card information. This is necessary for USCIS to track payment of the fee necessitated by the respondent’s activity with USCIS and reconcile the payment received in the Treasury, Financial Management Service, Federal Financial Management System (FFMS), and the applicant’s file (if they are not paying by check that would be included with the form filed). For persons paying through the pay.gov portal, USCIS will not receive the data elements required for payment processing, such as credit card information but will only receive confirmation of payment and tracking detail to allow USCIS to match the payment with the form filed. The list of data elements that are provided in the separate Excel spreadsheet represents the full list of data elements that may be required to process a payment. USCIS will not require all data elements for each payment processed, but rather a subset of them to facilitate payment processing.

This information collection is being revised to allow for the expanded use of Form G-1450 which will provide USCIS customers with greater flexibility and enable them to pay their USCIS LB processed filing fees with a credit card.

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.

Certain respondents will be able to make a payment electronically: immigrant visa fees and fees for certain forms filed electronically with USCIS will be made through access to the United States Department of Treasury’s pay.gov portal. Respondents to certain paper forms will be able to provide credit card information via the form G-1450, which will be mailed in with the form requiring a fee payment.

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.

The information collected in this collection will not be collected elsewhere; there is only one payment required for each fee.

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.

Small businesses or other small entities may be required to pay fees as per the application or petition they provide to USCIS. The information collected from either small businesses/small entities and from individuals is identical and limited to the least number of data elements necessary to effect completion of the payment.

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.

If USCIS is not able to collect this information it will not be able to process information collections submitted by the public; the fees are necessary to fund the agency as indicated in the answer to Question 1.

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.

This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

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 September 14, 2017, USCIS published a 60-day notice in the Federal Register at 82 FR 43248. USCIS did not receive comments after publishing that notice. On December 1, 2017, USCIS published a 30-day notice in the Federal Register at 82 FR 56987. USCIS has not received comments to date.

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

USCIS does not provide any payment or gift to respondents of this collection.

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

USCIS will maintain records of the payments in secure electronic files. The information provided is subject to protection under 5 U.S.C. 552. There is no assurance of confidentiality. The System of Record Notice associated with this information collection is DHS/USCIS-007 Benefits Information Systems, October 19, 2016 81 FR 72069. The Privacy Impact Assessment associated with this information collection is DHS/USCIS/PIA-061 Benefit Request, Intake Process, dated March 15, 2016.

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 persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature collected.

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.

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate*	Total Annual Respondent Cost
Individuals or Households	USCIS Electronic Payment Processing / No Form	1,805,284	1	0.12	216,635	$34.84	$7,547,563
Individuals or Households	Authorization for Credit Card Payment / G-1450	1,017,839	1	0.12	122,141	$34.84	$4,255,381
Businesses or other small entities	USCIS Electronic Payment Processing / No Form	465,630	1	0.12	55,876	$34.84	$1,946,720
Total		3,288,753			394,652		$13,794,664

* The above Average Hourly Wage Rate is the May 2016 Bureau of Labor Statistics average wage for All Occupations of $23.86 times the wage rate benefit multiplier of 1.46 (to account for benefits provided) equaling $34.84. The selection of “All Occupations” was chosen as the expected respondents for this collection could be expected to be from any occupation.

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.

The costs to the respondents are reported in the collections that necessitate a requirement to pay a fee. There is no cost for the respondents to pay a fee to USCIS.

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.

The costs to the Federal Government are reported in the collections that necessitate a requirement to pay a fee.

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

Data collection Activity/Instru-ment	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
USCIS Electronic Payment Processing				2,499,158	3,288,753	789,595
Total(s)				2,499,158	3,288,753	789,595

There has been an increase in the total burden hours previously reported for this

information collection. The increase is a result of a change in the time burden from five to seven minutes and an increase/decrease in the estimated number respondents who will complete and submit the G-1450. Below is a summary of the credit card payment expansion initiative that contributed to the increase total estimated burden reporting.

U.S. Citizenship and Immigration Services (USCIS) customers can currently use Form G-1450, Authorization for Credit Card Transactions, to pay for their Form N-400 filing fees. U.S. Citizenship and Immigration Services is working with the U.S. Department of Treasury to expand the use of Form G-1450 with all other USCIS fee-based forms that are submitted to and processed by a USCIS Lockbox (LB). The expanded use of the form will provide USCIS customers with greater flexibility and enable them to pay their USCIS LB processed filing fees with a credit card.

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.

This information collection will not be published for statistical purposes.

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.

USCIS 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.

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

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved with this collection.

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