SS A for 1601-Final DHSEngage v3 clean version

SUPPORTING STATEMENT FOR

EngageDHS

OMB Control No.: 1601-NEW

COLLECTION INSTRUMENT(S): EngageDHS

1. 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.

Under 41 U.S.C. § 3306, agencies are required to use advance procurement planning and conduct market research. Advance planning and market research is a means of developing the agency’s acquisition requirements. As part of this process, companies frequently ask to meet with DHS representatives for numerous reasons including: sharing information on technologies and company capabilities or to ask how to do business with DHS. DHS needs the information being collected to prepare for productive meetings, share information across the enterprise about touchpoints the company has had at DHS, and to better track the frequency and number of meetings between DHS and companies. No personal information is being collected.

This is a means of improving the procurement process that is used to support the DHS mission. The above statute is implemented by 48 C.F.R. (FAR) Part 10, Market Research. The information collection method the agency requests is not specifically mentioned in the regulation but it is nonetheless permissible because it reasonable and does not request more information than is necessary. Under 48 C.F.R. (FAR) 1.102-4(e), Role of the Acquisition Team, agencies are allowed to implement a policy, procedure, strategy or practice if it is in the interest of the Government and is not otherwise prohibit.

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 is being used by DHS to help determine the department personnel who should be attending the meetings. It is also used by DHS representatives to better prepare for the meeting, so that it is productive for both DHS and the companies It is helpful for DHS to know background information about the company as well as whether they have met with DHS before and whether they currently support the Department. DHS also receives inquiries from oversight bodies, such as Congress, regarding with how many companies DHS has met with as well as whether DHS has met with specific companies. The meeting information provides source data for answering those inquiries in an accurate and timely manner. EngageDHS is a fillable form that will be used to collect vendor/industry meetings with DHS.

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.

Upon a request for a meeting, DHS will ask companies to fill out a fillable paper based form, Microsoft PDF, and email it to the DHS Industry Liaison mailbox at [email protected]. Once it is received by DHS, this form could be electronically loaded into DHS’ system, called EngageDHS. (EngageDHS is DHS’ implementation of Microsoft Dynamics CRM.) This process makes it easier and faster for companies to send in the form (email versus paper mail). It also reduces the burden on DHS employees as they do not need to manually input the information into EngageDHS. Performing data collection as discussed above would also reduce the burden on the companies requesting meetings with DHS as they would only have to fill out the form at the time of their first meeting request. So for example, if a company over time meets with representatives from multiple DHS Components (e.g., TSA, FEMA, Coast Guard, ICE, etc.), they would only have to fill out the form once.

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.

This data collection is not duplicative. It enhances the ability for DHS to share information across the enterprise so that companies only have to provide their company information to DHS once. Similar information does not exist elsewhere as DHS cannot accurately forecast which companies want to meet with DHS or their reasons for requesting meetings.

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.

This information collection does not have an impact on small businesses or other small entities.

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 the collection is not conducted, it will impede the government from scheduling meetings with companies who want to meet with DHS. It will also make the meetings that are held less productive since the government may not be aware of what the company wants to discuss, and thus won’t be fully prepared and may not invite the best-suited DHS participants for the vendor meetings.

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 manner consistent with guidelines in 5 C.F.R. 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 C.F.R. 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 situate ion. These circumstances should be explained.

A 60 Day Federal Register Notice requesting public comments was published on Tuesday, October 17, 2017 at 82 FR 48236. No comments were received.

A 30 Day Federal Register Notice requesting public comments was published on Wednesday, February 7, 2018 at 83 FR 5454. No comments were received.

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

DHS will not provide payments or gifts to respondents of this information collection.

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 provided to the respondents for the collection of this information. The collection of information is covered by

DHS/ALL/PIA-006 DHS General Contact Lists

DHS/ALL-021 Department of Homeland Security Contractors and Consultants, October 23, 2008, 73 FR 63179

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 sensitive nature.

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

See table below.

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
Private company or organization	EngageDHS Vendor Engagement Form	750	1	0.25 hours	187.5	$27.84	$5220.00
Total		750	1	0.25 hours	187.5	$27.84	$5220.00

*We estimate that, on average, a company requests meetings with the DHS enterprise twice a year. There are ten DHS offices: 9 HCAs plus OCPO, and they each hold approximately 150 meetings. Vendors need only provide the data once, at the time of the first meeting request. The 150 meetings is based on the approximate number of meetings held annually by OCPO CPO and the Industry Liaison.

**The basis for the salary is BLS salary for occupation code 43-6011 Executive Secretaries and Executive Administrative Assistants. https://www.bls.gov/oes/current/oes_nat.htm#43-0000

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 out of pockets costs to the respondents associated with this 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 to the Federal Government

1. Annualized Cost to DHS to Receive and Process Forms

Form Name / Form Number	No. of Respondents*	No. of Responses per Respondent*	Avg. Burden to Receive and Process Form (in hours)	Total Annual Burden (in hours)**	Avg. Hourly Wage Rate	Total Estimated Annual Cost
EngageDHS Vendor Engagement Form	750	1	0.2 hour	150	$28.20	$4,230.00

*We estimate that, on average, a company requests meetings with the DHS enterprise twice a year. There are ten DHS offices: 9 HCAs plus OCPO, that each hold approximately 150 meetings each. The Vendor need only to provide the data once, at the time of the first meeting request. The 150 meetings is based on the number of meetings held annual by OCPO CPO and Industry Liaison.

**This is the hourly rate associated with an entry level position in Washington DC reviewing the information received (equivalent to a GS-10, Step 1, 2017 OPM salary data, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2016/DCB_h.pdf).

2. Annual O&M Cost for the EngageDHS System

Cost listed in the May 2017 Memorandum of Agreement (MOA) is: 83,086.20.

3. Total Cost

Cost Category	Annualized Cost
Form Processing	$4,230.00
EngageDHS System O&M	$83,086.20.
Total	$87,316.20

The EngageDHS System O&M was derived from working with the DHS Office of the Chief Information Officer (OCIO), Information Sharing Services Office (IS2O). This office will be creating and maintaining the system that will allow the Office of the Chief Procurement Officer (OCPO) to track its meetings with vendors and private firms and share information across the entire Department. The breakdown is as follows:

Resource	Monthly Cost	# of Months	Total Cost
Operations & Maintenance (Infrastructure)	$880.00	12	$10,560.00
Operations & Maintenance (ISSO)	$1,250.00	12	$15,000.00
Shared DC2 Pre-Pod Environment	$616.23	12	$7,394.76
CRM License	$3,385.50	12	$40,626.00
Cloud Support Fee	$792.12	12	$9,505.44
Total			$83,086.20

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

This is a new 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.

DHS will not publish this information nor will the department use the information for statistics.

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.

DHS 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.

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

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