TAB A-Supporting_Statement_JPAS OMB 0704-0496_Revisedv4 06.01.2018

SUPPORTING STATEMENT

for

OMB 0704-0496, Joint Personnel Adjudication System

SUPPORTING STATEMENT – PART A

A.  JUSTIFICATION

1.  Need for the Information Collection

50 U.S.C. 401, Congressional declaration of purpose; 50 U.S.C. 435, Purposes ; DoD 5200.2R, Department of Defense Personnel Security Program Regulation; DoD 5105.21-M-1, Sensitive Compartment Information Administrative Security Manual; E.O. 10450, Security Requirements for Government Employment; E.O. 10865, Safeguarding Classified Information Within Industry; E.O. 12333, United States Intelligence Activities; E.O. 12829, National Industrial Security Program; DoD 5220.22-M; and E.O. 12968, Access to Classified Information.

The Joint Personnel Adjudication System (JPAS) is a United States Department of Defense (DoD) automated system for personnel security, providing a common, comprehensive medium to record, document, and identify personal security actions within the Department including submitting adverse information, verification of security clearance status, requesting investigations, and supporting Continuous Evaluation activities. JPAS requires personal data collection to facilitate the initiation, investigation and adjudication of information relevant to DoD security clearances and employment suitability determinations for active duty military, civilian employees and contractors seeking such credentials.

DoD 5200.2R establishes regulations for personnel security that are mandatory for use by all DoD components. E.O. 12829, National Industrial Security Program (NISP) establishes the Department of Defense as the Executive Agent for NISP, and the Cognizant Security Agency (CSA) for DoD and non-CSA agencies, and lays out the responsibility for the CSA to maintain a system of eligibility and access determinations of contractor personnel. DoD 5220.22-M states that “When the CSA has designated a database as the system of record for contractor eligibility and access, the contractor shall be responsible for annotating and maintaining the accuracy of their employees’ access records.” The aforementioned authorities and DoD regulations designate JPAS as that system: a personnel security system serving as the authoritative source for clearance information resulting in accesses determinations to sensitive or classified information and facilities.

2.  Use of the Information

The respondents for this information collection are 22,225 Facility Security Officers (FSOs) working in industry companies, who are responsible for the regular servicing and updating of the JPAS records of individuals with an industry person category. The specific purpose of this information collection is for FSOs to update the JPAS records of contractor personnel within their company and Security Management Office (SMO) to facilitate DoD Adjudicators and Security Managers obtaining accurate up-to-date eligibility and access information on contractor personnel.

This submission addresses the aforementioned public information collection, but does not cover the entirety of information contained in JPAS, which is obtained from the following: individual persons; DoD personnel systems; Case Adjudication Tracking System (CATS); Continuous Evaluation Records; DoD and federal adjudicative facilities/organizations; DoD and Non-DoD agencies; and security managers, security officers, or other officials requesting and/or sponsoring the security eligibility or suitability determination or visitation of facility. Additional information may be obtained from other sources such as personnel security investigations, security representatives, subject's personal financial records, military service records, medical records, and unsolicited sources. Information collected from the individual, using Standard Form (SF) 85 is cleared under OMB Control Number 3206-0261. Information collected from the individual, using SF-86 is cleared under OMB Control Number 3206-0005.

JPAS limits the use of the information it contains to a specific population of authorized FSOs, Adjudicators and Security Managers who are required to maintain a minimum clearance of DoD Secret in order to maintain access privileges. Privacy disclosures visible to JPAS users are displayed in an accompanying screenshot to this submission. The means of access to JPAS is via secure web portal (https://jpasapp.dmdc.osd.mil/JPAS/JPASDisclosure).

3.  Use of Information Technology

100% of responses are collected electronically. The Office of Personnel Management (OPM) has determined that the Standard Form (SF) 86 may be initiated in JPAS by providing a minimal amount of subject Personally Identifiable Information (PII) through the JPAS web application. From this point, the subject will fill out the OPM SF-86 via the e-QIP web application. As referenced in Section 2, information collected from the individual using SF-86 is cleared under OMB Control Number 3206-0005.

4.  Non-duplication

No similar information or verification procedure exists that can be used to collect this information. Data collected in JPAS is not collected again unless there is a gap in service large enough to facilitate a reinvestigation. No culmination of data from other sources would provide the necessary information to facilitate the initiation, investigation and adjudication of information relevant to DoD security clearances and employment suitability determinations for contractors.

If clearances are properly maintained / reinvestigated (every 10 years for Secret and 5 years for Top Secret), then there is no requirement to collect redundant information. If the aforementioned timelines are exceeded, the information required to initiate and complete a background investigation will need to be reproduced. As referenced in Section 2, information collected from the individual using SF-86 is cleared under OMB Control Number 3206-0005.

5.  Burden on Small Business

There is no significant impact on small businesses.

6.  Less Frequent Collection

If collection occurred less frequently, the ability to make suitability determinations for employment and access to classified information by contractors would be negatively impacted.

7.  Paperwork Reduction Act Guidelines

This collection of information is not conducted under special circumstances. This collection will be conducted in a manner consistent with guidelines contained in 5 CFR 1320.5 (d) (2).

8.  Consultation and Public Comments

Part A: PUBLIC NOTICE. 

A 60-Day Federal Register Notice (FRN) for the collection published on Wednesday, March 14, 2018. The 60-Day FRN citation is 83 FRN 11189.

No relevant comments were received during the 60-Day Comment Period.

A 30-Day Federal Register Notice for the collection published on Friday, June 1, 2018. The 30-Day FRN citation is 83 FRN 25443.

Part B: CONSULTATION

Defense Manpower Data Center (DMDC) regularly consults with important stakeholders on the topic of FSO usage of JPAS, including the clarity and ease-of-use of the system, availability of system functionality and the continued importance of the JPAS information collection mechanism to the Federal personnel security enterprise. These stakeholders include, but are not limited to, the Office of the Under Secretary of Defense for Intelligence (USD-I), Office of Personnel Management (OPM), Accessions and Personnel centers of the Military Services, the Department of Defense Central Adjudicative Facility (CAF), and the DoD Defense Security Service (DSS).

9.  Gifts or Payment

No payments, gifts, or guarantees are made to respondents who provide this information.

10.  Confidentiality

JPAS provides a Privacy Advisory advising users that they are accessing a system that contains Privacy Act information. Screenshots of the privacy advisory are provided with the OMB submission package for this collection. A Privacy Act Statement is provided on the SF-86, cleared under OMB Control Number 3206-0005. Regarding Personally Identifiable Information (PII), respondents are advised that their data is for OFFICIAL USE ONLY and that PII will be maintained and used in strict confidence in accordance with Federal law. All personal information provided by the subject and stored by JPAS falls under the Privacy Act of 1974.

In order to ensure confidentiality and integrity of data, both asymmetric Public Key Encryption and SSL/TLS encryption are used for information exchange with JPAS.

Records are maintained in secure, limited access, or monitored areas. Physical entry by unauthorized persons is restricted through the use of locks, passwords, or other administrative procedures. Access to personal information is limited to those individuals who make account access determinations, update user records, verify access and eligibility information, and to perform their official assigned duties. The Retention and Disposal Schedule for this collection, as listed on the SORN, is that “Records are destroyed no later than 15 continuous years after termination of affiliation with the DoD.”

The Privacy Impact Assessments (PIA) for the Joint Personnel Adjudication Database is accessed at the following link, and accompanies this submission (https://www.dmdc.osd.mil/appj/dwp/rest/download?fileName=JPAS_PIA.pdf&groupName=websiteDocuments)

The System of Records Notice (SORN) oversees the collection of information in the Joint Personnel Adjudication Database: DMDC 12 DoD, Joint Personnel Adjudication System, October 14, 2010, 75 FR 63161. (http://dpcld.defense.gov/Privacy/SORNsIndex/DOD-wide-SORN-Article-View/Article/570567/dmdc-12-dod/)

11.  Sensitive Questions

Sensitive Questions (i.e. gender, race and ethnicity): JPAS does not directly collect information of this nature; however, it does store investigation results and corresponding adjudication information. Dependent upon type of background investigation being conducted, some or all of this sensitive information might be collected to verify that the individual in question is suitable to handle information related to national security.

Social Security Number (SSN) is requested to ensure accuracy of data involving the specified individual applicant or FSO. The SSN is obtained and stored in the initial record for proofing, vetting, and maintaining unambiguous identity for U.S. persons. As the primary method of personal identification in major DoD human resource systems (personnel, finance, and medical), the SSN remains the only unique identifier that ensures accuracy across all such systems for proper data retrieval. A copy of the SSN Justification Memorandum dated June 5, 2013, and Defense Privacy and Civil Liberties Division (DPCLO) acceptance letter dated August 22, 2013, are included with the OMB submission package for this collection.

12.  Respondent Burden, and its Labor Costs

a. Estimation of Respondent Burden

Estimation of Respondent Burden Hours
	Number of Respondents	Number of Responses per Respondent	Number of Total Annual Responses	Response Time (Amount of time needed to complete the collection instrument)	Respondent Burden Hours (Total Annual Responses multiplied by Response Time) Please compute these into hours)
Collection Instrument #1: Servicing JPAS records in the application by Facility Security Officers (FSOs)	22,225	45	1,000,125	20 minutes	333,375
Total	22,225	45	1,000,125	20 minutes	333,375

• There are 22,225 Facility Security Officers (FSOs) which are responsible for 22 to 23 JPAS records with an Industry person category, and there are 500,000 such person records in JPAS.

• FSOs typically update each person record they service in JPAS an average of 2 times per year, taking about 20 minutes each time, resulting in approximately one million annual responses.

• The figure for “Number of Responses per Respondent” is drawn from the fact that each FSO works on between 22 and 23 JPAS records annually (an average of 22.5), and each record is serviced twice annually on average (22.5 x 2 = 45 responses per respondent).

b. Labor Cost of Respondent Burden

Labor Cost of Respondent Burden
	Number of Responses	Response Time per Response	Respondent Hourly Wage	Labor Burden per Response (Response Time multiplied by Respondent Hourly Wage)	Total Labor Burden (Number of Responses multiplied by Response Time multiplied by Respondent Hourly Wage)
Collection Instrument #1(JPAS system – Servicing JPAS records)	1,000,125	20 minutes	$16	$5.33	$5,330,666.25
Total	1,000,125	20 minutes	$16	$5.33	$5,330,666.25

Hourly Rate estimate for FSOs taken from United States Department of Labor, Bureau of Labor Statistics Occupational Employment Statistics page titled “33-9099 Protective Service Workers, All Other” Link: http://www.bls.gov/oes/current/oes339099.htm

13.  Respondent Costs Other Than Burden Hour Costs

a. Total capital and start-up costs annualized over the expected useful life of the item(s):

Total capital and start-up costs are approximately $100 per Industry user to obtain PKI credentials, if not approved for a Common Access Card (CAC) to access the JPAS system.

Total Capital/Startup Costs Calculation:

Total Capital/Startup Costs = $100/card X 22,225 Industry Users = $2,222,500

Total Capital/Startup Costs (in thousands) = $2,222.5

b. Total operation and maintenance costs: $0 (in thousands)

14.  Cost to the Federal Government

a. Labor Cost to the Federal Government

Instrument #1: Joint Personnel Adjudication System

a. Number of Total Annual Responses: 1,000,125 as established in section 12a

b. Processing Time per Response: 2 minutes

c. Hourly Wage of Worker(s) Processing Responses: $21.01

d. Cost to Process Each Response: $0.70

e. Total Cost to Process Responses: $700,420.88

Overall Labor Burden to Federal Government

a. Total Number of Annual Responses: 1,000,125

b. Total Labor Burden: $700,420.88

Processing Time for the Federal Government of industry contractors includes but not limited to instances where federal employees must verify contractors’ eligibility for visit requests, onboarding, and in-or-out processing.

Hourly rate estimate is taken from the GS09 (step 1) salary per the adjusted 2018 OPM rates Reference: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/GS_h.pdf

b. Operational and Maintenance Costs

1. Equipment: $0

2. Printing: $0

3. Postage: $0

4. Software Purchases: $0

5. Licensing Costs: $0

6. Other: $0

7. Total (P: add A through F in this section): $0

JPAS is an enterprise-wide system for personnel security within the Department of Defense, and the processing of FSO responses is automated by the system, consuming miniscule amounts of system resources for operational and maintenance costs. As such, there is no Operational and Maintenance Costs associated with receiving FSO responses.

15.  Reasons for Change in Burden

This is a renewal of an existing collection, with change, for which OMB approval has expired.

An increase of 333,375 hours is the result of Program Change as the previously approved OMB Control Number 0704-0496 expired on 3/31/2016. An increase of $2,222.50 (in thousands) is the result of Program Change, as the previously approved OMB Control Number 0704-0496 expired on 3/31/2016.

Although OMB Control Number 0704-0496 expired 3/31/2016, the current submission is presenting a reduced burden estimate compared to the 2013 submission. Compared to the 2013 submission, JPAS has reduced the estimated burden on respondents by 382,716 hours:

375,383 hours are reduced, as 0704-0496, in its 2013 submission, covered FSOs servicing 1,063,138 JPAS person records for updates twice per year, for a total of 2,126,276 annual responses. Guidance from Washington Headquarters Service in 2015 indicated that servicing records for those subjects with dual-category or Reservist status does not constitute a public information collection. Therefore, the burden associated with servicing these 563,138 JPAS dual-category records is removed. The burden of servicing the remaining 500,000 records, all of whom are Industry personnel, remains.

7,333 hours are reduced, because 0704-0496 previously covered the time burden on respondents of completing the JPAS system access request form, the DD Form 2962, which is, as of November 2015, covered under a separate OMB Control Number, 0704-0542, expiration 9/30/2018. The burden estimates associated with JPAS users completing and submitting the DD 2962 to request JPAS access is no longer included (44,000 JPAS users completing an access request form for 10 minutes each).

16.  Publication of Results

Results of this information collection are not published.

17.  Non-Display of OMB Expiration Date

This submission does not seek approval to forego displaying the expiration date.

18.  Exceptions to "Certification for Paperwork Reduction Submissions"

This submission does not seek an exception to the certification statement.