OF 306-Supporting Statement___ROCIS FINAL_ccc_lml_rev

SUPPORTING STATEMENT FOR THE

DECLARATION FOR FEDERAL EMPLOYMENT,

OPTIONAL FORM 306 (OF 306)

OMB #3206-0182

Justification:

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

The information collected on this form is used to determine acceptability for Federal and Federal contract employment. The U.S. Office of Personnel Management (OPM) is authorized to request this information under Executive Order 13467, as amended; sections 1103 of title 5, United States Code (U.S.C.); and parts 2, 5, 731, and 736 of title 5, Code of Federal Regulations (CFR). Section 1104 of title 5 allows OPM to delegate personnel management functions to other Federal agencies

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 Optional Form (OF) 306 is completed by individual applicants during the hiring process.  It is a fillable form that collects information about an applicant’s selective service registration, military service, and general background.  The information collected on this form is mainly used to determine a person’s acceptability for Federal and Federal contract employment. The information on this form may be used in conducting an investigation to determine a person’s suitability or ability to hold a security clearance, and it may be disclosed to authorized officials making similar, subsequent determinations. 

 

This information is collected by human resources professionals during the hiring process.

 

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.

 The OF306 is available as a pdf on the web.

 

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.

Information collected on the OF 306 about a person’s selective service information, military service and general background information is used to determine the acceptability for Federal employment.  Other forms, specifically the SF-85P and SF-86, may request similar information, but these information collections are for the purpose determining an eligible employee’s suitability for a position of trust or eligibility to occupy a sensitive position or have access to National Security information. 

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.

Not applicable. This collection of information does not affect 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.

The OF 306, is completed by applicants who are under consideration for Federal or Federal contract employment. The OF 306 requests that the applicant provide personal identifying data, including convictions, imprisonments, probations, paroles or military court martial in the past 10 years, delinquency on a Federal debt, Selective Service Registration, United States military service and Federal civilian or military retirement pay or pension received or applied for.

If this information is not collected, OPM would be neglecting authorization to request this information under sections 1302, 3301, 3304, 3328, and 8716 of title 5, U.S.C. Section 1104 of title 5 allows OPM to delegate personnel management functions to other Federal agencies.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.

Not applicable. This information collection is in compliance with 5 CFR 1320.6.

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 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.

OPM previously solicited comments for this collection, with a 60-day public comment period, at 84 FR 5733 (February 22, 2019). 2,748 comments were received.

In the February 22, 2019 Federal Register Notice, OPM proposed to change the form to provide clarification for respondents who may have completed pretrial diversionary programs. The majority of comments received oppose OPM’s proposed change. OPM has decided to renew the form in its current state, without the modifications proposed in the February 22, 2019 Federal Register Notice.  This will permit OPM time to carefully evaluate and consider the 2,748 comments submitted during the comment period by members of the public and other stakeholders.  We will take these comments into consideration to evaluate the best way forward and will work with stakeholders regarding any future possible changes.

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

Not applicable.

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

The OF 306 contains a Privacy Act Statement, as required by 5 U.S.C 552a. The U.S. Office of Personnel Management (OPM) is authorized to request this information under sections 1302, 3301, 3304, 3328, and 8716 of title 5, U.S.C. Section 1104 of title 5 allows OPM to delegate personnel management functions to other Federal agencies. Any disclosure of this record or information in this record is in accordance with routine uses found in System Notice OPM/GOVT-1, General Personnel Records.

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.

Not applicable. The questions are not of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

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

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

Form Name	Form Number	No. of Respondents	No. of Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
OF 306	3206-0182	315,478	1	.25	78,870	$10.75	$847,853.00
Total		315,478	1	.25	78,870	$10.75	$847,853.00

Each OF 306 form takes an estimated 15 minutes to complete.

It is estimated that the total number of respondents for the OF 306 is 315,478 annually. Accordingly, the estimated annual burden is 78, 870 hours. 

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

There is no cost to individual respondents.

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 expenses that would not have been incurred without the paperwork burden.

It is estimated that the cost to print, and maintain the OF 306 form is $285,255.13. This figure is based on the annual response (315,478), supplies $73,292 + burden expense for OF 306s responses received ($211,963.13)= $285,255.13.

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

Not applicable.

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.

Not applicable. Information collected on the forms will not be published.

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.

Not applicable.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

Not applicable.