The previous version of this form was
approved by OMB/OIRA to replace forms OSC-11, OSC-12, AND OSC-13,
which were also previously approved by OMB. This updated electronic
form will be used by current and former federal employees and
applicants for federal employment, and other covered filers, to
submit allegations of possible prohibited personnel practices or
other prohibited activities for investigation and possible
prosecution by OSC, or review and possible referral to relevant
inspector general offices.
OSC cannot reasonably
comply with the normal clearance procedures under 5 CFR Part 1320
because of an unanticipated event. See 5 CFR 1320.13 (a)(2)(ii).
The usual 90-day notice and publication schedule would harm OSC and
the public because it would force OSC to postpone implementing the
new Form 14 and integrating it with eCMS until after the new fiscal
year begins October 1, 2019, and OSC does not have IT contracts
sufficient to cover the eCMS implementation past September 30,
2019. See id. OSC’s IT contracts for eCMS implementation expire at
the end of FY2019 because of unanticipated events in June and July
2019. This unforeseen exigency arose when the outside federal
agency that provides OSC’s contracting and procurement services
abruptly cancelled its agreement with OSC. (See attached email
exchanges.) The other agency was in the process of extending and
updating OSC’s contracts with the IT vendors managing the eCMS
implementation when that agency unilaterally revoked its agreement
with OSC. These circumstances were entirely beyond OSC’s control.
Because the interagency contracting/procurement agreement has been
suspended, the contracts with the IT vendors will now expire at the
end of FY2019. That means the contracts with the vendors who are
migrating OSC to eCMS and who manage transferring the data from the
dynamic Form 14 into OSC’s eCMS are expiring on September 30, 2019.
(OSC could not have anticipated this abrupt expiration; the process
of converting to eCMS has taken years of contracts with various
vendors.) Thus, OSC needs to implement Form 14 in August to allow
adequate time for the contractors to address any IT issues that
arise with eCMS implementation before the IT contract expires on
September 30, 2019. Pursuant to 5 CFR 1320.13 (a)(2), OSC has
determined that adherence to normal clearance procedures would
result in public harm related to the inability of OSC to integrate
Form 14 with the August 26th activation of OSC’s new electronic
case management system, which aims to fulfill OSC’s Congressional
mandate to operate an all-electronic record keeping system. If OSC
complied with normal timing required for clearance procedures and
PRA issuance, the updated Form 14 could not be timely integrated
with the eCMS, OSC’s newly designed website, and other electronic
record keeping systems. The normal process for clearance of the
updated Form 14 would prevent the collection of information because
a 60/30 day posting and comment schedule would postpone
implementation beyond the August 26, 2019 “go live” date for the
integrated eCMS system, thus preventing the integrated data
collection essential to OSC’s fulfillment of its mission and
statutory mandates. The usual 90-day notice and publication
schedule would also harm the government and OSC by subjecting OSC
to continued IT Security risk posed by its outdated “OSC 2000”
system through which Forms 11, 12, and 13 (the forms Form 14 is
replacing) are processed and accepted. The Federal Information
Security Modernization Act of 2014 (FISMA 2014) requires federal
agencies to follow U.S. Department of Homeland Security information
security policies mandating that agencies rapidly phase out legacy
IT systems lacking updated and strong information security
controls. OSC 2000 is woefully outdated, insecure, and inadequate
because Microsoft no longer supports the antiquated operating
system used to support OSC 2000, leaving the system highly
vulnerable to security incidents. Please see attached letter with
attachments for additional information.
US Code:
5 USC
1212 Name of Law: Powers and Functions of the Office of Special
Counsel
US Code:
5 USC CFR 1800 Name of Law: Filing of Complaints and
Allegations
updated electronic form will be
used by current and former federal employees and applicants for
federal employment, and other covered filers, to submit allegations
of possible prohibited personnel practices or other prohibited
activities for investigation and possible prosecution by OSC, or
review and possible referral to relevant inspector general
offices.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form OSC Form-14 FORM 14: ELECTRONIC SUBMISSION OF ALLEGATIONS AND DISCLOSURES
USOSC Form 14 Full Form.pdf
FORM 14: ELECTRONIC SUBMISSION OF ALLEGATIONS AND DISCLOSURES