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.
OSCâs 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 OSCâs 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 OSCâs contracts with the IT vendors managing the eCMS implementation when that agency unilaterally revoked its agreement with OSC. These circumstances were entirely beyond OSCâs 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 OSCâs 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 OSCâs new electronic case management system, which aims to fulfill OSCâs 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, OSCâs 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 âgo liveâ date for the integrated eCMS system, thus preventing the integrated data collection essential to OSCâs 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 âOSC 2000â 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