9000-0032 Supporting Statement 12.16.19

9000-0032 Supporting Statement 12.16.19.docx

Contractor Use of Interagency Fleet Management System Vehicles--FAR Sections Affected: 51.203 and 52.251-2

OMB: 9000-0032

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SUPPORTING STATEMENT

FOR INFORMATION COLLECTION SUBMISSION

9000-0032, CONTRACTOR USE OF INTERAGENCY

FLEET MANAGEMENT SYSTEM VEHICLES


FAR Section(s) Affected: 51.203, 52.251-2


A. Justification.


1. Administrative requirements. This justification supports a request for revision and renewal of OMB Control Number 9000-032. If it is in the best interest of the Government, the contracting officer may authorize cost-reimbursement contractors to obtain, for official purposes only, interagency fleet management system (IFMS) vehicles and related services. Federal Acquisition Regulation (FAR) 51.203 and the clause at FAR 52.251-2, Interagency Fleet Management System (IFMS) Vehicles and Related Services, are to be used in solicitations and contracts when a cost-reimbursement contract is contemplated and the contracting officer may authorize the contractor to use IFMS vehicles and related services.


Before a contracting officer may authorize cost-reimbursement contractors to obtain IFMS vehicles and related services, the contracting officer must have, among other requirements: (1) A written statement that the contractor will assume, without the right of reimbursement from the Government, the cost or expense of any use of the IFMS vehicles and services not related to the performance of the contract; (2) Evidence that the contractor has obtained motor vehicle liability insurance covering bodily injury and property damage, with limits of liability as required or approved by the agency, protecting the contractor and the Government against third-party claims arising from the ownership, maintenance, or use of an IFMS vehicle; and (3) Considered any recommendations of the contractor.


Authorized contractors shall submit requests for IFMS vehicles and related services in writing to the appropriate GSA point of contact in accordance with the FAR. Contractors’ requests for vehicles or related services must include: (1) Two copies of the agency authorization; (2) The number of vehicles and related services required and period of use; (3) A list of employees who are authorized to request the vehicles or related services; (4) A listing of equipment authorized to be serviced; and (5) Billing instructions and address.


2. Use of the information. The information is used by the Government to determine whether it is in the Government's best interest to authorize a cost-reimbursement contractor to obtain, for official purposes only, IFMS vehicles and related services, to ensure that contractors use IFMS vehicles and related services properly, and to keep track of such use.


3. Use of information technology. We use improved information technology to the maximum extent practicable. Where both the Government agency and contractors are capable of electronic interchange, the contractors may submit this information collection requirement electronically.


4. Efforts to identify duplication. These requirements are issued under the FAR which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication.


  1. If collection of information impacts small businesses or other entities, describe methods used to minimize burden. The burden applied to small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices.


6. Describe consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently. Collection of information on a basis other than contract-by-contract is not practical.


7. Special circumstances for collection. Collection is consistent with guidelines in 5 CFR 1320.6.


8. Efforts to consult with persons outside the agency.  

  1. A 60-day notice was published in the Federal Register at 84 FR 53730, on October 8, 2019. No comments were received.

  2. A 30-day notice was published in the Federal Register at 84 FR 71946, on December 30, 2019.


9. Explanation of any decision to provide any payment or gift to respondents, other than remuneration of contractors or guarantees. Not applicable.


10. Describe assurance of confidentiality provided to respondents. This information is disclosed only to the extent consistent with prudent business practices, current regulations, and statutory requirements.


11. Additional justification for questions of a sensitive nature. No sensitive questions are involved.


12 & 13. Estimated total annual public hour and cost burden. There is no centralized database in the Federal Government that captures information on agencies’ use of the IFMS for this information collection.


Fiscal Year (FY) 2018 data was retrieved from the Federal Procurement Data System (FPDS) to determine the number of agencies that awarded cost-reimbursement contracts that may utilize IFMS to provide vehicles to contractors for official purposes only. FPDS identified approximately 87 contracting agencies that awarded cost-reimbursement contracts in FY 2018. Of these agencies, it is estimated that approximately fifty percent, or 44, contracting agencies may utilize IFMS to provide vehicles to contractors for official purposes only. It is further estimated that each of the 44 agencies would average approximately 3 contractor requests per year to utilize the IFMS, for a total estimate of approximately 132 contactor requests per year. The requests should be limited because certain travel costs (FAR 31.205-46) are allowable under cost-reimbursement contracts, including the costs of contractor-owned or leased automobiles.


FAR 31.205-46(d) provides that these costs are allowable, if reasonable, to the extent that the automobiles are used for company business. Consequently, the FY 2018 FPDS data will serve as the basis for the number of respondents per year. One burden hour was estimated per response to read and prepare information.


No public comments were received in prior years that have challenged the validity of the Government’s estimate.


Estimated respondents/yr 132

Responses/respondent x 1

Total annual responses 132

Estimated hrs/response x 1

Estimated total burden hours 132

Hourly rate* x $ 55

Estimated cost to the public $ 7,260


*Based on the OPM GS-12/step 5 salary ($40.51 an hour) plus 36.25% fringe and overhead burden rate, the one mandated by OMB memorandum M-08-13 for use in public-private competition, rounded to the nearest dollar, or $55 an hour. Reference Salary Table 2019-RUS, Effective January 2019, found at www.opm.gov.


14. Estimated cost to the Government. Time required for Governmentwide review is estimated at 30 minutes, plus time required to process a request is estimated at 30 minutes.


Responses per year 132

Reviewing time/response (hours) x 1

Review time per year (hours) 132

Hourly rate* x $ 55

Estimated cost to the Government $ 7,260


15. Explain reasons for program changes or adjustments reported in Item 13 or 14. The number of responses and the associated estimated burden hours remain unchanged. The estimated cost to the public has decreased slightly because of the use of OPM pay table for the rest of the United States, Salary Table 2019-RUS. DoD, GSA, and NASA started using this salary table to standardize the FAR information collection inventory.


16. Outline plans for published results of information collections. Results will not be tabulated or published.


17. Approval not to display expiration date. Not applicable.


18. Explanation of exception to certification statement. Not applicable.


B. Collections of Information Employing Statistical Methods. Statistical methods are not used in this information collection.

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