Supporting Statement 1660-0100 Part A FINAL 04272020

Supporting Statement 1660-0100 Part A FINAL FINAL 04272020.docx

General Admissions Application (Long and Short) and Stipend Forms

OMB: 1660-0100

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February 5, 2020


Supporting Statement for Paperwork Reduction Act Submissions



OMB Control Number: 1660 - 0100

Title: General Admissions Applications (Long and Short) and Stipend Forms

Form Number(s): FEMA Forms

119-25-0-1

119-25-0-6

119-25-3

119-25-4

119-25-5


General Instructions


A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.


Specific Instructions


A. Justification


  1. Explain the circumstances that make the collection of information necessary.

Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information. Provide a detailed description of the nature and source of the information to be collected.

The Federal Emergency Management Agency (FEMA) offers courses and programs that are delivered at the National Emergency Training Center (NETC) in Emmitsburg, Maryland, the Center for Domestic Preparedness (CDP) in Anniston, Alabama, and throughout the Nation. This training is delivered in coordination with FEMA’s training partners, which include State and local jurisdictions, non-profit organizations, and colleges and universities. To facilitate meeting these requirements, FEMA collects information necessary for applicants to be registered, accepted, and, in some cases, partially reimbursed for attending preparedness courses. The authorities under which FEMA delivered this training are as follows:


  1. Section 7 of Pub. L. 93-498, the Federal Fire Prevention and Control Act, as amended, 15 U.S.C. § 2206, established the National Fire Academy (NFA) to advance the professional development of fire service personnel and of other persons engaged in fire prevention and control activities.

  2. Section 611(f) of Pub. L. 93-288, the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as amended, 42 U.S.C. § 5196(f), authorizes FEMA to conduct or arrange, by contract or otherwise, training programs for the instruction of emergency preparedness officials and other persons in the organization, operation, and techniques of emergency preparedness; conduct or operate schools or classes, including the payment of travel expenses and per diem allowances for these purposes, in lieu of subsistence for trainees in attendance or the furnishing of subsistence and quarters for trainees and instructors on terms prescribed by the Director; and provide instructors and training aids as deemed necessary. This training is conducted through the Emergency Management Institute (EMI).

  3. Title XIV of the National Defense Authorization Act of 1997, Pub. L. 104-201, 110 Stat. 2432; Title I of the Departments of Commerce, Justice, and State, the Judiciary, and Related Agencies Appropriations Act of 1998, Pub. L. 105-119, 111 Stat. 2440; Sections 403 and 430 of the Homeland Security Act of 2002, Pub. L. 107-296, 116 Stat. 2135; and Section 611 of the Post-Katrina Emergency Management Reform Act of 2006, Pub. L. 109-295, 120 Stat. 1355, all authorize CDP to serve as a training facility for all relevant Federally supported training efforts that target state and local law enforcement, firefighters, emergency medical personnel, and other key agencies such as public works and state and local emergency management. The focus of the training is to prepare relevant state and local officials to deal with chemical, biological, or nuclear terrorist acts and handle incidents dealing with hazardous materials.

  4. Pub. L. 110-53, the Implementing Recommendations of the 9/11 Commission Act of 2007, 6 U.S.C. § 1102, established a National Domestic Preparedness Consortium within the Department of Homeland Security. The Consortium is mandated to identify, test, and deliver training to State, local, and Tribal emergency response providers, provide on-site and mobile training at the performance, management, and planning levels, and facilitate the delivery of training by the training partners of the Department.


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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

FEMA Form 119-25-0-1, General Admissions Application (electronic or paper), is used to determine eligibility and to admit applicants to courses and programs offered at NETC, CDP and other FEMA training locations throughout the United States. Applicants complete the FEMA Form 119-25-0-1 and send it to the respective Admissions Office (NETC or CDP). Information from the application is maintained securely in the respective admissions systems per the Privacy Act of 1974, 5 U.S.C. § 552a, and applicable records management requirements.

FEMA Form 119-25-0-6, Registration Training Form (electronic or paper), is used to admit applicants to courses and programs offered at CDP and other FEMA training locations throughout the United States. Applicants use this form when less information is necessary to enroll respondents into certain courses and programs where travel reimbursement does not apply. Information from the application is maintained securely in the Student Application and Registration Records System per the Privacy Act of 1974, 5 U.S.C. § 552a, and applicable records management requirements.

FEMA Form 119-25-3, Student Stipend Agreement, is used by FEMA to reimburse a portion of the expense of attendance in the form of a stipend which is available to eligible students who attend a course or program offered by NFA or EMI. Certain financial information such as name and social security number of the student, the name of the financial institution, the name on the bank account for electronic payment purposes, the bank routing and account number, and the type of account to which the payment is being made is shared with the Department of the Treasury so that stipend payments can be made through the Treasury’s direct deposit process.

FEMA Form 119-25-4, Student Stipend Agreement (Amendment), is used by FEMA to reimburse an additional portion of the expense of attendance for which the student may be eligible.

FEMA Form 119-25-5, National Fire Academy Executive Fire Officer Program Application for Admission, is used to admit individuals who have applied for and completed the first portion of the application process (FEMA Form 119-25-0-1) for the NFA Executive Fire Officer Program. In addition to the required FEMA Form 119-25-5, applicants who apply for the NFA Executive Fire Officer Program must provide the following additional Documentation: Letter of Intent, Resume, Letter of Recommendation, Diploma Photocopy, and Organizational Chart. The respondent is required to submit all of these forms and documentation to be considered for selection to attend the Program.

FEMA may release information from the general admissions application forms to FEMA training agency staff and partners to analyze application and enrollment patterns; a physician providing medical assistance to students during training; Board of Visitors members to evaluate programmatic statistics; State, local, and Tribal agencies to provide FEMA training statistics; Members of Congress; and FEMA training program contractors.

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.

FEMA Forms 119-25-0-1, 119-25-0-6, and 119-25-5 are electronically accessible and can be downloaded for completion. The saved copy can be sent to FEMA via mail, email, or fax. Once the information has been received, FEMA admissions staff enters the data into a Student Application and Registration Records System (SARRS) (the general public does not have access to the system). FEMA Forms 119-25-0-1 and 119-25-0-6 can also be completed and submitted electronically using the on-line application capability of the various training providers.

FEMA Forms 119-25-3 and 119-25-4, Student Stipend Agreement and Student Stipend Agreement (Amendment), information is provided at the time and place of the course or program to individuals who have registered and have been accepted to attend FEMA courses for which a stipend is paid. The 119-25-3 and 119-25-4 are printed from the SARRS admissions system with certain information already completed. The student provides the financial institution information, verifies the pre-printed information on the form, and signs and dates the form. The student provides receipts for the expenses for which they may be eligible to receive a stipend. Student application information is maintained securely in the Student Application and Registration Records System.

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. 

This information is not collected in any other form and, therefore, is not duplicated elsewhere.

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.

This information collection does not have an impact on small businesses or other small entities.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

If the information was not collected, FEMA would not be able to determine eligibility to attend FEMA training. There would also be no record of the names or number of individuals that would be likely to attend FEMA training or who did attend such training. There would also be no records to show that FEMA was meeting its training mission or an accounting for the funds expended for training. Reimbursement would not be possible as Federal Travel Regulations require the collection of specific information. It would also be difficult to maintain the records necessary to keep the American Council on Education (ACE) recommendation for college credit awards, since accreditation standards require documentation of an official and consistent admission process. Applying for FEMA training is voluntary.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

  1. Requiring respondents to report information to the agency more often than quarterly.


 (b) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

  1. Requiring respondents to submit more than an original and two

copies of any document.

  1. Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.

  1. In connection with a statistical survey, that is not designed to

produce valid and reliable results that can be generalized to the universe of study.

 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.


 (g) That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use.

 (h) Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

The special circumstances contained in item 7(a) thru (h) of the supporting statement are not applicable to this information collection.

8. Federal Register Notice: 

 a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice 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.

A 60-day Federal Register Notice inviting public comments was published on October 7, 2019, 84 FR 53452. No comments were received.

A 30-day Federal Register Notice inviting public comments was published on 2/11/2020, 85 FR 7780. No comments were received.

 b. 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.

The American Council on Education (ACE) reviews NFA and EMI courses and makes recommendations for credit equivalencies. Through its Program on Non-Collegiate Sponsored Instruction, ACE reviews formal training developed outside colleges and universities and publishes its recommendations in The National Guide to Educational Credit for Training Programs, a guide used by educational institutions throughout the country.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Most FEMA students who participate in the courses are able to provide feedback at the time of the course. The courses are offered on a continuous basis and their comments, suggestions, and feedback are reviewed for enhancement of the program. Consultation also takes place on a regular basis with FEMA stakeholders.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

A Privacy Threshold Analysis (PTA) was approved for FEMA Forms 119-25-4 and 119-25-5 on July 24, 2019; FEMA Forms 119-25-0-1 and 119-25-3 on August 16, 2019; and FEMA Form 119-25-0-6 on August 21, 2019. A Privacy Impact Assessment (Student Training/Exercise Application and Registration Records (STARRS), DHS/FEMA PIA-022) was approved for this collection on March 29, 2012. An approved System of Records Notice (Training and Exercise Program Records System) was published for this collection on April 6, 2011, 76 FR 19107.

According to the Uses section of the Privacy Act Statement on the General Admissions Application, FEMA may release information to: FEMA training agency staff and partners to analyze application and enrollment patterns; a physician providing medical assistance to students during training; Board of Visitors members to evaluate programmatic statistics; State, local, tribal agencies to provide FEMA training statistics; Members of Congress; and FEMA training program contractors. Although these uses provide for the release of certain information provided by applicants, the information being released is restricted to general statistical data and business-related information. Privacy related information such as home address, home telephone numbers, date of birth, gender and race, and banking information is not released. The security of that information is maintained through administrative and technological controls within the FEMA network and the Admissions System. Administratively, student data use is restricted to authorized employees who must access such information in their normal duties. Release of individual student information must be requested in writing by the individual or with his or her written approval.

Update information related to the Privacy Impact Assessment

11. Provide additional justification for any question 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.

There are no questions of a sensitive nature. The questions regarding race and ethnicity of the applicant are in compliance with the Standards for the Classification of Federal Data on Race and Ethnicity. Responding to the race and ethnicity questions is voluntary and has no impact on the disposition of an application.

 12. Provide estimates of the hour burden of the collection of information. The statement should:

 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

FEMA Form 119-25-0-1 will be completed by an estimated 52,000 respondents (fire department and emergency management personnel from the Federal, State, local, and Tribal government; business or other for-profit organizations; and not-for-profit institutions who are charged with fire prevention and control and emergency management activities). The average burden per response is estimated at 9 minutes per respondent, for a total Annual Burden Hour of 7,800 hours. There is no change in the burden hours.

FEMA Form 119-25-0-6 will be completed by an estimated 154,500 respondents (fire department and emergency management personnel from the Federal, State, local, and Tribal government; business or other for-profit organizations, and not-for-profit institutions who are charged with fire prevention and control and emergency management activities) applying for courses offered by the Consortium. The average burden per response is estimated at 6 minutes per respondent, for a total Annual Burden Hour of 15,450. There is no change in the burden hours.

FEMA Form 119-25-3 will be completed by an estimated 7,000 respondents (fire department personnel from the State, local or Tribal government; business or other for-profit organizations; and not-for-profit Institutions who are charged with fire prevention and control activities). The average burden per response is estimated at 2 minutes, for a total Annual Burden Hour of 233 hours. There is no change in the burden hours.

FEMA Form 119-25-4 will be completed by an estimated 500 respondents (fire department personnel from the State, local or Tribal government; business or other for-profit organizations; and not-for-profit Institutions who are charged with fire prevention and control activities) and the average burden per response is estimated at 2 minutes, for a total Annual Burden Hour of 17 hours. There is no change in the burden hours.

FEMA Form 119-25-5 will be completed by an estimated 300 National Fire Academy Executive Fire Officers respondents (fire department personnel from the Federal, State, local or Tribal government; business or other for-profit organizations; and not-for-profit fire departments). These same 300 fire officer respondents will also submit supplemental information including a Letter of Intent, Letter of Recommendation, Diploma, organizational chart, possibly a short essay, and additional documentation. The average burden response time per response will be 3 hours, for a total burden of 900 hours. There is no change to the burden hours.

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

See the responses for the individual forms above.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.4 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

















Estimated Annualized Burden Hours and Costs

Type of Respondent

Form Name / Form Number

No. of Respon-dents

No. of Respon-ses per Respon-dent

Total No. of Responses

Avg. Burden per Response (in hours)

Total Annual Burden (in hours)

Avg. Hourly Wage Rate

Total Annual Respondent Cost

Federal, State, local, or Tribal government; business or other for-profit organizations; not-for-profit Institutions

 General Admissions Application / FEMA Form 119-25-0-1


52,000

1

52,000

0.15 (9 min.)

7,800

$46.88

$365,664

Federal, State, local, or Tribal government; business or other for-profit organizations; not-for-profit Institutions

 Training Registration Form / FEMA Form 119-25-0-6

154,500

1

154,500

0.10 (6 min.)

15,450

$46.88

$724,296

State, local, or Tribal government; business or other for-profit organizations; not-for-profit Institutions

 Student Stipend Agreement / FEMA Form 119-25-3


7,000

1

7,000

0.0333 (2 min.)

233

$46.88

$10,983

State, local, or Tribal government; business or other for-profit organizations; not-for-profit Institutions

 Student Stipend Agreement (Amendment) / FEMA Form 119-25-4

500

1

500

0.0333 (2 min.)

17

$46.88

$797

Federal, State, local, or Tribal government; business or other for-profit organizations; not-for-profit Institutions 

National Fire Academy Executive Fire Officer Program Application for Admission/FEMA Form 119-25-5 and other required documentation

300

1

300

3

900

$74.07

$66,663

Total

 

214,300

 

214,300

 

24,400

 

$1,168,387



Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.41. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.4, and the entry for the “Avg. Hourly Wage Rate” would be $59.51.

According to the U.S. Department of Labor, Bureau of Labor Statistics2, the May 2018 Occupational Employment and Wage Estimates wage rate for Local government Firefighters (Standard Occupational Classification 33-2011) is estimated to be $25.60, and Local government First Line Supervisors/Managers of Firefighting and Prevention Workers (SOC 33-1021) $38.61. Including the wage rate multiplier of 1.46, the fully-loaded wage rates are an estimated at $37.38 per hour for Firefighters, and $56.37 for First Line Supervisors of Firefighters. Assuming an even split of Firefighters and Supervisors, the average wage is estimated at $46.88. Therefore, the estimated annual burden hour cost is estimated to be $1,100,508 ($37.38 x 23,500 hours) + ($56.37 x 900 hours).

The wage rate category for National Executive Fire Officers based on Local government General and Operations Managers (SOC 11-1021) is estimated to be $50.73 and using the 1.46 multiplier the wage is $74.07 per hour. Therefore, the total cost burden is estimated to be 900 hours x $74.07 = $66,663.

The total annual cost burden hour for this collection is estimated to be $1,168,387.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

There are no recordkeeping, capital, start-up or maintenance costs associated with this information collection.

The cost estimates should be split into two components:

a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred.

b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.

Annual Cost Burden to Respondents or Recordkeepers

Data Collection Activity/Instrument

*Annual Capital Start-Up Cost (investments in overhead, equipment, and other one-time expenditures

*Annual Operations and Maintenance Costs (such as recordkeeping, technical/professional services, etc.)

Annual Non-Labor Cost (expenditures on training, travel, and other resources)

Total Annual Cost to Respondents



$0

$0

$0

$0


Total

$0

$0

$0

$0




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 expense that would have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item

Cost ($)

Contract Costs (See Appendix A)

$70,770

Staff Salaries* (See Appendix A)

$203,598

Facilities [cost for renting, overhead, etc. for data collection activity]

$0

Computer Hardware and Software [cost of equipment annual lifecycle]

$0

Equipment Maintenance [cost of annual maintenance/service agreements for equipment]

$0

Travel

$0

Other

$0

Total

$274,368

1 Office of Personnel Management 2020 Pay and Leave Tables for the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA locality. Available online at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/20Tables/html/DCB.aspx. Accessed January 24, 2020.

2 Wage rate includes a 1.46 multiplier to reflect the fully-loaded wage rate.



The information is broken down by organization in Appendix A.

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

In the previous submission, the number of responses was not captured correctly. This submission captures the accurate number of responses, 154,500 versus 52,000 on the previous submission; FEMA Form 119-25-0-6, Training Registration Form.

A "Program increase" is an additional burden resulting from a Federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours

Data Collection Activity/Instrument

Program Change (hours currently on OMB inventory)

Program Change (new)

Difference

Adjustment (hours currently on OMB inventory)

Adjustment (new)

Difference



0

0

0

0

0

0


Total

0

0

0

0

0

0




Explain:

There are no changes in the burden hours.

Itemized Changes in Annual Cost Burden

Data Collection Activity/Instrument

Program Change (cost currently on OMB inventory)

Program Change (new)

Difference

Adjustment (cost currently on OMB inventory)

Adjustment (new)

Difference

FEMA Form 119-25-0-1, General Admissions Application





$321,048

$365,664

+$44,616

FEMA Form 119-25-0-6, Training Registration Form




$635,922

$724,296

+$88,374

FEMA Form 119-25-3, Student Stipend Agreement





$9,590

$9,845

+$255

FEMA Form 25-4, Student Stipend Agreement (Amendment)





$700

$703

+$3

FEMA Form 119-25-5, National Fire Academy Executive Fire Officer Program Application





$44,559

$86,157

+$22,104

Total

0

0

0

$1,011,819

$1,167,171

$155,352



Explain:

The increases are the result of wage rate increases. For firefighters and first level supervisors, the wage rate increased from $41.16 to $46.88 while the wage rate for executive fire officers increased from $49.51 to $74.07.

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.

There are no outline plans for tabulation and publication of data for this information collection.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

This collection does not seek approval to not display the expiration date for OMB approval.

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

This collection does not seek an exception to “Certification for Paperwork Reduction Act Submissions.” This collection does not use efficient statistical survey methodology or use of information technology.  Statistical Survey methodology "is not applicable". Question #3 in the supporting statement justifies the non-use of information technology.



Appendix A


Annual Cost to the Federal Government


National Emergency Training Center, Emmitsburg MD (NETC)


Staff Salaries

Admissions Clerk, GS-5/5 $44,532 @75% x 1.46 $48,763

Admissions Clerk, GS-5/5 $44,532 @75% x 1.46 $48,763

Admissions Clerk, GS-5/7 $47,152 @75% x 1.46 $51,631

Admissions Clerk, GS-5/5 $44,532 @25% x 1.46 $16,254

Total Salaries $165,411


NOTE: Office of Personnel Management 2020 Pay and Leave Tables for the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA locality. Available online at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/20Tables/html/DCB.aspx. Accessed January 24, 2020. Salaries include a 1.46 multiplier.

Center for Domestic Preparedness, Anniston AL (CDP)


Contract Costs

3 Admissions Clerks, $94,360 @75% $70,770


Staff Salaries

Program Specialist, GS-12/8 $94,879 @10% x 1.46 $13,852

Program Specialist, GS-12/2 $79,490 @10% x 1.46 $11,606

Program Specialist, GS-12/5 $87,185 @10% x 1.46 $12,729

Total Salaries $38,187


NOTE: Office of Personnel Management 2020 Pay and Leave Tables for the Birmingham-Hoover-Talladega, AL locality. Available online at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/20Tables/html/BH.aspx. Accessed January 24, 2020. Salaries include a 1.46 multiplier.


Total $108,957


1 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1.  “Employer costs per hour worked for employee compensation and costs as a percent of total compensation:  Civilian workers, by major occupational and industry group, September 2016.”  Available at http://www.bls.gov/news.release/archives/ecec_06182019.pdf.  Accessed September 12, 2019.  The wage multiplier is calculated by dividing total compensation for all workers of $36.77 by wages and salaries for all workers of $25.22 per hour yielding a benefits multiplier of approximately 1.46

2 Information on the mean wage rate from the U.S. Department of Labor is available online at: https://www.bls.gov/oes/tables.htm

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