OGE Form 201 Justification for a Nonsubstantive Change

U. S. OFFICE OF GOVERNMENT ETHICS
JUSTIFICATION FOR A NONMATERIAL/NONSUBSTANTIVE CHANGE
OGE FORM 201 REQUEST TO INSPECT OR RECEIVE COPIES OF EXECUTIVE BRANCH
PERSONNEL PUBLIC FINANCIAL DISCLOSURE REPORTS OR OTHER COVERED RECORDS
MAY 2020

In February, 2020, OGE submitted to the Office of Management and Budget
(OMB) a request for a three-year extension under the Paperwork Reduction Act of the
OGE Form 201 Request to Inspect or Receive Copies of Executive Branch Personnel
Public Financial Disclosure Reports or Other Covered Records. OMB approved the
request in April, 2020. The submission included one information collection instrument, a
pdf form. Shortly after the information collection request was approved in April, it came
to OGE’s attention that the submission should have included a second information
collection instrument, for the online version of the form accessible from OGE’s website
at www.oge.gov. Accordingly, OGE is requesting a nonmaterial/nonsubstantive change
to add the second information collection instrument to the information collection.
The two versions of the form are identical in all substantive respects, although the
format does vary slightly. The estimated average amount of time to complete each
version of the form is the same, at ten minutes. The estimated annual public burden of
1,300 hours, which was detailed in the February, 2020 submission, includes the use of the
online application as well as the pdf version. About 30% of the estimated annual public
burden originates from the use of the online application compared to the pdf version. The
burden estimates on each information collection instrument have been adjusted
accordingly.