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A. JUSTIFICATION
1. Why is this collection necessary and what are the legal statutes that allow this?
Emergency loans are issued to U.S. citizens abroad in several scenarios, two of which are to be covered by this form:
-- Repatriation loans for destitute U.S. citizens who are outside the United States to provide for the citizen’s and/or family member’s return to the United States;
-- Emergency medical and dietary assistance loans for U.S. citizens incarcerated abroad or destitute U.S. citizens abroad who are unable to obtain such services otherwise;
22 U.S.C. § 2670(j) authorizes the Secretary of State to provide emergency medical assistance and dietary supplements, and other emergency assistance, to United States citizens incarcerated abroad or to destitute U.S. citizens abroad who are unable to obtain such services otherwise, such assistance is to be provided on a reimbursable basis to the extent feasible. Such assistance is referred to as Emergency Medical and Dietary Assistance (EMDA).
22 U.S.C. § 2671 authorizes the Secretary of State to make expenditures for unforeseen emergencies arising in the diplomatic and consular service. 22 U.S.C. § 2671(b)(2)(B) provides that such emergency expenditures include loans made to destitute U.S. citizens who are outside of the United States for the purpose of their return to the United States. This is known as the repatriation loan program. 22 U.S.C. § 2671(d) sets forth what the Secretary of State shall require in an application for a repatriation loan, collection procedures, and passport limitations.
Department of State regulations pertaining to, inter alia, services to U.S. citizens in distress are published in 22 CFR Part 71.
2. What business purpose is the information gathered going to be used for?
The information collected in the DS-3072 is used to document the issuance of emergency repatriation and EMDA loans provided in the contexts described above, to obtain consent under the Privacy Act to facilitate sharing information about the welfare of a citizen or lawful permanent resident with designated persons, and to facilitate debt collection.
3. Is this collection able to be completed electronically (e.g. through a website or application)?
The Department of State’s Bureau of Consular Affairs (CA) created an electronic version of the DS-3072, presently available on the Department of State’s website, allowing applicants to type their information into their loan request forms. The form must still be printed and signed by the applicant, and presented to the consular officer who will witness the signature and adjudicate issuance of the loan on behalf of the Department of State. The Department does not accept electronic submission of the form, or electronic signatures.
In connection with the electronic DS-3072, the Department is moving toward acceptance of electronic signatures in some circumstances. However, the Department does not yet accept electronic signatures on the form and is currently assessing the acceptability of e-signatures for different categories of applicants.
When available, electronic submission or online application will not supplant the physical DS-3072. In areas where internet access is unavailable or unreliable, if applicants do not have the level of technological literacy to successfully submit an application online, or when other circumstances exist that make the use of the electronic form impracticable (e.g., situations in which a crisis has impacted the local internet and/or telecommunications infrastructure), the Department of State must provide applicants with the option to use a paper application.
Until a mechanism for electronic submission of the DS-3072 is launched, applicants will continue to provide a paper copy of their application and supporting documentation to a consular officer for adjudication consistent with existing policies and procedures. Consular professionals will examine the documentation and coordinate with CA to ensure information from the DS-3072 is entered into the pertinent Department of State electronic systems including the Consular Task Force system within the Consular Consolidated Database.
4. Does this collection duplicate any other collection of information?
The information in the DS-3072 is not duplicative of information maintained elsewhere or otherwise available.
5. Describe any impacts on small business
The information collection does not involve small businesses or other small entities.
6. What are consequences if this collection is not done?
The DS-3072 is essential to providing a mechanism for issuance of repatriation and EMDA loans to eligible U.S. citizens. Providing emergency assistance to U.S. citizens overseas is a service which the Department has clear statutory authority to provide. If this information collection were not conducted, the consequences would include a considerable hardship to destitute U.S. citizens stranded in foreign countries.
7. Are there any special collection circumstances?
No special circumstances exist.
8. Document publication (or intent to publish) a request for public comments in the Federal Register
The Department of State will publish a 30-day Federal Register notice for public comment. The 60-day notice was published in the Federal Register for public comment on May 13, 2020. There was one comment, which was not relevant to the collection.
9. Are payments or gifts given to the respondents?
No payment or gift is provided to respondents.
10. Describe assurances of privacy/confidentiality
There are no assurances of privacy or confidentiality. In fact, the DS-3072 informs applicants that the Department of State may release their information consistent with the provisions of the Privacy Act of 1974. The form also provides applicants the opportunity to designate additional persons to whom the Department of State may provide information.
11. Are any questions of a sensitive nature asked?
The Secretary of State is required by law at 22 U.S.C. § 2671(d)(1) to request both a verifiable address and Social Security number at the time of loan application. Applicants may not be eligible for the requested assistance if they do not provide the required information.
12. Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection
The estimated hour burden of 486 hours per year is based on estimates that the DS-3072 form is completed by approximately 1,459 loan applicants per year, and only one response is permitted per applicant. Completion time for the form is estimated at 20 minutes. The information involves personal biographic data, the financial cost of repatriation to the United States, and/or emergency medical and dietary assistance in the foreign country and does not require any special research.
The annualized cost to all respondents for the hour burden for collections of information is $17,870.22. The responding custodial parent/legal guardian respondents may hold any occupation. The Department used the mean hourly wage rate from the Bureau of Labor Statistics - Comparison of All Employee Average Hourly Earnings1 to determine the mean hourly wage rate. At the end of December 2018, the mean hourly wage rate was $36.77/hr. To get to $17,870.22, we multiplied the mean hourly wage rate, which is $36.77/hr., by 486 burden hours.
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1 Source: Bureau of Labor Statistics, “Employer Costs for Employee Compensation news release text”. https://www.bls.gov/news.release/ecec.nr0.htm
13. Describe the monetary burden to respondents (out of pocket costs) needed to complete this collection.
There are three costs associated with this application that respondents may incur. The first cost is the cost to notarize the form if executed by someone in the United States on behalf of the U.S. citizen/eligible foreign national facing an emergency abroad. The approximate cost to each respondent to have the form notarized in the United States is $52. Second, there is a cost to the applicant who has to express mail the application to Washington D.C. (only in cases where the applicant is in the United States and the beneficiary minor or incompetent adult is abroad); or an applicant applying abroad who must send the application by express mail to the U.S. embassy/consulate handling the case. The third cost consists of the mileage travel costs for submitting the form to the U.S. diplomatic mission in person.
There are an estimated 136 loan applicants per year who pay a notary to notarize the form if executed by someone in the United States on behalf of the U.S. citizen/eligible foreign national facing an emergency abroad. By multiplying 136 applicants by the $5 notary fee, the notary cost for all respondents combined is $680.
The domestic cost for express mail averages $18, and international express mail has an average cost of $120.3 4 The average rates were based on data for FedEx express mail shipments. Approximately 277 applicants send the form by express mail. The average total cost per applicant for both international and domestic express mail shipments is $70. Multiply 277 applicants by $70 and the total overall cost for express mail is $19,390
Mileage costs for traveling by car to deliver the form to the U.S. diplomatic mission will vary based on how far the person has to travel. If the travel is ten miles, the overall total cost based on 395 respondents that drive is $2,330.50. If the travel is 25 miles, the overall total cost based on 394 respondents is $5,811.50. If the travel is 50 miles, the overall total cost based on 394 respondents is $11,623. The grand total mileage cost is $19,765 based on a total of 1,182 respondents that are anticipated to drive.
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3 Source: FedEx, “Shipping with FedEx”. https://www.fedex.com/en-us/shipping.html
4 Source: FedEx, “International Shipping”. https://www.fedex.com/en-us/shipping/international.html
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Total # of Respondents |
1,459 |
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Total # of Respondents that Drove |
1,182 |
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# of People |
# of Miles |
5Reimbursement Cost Per Mile |
Total Reimbursement for mileage listed for one person |
Totals |
395 |
10 |
$0.59 |
$5.90 |
$2,330.50 |
394 |
25 |
$0.59 |
$14.75 |
$5,811.50 |
394 |
50 |
$0.59 |
$29.50 |
$11,623.00 |
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$19,765.00 |
The estimated grand total cost for all respondents is $39,861 (681 + 19,415 + 19,765).
There is no consular fee associated with this service.
14. Describe the cost incurred by the Federal Government to complete this collection.
The total cost to the Federal Government for evaluating the responses to this information collection is $28,888.20. This total comes from calculating the total number of applicants who submitted the DS-3072 form times the cost for a overseas Foreign Service officer to review. The Department receives an average of 1,459 DS-3072 forms per year. Each DS-3072 is reviewed for 15 minutes by an overseas Foreign Service officer (1,459 x $19.80). These calculations are based on the internal to the Department of State position costs from the Budget and Planning New Position Cost Model.6 The cost rates include fringe and overhead costs.
15. Explain any changes/adjustments to this collection since the previous submission
The number of respondents varies from year to year depending on the number of citizens in need. Major events that occur during any fiscal year can drastically enlarge the average number of responses received across all U.S. posts abroad.
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5 Source: “Average Cost of Owning and Operating an Automobile”. https://www.bts.gov/content/average-cost-owning-and-operating-automobile
6 Source: “Bureau of Budget and Planning New Position Cost Model”, Department of State, Internal Use Only.
16. Specify if the data gathered by this collection will be published.
General tabulations of information regarding applications for Repatriation and EMDA loans are maintained in the “Consular Package,” the Consular Workload Statistical System (CWSS) system. This contains raw data broken down by the Foreign Service post issuing the report. Until the debt is paid in full, records of emergency repatriation and EMDA loans are maintained in the files of the Department of State, Passport Services, filed alphabetically by the name of the subject, the automated case record system of the Office of American Citizens Services and Crisis Management, and the Bureau of the Comptroller and Global Financial Services, Accounts Receivable Branch.
17. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date. Otherwise, write “The Department will display the OMB expiration date.”
The Department will display the OMB expiration date.
18. Explain any exceptions to the OMB certification statement below. If there are no exceptions, write “The Department is not seeking exceptions to the certification statement”.
No exceptions are requested.
This collection does not employ statistical methods.
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | CROBA 30 day supporting statement 2006 |
| Author | MeszarosM |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |