SS-A 0937-0025 PHS 50 and PHS 1813 revised

SUPPORTING STATEMENT

FOR

Form PHS-50 Application for Appointment as a Commissioned Officer in the United States Public Health Service Commissioned Corps

AND SUPPORTING REGULATIONS

CONTAINED IN 42 CFR 21.22 AND 21.34

Background

Pursuant to the Paperwork Reduction Act of 1995, Commissioned Corps Headquarters (CCHQ) previously named the Division of Commissioned Corps Personnel and Readiness (DCCPR) Department of Health and Human Services (HHS), requests an approval by the Office of Management and Budget (OMB) for a revision on form PHS-50, Application for Appointment as a Commissioned Officer in the Commissioned Corps of the U.S. Public Health Service, (OMB No. 0937-0025).

A. Justification

1. Circumstances Making the collection of Information Necessary

The principal purpose of this revision is a result of the Coronavirus Aid, Relief, and Economic Security (CARES) Act that was signed into law on March 27, 2020. The Public Health Service Act was amended to provide for a Ready Reserve Corps in times of public health emergencies, in addition to national emergencies. collecting the information is to permit HHS to determine eligibility for appointment of applicants into the Regular Corps and Ready Reserve Corps of the Commissioned Corps of the U.S. Public Health Service (Corps). The Corps is one of the seven Uniformed Services of the United States (37 U.S.C. 101(3)), and appointments in the Corps are made pursuant to 42 U.S.C. 204 et seq. and 42 CFR 21.58.

Applicants for appointment in the Corps must submit the information requested in the application process, including form PHS-50, so that a determination can be made about their qualifications for appointment as required by law and regulations. The application process begins at http://www.usphs.gov .

Recruitment and retention is a primary focus of the Corps, and efforts are directed toward recruiting entry-level and experienced health professionals and attempting to interest them in career service in the Regular Corps and Reserve Corps.

2. Purpose and Use of Information Collection

The Commissioned Corps of the U.S. Public Health Service has a need for the information in order to assess the qualifications of each applicant and make a determination whether the applicant meets the requirements to receive a commission. The information is used to make determinations on candidates/applicants seeking appointment to the Regular Corps and Ready Reserve Corps to assess whether they are suitable for life in the uniformed services based upon a review of a variety of assessment factors including, but not limited to: personal adjustment, employment history, character, and a candidate's prior history of service in one of the uniformed services. Their potential for leadership as a commissioned officer and their ability to deal effectively with people is evaluated.

In addition to the uses authorized by law, information from an individual’s records may be disclosed to: prospective employers or other organizations at the request of the individual; other Federal agencies to the extent necessary to obtain suitability and security investigation reports; non-HHS organizations if the applicant is a candidate for assignment by the Corps to a non-HHS organization, e.g., Federal Bureau of Prisons, U.S. Marshals Service (both with the Department of Justice), U.S. Coast Guard (Department of Homeland Security), U.S. Department of Agriculture, Department of the Interior, Commissioned Corps of the National Oceanic and Atmospheric Administration (Department of Commerce), Department of Defense, and Environmental Protection Agency, etc. If the information was not collected, it would not be possible to evaluate applicants for appointment to the Corps.

The purpose of the revision is to allow the Types of Duty(ies) for which an applicant may apply to the Public Health Service Commissioned Corps to include the Ready Reserves. The PHS-50 form currently allows applicants to apply to following Types of Duty(ies): General Duty (extended Active Duty –Full Time), Junior COSTEP and Senior COSTEP.

The newly implemented electronic application process which allows for opening the application to all interested health professional for the Regular Corps and the Ready Reserve Corps such as: Medical, Dental, Nurse, Pharmacy, Scientist, Dietician, Therapist, Health Services, Engineer, Environmental Health and Veterinarians which increased the number of respondents from 3,000 to 3,500.

If the applicant is appointed, the information collected will be used for subsequent personnel actions such as call to active duty in the Regular Corps or the Ready Reserve Corps, transfer, and promotion orders, and in determining eligibility for benefits.

If the applicant is not appointed, the records are retained for 1 year and then destroyed.

3. Use of Improved Information Technology and Burden Reduction

An electronic submission process using the Applicant Enrollment System (AES) will be utilized. A digital signature will be accepted. Applicants will also have the ability to submit a paper-based application if needed. The PHS -1813 will remain in its current form and submitted electronically via the AES system. The Commissioned Corps Personal Statement will remain in its current form and submitted electronically via the AES system.

1. Efforts to Identify Duplication and Use of Similar Information

The Corps has its own requirements for appointment so there is no duplication of efforts with respect to its application requirements.

4. Impact on Small Businesses or Other Small Entities

The information collection involves only individuals.

4. Consequences of Less Frequent Collection of the Information

The electronic application process pertains only to professionals who wish to apply for appointment in the Regular Corps and the Ready Reserve Corps. If so, the individual must submit the required forms. There is no other method to collect this information, and if the information is not collected, there would be no way to determine eligibility for appointment in the Corps. There are no legal obstacles to reduce the burden.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

Each applicant must complete the forms in the electronic application process. The applicant completes only one application for the Regular Corps or the Ready Reserve Corps regardless of the number of professional positions in the HHS Operating Divisions (OPDIVs)/Staff Divisions (STAFFDIVs) and non-HHS organizations in which he/she may be interested. The request fully complies with the regulation.

8. Comments in Response to the Federal Register Notice/Outside Consultation

The 60-day FRN published, Monday, August 3, 2020, p 46679- Vol. 85, No. 149. No public comments received.

9. Explanation of Any Payment/Gift to Respondent

No payments or gifts are provided to respondents.

10. Assurance of Confidentiality Provided to Respondents

Data will be kept private to the extent allowed by law of the data collected is provided pursuant to the Privacy Act of 1974 (5 U.S.C. 552a). Arrangements concerning the handling, storage, and disposition of information are explained in the Privacy Act System of Notice (09-40-0001, PHS Commissioned Corps General Personnel Records,@ HHS/PSC/HRS) published in the Federal Register, Vol. 63, No. 238, page 68596, December 11, 1998 (see Tab E). The methods of collecting and handling the information comply with the Privacy Act of 1974 and OMB Circular A-130, Management of Federal Information Resources, Appendix I, AFederal Agency Responsibilities for Maintaining Records About Individuals.

11. Justification for Sensitive Questions

The Corps is not currently collecting information on the PHS-50 about an applicant’s race and ethnic background, but form PHS-50 has been revised to contain a request for gender as staff members have found it difficult to ascertain by name how to address an individual in written correspondence, phone conversations, and execution of personnel orders.

Age information historically has been collected on form PHS-50 because this information has a direct bearing on an applicant’s qualification for appointment in the Corps. Under 42 U.S.C. 209(a)(3), no individual who has attained the age of 44 may be appointed to the Corps unless the Surgeon General determines that the applicant possesses exceptional qualifications not readily available elsewhere in the Corps. It is important that information about an applicant’s age be available on form PHS-50, and this form has safeguards designed to protect. Because of statutory requirements imposed by 42 U.S.C. 209(a)(3), provision of this information is not voluntary for applicants to the Corps.

Naturalized citizens are requested to provide information on form PHS-50 about the date they entered the country, the date they were naturalized, their naturalization number, the person to whom the naturalization number was issued, and the place naturalized. This information is necessary to obtain information from the U.S. Citizenship and Immigration Service in the Department of Homeland Security for purposes of conducting the suitability investigation.

Disclosure of the social security number is mandatory under provisions of the Social Security Act. Corps officers are under Social Security ‘covered employment’ and taxes must be withheld from their salaries. The social security number is also used as an identifier throughout an officer's career. It is used primarily to identify an officer’s personnel, leave, and pay records and to relate one to the other. The social security number is also used in connection with lawful requests for information from former employers, educational institutions, and financial or other organizations. The information gathered through the use of the number will be used only as necessary in personnel administration processes carried out in accordance with established regulations and published notices of systems of records. The use of the social security number is made necessary because of the large number of officers (active, retired, inactive) and applicants who have identical names and birth dates, and whose identities can only be distinguished by the social security number.

The information requested on form PHS-1813 is needed in order to determine an applicant’s suitability for competitive appointment in accordance with Executive Order No. 10450 and regulations prescribed in CCD 123.01, “Involuntary Separation” of the electronic Commissioned Corps Issuance System at http://dcp.psc.gov. Appointment boards assess the professional qualifications of applicants and the boards are responsible for making certain that only fully-qualified applicants are recommended for appointment.

1. Estimates of Annualized Hour and Cost Burden

The number of respondents will increase with the implementation of the Reserve Corps. The estimated number of respondents for the PHS-50 is 3,500 per year.

Each applicant must complete the form electronically original and one copy of form PHS-50. The original is retained for records management purposes

Based on a sample of individuals who completed form PHS-50, the average amount of time required to complete the form is 1 hour. Each applicant must submit references from four (4) individuals. Based on a sample of individuals who completed form PHS-1813, the average amount of time required to complete the form is less than 5 minutes for the applicant, and 15 minutes for each individual who provides a reference.

The prequalification questionnaire is included in the electronic application intake process. The allocation of time is 10 minutes. Currently the entire process is conducted by the Recruitment and Assignments Branch in the CCHQ, with some assistance provided by CCHQ’s helpdesk personnel.

It should be noted, however, that each applicant is required to complete several DoD forms in order to make application to the Corps:

DD Form 2807-1, AReport of Medical History, and

DD Form 2808, AReport of Medical Examination.

However, the response burden for these forms is reported annually by DoD. Therefore, the response burden listed below pertains only to form PHS-50, form PHS-1813, and the Commissioned Corps Personal Statement:

12A. Estimated Annualized Burden Hours

Type of Respondent	Form Name	No. of Regular Corps Respondents	No of Reserve Corps Respondents	No Response per Respondent)	Average Burden per Responses (in hours)	Total Burden Hours
Interested Health Professionals	Prequalification Questionnaire	6,000	1,000	1	10/60	1,167
Health Professionals	Form PHS-50	3,000	500	1	15/60	875
References (college professors/teachers)	Form PHS-1813	3,000	500	1	15/60	875
Health Professionals	Addendum: Commissioned Corps Personal Statement	3,000	500	1	15/60	875
Total						3,792

12B. Estimated Annualized Burden Costs

Type of Respondent	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
Interested Health Professionals	1,167	$8.75	$10,211.25
Health Professionals	875	$75.00	$65,625.00
References (college professors/teachers)	875*	$35.00	$30,625.00
Health Professionals	875**	$75.00	$65,625.00
Total			$172,086.25

*Represents four (4) references (15/60) submitted on each applicant’s suitability.

12. Estimates of Other Total Annual Cost Burden to Respondents or Record keepers/Capital Costs

The only costs to the respondents are the time required to complete the forms in the application process and for the acquisition of college transcripts, a one-time cost of approximately $10 depending on the educational institution, and applicants are also required to pay required postage, a one-time cost of approximately $2.00. There are no other identified costs associated with collection of the information.

Type of Respondent	Number of Respondents	College Transcripts ($10.00) and Mailing Costs ($2.00) = $12.00	Total Respondent Costs
Health Professionals	3,500	$12.00	$42,000.00
Total			$42,000.00

 Annualized Cost to the Federal Government

On average, approximately 4 hours of staff time by the Recruitment and Assignments Branch staff of CCHQ are required to process each application. At approximately $48.79 per hour the cost of processing by the Recruitment and Assignments Branch staff is approximately $683,060 per year for 3,500- PHS-50 applications.

Type of Respondents	Number of Respondents	Staff Hourly Rate (salary plus overhead)	Staff Time Spent on Each Application	Total
Health Professionals	3,500	$48.79	4 hours	$683,060.00

15. Explanation for Program Changes

This is a modification request due to a program adjustment of hours as a result of implementation of the Ready Reserve Corps. The modification of Table 12 includes the additional burden hours for the Ready Reserve.

A newly implemented digital application process which allows for opening the application to all interested health professional to include: Medical, Dental, Nurse, Pharmacy, Scientist, Dietician, Therapist, Health Services, Engineer, Environmental Health and Veterinarians which increased the number of respondents from 3,000to 3,500. The implementation of the Ready Reserve increases the number of interested health professionals by 1,000 and as a result increasing the burden hours as reflected in Table 12A.

There are no changes to how candidates receive the application forms.

1. Plans for Tabulation and Publication and Project Time Schedule

The Commissioned Corps requests OMB review of the supporting documents by November 2, 2020 with approval by mid-November, 2020.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

The date of expiration of OMB approval will be displayed, as it is appropriate to do so.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

B. Collection of Information Employing Statistical Methods

Not applicable. The information collected will not be analyzed by employing statistical methodology.

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