New Collection - USM-234 - Supporting Statement

New Collection - USM-234 - Supporting Statement.docx

USM-234, District/Aviation Security Officers (DSO/ASO) Personal Qualifications Statement

OMB: 1105-0104

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Supporting Statement for Paperwork Reduction Act Submissions



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 of 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

  1. 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.

This form is the basis for an initial criminal background investigation that will be used to determine the applicant’s law enforcement qualifications and suitability to work for the U.S. Government under contract. The U.S. Government is authorized to ask for this information under 5 U.S.C. 3301 and 28 U.S.C. 561.

3301. Civil service; generally The President may

(1) prescribe such regulations for the admission of individuals into the civil service in the executive branch as will best promote the efficiency of that service;

(2) ascertain the fitness of applicants as to age, health, character, knowledge, and ability for the employment sought; and

(3) appoint and prescribe the duties of individuals to make inquiries for the purpose of this section.

561. United States Marshals Service

(a) There is hereby established a United States Marshals Service as a bureau within the Department of Justice under the authority and direction of the Attorney General. There shall be at the head of the United States Marshals Service (hereafter in this chapter referred to as the ‘‘Service’’) a Director who shall be appointed by the President, by and with the advice and consent of the Senate.

(b) The Director of the United States Marshals Service (hereafter in this chapter referred to as the ‘‘Director’’) shall, in addition to the powers and duties set forth in this chapter, exercise such other functions as may be delegated by the Attorney General.

(c) – (e) not applicable

(f) The Director is authorized to appoint and fix the compensation of such employees as are necessary to carry out the powers and duties of the Service and may designate such employees as law enforcement officers in accordance with such policies and procedures as the Director shall establish pursuant to the applicable provisions of title 5 and regulations issued thereunder.

(g) The Director shall supervise and direct the United States Marshals Service in the performance of its duties.

(i) not applicable

  1. 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.

The United States Marshal District will use the information on these applications to pre-screen applicants’ law enforcement qualifications and suitability to work for the U.S. Government under contract.

  1. 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.

The collection of information does not currently use automated collection techniques. The pool of suitable law enforcement applicants is very limited therefore putting in place the information technology infrastructure necessary to allow applicants to submit their applications on line is not cost effective at this time.

  1. 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.

The USM-234 is a job application form and therefore the information being requested is not available anywhere else in the DOJ and USMS databases.

  1. 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 burden.

Not applicable. The form is specific to individual applicants not small businesses.

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

The USMS derives its statutory authority to acquire DSOs/ASOs via personal services contracts under 28 U.S.C. §565. If the collection is not conducted, then the USMS will not be able to hire District/Aviation Security Officers.

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

    • requiring respondents to report information to the agency more often than quarterly;

This is an employment application, therefore applicants will typically only submit an applications once.

    • requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Applicants using this form are not required to respond to this collection of information.

    • requiring respondents to submit more than an original and two copies of any document;

This collection of information does not require respondents to submit any other documentation.

    • requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

This collection of information does not require respondents to retain records.

    • 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;

The collection of information has nothing to do with statistical surveys.

    • requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

The collection of information has nothing to do with statistical surveys.

    • 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; or

The collection of information does not include a pledge of confidentiality from the respondent.

    • requiring respondents to submit proprietary trade secrets, 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 collection of information does not require respondents to submit proprietary trade secrets, or other confidential information.

  1. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), 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. 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. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Not applicable.

  1. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

Not applicable. This form is an application for possible employment.

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

Assurances of confidentiality are provided by the inclusion of Privacy Act of 1974 Compliance information on the form and the declaration that the information contained on the form may be disclosed in accordance with routine disclosures set forth in the Office of Personnel Management, Government-wide system of records, OPM/Gov-1, General Personnel Records, 76 Federal Register 32997 (June 7, 2011).

  1. Provide additional justification for any questions 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.

This employment application only asks questions pertinent to ascertaining an applicant’s suitability to work in a law enforcement environment; specifically, applicants are asked to provide their education, training, employment, and any criminal history in the past 10 years.

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

    • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 desirable. 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.

    • 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.

    • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost 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.

It is estimated the USMS will get 1,000 applications nationwide annually. Public reporting burden for this collection of information is estimated to average 60 minutes per response. The annual hour burden was determined by through actual experience using similar employment application forms. Based on a national Correction/Detention Officer Wage Determination Rate of $23, it is estimated the cost burden to each applicant will be $23.00.

  1. Provide an estimate for the total annual cost burden to respondents or record-keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12.

Not applicable. There are no “resultant” costs to collecting these employment applications.

  1. The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the 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. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

    • If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

    • Generally, estimates should not include purchases of equipment or services, or portions thereof, made:

      • prior to October 1, 1995,

      • to achieve regulatory compliance with requirements not associated with the information collection,

      • for reasons other than to provide information or keep records for the government, or

      • as part of customary and usual business or private practices.

Not applicable. This form is an employment application.

  1. Provide estimates of annualized costs 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 not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

It is estimated it will take the Federal Government 15 minutes to review each application. At an average hourly rate of $41.50/hr., the estimated cost to process each application is $10.38/application. The method used to estimate cost comes from actual experience processing these applications.

  1. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

Not applicable – New Collection.

  1. 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.

Not applicable. The information on these applications will not be published.

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

Not applicable.

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

No exceptions.

B. Collections of Information Employing

Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked, "Yes," the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:

Item 17 will be checked “No.”

  1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

  2. Describe the procedures for the collection of information including:

    • Statistical methodology for stratification and sample selection,

    • Estimation procedure,

    • Degree of accuracy needed for the purpose described in the justification,

    • Unusual problems requiring specialized sampling procedures, and

    • Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

  1. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

  2. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of test may be submitted for approval separately or in combination with the main collection of information.

  3. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
AuthorLynn Bryant
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File Created2021-05-20

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