Supporting Statement - Information Collection Requirements per (48 CFR) Chapter 7, AIDAR 701.106

SUPPORTING STATEMENT FOR REQUEST FOR APPROVAL UNDER
THE PAPERWORK REDUCTION ACT AND 5 CFR 1320
SECTION A. JUSTIFICATION
1. Section 635(b) of the Foreign Assistance Act (FAA) authorizes USAID to contract with any
corporation, international organization, or other body or persons in or outside of the United
States in furtherance of the purposes and within the limitations of the FAA. Attachment 1 to this
Justification contains the information collection requirements placed on the public by the USAID
Acquisition Regulation (AIDAR), published as 48 CFR Chapter 7. These nine information
collections are all USAID unique procurement requirements. The only information collection
requirement for the pre-award stage (the Employee Biographical Data Sheet) is needed to ensure
Agency contracting personnel can exercise prudent management in determining that an offeror
either has or can obtain the ability to competently manage development assistance programs
utilizing public funds. Information collection requirements during the post-award period are
needed to administer public funds prudently. See Attachment 1 for brief statements of specific
circumstances applicable to individual collections. Copies of the applicable sections of the
AIDAR establishing the information collections are attached as Attachment 2.
2. The collections shown in Attachment 1 are required to award and administer USAID
contracts. All but one of the information collections shown on Attachment 1 are for post contract
award purposes and are needed to properly administer the contract. The various types of
information required by the AIDAR are reviewed by either the contracting officer, the
contracting officer’s representative, or the financial management officer to monitor financial,
technical, and cost data. Without the information, USAID cannot prudently manage public
funds. The other remaining information collection is the Employee Biographical Data Sheet,
AID Form 1420-17. Offerors (at the pre-award stage) and contractors (during contract
administration) complete this form for employees and consultants who will work on the contract
and whose salaries are reimbursable under the contract. The contracting officer uses the
information provided to determine if the individual meets the contract requirements and if the
salary is reasonable for the work to be performed.
3. USAID encourages the use of email, internet or other electronic technology. All of the
AIDAR information collections can be submitted and reviewed electronically through email.
We are continually reviewing the AIDAR to simplify the submission requirements wherever
possible.
4. We have reviewed these AIDAR requirements to ensure that they are not duplicated by other
agency-specific or Government-wide policies. Of the information collection requirement/forms
listed herein, no similar information is already available in USAID, or from any other source
known to us, which can be used or modified for our purposes.
5. As we have reported in the past and further explained in item #12 below, while the hourly
burden for the information collections under this submission falls on the public, the cost for most
of these collections are reimbursable as either direct or indirect contract expenses. Thus, the
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public burden, including that for small businesses, is limited to costs related to submission of
Biodata forms in accordance with AIDAR section 752.7001 (Item #5 in Attachment 1). Given
that these costs can be reimbursed when included in the offeror’s indirect costs and only affect
offerors that do not have existing federal contracts, as we have done in the past, we are
estimating that 25 percent of the submissions under the Item #5 constitute a cost to the public.
Based on the active awards data for FY’2020, USAID has 134 cost-reimbursement contracts
with small businesses. Given our estimate of approximately 8 submissions per award and the
hourly rate of $92.26, we anticipate that the total burden on the small businesses will be $49,451.
And 25% of that is $12,363, so we conclude that the collection of the information will not have a
significant impact on a substantial number of small businesses or other small entities.
6. USAID cannot reduce the frequency of these information collection requirements without
losing its ability to properly award and administer contracts using public funds.
7. One of the information collections included in this report allows for submission more
frequently than the OMB guideline for reporting no more frequently than quarterly. AIDAR
752.7003 Documentation for Payment (Item #7 in Attachment 1) supplements the FAR payment
clauses, FAR 52.216-7 Allowable Cost and Payment (for cost reimbursement contracts) and
FAR 52.232-7 Payments Under Time-and-Materials and Labor Hour contracts. These clauses
allow contractors to invoice for payment as frequently as once every two weeks, and more
frequently for small businesses. The AIDAR clause requires this submission as part of the FAR
invoice process. Collecting this information more frequently than quarterly allows contractors to
be paid as work progresses and assists with cash flow.
8. We published a both a 60-day notice for this collection in the Federal Register on 03/05/2021
(86 FR 12901) and received one comments. We also published a 30-day notice on 07/15/2021
(86 FR 31693). In addition to the notices, we routinely communicate with our contractors
through semi-annual “Partners Days” sponsored by the USAID Acquisition Ombudsman.
USAID contractors fully participate in these sessions but have not questioned the need for any of
these information collections.
9. Not applicable since any payments are in the form of remuneration to contractors.
10. USAID shares or protects information as required by law.
11. Information of a sensitive nature is not requested in these collections.
12. We estimated the hour burden for the information collections as shown below. The
estimates are supported by Attachment 1, Information Collection Summary and Justification as
follows:
Block 13, Form 83-I

Attachment 1

a. Number of respondents (and
frequency of responses)

varies by item, see narrative a. below

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b. Total annual responses

varies by item, see narrative b. below;
includes percentage of these responses
collected electronically

c. Total annual hours requested

see c. below

a.
The "Number of respondents" and the frequency of responses vary by item, as
summarized in Attachment 1 and explained herein. We based our estimates on the number of
active contracts/task orders of record during fiscal year (FY) 2020, the most recent year for
which we have complete data. The data came from the Agency’s world-wide web-based
acquisition system, Global Acquisition and Assistance System (GLAAS). In FY 2020 USAID
had 1028 active contracts and orders, excluding those under the simplified acquisition threshold
and fixed price ocean transportation, comprised of the following:

Out of 624 cost reimbursable contracts, 554 of those were performed outside of the U.S.
Even though the same contractor may have multiple contracts and/or task orders, we estimate
that contractors and prospective contractors will have a different respondent or respondents per
contract or order for each type of submission.
For each collection, we used either the frequencies required by the submission prescription itself
to estimate the number of submissions expected per year or, for those submissions triggered by
events, we used our experience with how often these events occur per contract to estimate the
average.
The following submissions, identified by item number and AIDAR section in Attachment 1, are
triggered by an event:
#1
#3
#4

752.219-8
752.245-71(c)(2)
752.247-70(c)

#6, 752.7002(j)
#8, 752.7004
#9, 752.7032
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#5

752.7001

In Attachment 1, we indicate after each item the estimated number of respondents for that item,
and for Items #4, #5, #7, #8 and #9, we also specify the frequency of responses by each
respondent. For Items #1, #2, #3 and #6, we estimate that each respondent submits one time per
year.
For Item #1, AIDAR 752.219-8 we used the same number of submissions per year as in the
previous request (100 submissions) based on our past experience.
For Items #2, AIDAR 752.245-70 and Item 3, 752.245-71(c), as in the previous request, we
estimate that approximately 60% of all contracts, excluding those for ocean transportation
services and commercial items below the simplified acquisition threshold, would require the
annual report under item# 2 and 10% of those contracts would require an annual report under
item# 3.
Frequency of reporting under Item #4, AIDAR 752.247-70(c) and Item 6, AIDAR 752.7002(j) is
based on our past experience and remains unchanged.
For Item #5, AIDAR 752.7001, as with the previous request, we estimate eight submissions per
year for each cost-reimbursement contract/order.
For Item #7, AIDAR 752.7003 we continue to estimate that contractors for each contract and
task order will invoice biweekly, and this clause will apply each time. As with the previous
submission, we use the total number of all awards, exclusive of all fixed price contracts and task
orders to estimate the number of respondents.
For both Items #8, AIDAR 752.7004 and Item #9, AIDAR 752.7032, we revised the number of
submissions per year to reflect the contract statistics in Item 12 above. Both clauses apply in all
task orders, and in all contracts excluding the ocean transportation contracts and purchase orders.
For Item#8, we continue to estimate that there are eight respondents per contract or task order
per year, and for Item#9, we continue to estimate that there are three responses per contract or
task order per year.
The total number of respondents is the sum of the number of respondents for each item, 4,877.
b.
The "Total annual responses" is 33,249, the sum of line D amounts (Number of
submissions per year from Attachment 1). The percentage of collections submitted
electronically was 100%, as email has become the principle method of communication between
the Agency and contractors.
c.
The "Total annual hours requested" (line 13.c of Form 83-I) is the total of the response
times from the public for each collection. In Attachment 1, this equates to the Total Hour
Burden, line E under the public burden column, 43,943 hours. We used the same hours per
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submission that we reported in our last request, since the collections are the same and the effort
and methods the public uses in preparing the submissions are basically unchanged.
The annualized cost for the Annual Public Burden is also provided in Attachment 1 for each
information collection. This cost is $ 4,054,200 and is the sum of all line G amounts in the far
right hand column. However, as we’ve reported in the past, the hourly burden for these
information collections falls on the public, but the cost for most of these collections falls under
the federal cost burden, since they are either direct or indirect expenses reimbursable under
federal contracts. The only exception is the burden of submissions for AIDAR section 752.7001
“Biographical Data” (Item #5 in Attachment 1) that are collected in a proposal submission at the
pre-award stage. Costs related to this submission may be included in the offeror’s indirect costs,
but if the offeror does not have existing federal contracts or if the proposal submission does not
result in a contract award, then the cost is the responsibility of the offeror (submitter). We would
need to conduct a large survey in order to accurately determine how many Biographical Data
forms are submitted per year in unsuccessful proposals (i.e., proposals that do not result in a
contract award) or from offerors with no existing federal contracts. As we have done in the past,
we are estimating that 25 percent of the submissions are actually a cost to the public.
Therefore, the annual public cost burden for this collection is 25 percent of total cost burden
for the Biographical Data sheet ($230,281) or $57,570. The remaining total cost burden,
$3,996,629 is included in the annualized cost to the federal government (ref. Item 14, below).
To estimate the annualized cost to respondents, we calculated the hourly rate based on
estimated income per hour from the Bureau of Labor Statistics for a Business and Financial
Operations Occupation in the DC area as of May 2019 ($46.13), and then applied the estimated
amount for overhead and fringe benefits @100% of the salary. The calculation is therefore
$46.13/hr x 2 (fringe and overhead) = $92.26/hr.
13. There are no capital and start-up costs, or operation, maintenance, or purchase of services
components associated with the information collection. The total annual cost burden to
respondents is addressed in either Item 12 or Item 14.
14. The estimate of the annualized cost to the federal government is the sum of the cost of
federal employee effort for each collection (“Annual Federal Burden” in the column so labeled in
Attachment 1) and the part of the cost of the Annual Public Burden (in the far right-hand column
in Attachment 1) that is reimbursed by the government through contracts. As already stated in
Item 12 above, the only element of cost in the public burden that is a cost to the public is the
amount reported at the end of Item 12 above. Therefore, the annualized cost to the federal
government is the sum of all line G (Total cost burden) under the Annual Federal Burden (or $
2,843,482) plus the sum of all line G (Total cost burden) for the Annual Public Burden (or $
4,054,200) less the amount reported in Item 12 above as a cost to the public (or $ 57,570). The
total annualized cost to the federal government is therefore $ 6,840,111.
We estimated these costs as follows. For the federal cost burden, all federal salary costs in
Attachment 1 are estimated using the base rate from the Office of Personnel Management Salary
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Table 2021 for the locality pay area of Washington-Baltimore, DC-MD-VA-WV. We used the
salary of the federal employee who typically reviews the submission applied to the estimated
amount of time the federal employee spends on each collection (line C under the Annual Federal
Burden column in Attachment 1). For all Items except #1 and #4 that individual is typically a
GS 13, Step 5, whose hourly rate for 2020, including the Washington, D.C. locality pay, is
$56.50. We applied a burden rate of 110% for fringe benefits and operational expenses as we
have done in the past, to arrive at a burdened hourly rate for the federal burden of $118.65. As
explained earlier, we used the same number of hours for each submission as in the past, for both
the federal and the public hour burden, since the submission requirements are basically the same.
We applied the burdened hourly rate (line F) to the total burden hours (line E) to determine the
total Annual Federal Burden (line G) for each item.
For Item #1, AIDAR 752.219-8, the federal burden is shared between the two federal employees
who review this submission. One is a GS 13 Step 8 for one third of the effort, and the other is a
GS 7 Step 5, for two thirds of the effort. We developed a composite hourly rate based on these
proportions and applied the same burden rate of 110% for operational expenses, for an hourly
burdened rate of $80.29.
The total hourly burden for Item #4, AIDAR 752.247-70(c) is estimated based on the hourly
rates of two federal employees normally processing this form (GS 11, step 5 at 90% of the time
allotted and a GS-15, step 5 at 10% of the time allotted for each submission, a prorated hourly
rate of $43.53) plus 110% burden. The hourly rate is therefore estimated at $91.41.
15. There are no program changes or adjustments reported under item#13. The difference in
hours is due to variation in the amount of contracts the agency has at any given time.
16.

Not applicable.

17.

Not applicable.

18.
Since the information must be collected for a specific individual transaction, statistical
survey methodology is not appropriate (certification statement (i) in Item 19 of the OMB 83-I).
SECTION B. Collections of Information Employing Statistical Methods.
The collection does not employ statistical methods.

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