Supporting Statement Part A_4.23.2021 - Vaccination Attestation Form v9_20210824

Supporting Statement Part A_4.23.2021 - Vaccination Attestation Form v9_20210824.docx

COVID-19 Vaccination Attestation Form

OMB: 0704-0613

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SUPPORTING STATEMENT - PART A

Certification of Vaccination – OMB Control Number



1. Need for the Information Collection (1-3 paragraphs)

Consistent with guidance from the Centers for Disease Control and Prevention (CDC), and guidance from the Safer Federal Workforce Task Force established pursuant to Executive Order 13991, “Protecting the Federal Workforce and Requiring Mask-Wearing” (January 20, 2021), the Department of Defense (DoD) is establishing specific safety protocols concerning individuals fully vaccinated and not fully vaccinated against coronavirus disease 2019 (COVID-19). Individuals who attest that they are not fully vaccinated against COVID-19 or who choose not to provide this information will be required to comply with applicable CDC and DoD guidance for individuals not fully vaccinated against COVID-19, including wearing masks regardless of the transmission rate in a given area, physical distancing, regular screening testing, and adhering to applicable travel requirements.


2. Use of the Information (2-4 paragraphs)

This information is being requested in order to promote the safety of individuals in Federal buildings and on DoD installations, consistent with the COVID-19 Workplace Safety: Agency Model Safety Principles established by the Safer Federal Workforce Task Force and guidance from the CDC and the Occupational Safety and Health Administration. This information will be used by DoD staff charged with implementing and enforcing workplace safety protocols and is required for ensuring compliance with the requirement for attestation by all civilian employees, on-site contractors, and official visitors. Vaccination status for Military Service members will be obtained by alternate means using DoD’s Individual Medical Readiness system.


3. Use of Information Technology (1-4 sentences)

Currently, DoD is planning to collect the information electronically using the MilConnect platform that will require the individual responder to fill out DD Form 3150, the DoD form that will serve as the collection instrument for the vaccination attestations. However, for certain populations for whom computer access is restricted or minimally accessible, a paper copy of DD Form 3150 will be provided and collected by the supervisor of civilian employees or by the contracting officer’s representative for contractor employees performing on-site at Federal or DoD installations and facilities. Official visitors seeking access to DoD installations and facilities will be provided a DD Form 3150 via email or at the entrance to a DoD installation or facility. Civilian employees and contractor employees performing on-site at Federal or DoD installations and facilities will return a signed copy to their designated supervisor or contracting officer representative. Official visitors will present the form, when requested, to gain access to a DoD installation or facility and maintain a copy of the form on their person while present at a Federal or DoD installation or facility. The information on DD Form 3150 itself will be provided directly by the individuals who are attesting to their vaccination status.


4. Non-duplication (1-2 sentences)

The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.


5. Burden on Small Businesses (1-2 sentences)

This information collection is assessed to not impose a significant economic impact on a substantial number of small businesses or entities.


6. Less Frequent Collection (1-3 sentences)

The frequency of the data collection depends upon any changes in vaccination status or a respondent’s decision to provide this data after electing to refrain from responding. It is anticipated that the majority of respondents will only need to provide this information one time. Failure to collect such information may hinder DoD's ability to fully implement COVID-19 workplace safety plans, thereby increasing risk to the health or safety of DoD personnel, DoD-affiliated personnel, and visitors at DoD installations and facilities.


7. Paperwork Reduction Act Guidelines (1 sentence)

This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).


8. Consultation and Public Comments

Part A: PUBLIC NOTICE

Emergency approval was received to waive the public notice requirement under the Public Records Act.


Part B: CONSULTATION (2-4 sentences)

Aside from discussions with Office of Management and Budget (OMB) personnel, no additional consultation was conducted for this submission.


9. Gifts or Payment (1-3 sentences)

No payments or gifts are being offered to respondents as an incentive to participate in the collection.


10. Confidentiality

The Privacy Act Statement is provided near the top of the form provided to the respondent.


The System of Records Notices associated with this data collection is as follows:

  1. OPM/GOVT-10: Employee Medical File System of Records, 75 Fed. Reg. 35099 (Jun. 21, 2010), amended by 80 Fed. Reg. 74815 (Nov. 30, 2015).

  2. Federal employees not covered by OPM/GOVT-10, contractor personnel, and other DoD-affiliated persons: DPR 39 DoD, DoD Personnel Accountability and Assessment System.


A privacy impact assessment (PIA) has previously been prepared for the Defense Enrollment Eligibility Reporting System, which supports the MilConnect platform.


11. Sensitive Questions (1 paragraph)

The responses collected to this form are necessary to ensure the health and safety of DoD personnel and persons visiting DoD installations and facilities.


12. Respondent Burden and its Labor Costs

Part A: ESTIMATION OF RESPONDENT BURDEN


  1. Collection Instrument(s)

[Certification of Vaccination]

  1. Number of Respondents: 3,500,000

  2. Number of Responses Per Respondent: 1

  3. Number of Total Annual Responses: 3,500,000

  4. Response Time: 2 minutes

  5. Respondent Burden Hours: 116,667 hours


  1. Total Submission Burden (Summation or average based on collection)

    1. Total Number of Respondents: 3,500,000

    2. Total Number of Annual Responses: 3,500,000

    3. Total Respondent Burden Hours: 116,667 hours


Part B: LABOR COST OF RESPONDENT BURDEN


  1. Collection Instrument(s)

[Certification of Vaccination]

  1. Number of Total Annual Responses: 3,500,000

  2. Response Time: 2 minutes

  3. Respondent Hourly Wage: $27.07

  4. Labor Burden per Response: $0.90

  5. Total Labor Burden: $3,150,000


  1. Overall Labor Burden

    1. Total Number of Annual Responses: 3,500,000

    2. Total Labor Burden: $3,150,000.00


The Respondent hourly wage was determined by using the Department of Labor Wage Website ([http://www.dol.gov/dol/topic/wages/index.htm])


13. Respondent Costs Other Than Burden Hour Costs (1-4 sentences)

There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.


14. Cost to the Federal Government


Part A: LABOR COST TO THE FEDERAL GOVERNMENT


  1. Collection Instrument(s)

[Certification of Vaccination]

  1. Number of Total Annual Responses: 3,500,000

  2. Processing Time per Response: 1 hour

  3. Hourly Wage of Worker(s) Processing Responses: $27.07

  4. Cost to Process Each Response: $27.07

  5. Total Cost to Process Responses: $94,745,000


  1. Overall Labor Burden to the Federal Government

    1. Total Number of Annual Responses: 3,500,000

    2. Total Labor Burden: $94,745,000


Part B: OPERATIONAL AND MAINTENANCE COSTS


  1. Cost Categories

    1. Equipment: $0.00

    2. Printing: $280,000

    3. Postage: $0.00

    4. Software Purchases: $0.00

    5. Licensing Costs: $0.00

    6. Other: $725,000.00


  1. Total Operational and Maintenance Cost: $1,005,000


Part C: TOTAL COST TO THE FEDERAL GOVERNMENT


  1. Total Labor Cost to the Federal Government: $97,895,000


  1. Total Operational and Maintenance Costs: $1,005,000


  1. Total Cost to the Federal Government: $98,900,000


15. Reasons for Change in Burden (1-7 sentences)

This is a new collection with a new associated burden.


16. Publication of Results (1 sentence/1 paragraph)

The results of this information collection will not be published.


17. Non-Display of OMB Expiration Date (1 sentence/1 paragraph)

DoD is not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.


18. Exceptions to “Certification for Paperwork Reduction Submissions” (1 sentence)

DoD is not requesting any exemptions to the provisions stated in 5 CFR 1320.9.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
AuthorKaitlin Chiarelli
File Modified0000-00-00
File Created2021-08-25

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