Supporting Statement A_3206-0036

SUPPORTING STATEMENT FOR CLEARANCE OF DATA COLLECTION
FORMS
FOR THE FEDERAL WAGE SYSTEM WAGE SURVEYS
OMB #3206-0036
Justification:
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection.
The information collected on these forms is used to establish pay rates for Federal
Wage System (FWS) employees. Under section 5341 of title 5, United States Code,
the pay of Federal trade, craft, and laboring employees is to be maintained in line
with prevailing private sector levels for comparable work within a local wage area.
The pay system for these employees is known as the FWS. The pay of FWS
employees is fixed and adjusted on an annual basis. The Office of Personnel
Management (OPM) has designated the Department of Defense (DOD) as the lead
agency which sponsors and conducts annual wage surveys in numerous geographic
areas to determine local prevailing rates and set pay for FWS employees.
2. 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.
FWS wage surveys are conducted by DOD under regulatory guidelines established by
OPM in part 532 of title 5, Code of Federal Regulations. The forms developed by
OPM for FWS wage surveys are the Establishment Information Form, the Wage Data
Collection Form, and the Wage Data Collection Continuation Form. The information
collected on these forms enables DOD to establish the rates of pay for FWS
employees based on prevailing rates of pay in the private sector for similar levels of
work. OPM developed the data elements to be collected by DOD. DOD is
authorized to vary the layout of the forms if necessary to meet its needs. The forms
are printed by DOD. The forms are used as interview guidelines by Federal
employees who collect data necessary to determine local prevailing rates. Federal
employees complete the forms rather than private sector establishment officials.

3. 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.

A combination of in-person interviews and electronic technology to college wage
data. DOD uses electronic technology to process collected data. Absent legislation to
change the procedures associated with this collection, we do not anticipate an
immediate reduction in the reporting burden.
4. 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 Bureau of Labor Statistics (BLS) is the only Federal agency that collects data
somewhat similar to the data collected during FWS wage surveys. However, BLS
does not collect adequate data in the work environments appropriate to determine pay
rates for FWS employees. Also, active labor participation is required by law at every
level of the FWS wage survey process, and BLS has been unwilling historically to
have labor union data collectors accompany BLS data collectors on surveys.
DOD collects the information necessary to determine local prevailing rates. The
private research firm Dunn and Bradstreet provides the universe file of private sector
establishments for possible inclusion in FWS wage surveys, and DOD performs the
statistical sampling necessary to make local wage surveys manageable. To avoid
duplication, DOD verifies data against prior survey lists before preparing
establishment lists for wage surveys.
5. 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.
OPM’s survey requirements are designed to minimize the burden on small
organizations. Wage surveys are scheduled at annual intervals in each wage area.
Two kinds of wage surveys are made on an alternating cycle. A full-scale survey,
which includes the development of a current sample of establishments and collection
of wage data by in-person visits to the establishments, is made annually for about
one-half of the survey areas. A wage-change survey (in which wage data may be
collected by telephone, mail, or personal contact) is made every other year using the
same employers, occupations, and weights used in the full-scale survey.
6. 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 frequency of local wage surveys is mandated by 5 U.S.C. 5343(b).
7. Explain any special circumstances that would cause an information collection to
be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.

We are not aware of any circumstances that require this collection to be conducted in
a manner inconsistent with the guidelines in 5 CFR 1320.6.
8. 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.
The 60-day Federal Register Notice was published on February 26, 2021 (86 FR
11804). No comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Payments or gifts are not given to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
Confidentiality of the information collected is assured by section 532.233(f) of title 5,
Code of Federal Regulations,
(f)(1) Each member of a local wage survey committee, each data collector,
and any other person having access to data collected must retain this
information in confidence, and is subject to disciplinary action by the
employing agency or activity if the employee violates the confidence of data
secured from private employers.
(2) Any violation of the above provision by a Federal employee must be
reported to the employing agency and, in the case of a participant designated
by a labor organization, to the recognized labor organization and its
headquarters, and shall be cause for the lead agency immediately to remove
the offending person from participation in the wage survey function. Provide
an explanation for any pledge of confidentially that is not supported by
authority established in stature of regulation, that is not supported by
disclosure and data security policies that are consistent with the pledge.

11. 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.
The information collection does not include questions of a sensitive nature, such as
questions about sexual behavior and attitudes, religious beliefs, and other matters that
are commonly considered private.
12. Provide estimates of the hour burden of the collection of information.
Data survey about 21,760 businesses annually. Based on past experience with local
wage surveys, DOD estimates that each survey collection requires 1.5 hours of
respondent burden for collection forms, resulting in a total yearly burden of 32,640
hours. The response burden may vary depending on the size of the establishment.
Some establishments have only a limited number of the jobs surveyed, while others
have nearly all jobs surveyed. Most, if not all, of the information requested is
available in payroll and/or personnel files. Data collectors collect information using
three separate forms, the Establishment Information Form, the Wage Data Collection
Form, and the Wage Data Collection Continuation Form. Obtaining the information
necessary to complete the Establishment Information Form requires about 15
minutes. Collecting the information necessary to complete the Wage Data Collection
Form requires about 15 minutes. Collecting the information necessary to complete
the Wage Data Collection Continuation Form requires between 0 and 10 minutes,
depending on the complexity of the job matching. A Wage Data Collection Form
must be completed for each job matched at an establishment. There are 21 jobs
required for all local wage surveys. In addition, DOD may add optional jobs
depending on the distribution of Federal and private sector employees in a local wage
area. The time spent with an establishment will vary depending on how many
occupations are matched. A study by DOD indicates that each establishment
provides wage data on an average of four survey jobs.
In addition to the time spent with a data collector, a respondent may also spend up to
about 2 hours of preparation time gathering requested wage data from their personnel
and payroll files. After the initial interview, additional information may be required
to validate the matching of survey job descriptions with establishment job
descriptions or to verify wage data.

Form
Name

DD
Form
1918;
DD
Form
1919;
DD
Form
1919C

Form
No.

No. of
Respondents

No. of
Responses
per
Respondent

Average
Burden
per
Response
(in hours)

Total
Annual
Burden
(in
hours)

Ave.
Hourly
Wage
Rate

Total
Annual
Respondent
Cost

32060036

21.760

1

1.5

32,640

$31.20

$1,018,368

DD Form 1918;
DD Form 1919;
DD Form 1919C

Number of Respondents
21,760

Burden Hours
32,640

13. Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
DOD employs a full-time staff to discharge its responsibilities under the FWS. The
respondents’ cost is annualized to $1,018,368 based on an average of $31.20 per
reporting hour. This $31.20 figure is based on an average annual salary of $65,114
and includes overhead costs. The adjustment in the annualized costs reflects wage
increases for employees of survey respondents.
14. Provide estimates of annualized cost 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 expenses that would not have been
incurred without the paperwork burden.
The cost estimate of $10 million for the Federal Government is based primarily on
actual cost allocated to the various aspects of the wage survey process.
15. Explain the reasons for any program changes or adjustments reported in Items
13 or 14 of the OMB Form 83-I.

No changes were made.
16. 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.
The surveys are scheduled annually. OPM sets the month when each survey begins.
However, there is considerable overlap because of the geographic distribution and
number of surveys conducted each year. The tabulation and publication of the
information is completed by DOD. The publications consist of wage schedules
applicable to FWS employees. OPM receives copies of wage schedules and uses
them as a basis for other studies. The new rates become effective on the first day of
the first pay period that begins on or after the 45th day, excluding Saturday and
Sunday, following the date a wage survey is ordered to begin. If the tabulation is not
completed within that time period, the new pay rates are effected retroactive to that
same date.
17. 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. The date is shown.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
Not applicable. No exceptions are made.