0524-0041 Supporting Statement 8-10-22

0524-0041 Supporting Statement 8-10-22.docx

NIFA Proposal Review Process

OMB: 0524-0041

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National Institute of Food and Agriculture

U.S. Department of Agriculture

OMB No. 0524-0041

NIFA Proposal Review Process


SUBJECT: Supporting Statement for Paperwork Reduction Act Submission to Extend and Revise a Currently Approved Information Collection for the NIFA Proposal Review Process


A. JUSTIFICATION


1. CIRCUMSTANCES MAKING COLLECTION OF INFORMATION NECESSARY


The United States Department of Agriculture (USDA), National Institute of Food and Agriculture (NIFA) administers competitive, peer-reviewed research, education, and extension programs. The reviews are undertaken to ensure that projects supported by NIFA are of a high-quality and are consistent with the goals and requirements of the funding program. These programs are authorized pursuant to the authorities contained in the National Agricultural Research, Extension, and Teaching Policy Act of 1977, as amended (7 U.S.C. 3101 et. seq., Pub. L. 95-113), the Smith-Lever Act (7 U.S.C. 341 et. seq., As Amended Through Pub. L. 110-246), and other legislative authorities.


This information collection is authorized under 7 CFR 3403.10 specifically for the Small Business Innovation Research program (Pub. L. 99-219) and 7 CFR 3430 which governs competition in the awarding of discretionary grants and cooperative agreements for NIFA. 7 CFR 3430.33 specifies the criteria that are to be used to select reviewers including their relevant training and experience, the variety of specialization and expertise, their location and organization type, and minority representation. Reviewers are to make written comments, as appropriate, for each application. It also specifies that confidentiality of the reviewers and applicants is maintained, and conflicts of interest evaluated with care to remove any actual or perceived conflicts, and that reviewers provide this assurance through the NIFA Peer Review System (PRS). PRS is a web-based system which allows reviewers and potential reviewers to update personal information, provide assurances for confidentiality, and to complete and submit reviews electronically to NIFA. Electronic reviews are included in the application electronic record maintained at NIFA.

NIFA is also requesting that reviewer demographic information, based on approved language from the OMB AD2106, not previously updated through the PRS system, be included on the Reviewer Questionnaire. Demographics are already collected from applicants, including Project Directors and Co-Project Directors, using forms OMB 4040-001, Research & Related Personal Data and the Research & Related Senior/Key Person Profile (Expanded) of the approved R&R Family. Since many applicants may also be reviewers, NIFA is proposing to leverage information collected from these forms to populate the additional question to be presented to reviewers for update, if applicable. If this information is unavailable for a reviewer from a previous application with NIFA, then it will be a new collection from a new reviewer and from all individuals interested in serving as a panel reviewer. This criteria for the NIFA Peer-Review process is specified in 7 CFR 3430.33 and 7 CFR 3403.10, and will include gender, race, and ethnicity to ensure that reviewers represent a broad demographic range. This addition will allow NIFA to standardize and leverage the information in our reviewer database to monitor from an EEO/CR perspective how reviewers are selected, utilize compliant methods for reviewers to self-report their demographics, and to allow for the information to be included in the application’s electronic record. The additional question is added to the previously approved Reviewer Questionnaire submitted as additional questions for question 1. The percentage breakdown of Research, Education, Extension and Other, as well as the individuals Rank are added to the Reviewer Questionnaire to ensure broad representation across appointment types/positions, and the expertise needed for particular programs is addressed for each panel.


NIFA receives research, education, and extension grant applications each year, of which approximately a quarter are awarded. The majority of these applications are subjected to a rigorous peer-review involving technical experts (scientists, educators, farmers, engineers, extension specialists) located world-wide. Given the highly technical nature of many of these applications, the quality of the peer-review greatly depends on the appropriate matching of the subject matter of the application with the technical expertise of the potential reviewer. NIFA maintains a database of potential reviewers. Information in the database is used to match applications with the most appropriate (potential) reviewers. Therefore, the accuracy and completeness of the database content is integral to the success of the NIFA peer review process.


If this information is not collected, it would be difficult for a review panel and NIFA staff to determine which projects warrant funding, or identify appropriate qualified reviewers. In addition, Federal grants staff and auditors could not assess the quality or integrity of the review, and the writer of the application would not benefit from any feedback on why the application was funded or not. The additional demographics information of this update would standardize how NIFA leverages and updates the information in our database to increase the integrity of the reviewer database and the reviewer selection process. This also would help increase the integrity of our application electronic records by allowing the information to be included. Current processes record this information in manual Management Reports and paper-based records.

2. HOW, BY WHOM, AND PURPOSE FOR WHICH INFORMATION IS TO BE USED

The NIFA Application Review Process is accomplished through the use of the NIFA Peer Review System (PRS). This web-based system allows reviewers and potential reviewers to update personal information, provide assurances for confidentiality, and complete and submit reviews electronically to NIFA.


Information about potential panel and ad hoc reviewers is collected via NIFA PRS. Individuals volunteering to be considered as a panelist can complete the Volunteer Survey on the PRS home screen, and access this home screen from the NIFA Website – Panelist Information page. Furthermore, outreach efforts via avenues such as e-mail messages from NIFA staff prompt individuals to sign up as new reviewers in the NIFA PRS system. This update enables the inclusion of demographic information from the OMB approved AD-2106 form. Even if f a reviewer previously served on a panel for NIFA, the PRS will prompt for the potential reviewer to update their information. Completing this volunteer survey does not commit the respondent to review applications for NIFA.

Information in the database system (PRS) is used to match applications with the most appropriate (potential) reviewers. The purpose of this information is to obtain and maintain current potential reviewer expertise, contact information, willingness to review, and other biographical information including their demographics, conflicts, and location. This in turn ensures that the best possible reviewers are assigned to review applications submitted to NIFA. NIFA program staff can search the expertise information in this database when seeking reviewers for applications. The program staff will not only look for specific technical expertise appropriate to an application, but institutional information in assessing conflict-of-interest, geographic location, organization type, demographics information, and expressed willingness of the potential reviewer to review at that time. Once appropriate reviewers have been selected by NIFA and the reviewer agrees to perform a review, the application and associated materials are then made available to them through PRS. With respect to the application, a reviewer must assure they: (1) will comply with the NIFA Confidentiality Guidelines and (2) do not have a conflict of interest prior to viewing an application. Furthermore, NIFA EEO/CR staff will continuously monitor from an EEO/CR perspective how reviewers are selected, and ensure compliant methods for reviewers to self-report their demographics are being followed.


Upon completion of a review, the reviewer completes a Reviewer Worksheets in PRS evaluating an application against established criterion, providing comments as necessary. If appropriate, a peer panel is convened to review and discuss proposals and make funding recommendations. Once collected, this information is used by a panel of external reviewers from various institutions to determine which applications are fundable based on a series of specified criteria. The information is utilized by NIFA staff in selecting and awarding applications to provide feedback to the writer of the application, and by auditors in ensuring the integrity of the review.


3. USE OF IMPROVED INFORMATION TECHNOLOGIES


This information collection does employ the use of improved information technologies. Reviewers are able to maintain their profile information and have the option of submitting reviews through the NIFA Peer Review System (PRS). This web based submission tool accommodates the selection of reviewers, the instructions for the review, the assignment of applications to reviewers, and permits reviewers to electronically submit ratings and comments. The system is a critical tool supporting the NIFA review process. Further, NIFA staff utilize this information for the Panel Composition Approval Process, significantly decreasing the burden and errors caused by manually inputting panelist information into an Excel sheet for approval. By gathering this information directly from PRS, NIFA staff can generate reports in GMRA to assess panels and better address needs for future improvements. This technical improvement provides ease for offices across NIFA to access and use the information, while decreasing time for Program Staff to compile a panel of qualified peer reviewers.


  1. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION.

Reviewers may have to prepare reviews for more than one application, however each application is unique and the effort is not duplicated. Efforts are made to minimize the number of applications any one reviewer is asked to prepare written reviews of. In addition, NIFA has taken steps to minimize the number of duplicate accounts in our peer review system through our data governance initiative. Reviewers will only be prompted to update their information once each year as applicable.


  1. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES.

The respondents for this collection do not include any small business.


Therefore, this collection should have trivial impact on small businesses or entities.


6. CONSEQUENCES IF INFORMATION COLLECTION WERE LESS FREQUENT.

To ensure the highest quality of funded research, NIFA must collect reviews in a timely manner and on an individual application basis. If this information was not collected and documented, the decision to fund a particular application could be questioned.


In addition, because of the rate of change of science and thus scientific expertise, the need to have correct contact information, and the need to update willingness to review (which can be fluid based on events in the potential reviewer’s life and career), respondents must be asked to update their information in PRS annually.


  1. SPECIAL CIRCUMSTANCES FOR INFORMATION COLLECTION.


There are no special circumstances for this information collection. This collection is consistent with the regulation of 7 CFR 3430 authorizing its use.



Requiring respondents to report information to the agency more often than quarterly:


The agency does not require respondents to report information more often than quarterly.


 Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.


Response is voluntary and respondents have more than 30 days to reply.


 Requiring respondents to submit more than an original and two copies of any document:


Only one response is requested and is collected electronically.


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


Respondents are not required to retain records in response to this request.


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;


This information collection does not include statistical surveys. Analysis of the information provided by reviewers is to ensure compliance with requirements when selecting reviewers, and to monitor the operation of our review and award process to identify and address any inequities based on gender, race, or ethnicity.


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


This information collection does not require the use of statistical data classification that has not been reviewed and approved by OMB.


 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;


This information collection does not require 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.


Requiring respondents to submit proprietary trade secret, 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.


This information collection does not require respondents to submit proprietary trade secret, or other confidential information.


8. FEDERAL REGISTER NOTICE, SUMMARIZATION OF COMMENTS AND CONSULTATION WITH PERSONS OUTSIDE THE AGENCY.


Notice of intent to revise this information collection was published in the Federal Register on Thursday May 26, 2022, Vol. 87 No. 102 (87 FR 31973). Two comments were received on the 30-day notice which was published on August 8, 2022, Vo. 87 No. 151 pg. 48148, but they did contain input relevant to this information collection.


The names and contact information for 4 people surveyed for the burden estimates are below.


Vivien McCurdy, Director of Food Protection Division

Indiana Department of Health

[email protected]


Muhammad Haseeb, Associate Professor of Entomology

Florida A&M University

[email protected]


Boce Zhang, Assistant Professor, Food Science and Human Nutrition Department

University of Florida

[email protected]


Shyam Sablani, Professor of Food Engineering

Washington State University

[email protected]


The individuals we consulted regarding this collection provided information about the time needed to complete forms associated with this collection. NIFA has revised the burden estimate based on their input. They also stated that they they were able to understand and complete the forms, and did not provide any additional suggestions for improvement.


9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS.


Payments or gifts are not given to any respondents for completing the information collection. Participation in this collection is voluntary. However, eligible panelists are compensated with an honorarium for the time they spend in panel.


10. CONFIDENTIALITY PROVIDED TO RESPONDENTS.


Verbatim but anonymous copies of review comments are sent to the principal project director for each application. Subject to NIFA policy and applicable laws, reviewers’ comments and names will be kept confidential to the extent permitted by law. The notice requesting respondents to complete the questionnaire includes a privacy information notice.


Every reviewer assures, in the Peer Review System, prior to preparing a review that they do not have a conflict of interest with a particular application and will maintain its confidentiality.


Privacy information collected as a part of this information collection is covered by the USDA/OASCR-1 Civil Rights Enterprise System (CRES) Systems of Record Notice (SORN), 83 FR 64135, December 19, 2018.



11. QUESTIONS OF A SENSITIVE NATURE.


This collection will permit NIFA to continue to collect/update reviewer demographics information that is already collected from applicants, including Project Directors and Co-Project Directors, using forms OMB 4040-001, the Research & Related Personal Data form and the Research & Related Senior/Key Person Profile (Expanded) form of the approved R&R Family. The reviewer self-reported response in the NIFA PRS will serve as the source of the information to enable NIFA to effectively ensure minority representation of reviewers according to the criteria in 7 CFR 3430.


12. ESTIMATE OF BURDEN.

The burden estimates for the three components to the NIFA review process are as follows.


Transaction Name

Estimated # of Respondents

Estimated # of Responses per Respondent

Estimated # of annual responses

Estimated burden in hours per response

Estimated total annual burden in hours

Standard Worksheet

18,400

1

18,400

1.5

27,600

Reviewer Questionnaire

50,000

1

50,000

.75 hours or 45 minutes

37,500

Conflict of Interest and Confidentiality Certification Form

2000

1

2000

.2 hours or 12 minutes

400

Totals

52,000


70,400


65,500

TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS.


Based on an average faculty hourly wage of $47.91, NIFA estimates the total annual cost burden to respondents for the value of their time to participate in the NIFA review process to be $3,138,105.


The hourly wage was derived from the American Association of University Professors 2020-2021 Faculty Salary Report data. The average annual associate level professor salary of $95,828 was used, with an average of 2000 hours worked per year. This estimate also includes the cost of fringe benefits.

13. START-UP COSTS


There are no start-up or capital costs incurred by respondents of this collection.


14. PROVIDE ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT.

NIFA estimates the total annual cost to the agency for the collection of this information to be $95,828 which includes staff time in reviewing and managing the information, panel costs, and system maintenance. This estimate also includes the cost of fringe benefits.


15. REASONS FOR CHANGES IN BURDEN.


The burden estimate for this collection has decreased by approximately 37,900 hours (from 103,400 hours to 65,500 hours) based on more recent input from stakeholders regarding the time needed to complete the forms, as well as the consolidation of two forms into a single form.


16. TABULATION, ANALYSIS AND PUBLICATION PLANS.


The information collected is not planned for publication. It is used solely to administer NIFA programs.


17. REASONS DISPLAY OF EXPIRATION DATE OF OMB APPROVAL IS INAPPROPRIATE.

NIFA will display the OMB approval number on the Peer Review System. To prevent from having to modify system screens exemption is requested to not display the expiration date of this collection.


18. EXCEPTIONS TO 83-I CERTIFICATION STATEMENT.


A certification of exception is not requested.


B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS


Information to be collected does not employ statistical methods.

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