G-1190 & G-1515 EXT Supporting Statement

SUPPORTING STATEMENT FOR

Civics and Citizenship Toolkit/Teacher Training Registration

OMB Control No.: 1615-0120

COLLECTION INSTRUMENT(S): G-1190 and G-1515

A. 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.

Section 312 of the Immigration and Nationality Act requires immigrants aspiring for U.S. citizenship to have a “knowledge and understanding of the fundamentals of the history, and of the principles and form of government, of the United States.” Section 451 of the Homeland Security Act of 2002 (Pubic Law 107–296) requires U.S. Citizenship and Immigration Services (USCIS), to promote instruction and training on citizenship rights and responsibilities, including the development of educational materials.

To comply with these requirements, USCIS developed a citizenship toolkit and training seminars.

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.

The toolkit is provided free to organizations that serve, or that are interested in serving, immigrants. The toolkit includes immigration and civics publications, handbooks, multimedia tools, and guidance on how to use these products to help legal permanent residents integrate into their local communities and American society.

Adult educators and volunteers who work with immigrants may use the publications and videos in the toolkit to teach American history, civics, and citizenship in a classroom setting. Immigrants may also use the toolkit as a self-study resource to learn more about the United States and prepare for the naturalization process.

In addition, USCIS provides free training seminars and conferences for:

• Adult English as a Second Language (ESL),

• Civics and citizenship teachers, volunteers, and immigrant-serving organizations to enhance their skills in teaching U.S. history, civics, and the naturalization process to immigrant students.

These training opportunities will include sessions on the new naturalization test, the naturalization process, instructional methods and activities for teachers, and an overview of the Office of Citizenship’s resources and materials.

Individuals and organizations wishing to obtain a toolkit or training must complete and submit a registration form to USCIS.

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.

The registration form for the toolkit is hosted by USCIS and can be completed and submitted electronically from https://www.uscis.gov/citizenship/organizations/civics-and-citizenship-toolkit/registration.

To register for training an applicant can complete the form on the USCIS Website at https://www.uscis.gov/sites/default/files/USCIS/Teacher_Training/G-1190.pdf .

The email address it is sent to is [email protected] or they can click the Submit button at the bottom of the form and it automatically adds it to an outlook message to be sent via email.

http://www.uscis.gov/sites/default/files/USCIS/Teacher_Training/G-1190, print the completed form, and fax/email to USCIS.

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.

A review of USCIS Forms Inventory Report revealed no duplication of effort, and there is no other similar information currently available which can be used for this purpose.

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.

This collection of information does not have an impact on small businesses or other small entities.

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.

If the information is not collected USCIS will not be able to enroll an applicant or organization for training or distribute the toolkit.

7. 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;

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

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

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

• 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;

• requiring the use of a 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; or

• 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 is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. If applicable, provide a copy and identify the data 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.

On July 13, 2022, USCIS published a 60-day notice in the Federal Register at 87 FR 41735. USCIS received one comment after publishing that notice. The comment was not germane to the information collection. USCIS did not make any changes to the information collection as a result of this comment.

On October 24, 2022, USCIS published a 30-day notice in the Federal Register at 87 FR 64245. USCIS received one comment after publishing that notice. The comment was not germane to the information collection. USCIS did not make any changes to the information collection as a result of this comment.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

USCIS does not provide payments or gifts to respondents in exchange for a benefit sought by the respondents.

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

There is no assurance of confidentiality.

This collection is covered under the following Privacy Impact Assessment:

• DHS/ALL/PIA-006 DHS General Contact Lists

The collection is covered under the following System of Records Notices:

• DHS/All-003 Department of Homeland Security General Training Records November 25, 2008, 73 FR 71656

• DHS/ALL-002 Department of Homeland Security (DHS) Mailing and Other Lists System November 25, 2008, 73 FR 71659

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 person’s from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. 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 14.

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Total Number of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
Individuals or Households	Application for free Training for Civic and Citizenship Teachers of Adults / G-1190	2,500	1	2,500	0.083	208	$37.55	$7,810
Individuals or Households	Civics and Citizenship Toolkit / G-1515	1,200	1	1,200	0.166	199	$37.55	$7,472
Total				3,700		407		$15,282

* The above Average Hourly Wage Rate is the May 2019 Bureau of Labor Statistics average wage for All Occupations [or Insert Other Category from BLS Table] of $25.72 [or Insert Other Mean Wage Rate from BLS Table] times the wage rate benefit multiplier of 1.46 (to account for benefits provided) equaling $37.55 [or Enter Other Product Here]. [When “All Occupations” is selected, include the following language: The selection of “All Occupations” was chosen because respondents to this collection could be expected from any occupation.]

13. Provide an estimate of 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 and 14).

• 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 collection 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: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government or (4) as part of customary and usual business or private practices.

There are no capital or start-up costs associated with this information collection.

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 expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annualized Cost Analysis:

a. Collecting and Processing $ 16,268

b. Total Cost to Program $ 16,268

c. Fee Charge, if any $ 0

d. Total Annual Cost to Government $ 16,268

Government Cost

The estimated cost of the program to the Government is $16,268. This figure is calculated by multiplying:

• The number of respondents applying for the toolkit (1,200) x (1) number of responses x .166 (10 minutes) x $40 (Suggested average hourly rate for clerical, officer, and supervisory time with benefits) = 7,968; plus

• The number of respondents applying for training (2,500) x (1) number of responses x .083 (5 minutes) x $40 (Suggested average hourly rate for clerical, officer, and supervisory time with benefits) = 8,300.

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

There are no changes to the time burden reported for this collection. There are no changes to the form/instructions.

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.

This information collection will not be published for statistical purposes.

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.

USCIS will display the OMB expiration date for this information collection.

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

USCIS does not request an exception to the certification of this information collection.

B. Collection of Information Employing Statistical Methods

There is no statistical methodology involved with this collection.