SUPPORTING STATEMENT PART A
TITLE OF INFORMATION COLLECTION: NASA Contractor and Subcontractor Compensation Plans
TYPE OF INFORMATION COLLECTION: Reinstatement of Expired Information Collection
A. JUSTIFICATION
Explain the circumstances that make the collection of information necessary.
The collection of a contractor and subcontractor compensation plan is required to comply with Federal Acquisition Regulation (FAR) provision 52.222-46, Evaluation of Compensation for Professional Employees, as well as NASA FAR Supplement (NFS) provision 1852.231-71 Determination of Compensation Reasonableness.
In accordance with FAR provision 52.222-46(a): Recompetition of service contracts may in some cases result in lowering the compensation (salaries and fringe benefits) paid or furnished professional employees. This lowering can be detrimental in obtaining the quality of professional services needed for adequate contract performance. It is therefore in the Government’s best interest that professional employees, as defined in 29 CFR 541, be properly and fairly compensated. As part of their proposals, offerors will submit a total compensation plan setting forth salaries and fringe benefits proposed for the professional employees who will work under the contract. The Government will evaluate the plan to assure that it reflects a sound management approach and understanding of the contract requirements. This evaluation will include an assessment of the offeror’s ability to provide uninterrupted high-quality work. The professional compensation proposed will be considered in terms of its impact upon recruiting and retention, its realism, and its consistency with a total plan for compensation. Supporting information will include data, such as recognized national and regional compensation surveys and studies of professional, public and private organizations, used in establishing the total compensation structure.
When NFS provision 1852.231-71 is included in a solicitation the proposal shall include a total compensation plan. This plan shall address all proposed labor categories, including those personnel subject to union agreements, the Service Contract Act, and those exempt from both above. The total compensation plan shall include the salaries/wages, fringe benefits and leave programs proposed for each of these categories of labor. The plan also shall include a discussion of the consistency of the plan among the categories of labor being proposed. Differences between benefits offered to professional and non-professional employees shall be highlighted. The requirements of this plan may be combined with that required by the provision at FAR 52.222-46, "Evaluation of Compensation for Professional Employees."
Indicate how, by whom, and for what purpose the information is to be used.
The information collected is used to properly evaluate contractor proposals to ensure service contracts that meet the requirements for including FAR provision 52.222-46 also include proper and fair compensation of professional employees as defined in 29 CFR 541.
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.
The majority of the data is submitted via electronic means as part of a contractor proposal, although paper proposals may be accepted in some cases. The electronic format is usually in the form of Microsoft office products such as word and/or excel consistent with how other contractor proposals are normally submitted in response to Solicitations or Request for Proposals (RFPs).
Describe efforts to identify duplication.
There is no duplication of effort as the data submitted is compensation data specifically in support of their proposal in response to our RFP. Each RFP and proposal are for unique requirements and therefore the corresponding compensation data would be specific to the types of professional employees required to fulfill that specific RFP and its associated requirements.
If the collection of information impacts small businesses or other small entities (Item 5 of the OMB Form 83-I), describe the methods used to minimize burden.
Collection of this information does not have a significant impact on small businesses.
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 this information were not collected, NASA would be unable to comply with FAR provision 52.222-46 and NFS provision 1852.231-71 and ultimately be unable to award contracts that contain service requirements with a meaningful number of professional employees.
Explain any special circumstances that would cause an information collection to be conducted in an exceptional manner:
All answers are “No”. There are no special circumstances.
Provide the date and page number of publication in the Federal Register for the 60-day and 30-day FNRS, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.
60-day FRN: Federal Register Volume 88 FR 21725 on 4/11/2023. No comments were received.
30-day FRN: Federal Register Volume 88 FR 45247 on 7/14/2023.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Information collected for this in addition to contractor proposals are protected from any unauthorized disclosure in accordance with FAR 3.104-4 Disclosure, protection, and marking of contractor bid or proposal information and source selection information.
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.
Questions of a sensitive nature are not included in this information collection.
Provide estimates of the hour burden of the collection of information.
Provide estimates of the hour burden of the collection of information.
RESPONDENT CATEGORY |
NUMBER OF RESPONDENTS |
ESTIMATED COMPLETION TIME |
ANNUAL BURDEN |
Contractor Proposal Managers |
371 |
2 hours |
742 hours |
|
|
|
|
TOTAL |
371 |
2 hours per |
742 hours total |
Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
|
Burden hours |
Hourly Rate |
Total |
Contracting Officers |
742 |
$ 75.00 |
$ 55,650.00 |
Contract Specialists |
742 |
$ 45.00 |
$ 33,390.00 |
Total |
1,484 |
|
$ 89,040.00 |
Cost to the Federal Government: Provide estimates of annualized costs to the Federal government.
Not applicable. Contractor proposals and associated data submissions for competitive RFPs are not direct chargeable to the Federal Government, however, they may be allocated as part of a contractor’s indirect cost pool.
Changes in Burden: Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I, if applicable.
Not applicable. The information collection is requesting OMB approval.
Publication of Results: For collections of information whose results will be published, outline plans for tabulation and publication.
Not applicable. The information collection is and will not be published and maintained internally as part of evaluation of contractor proposals in response to RFPs.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
NASA will display the expiration date on the electronic version of the forms within the required PRA Statement with the exception of the paper forms. NASA is seeking approval to not display the expiration date on the paper forms associated with this information collection. An exemption from printing the expiration date on the paper forms is requested based on the high cost of reprinting.
Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
Not applicable
The NASA office conducting or sponsoring this information collection certifies compliance with all provisions listed above.
Name: Edgar Lee
Title: Procurement Analyst, Procurement Management and Policy Division
Email address or Phone number: [email protected]
Date: July 7, 2023
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | TEMPLATE/GUIDELINES FOR PREPARING THE SUPPORTING STATEMENT |
| Author | IMB, ERO |
| File Modified | 0000-00-00 |
| File Created | 2023-07-31 |