ICR Supporting Statement - UPDATED 20231215

ICR Supporting Statement - UPDATED 20231215.pdf

USAID Background Investigator Quality Control Survey

OMB: 0412-0627

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S‭ UPPORTING STATEMENT – Part A‬
‭ EQUEST FOR APPROVAL UNDER THE PAPERWORK REDUCTION ACT AND 5 CFR 1320‬
R
‭OMB 0412-‬‭XXXX‬
‭Collection Title:‬ ‭USAID Background Investigator Quality‬‭Control Survey‬
‭PART A. JUSTIFICATION‬
‭1.‬ E‭ xplain 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.‬
‭Since our investigators work completely independently, there is no other way for the agency to obtain‬
‭feedback on their presentation, representation, and performance other than soliciting information‬
‭from the members of the public whom they interact with on a daily basis. Per the Office of the‬
‭Director of National Intelligence (ODNI) & the Defense Counterintelligence & Security Agency‬
‭(DCSA), agencies with delegated investigative authority (such as USAID) must have a quality‬
‭control process to ensure that the information reported in background investigations is accurate as‬
‭reported. Further, USAID must be able to prove & report about this process every two years when‬
‭audited by ODNI & DCSA. Refer to attached 10-page MOU from OPM, specifically pg. 4 Section E.‬
‭2.‬ I‭ ndicate 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.‬
‭This information will be collected electronically via the USAID-housed Google Forms platform. The‬
‭USAID Office of Security - Field Investigations Branch Chief and Investigations Program Managers will‬
‭have access to this information (4 people in total). The information collected will be used to assess the‬
‭accuracy of USAID background investigation reports, performance/conduct/presentation of its‬
‭investigators, and will also be used for training purposes.‬
‭3.‬ D
‭ escribe 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.‬
‭This information will be collected electronically via the USAID-housed Google Forms platform. This‬
‭collection will be entirely electronic. Previously, this collection was performed via US Mail. Using the‬
‭mail system is no longer a sensical and viable option for a number of reasons. Collecting information‬
‭electronically will be of no cost to the US Government, whereas collecting information via mail was a‬
‭substantial cost both in terms of postage as well as manpower hours in printing forms, folding forms,‬
‭placing into envelopes, writing addresses, and sealing envelopes. The results of this collection will not be‬
‭made public, as it is for internal quality control purposes, only.‬
‭4.‬ D
‭ escribe 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.‬
‭There is no ability to duplicate this objective, as this survey is very specific and unique to USAID/SEC Field‬
‭Investigations.‬
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‭5.‬ I‭ f the collection of information impacts small businesses or other small entities, describe any‬
‭methods used to minimize burden.‬
‭ ot applicable.‬
N
‭6.‬ D
‭ escribe 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.‬
‭As previously stated, USAID is required by ODNI & DCSA to have a bonafide checks and balances system‬
‭in place to ensure the accuracy of investigative reports being completed by its investigators on a daily‬
‭basis. If this system did not exist, USAID would be at risk of losing its delegated investigative authority as‬
‭granted by ODNI. Collecting this information electronically will occur in real-time versus the drawn-out‬
‭process currently being conducted in which we need to wait to receive mail to collect and evaluate‬
‭results. Collecting information electronically and in real-time will allow our program to immediately‬
‭react and respond to anyone who registers a complaint or concern about our field investigators.‬
‭7.‬ ‭Explain any special circumstances for the information collection.‬
‭None.‬
‭8.‬ I‭ f 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.‬
‭60 day notice: 88 FR 62770, page 62770, published 09/13/23. No public comments have been‬
‭received.‬
‭30 day notice: 88 FR 86623, page 86623, published 12/14/23. No public comments have been‬
‭received.‬
‭9.‬ E‭ xplain any decision to provide any payment or gift to respondents, other than remuneration of‬
‭contractors or grantees.‬
‭ ot applicable.‬
N
‭10.‬‭Describe any assurance of confidentiality provided to respondents and the basis for the‬
‭assurance in statute, regulation, or agency policy. If the collection requires a Systems of Records‬
‭Notice (SORN) or Privacy Impact Assessment (PIA), those should be cited and described here.‬
‭All information collected will be stored on the USAID information technology network and will not be‬
‭disseminated nor available outside of this avenue.‬
‭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.‬
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‭Not applicable.‬
‭12.‬‭Provide estimates of the hour burden of the collection of information.‬

‭Category of Respondent‬

‭# Of‬
#‭ Of‬
‭ esponses Per‬
R
‭Respondents‬
‭Year‬

‭ articipation‬
P
‭Time‬

‭ urden‬
B
‭Hours‬

‭Public‬

‭500‬

‭5 minutes‬

‭ 0-50‬
4
‭hours/year‬

‭1‬

‭Totals‬

‭13.‬‭Provide an estimate for 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 already reflected‬
‭on the burden worksheet).‬
‭There will be zero cost burden on all levels.‬
‭14.‬‭Provide estimates of annualized costs 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. If there will be no‬
‭costs beyond the normal labor costs for staff, state that here.‬
‭There will be no cost to the USG. It is simply factored into standard labor.‬
‭ 5.‬‭Explain the reasons for any program changes or adjustments reported on the burden worksheet.‬
1
‭Not applicable.‬
‭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.‬
‭ one of this information will be published, as it is for internal use only.‬
N
‭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.‬
‭ ot applicable.‬
N
‭18.‬‭Explain each exception to the topics of the certification statement identified in “Certification for‬
‭Paperwork Reduction Act Submissions.” (See Pg. 2 of the OMB 83-I form)‬
‭ ot applicable.‬
N
S‭ UPPORTING STATEMENT – B‬
‭ EQUEST FOR APPROVAL UNDER THE PAPERWORK REDUCTION ACT AND 5 CFR 1320‬
R
‭OMB 0412-‬‭XXXX‬
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‭PART B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS OR SURVEYS‬
‭1.‬ D
‭ escribe (including a numerical estimate) the potential respondent universe and any sampling‬
‭or other respondent selection methods to be used. Data on the number of entities (e.g.,‬
‭establishments, State and local government units, households, or persons) in the universe‬
‭covered by the collection and in the corresponding sample are to be provided in tabular form‬
‭for the universe as a whole and for each of the strata in the proposed sample. Indicate‬
‭expected response rates for the collection as a whole. If the collection had been conducted‬
‭previously, include the actual response rate achieved during the last collection.‬
‭ /A‬
N
‭ .‬ ‭Describe the procedures for the collection of information.‬
2
‭ /A‬
N
‭3.‬ D
‭ escribe methods to maximize response rates and to deal with issues of nonresponse. The‬
‭accuracy and reliability of information collected must be shown to be adequate for intended‬
‭uses. For collections based on sampling, a special justification must be provided for any‬
‭collection that will not yield "reliable" data that can be generalized to the universe studied.‬
‭ /A‬
N
‭4.‬ D
‭ escribe any tests of procedures or methods to be undertaken. Testing is encouraged as an‬
‭effective means of refining collections of information to minimize burden and improve utility.‬
‭Tests must be approved if they call for answers to identical questions from 10 or more‬
‭respondents. A proposed test or set of tests may be submitted for approval separately or in‬
‭combination with the main collection of information.‬
‭ /A‬
N
‭5.‬ P
‭ rovide the name and telephone number of individuals consulted on statistical aspects of the‬
‭design and the name of the agency unit, contractors, grantees, or other person(s) who will‬
‭actually collect or analyze the information for the agency.‬
‭ /A‬
N

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