SUPPORTING STATEMENT - PART A
Federal Background Investigation and Personnel Vetting Investigative Request Forms (INV 40-44) – OMB Control Number 0705-0003
Summary of Renewal from Previously Approved Collection
INV 40, Removal of: __If additional information is provided below, you must fill in this mark.
INV 41, 42, 43, & 44, Removal of selection field: INV 41, #6. __ FILL IN THIS MARK IF RECORD IS ATTACHED INV 42, #8. __ FILL IN THIS MARK IF RECORD IS ATTACHED INV 43, Above REMARKS. __ FILL IN THIS MARK IF RECORD IS ATTACHED INV 44, #3. __ FILL IN THIS MARK IF RECORD IS ATTACHED
INV 44: Change from: Disclosure Statement: Disclosure is voluntary. However, failure to provide DCSA Access to the requested information may result in our agency's to conduct a thorough investigation and may prevent the government from making a determination or adjudication regarding the qualifications, suitability, eligibility or fitness of the person being investigated. Change to: Disclosure Statement: Disclosure is mandatory. Title 5 U.S.C. § 9101 requires law enforcement participation. Failure to provide DCSA access to the requested information may result in our agency's inability to conduct a thorough investigation and may prevent the government from making a determination or adjudication regarding the qualifications, suitability, eligibility or fitness of the person being investigated.
INV 44, Removal of selection field: __Request covered by 5 USC 9101 __Request not covered by 5 USC 9101
INV 44, Removal of field: Position Requiring Investigation |
1. Need for the Information Collection
The information collected on the General Request for Investigative Information (INV 40), Investigative Request for Employment Data and Supervisor Information (INV 41), Investigative Request for Personal Information (INV 42), Investigative Request for Educational Record Data (INV 43), and Investigative Request for Law Enforcement Data (INV 44) forms is necessary to obtain background information and personal records for investigating and determining an individual’s initial or continued: eligibility for access to classified national security information or assignment to positions with sensitive duties, suitability for enlistment or appointment into military service, suitability for federal employment, fitness for assignment to work under contract for or on behalf of the government, or eligibility for physical or logical access to U.S. Government systems or facilities. This collection of information by the Defense Counterintelligence and Security Agency (DCSA) is authorized by Section 925 of Public Law 115-91, 5 U.S.C. 301, 5 CFR 736, and Executive Order 13467, as amended by Executive Order 13869. The INV Form 44 facilitates DCSA's collection of criminal history record information authorized by 5 U.S.C. 9101.
2. Use of the Information
The INV 40, 41, 42, 43, and 44 forms are used to collect information from a multitude of record sources to support federal background investigation and personnel vetting processes such as: investigations and determinations of eligibility for access to classified national security information, and for access to special access programs; suitability for federal employment; fitness of contractor personnel to perform work for or on behalf of the U.S. Government; and Homeland Security Presidential Directive (HSPD)-12 determinations for Personal Identity Verification (PIV) credentials to gain logical or physical access to government facilities and systems.
The content of the INV forms is also designed to meet notice requirements for personnel investigations specified by 5 C.F.R. 736.102(c). These notice requirements apply to any "investigation . . . to determine the suitability, eligibility, or qualifications of individuals for Federal employment, for work on Federal contracts, or for access to classified information or restricted areas." None of the forms are used for any purpose other than a personnel background investigation, as described above.
Procedurally, the subject of a personnel background investigation discloses the identity of relevant sources, such as supervisors, coworkers, neighbors, friends, current or former spouses, instructors, relatives, or schools attended on the Standard Form (SF) 85, Questionnaire for Non-Sensitive Positions; the SF 85P, Questionnaire for Public Trust Positions; or the SF 86, Questionnaire for National Security Positions. The INV forms are distributed to the provided source contacts identified on the standard form questionnaire through an automated mailing operation.
The INV 40 is used to collect records from a Federal or State record repository or a credit bureau. The INV 44 is used to collect law enforcement data from a criminal justice agency. The INV 41, 42, and 43 are sent to employment references, associates, and educational institutions. The INV 40, 41, 43, and 44 contain the subject’s full name, date of birth and full SSN. The INV 42 does not include the subject’s SSN or DOB. The forms disclose that the source's contact information was provided by the subject to assist in completing a background investigation regarding the subject's eligibility for employment or security clearance, and request that the source complete the form to help in this determination.
The INV forms are completed, hardcopy, by the noted source; then returned, in a self-addressed envelope, to the DCSA investigations processing center. The completed forms are maintained by DCSA subject to the provisions of the Privacy Act of 1974, as amended, and the DUSDI-02 Personnel Vetting Records System SORN.
3. Use of Information Technology
Zero percent of forms are submitted electronically. Once completed, forms are returned to DCSA, and data is extracted using an automated bar code scanning procedure. The scanning procedure is leveraged to preserve data integrity and accuracy, and to ensure the efficient transfer of the information collected into DCSA systems. The forms are subject to the Government Paperwork Elimination Act (GPEA). However, they are not posted on DCSA’s website because the forms contain individually pre-printed information. Therefore, it is not practical, due to privacy considerations, to access the forms through the DCSA public website.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
The INV 41 may be provided to small businesses that employ or that have employed the subject of the investigation. The collection is brief and voluntary to minimize burden. The estimated time for response is 5 minutes.
6. Less Frequent Collection
DCSA’s ability to conduct effective written investigative checks would be compromised absent the use of the INV forms. Furthermore, the forms allow for the written collection of data. If DCSA did not utilize these information collections, DCSA would otherwise have to conduct in-person interviews which would increase the cost of investigative products, and DCSA would potentially not be operating in compliance with OPM and ODNI Federal Investigative Standards.
None of the forms are used for any purpose other than those described above.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for the collection published on Monday, March 18, 2024. The 60-Day FRN citation is 89 FR 19305 .
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice for the collection published on Thursday, June 6, 2024. The 30-Day FRN citation is 89 FRN 48412.
Part B: CONSULTATION
No additional consultation apart from soliciting public comments through the Federal Register was conducted for this submission.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
The INV 40, INV 41, INV 42, INV 43, and INV 44 include a Privacy Act Statement at the top of each form. The statement indicates that the forms are in full compliance with 5 U.S.C. 552a (the Privacy Act of 1974) and other laws protecting the rights of the respondent. Further, the forms note that the information provided by the respondent, including the identity of the respondent, may be disclosed to the respondent upon request. Additionally, the INV 41 and INV 42 provides instructions to respondents allowing the respondents to keep his or her identity confidential, in compliance with Title 5 Code of Federal Regulations, Part 736.102(c).
The INV 40, INV 41, INV 42, INV 43, and INV 44 are covered by the DUSDI-02 – Personnel Vetting Records System SORN, which can be accessed at the following link: https://www.federalregister.gov/documents/2018/10/17/2018-22508/privacy-act-of-1974-system-of-records
This information collection is maintained in an IT system that does require a Privacy Impact Assessment (PIA). The applicable approved PIAs for the Personnel Investigations Processing System (PIPS) and the PIPS Imaging System (OPIS) are provided with this package for OMB’s review.
The applicable Records Retention and Disposition Schedules is: DAA-0446-2019-0004.
11. Sensitive Questions
A SSN Justification Memo is included in the package for this collection. It details the applicable Acceptable Use Cases in accordance with DoDI 1000.30 and is currently under review by the Office of the Assistant to the Secretary of Defense for Privacy, Civil Liberties, and Transparency.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instruments
General Request for Investigative Information (INV 40)
Number of Respondents: 14,005
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 14,005
Response Time: 5 minutes
Respondent Burden Hours: 1,167 hours
Investigative Request for Employment Data and Supervisor Information (INV 41)
Number of Respondents: 2,022,183
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 2,022,183
Response Time: 5 minutes
Respondent Burden Hours: 168,515 hours
Investigative Request for Personal Information (INV 42)
Number of Respondents: 57,285
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 57,285
Response Time: 5 minutes
Respondent Burden Hours: 4,774 hours
Investigative Request for Educational Registrar and Dean of Students Record Data (INV 43)
Number of Respondents: 247,731
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 247,731
Response Time: 5 minutes
Respondent Burden Hours: 20,644 hours
Investigative Request for Law Enforcement Data (INV 44)
Number of Respondents: 508,867
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 508,867
Response Time: 5 minutes
Respondent Burden Hours: 42,406 hours
Total Submission Burden
Total Number of Respondents: 2,850,071
Total Number of Annual Responses: 2,850,071
Total Respondent Burden Hours: 237,506 hours
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instruments
General Request for Investigative Information (INV 40)
Number of Total Annual Responses: 14,005
Response Time: 5 minutes
Respondent Hourly Wage: $17.92
Labor Burden per Response: $1.49
Total Labor Burden: $20,914
Investigative Request for Employment Data and Supervisor Information (INV 41)
Number of Total Annual Responses: 2,022,183
Response Time: 5 minutes
Respondent Hourly Wage: $17.92
Labor Burden per Response: $1.49
Total Labor Burden: $3,019,793
Investigative Request for Personal Information (INV 42)
Number of Total Annual Responses: 57,285
Response Time: 5 minutes
Respondent Hourly Wage: $17.92
Labor Burden per Response: $1.49
Total Labor Burden: $85,546
Investigative Request for Educational Registrar and Dean of Students Record Data (INV 43)
Number of Total Annual Responses: 247,731
Response Time: 5 minutes
Respondent Hourly Wage: $17.92
Labor Burden per Response: $1.49
Total Labor Burden: $369,945
Investigative Request for Law Enforcement Data (INV 44)
Number of Total Annual Responses: 508,867
Response Time: 5 minutes
Respondent Hourly Wage: $17.92
Labor Burden per Response: $1.49
Total Labor Burden: $759,908
Overall Labor Burden
Total Number of Annual Responses: 2,850,071
Total Labor Burden: $4,256,106
The Respondent hourly wage was determined by using the BLS-estimated average hourly wage Data Entry and Information Processing Workers (Occupation Code 43-9020): https://www.bls.gov/oes/current/oes_nat.htm
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instrument(s)
General Request for Investigative Information (INV 40)
Number of Total Annual Responses: 14,005
Processing Time per Response: .12 hours
Hourly Wage of Worker(s) Processing Responses: $17.92
Cost to Process Each Response: $2.15
Investigative Request for Employment Data and Supervisor Information (INV 41)
Number of Total Annual Responses: 2,022,183
Processing Time per Response: .12 hours
Hourly Wage of Worker(s) Processing Responses: $17.92
Cost to Process Each Response: $2.15
Total Cost to Process Responses: $4,348,502
Investigative Request for Personal Information (INV 42)
Number of Total Annual Responses: 57,285
Processing Time per Response: .12 hours
Hourly Wage of Worker(s) Processing Responses: $17.92
Cost to Process Each Response: $2.15
Total Cost to Process Responses: $123,186
Investigative Request for Educational Registrar and Dean of Students Record Data (INV 43)
Number of Total Annual Responses: 247,731
Processing Time per Response: .12 hours
Hourly Wage of Worker(s) Processing Responses: $17.92
Cost to Process Each Response: $2.15
Total Cost to Process Responses: $532,721
Investigative Request for Law Enforcement Data (INV 44)
Number of Total Annual Responses: 508,867
Processing Time per Response: .12 hours
Hourly Wage of Worker(s) Processing Responses: $17.92
Cost to Process Each Response: $2.15
Total Cost to Process Responses: $1,094,268
Overall Labor Burden to the Federal Government
Total Number of Annual Responses: 2,850,071
Total Labor Burden: $6,128,793
Part B: OPERATIONAL AND MAINTENANCE COSTS
Cost Categories
INV 40-44
Equipment: $0
Printing: $256,506 ($.09/voucher)
Postage: $2,821,570 ($.99/voucher)
Software Purchases: $0
Licensing Costs: $0
Other: $0
Total Operational and Maintenance Cost: $3,078,077
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Labor Cost to the Federal Government: $6,128,793
Total Operational and Maintenance Costs: $3,078,077
Total Cost to the Federal Government: $9,206,869
15. Reasons for Change in Burden
The burden has been updated to more accurately reflect the amount of background investigations being conducted.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
DCSA is not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
DCSA is not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Kaitlin Chiarelli |
| File Modified | 0000-00-00 |
| File Created | 2024-07-19 |