OMB Supporting Statement

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Supporting Statement A Paperwork Reduction Act Submission
OMB Control Number 3206-0248

OPM Form 1655 – Application for Senior Administrative Law Judge

OPM Form 1655-A – Geographic Preference Statement for Senior Administrative Law Judge Applicant

Justification: Renewal without change of an existing information collection.

Title 5 U.S.C. § 3323(b), 5 CFR 930.204(b), and 5 CFR 930.209 describe the Office of Personnel Management’s (OPM) role in managing the Senior Administrative Law Judge (ALJ) Program and define the rules and regulations that govern the program. This program allows retired ALJs to be reemployed as Senior ALJs to hear and decide agency cases in a variety of subject matters. OPM currently maintains a Senior ALJ Master List of retired ALJs who are available to serve as Senior ALJs. They are required to submit an application for reemployment and proof of licensure and to answer a series of questions regarding geographic and personal preferences.

OPM Form 1655 is an application form used to capture the necessary information required for reemployment as a Senior ALJ. The creation of this form streamlined the application process for the Senior ALJ position by allowing the retired judges to place all their requested information on these tailored forms. In addition, it allows for easier data entry, and eliminated the need for further contact with Senior ALJ applicants for additional information.

The information collected cannot be obtained from other sources. The forms are available on the OPM.gov and are downloadable in a PDF format. OPM will continue to explore automation, electronic, and other technological tools to attempt to minimize burden to both respondents and the agency.

Respondents initiate the application process to return to work as a Senior ALJ. The form was drafted to attempt to collect the minimum information needed in order to properly assess their re-employment eligibility, experience, and desired geographic location - all information either the agency does not have or that may have drastically changed over a short period of time. 

This collection of information does not affect small businesses or other small entities.

Senior ALJs hear and decide cases involving a variety of subject matters. According to 5 CFR 930.209, they must be deemed qualified to serve as a Senior ALJ as defined by OPM regulations. Insufficient collection of information could result in noncompliance with law and regulation.
    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 secrets, 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.

OPM Forms 1655 and 1655-A do not meet the criteria listed under item 7.


A 60 Day Federal Register Notice was published on September 25, 2023 (88 FR 65759) and a 30 Day Federal Register Notice was published on August 5, 2024 (89 FR 63453).  No comments were received for either posting.

No gifts or payments of any kind have been or will be provided to respondents in connection with this collection.

This information collection is protected by the Privacy Act of 1974 and OPM regulations (5 CFR 831.106, 47 FR 12937).  The routine uses for disclosure appear in the Federal Register for OPM/Central-6 (87 FR 5874, February 2, 2022).

This information collection does not include questions that are of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

Based on program activity of the past three years, we estimate 150 respondents for OPM Form 1655. Because OPM Form 1655-A only asks for geographic preferences, which will change based on the respondent’s preferences at any point in time, we estimate a slightly larger pool of responses at 200. 
The only cost to respondents is the time taken to complete an application. The wage rate used below is based on the Bureau of Labor and Statistics as of May 2023 for Administrative Law Judges.

Form Name

Form Number

No. of Respondents

Average Burden per Response (in
hours)

Total Annual Burden (in hours)

Average Hourly Wage Rate

Total Annual Respondent Cost
Application for Senior Administrative Law Judge

OPM Form 1655

150

.75

113

$57.67

$6,488
Geographic Preference Statement for Senior Administrative Law Judge Applicant

OPM Form 1655-A

200

.42

84

$57.67

$4,844

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: (1) 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 to keep records for the government, or
(4) as part of customary and usual business or private practices.

OPM does not charge any fees for this collection. On average, four respondents annually (or one per quarter) will submit this form by mail. Those respondents print the four pages of the form plus another page to submit proof of their license, estimated at $.08 each. The United States Postal Services website lists the standard letter size postage as $0.68. In addition, OPM believes that these respondents’ preference to use USPS over electronic mail would mean they are able to use their own mailbox or access others easily in their daily lives, making calculating mileage for this collection unnecessary. Therefore, OPM estimates the annual monetary cost of this collection is $4.32


The estimated annualized cost to the Federal Government is based on the 2024 annual GS-12/5 salary of the support staffer used to review and process these applications as part of their general work assignments. We’ve also added an additional 100% overhead.
$53.87 x 2.5 hours per week x 52 weeks per year = $7,003
$7,003 x 2 = $14,006

The updates in the hour and cost burden described above are due to the latest statistics provided by government reporting and other resources as well changes in the agency’s reporting of information available. OPM therefore considers these updates “adjustments” and not the result of deliberate Federal government action.

Information collected on the forms will not be published. OPM only uses this information to match the respondent to employing agencies in need of retired ALJ expertise.

We are not seeking approval to not display the expiration date.

There are no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods
This information collection does not employ statistical methods.