Supporting Statement 8(a) Audit Final

Supporting Statement 8(a) Audit Final.docx

Review of 8(a) Business Development Program & Relevant Information

OMB: 3245-0430

Document [docx]
Download: docx | pdf

U.S. Small Business Administration

SUPPORTING STATEMENT

OMB CONTROL NUMBER 3245-XXXX

Review of 8(a) Business Development Program & Relevant Information


  1. JUSTIFICATION


  1. Need & Method for the Information Collection.


The Small Business Administration (“SBA”) must collect this information to examine participants in SBA’s program under 15 U.S.C. § 637 (the “8(a) program”) in response to urgent concerns regarding small business federal contracting and subcontracting compliance by businesses participating in the program, as well as other instances of waste, fraud and abuse in the same program. This information will be used to determine continued eligibility, program and contract term compliance, and to identify instances of fraud. SBA is authorized to collect this information as part of its general investigative authority under the Small Business Act (codified at 15 U.S.C. § 634(b)(11)).


  1. Use of the Information.


The information requested will be used by SBA’s Office of Government Contracting and Business Development (“GCBD”), to determine whether the 8(a) program participants in question continue to be eligible for inclusion in the 8(a) program under existing regulation and statute, whether they are in compliance with program rules and contract terms, whether they accurately represented their eligibility at the start of the program, and whether they are otherwise performing in the Government’s best interest. If fraud, waste or abuse are detected through this examination, corrective action may result from such reviews. If this information were not collected, the Government would be jeopardizing its operations by failing to enforce the rules of the 8(a) program to the detriment of the American taxpayer.


  1. Use of Information Technology.


Many sources of the requested information utilize automated word processing systems, databases, spreadsheets, and other commercial software to facilitate preparation of material to be submitted, particularly in the submission of financial documents. It is commonplace within many of SBA’s enforcement actions for submissions to be electronic. Consequently, SBA plans to rely on electronic submission via secure portal to ease the compliance burden on affected firms.


  1. Non-duplication.


The information to be collected by SBA is contemplated as a one-time data call to 8(a) participants. The 8(a) participants will be informed that particular information submitted as part of their annual review need not be re-submitted if duplicative of any data already submitted, so long as the data submitted is not reported in greater detail than requested. For instance, data reported in a monthly increment would not be duplicative of the same data already submitted in an annualized form.

  1. Burden on Small Business


Information collection will involve small businesses. The burden applied to small businesses is the minimum possible to address existing concerns about eligibility, compliance with program and contract rules and regulations, and other fraud, waste and abuse, consistent with SBA goals, rules, and regulations.


  1. Less Frequent Collection.


Failure to collect such information in a timely manner will prevent SBA from accurately determining continued eligibility, determining program and contract term compliance, and identifying fraud, waste and abuse in the 8(a) program. This data is necessary to examine participants in the 8(a) program in response to urgent concerns regarding small business federal contracting and subcontracting compliance, as well as other instances of waste, fraud and abuse in the program. A delay in collection of this information will likely result in the continued participation of ineligible businesses in SBA’s 8(a) program, utilized by all federal agencies, to the detriment of the American taxpayer. Moreover, it will result in further erosion of the integrity of the program. Finally, delaying implementation until completion of normal Paperwork Reduction Act clearance procedures would perpetuate risk, including evidentiary spoilation risks, during active oversight investigations. SBA’s ability to document participant eligibility and compliance is essential to ensuring that small-business set-aside awards meet requirements and maintain program integrity. The requested emergency clearance will allow SBA to gather baseline data and support interagency coordination with OMB, Treasury and other Federal Agencies utilizing SBA’s 8(a) program to inform a permanent, government-wide solution. This is a one-time data collection that cannot be collected less frequently.


  1. Paperwork Reduction Act Guidelines.

There are no details of the requested information collection that meet any special circumstances.


  1. Consultation and Public Comment.

This reinstatement is being submitted for review in accordance with emergency procedures (5 CFR 1320.13). As such, advanced public notice and comment has not been conducted on the current collection.


  1. Gifts or Payment.


No payments or gifts are made to respondents, other than contract payments made in accordance with contract terms and conditions.


  1. Privacy & Confidentiality.


There is no assurance of confidentiality. During contract administration, disclosure/non-disclosure of information is handled in accordance with Federal Acquisition and agency regulations as well as the Freedom of Information Act. 5 U.S.C. §552, and the Privacy Act, 5 U.S.C. § 552a and SBA Systems of Records Notice 30, Government Contracting and Business Development System, SBA 30.

  1. Sensitive Questions.


There are no questions of a sensitive nature.


  1. Burden Estimate.

The total public information burden for this collection of information is estimated to be 157,500 to 382,500 total hours ($13,349,970 to $32,420,700), including the time for reviewing instructions, searching existing records, gathering the information needed, verifying and checking the information, and transmitting the information to SBA. Respondents are expected to provide one response with all the requested information.


Respondents: 4,500


Information collection hours per respondent: 35 to 85 hours


Total response burden hours: 157,500 to 382,500


Cost per hour: $84.76 (2025$) National Income per Hour1


Estimated cost burden per respondent: $2,966.66 to $7,204.60


Total estimated cost burden to the public: $13,349,970 to $32,420,700


Collection time depends on the contractor's recordkeeping systems, business complexity, and level of accounting support. Contractors with up-to-date accounting software and routine procedures will require less time. Contractors with more complex operations or manual recordkeeping will require more time.


  1. Respondent Costs Other Than Burden Hour Costs.


There are no non-labor costs associated with this collection.  


  1. Estimated Cost to the Government.


The analysis of these submissions will be performed by salaried SBA staff; there are no expected additional costs for this analysis besides the ordinary and expected costs of SBA employee salaries and benefits.


  1. Reasons for changes.

This is a new collection.


  1. Publicizing Results.


There is no planned publication of information for statistical use; while SBA plans to publicize the broader outcome of its review through a press release or other means, there are no plans for the publication of individual, specific information for statistical use.


  1. OMB Not to Display Approval.


SBA is not seeking approval to not display the expiration date for OMB approval of the information collection.


  1. Exception to “Certification for Paperwork Reduction Submissions.”


There are no exceptions to the certification statement.


  1. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS


The collection does not employ statistical methods.


4

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File Modified0000-00-00
File Created2025-11-19

© 2025 OMB.report | Privacy Policy