Supporting Statement for OMB No

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SUPPORTING STATEMENT - PART A for
OMB Control Number 0584-0686  
 EmpowHR/Person Model NON-EMPLOYEE DATA SHEET – FNA-775


Tonya Johnson
Human Resources Specialist
Food and Nutrition Administration 

United States Department of Agriculture (USDA), Food and Nutrition Administration (FNA)
1320 Braddock Place 
Alexandria, Virginia 22314


Table of Contents
A1. Circumstances that make the collection of information necessary.	3
A2. Purpose and Use of the Information.	3
A3.  Use of information technology and burden reduction.	3
A4.  Efforts to identify duplication.	4
A5.  Impacts on small businesses or other small entities.	4
A6.  Consequences of collecting the information less frequently.	4
A7.  Special circumstances relating to the Guidelines of 5 CFR 1320.5.	5
A8.  Comments to the Federal Register Notice and efforts for consultation.	5
A9.  Explain any decisions to provide any payment or gift to respondents.	6
A10.  Assurances of confidentiality provided to respondents.	6
A11.  Justification for any questions of a sensitive nature.	7
A12.  Estimates of the hour burden of the collection of information.	7
A13.  Estimates of other total annual cost burden.	8
A14.  Provide estimates of annualized cost to the Federal government.	8
A15.  Explanation of program changes or adjustments.	8
A16.  Plans for tabulation, and publication and project time schedule.	8
A17.  Displaying the OMB Approval Expiration Date.	9
A18.  Exceptions to the certification statement identified in Item 19.	9



Appendices
Appendix A Legal Authority Homeland Security Presidential Directive 12
Appendix B FNA 775 EmpowHR/Person Model 
Appendix C USDA OP-1Personnnel and Payroll System for USDA Employees (SORN)
Appendix D USDA OP-2 Security Records for USDA Employees (SORN)
Appendix E EmpowHR Screenshots
Appendix F Burden Table












A1. 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.

This is a revision of an approved information collection request. The data collected is requested from agency affiliates who are non-employees, such as contractors, interns, and volunteers who will require physical and or/logical access to agency facilities and/or systems.  The collection of the data such as full legal name, address, phone, social security number, birthdate, place of birth, country of citizenship is required to input into the USDA system of record, EmpowHR, so that upon submission, it conforms to the data requirements set forth by agency credentialling system, USAccess. 

The FNA 775 EmpowHR/Person Model (Appendix B) shows the required biographic data to be collected for system input.  Legal authority for gathering of data fields mentioned above comes from the Homeland Security Presidential Directive 12 (Appendix A Legal Authority).  The Directive references HSPD-12 as the chosen standard for data collection for employees and contractors.  HSPD-12 was issued on August 12, 2004 and calls for a mandatory, government-wide standard for secure and reliable ID for all of its employees and contractors to access federally controlled facilities and networks. Based upon this directive, the National Institute for Standards and Technology (NIST) developed Federal Information Processing Standards Publication (FIPS Pub) 201. USDA’s LincPass card is designed to link a person’s identity to an ID credential and the credential to a person’s ability to physically and logically access federally controlled buildings and information systems, respectively.  

Authorizing statutes include 731.106(c)(2).Additional Legal authority includes the Privacy Act (5 U.S.C. 552a(e)(11)), the Department of Agriculture Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (Pub. L. 104–193, as noted in Appendix C USDA OP-1 Personnel and Payroll System for USDA Employees (SORN).

A2. Purpose and Use of the Information.

Indicate how, by whom, and for what purpose the information is to be used.  Except for a new collection, indicate how the agency has actually used the information received from the current collection.

The data collected on the FNA 775 EmpowHR/Person Model sheet (Appendix B) is used to input data for individuals who are contractors employed by an external company or business, interns, or volunteers.  The mandatory data collected (full legal name, address, phone, social security number, birthdate, place of birth, country of citizenship) is then input to the System of Record, EmpowHR. The personal identifiable information (PII) data collected is for the specific purpose of sponsorship for the agency's PIV (Personal Identity Verification) credential and will be used during background investigation as required for access to agency facilities, systems, and information.

A3.  Use of information technology and burden reduction.  

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. Also describe any consideration of using information technology to reduce burden.



Burden Reduction Efforts
FNA makes every effort to comply with E-Government Act, 2002 (E-Gov) and to provide for alternative submission of information collections.  

A4.  Efforts to identify duplication. 

Describe efforts to identify duplication.  Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2.

There is no similar information collection. Every effort has been made to avoid duplication. The data collected on this form for the intended purpose is not being collected elsewhere.  These fields are required as FNA solely monitors sponsor PIV credentials for background investigations to ensure integrity when granting access to FNA systems. 

A5.  Impacts on small businesses or other small entities.  

If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

FNA has determined that the requirements for this information collection do not adversely impact small businesses or other small entities.  Information being requested or required has been held to the minimum required for the intended use.
FNA proactively implements roughly 30 (or 50%) small business contracts that require contractor employees to complete the FNA 775 EmpowHR/Person Model sheet as a manual process.  The collection will be incorporated into the ServiceNow On/Offboarding application that will automate the collection of the non-employee data with a digital signature option.  The digitized option will require less time and effort than the manual process currently in use.

A6.  Consequences of collecting the information less frequently.  

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.

This is an ongoing and mandatory data collection.  If the collection is not conducted, sponsorship for PIV credentials required for facility and system could not be granted; the agency would not be able to conduct a background investigation to ensure integrity before granting access to FNA systems. The PII information is only required to be collected upon their affiliation with the agency and only when it is determined they affiliate will require physical and/or logical access to agency resources.

A7.  Special circumstances relating to the Guidelines of 5 CFR 1320.5.  

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 secret, 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.


There are no special circumstances.  The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.5.

A8.  Comments to the Federal Register Notice and efforts for consultation.  

If 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.	

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.  

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the collection of information activity is the same as in prior years. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), FNA published a notice on June 16, 2026, in the Federal Register, Volume 91, Number 35951, and provided a 60-day period for public comments. The public comment period ended on August 14, 2026.  FNA received two comments of which one comment appears to be spam. The other comment describes the internal tracking process for the contracting company but did not provide any actional feedback for the Agency.

Consultation was conducted with three federal contractors, who participated in completion of this form as part of their contractor onboarding process. The respondents replied in writing to the questions provided. The participants were: Shauna Barella, Alana Hulsey and Tamara Davis, all affiliated with GovStrive. The respondents communicated that the form is very straightforward, easy to complete and did not encounter any confusion or issues when filling it out. Therefore, they had no specific recommendations for any changes to the form for the purpose of the collection. 
A9.  Explain any decisions to provide any payment or gift to respondents.  

Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift will be provided to respondents.


A10.  Assurances of confidentiality provided to respondents.  

Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

FNA complies with the Privacy Act of 1974 (5 USC 552a), which requires the safeguarding of individuals against invasion of privacy. The Privacy Act also provides for the treatment of records collected, used, maintained or disseminated by a Federal agency according to either the individual’s name, social security numbers, date of birth and fingerprint (if necessary).  The FNA 775 is used to collect this data.  This collection contains personally identifying information. The Privacy Act Statement will be displayed on the FNA 775 form (Appendix B) for the respondent’s review.  EmpowHR is covered under the USDA/OP-1, Personnel and Payroll System for USDA Employees, Volume 63, No. 18, page 4213, published January 28, 1998, and USDA/OP-2 Security Records for USDA Employees.  Both are attached as Appendix C and D.
The USDA Privacy Officer, Deea Coleman, reviewed the ICR package on 6/1/2026, and recommended approval of the request.
A11.  Justification for any questions of a sensitive nature.    

Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

FNA complies with the Privacy Act of 1974 (5 USC 552a), which requires the safeguarding of individuals against invasion of privacy. The Privacy Act also provides for the treatment of records collected, used, maintained or disseminated by a Federal agency according to either the individual’s name, social security numbers, date of birth and fingerprint (if necessary).  Gathering of this sensitive data is needed to identify and validate new hires. Other than the specific personally identifiable information outlined here that the agency HRIS requires, there are no questions of a sensitive nature. The USDA Privacy Officer, Deea Coleman, reviewed the ICR package on 6/1/2026, and recommended approval of the request.

A12.  Estimates of the hour burden of the collection of information.  Provide estimates of the hour burden of the collection of information.  Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.  Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.  If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

FNA anticipates 750 respondents (contractors, interns, affiliates) will respond to the FNA-775 one time annually for a total of 750 total annual responses, and that it will take approximately 30 minutes (0.5) for a total of 375 annual burden hours.  
Appendix F Burden Table
Affected public
Type of respondents (optional)
Instruments
Form
Number of respondents
Frequency of response
Total Annual responses
Hours per response
Annual burden (hours)
Hourly Wage Rate
Total Annualized Cost of Respondent Burden
Businesses
Contractors
FNA 775
FNA 775
688
1
688
0.5
344
 $      150.00 
 $     $51,600 
Individuals 
 Affiliates, Interns
FNA 775
FNA 775
62
1
62
0.5
31
 $      150.00 
 $       4650.00 
 
TOTAL
 
 
750
 
750
 
375
 
 $    56,250.00 + 33% =
            $74, 812.50



B.	Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

The average hourly rate for respondents, the majority of who are technology contractors, is $150 per hour, for all respondents is $ 56,250,00 ($150 x 375hrs).  The estimates for technology contractors were taken from a typical mid-range software development BPA within the USDA.   These rates are consistent with other vendors on the BPA.  Wage rates were also researched on the BLS.GOV website but were much lower than the average wage rates for technology contractors. An additional 33% of the estimated base annual respondent cost must be added to represent fully loaded wages, equaling $18,562.50. Thus, the total annual respondent cost is $74,812.50.
A13.  Estimates of other total annual cost burden.

Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information, (do not include the cost of any hour burden shown in questions 12 and 14).  The cost estimates should be split into two components: (a) 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.

There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.
A14.  Provide estimates of annualized cost to the Federal government.  

Provide estimates of annualized cost to the Federal government.  Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The total cost to the Federal government is $2,197,308.96 over a 12-month period, or on an annualized basis.  The information collection also assumes an average of 25% of a Federal COR employee’s time per year for a GS-14, step 1 in the rest of USA with the locality annual salary of $143,913.00.  Annual COR cost: $143,913.00 x 25% = $35,978.00 (30 CORS) = $1,079,340.00
The information collection also assumes an average of 100% of a Federal PSO (Physical Security Officer) employee’s time per year for a GS-14, step 1 in the rest of USA with the locality annual salary of $143,913.00.  Annual PSO cost: $143,193.00 x 4 PSO = $572,772.00
An additional 33% of the estimated base annual cost to the Federal government must be added to represent fully loaded wages, equaling $545,196.96. Federal employee pay rates are based on the General Schedule of the Office of Personnel Management (OPM) effective January 2026.

A15.  Explanation of program changes or adjustments.

Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

This is a revision of a currently approved information collection with no change in burden of 750 respondents, 750 total annual responses and 375 total annual burden hours in the OMB collection inventory. There are programmatic revisions to this information collection to update language throughout the collection to reflect the Agency’s name change. 

A16.  Plans for tabulation, and publication and project time schedule.  For collections of information whose results are planned to be published, outline plans for tabulation and publication.

Results will not be tabulated or published.  Data collected will be used for internal administration of contracts.

A17.  Displaying the OMB Approval Expiration Date.

If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.
A18.  Exceptions to the certification statement identified in Item 19.  

Explain each exception to the certification statement identified in Item 19 of the OMB  83-I" Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.