Supporting Statement A

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SUPPORTING STATEMENT - PART A

Supporting Statement for
Department of Veterans Affairs Acquisition Regulation Provision 852.209-70
OMB Control No. 2900-0418

Summary of Changes from the Previously Approved Collection 

    • There are no revisions to the previously approved information collection (IC) instrument.
    • The supporting statement was updated to the current format.
    • Section 7 provides expanded discussion on the Paperwork Reduction Act (PRA) Guidelines.
    • Section 15 shows there is no change in burden hours since the previous approval. The cost burden of this information collection increased by $1,798 because wage rates are higher. 
    • The 60-day comment period ended on 11/2/2026. VA received one comment. The comment and the agency response are noted in Section 8.

    1. Need for the Information Collection

The Department of Veterans Affairs (VA), Office of Procurement, requests the Office of Management and Budget (OMB) grant an extension of a previously approved information collection (IC) under OMB control number 2900-0418, concerning Organizational Conflicts of Interest.  

VAAR 809.507-1, Solicitation provisions, and VAAR provision 852.209-70, Organizational Conflicts of Interest, requires offerors on solicitations for management support and consulting services to advise, as part of the firm’s offer, whether or not award of the contract to the firm might involve a conflict of interest or potential conflict of interest, and, if so, to disclose all relevant facts regarding the conflict or potential conflict.

VA is requesting a 3-year extension to collect this information from public or private entities.

Authority: 40 U.S.C. 121(c); 44 U.S.C. 3507, Paperwork Reduction Act of 1995; section 8141 of the 1989 Department of Defense Appropriation Act, Pub. L. 100-463; 102 Stat. 2270-47 (1988); and 48 CFR 1.301–1.304.

2.	Use of the Information 

This information collection requirement is used to identify and mitigate organizational conflicts of interest of providers of certain services to the government.

The offeror on applicable VA acquisitions must provide a statement with their offer which describes, in a concise manner, all relevant facts concerning any past, present, or currently planned interest (financial, contractual, organizational, or otherwise) or actual or potential organizational conflicts of interest relating to the services to be provided under this solicitation. There is no required format, and each submission is unique to the individual offeror (contractor) and the situation. Offerors complete the information collection by providing information about the actual or potential organizational conflict of interest. 

The offeror must also provide statements with their offer containing the same information for any consultants and subcontractors identified in their proposal that will provide services under the solicitation. The offeror may also provide relevant facts that show how its organizational and/or management system or other actions would avoid or mitigate any actual or potential organizational conflicts of interest.

Offerors are made aware of the required information collection via the provision in each applicable solicitation. Information is submitted to the cognizant contracting officer identified in each solicitation. Using the submitted information, the contracting officer may determine that an organizational conflict of interest exists which would warrant disqualifying the contractor for award of the contract unless the organizational conflict of interest can be mitigated to the contracting officer's satisfaction by negotiating terms and conditions of the contract.

3. 	Use of Information Technology 

VA almost always requests or allows offerors/contractors to submit this IC electronically – typically via email or uploading into VA-provided portal links. VA complies with the policy in Federal Acquisition Regulation (FAR) 4.002 (Deviation, Nov 2025) that mandates using electronic commerce whenever practicable and cost-effective.

4. 	Non-duplication 

The information obtained through these collections 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. Small businesses will be affected in the same way as large businesses.

6.	 Less Frequent Collection 

This information is only collected once for each applicable solicitation issued.  
Generally, an offeror must provide the required information with their proposal.



7. 	Paperwork Reduction Act Guidelines 
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5(d)(2). More specifically to two requirements: First, the nature and extent of confidentiality; the protection of contractor proprietary, trade secret, or other confidential information and the Government’s right to use that data are covered by contract-specific clauses available to all offerors. 
Second, regarding reducing burden on small entities to the extent practicable and appropriate, this information is required by the Government to protect transparency and fairness in Government contract transactions by ensuring organizational conflicts of interest are identified. It applies equally to businesses of any size. 
VA permits offerors to submit information in their own form and format, and to submit electronically, thus reducing burden on small entities to the extent practicable. The capture and maintenance by an offeror/contractor of such information is a standard business practice.
Contract laws and regulations specify record retention requirements for contracts. 
FAR subpart 4.7, Contractor Records Retention, states the required records retention period based on different contract actions and circumstances.
The protection of contractor proprietary, trade secret, or other confidential information and the Government’s right to use that data are covered by contract-specific clauses.
8. 	Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice (FRN) for this collection was published on Thursday September 3, 2026. The 60-Day FRN citation is 91 FR 56733. 
One comment was received during the 60-Day Comment Period. The comment and VA’s response are included below.
Comment received from Reggie Greenwood on 9/3/2026, tracking number mtm-2rke-4np2):	
I support the Department of Veterans Affairs' renewal of OMB Control No. 2900-0418 concerning VAAR provision 852.209-70, Organizational Conflicts of Interest.

VA relies extensively on contractors to support its mission and serve our Nation's Veterans. When Federal taxpayer dollars are involved, VA has a responsibility to ensure that companies competing for contracts disclose actual or potential organizational conflicts of interest that could impair their objectivity, influence contract performance, or create an unfair competitive advantage.
This information collection provides contracting officers with information necessary to identify potential conflicts before Federal funds are committed. Contractors seeking Federal business should be expected to disclose relevant relationships or circumstances that could compromise the integrity of the acquisition process.
I also believe these disclosures must be meaningful rather than simply another administrative requirement. When an actual or potential conflict is identified, contracting officers should receive sufficient information to evaluate the conflict, determine whether it can be effectively mitigated, and document appropriate safeguards. Material nondisclosure or misrepresentation should be taken seriously.
At the same time, VA should minimize unnecessary administrative burdens. The estimated average burden of 60 minutes per respondent appears reasonable given the importance of protecting the integrity of Federal procurement. However, VA should continue using electronic submission, standardized disclosure formats, clear instructions, and existing Government information whenever practicable to prevent unnecessary duplication.
A streamlined electronic process can strengthen accountability while reducing costs for both contractors and VA employees. Contractors should be able to clearly identify the nature of a potential conflict and explain any proposed measures to avoid, neutralize, or mitigate it.
Strong conflict-of-interest requirements also protect responsible contractors. Companies competing fairly for Federal contracts should not be disadvantaged by competitors that fail to disclose relationships or circumstances that provide an improper advantage.
I therefore support renewal of OMB Control No. 2900-0418. I recommend that VA continue requiring meaningful organizational conflict-of-interest disclosures while emphasizing transparency, accountability, fair competition, electronic processing, and the elimination of unnecessary or duplicative paperwork.
Federal contractors entrusted with taxpayer resources should be held to clear standards of integrity and transparency. VA should maintain effective oversight while ensuring that its information requirements remain focused, efficient, and directly related to legitimate procurement needs.
Respectfully submitted, Reggie
VA Response: VA elects to not change information collection 2900-0418 in response to this comment. The commenter supports the renewal of this information collection; he recommends that VA continue to require meaningful organizational conflict-of-interest disclosures via this information collection. He notes that the estimated average burden of 60 minutes per respondent appears reasonable.
A 30-Day FRN for this collection was published on Thursday, November 12, 2026. The 30-Day FRN citation is 91 FR 72975.
Part B: CONSULTATION 
Public comments were solicited via the Federal Register. No other consultation is planned.
9. 	Gifts or Payment 

No payments or gifts are being offered to respondents as an incentive to participate in the collection.


10. 	Confidentiality 

    • A Privacy Act Statement is not required for these collections because we are not requesting individuals to furnish personal information for a system of records.
    • A System of Record Notice (SORN) is not required for these collections because records are not retrievable by Personally Identifiable Information (PII).
    • A Privacy Impact Assessment (PIA) is not required for these collections because PII is not being collected electronically.
    • No assurances of privacy/confidentiality will be provided to respondents. 
However, data will be kept private to the extent allowed by law. Information provided to VA by a contractor is subject to being requested by third parties under the Freedom of Information Act (FOIA), as amended (5 U.S.C. § 552), but business-proprietary information is generally exempt from public disclosure under the FOIA.

11. 	Sensitive Questions 

No questions considered sensitive are being asked in these collections.

12. 	Respondent Burden and its Labor Costs

Part A: ESTIMATION OF RESPONDENT BURDEN

    1) Collection Instrument(s)
VAAR 809.507-1 and VAAR Provision 852.209-70
    a) Number of Respondents: 102
    b) Number of Responses Per Respondent: 1 per each solicitation
    c) Number of Total Annual Responses: 102
    d) Response Time: 60 minutes (1 hour)
    e) Respondent Burden Hours (102 x 60) ÷ 60 equals: 102 hours 

    2) Total Submission Burden
        a) Total Number of Respondents: 102
        b) Total Number of Annual Responses: 102
        c) Total Respondent Burden Hours: 102 hours

Part B: LABOR COST OF RESPONDENT BURDEN

    1) Collection Instrument(s)
VAAR 809.507-1 and VAAR Provision 852.209-70
    a) Number of Total Annual Responses: 102
    b) Response Time: 1 hour
    c) Respondent Hourly Wage: $122.43
    d) Labor Burden per Response: $122.43
    e) Total Labor Burden: $12,488

    2) Overall Labor Burden 
        a) Total Number of Annual Responses: 102
        b) Total Labor Burden: $12,488

The Respondent hourly wage was determined by using the Bureau of Labor Statistics (BLS) website at https://www.bls.gov/home.htm and the particular index at https://www.bls.gov/oes/current/oes_stru.htm#11-0000. According to the latest  available BLS data (May 2025), the mean hourly wage is $89.86 on BLS wage code – “11-3031 Financial Managers” plus 36.25% per OMB Memo M-08-13 dated March 11, 2008.

13.	Respondent Costs Other Than Burden Hour Costs 

There are no costs to respondents, other than the labor burden costs in Section 12.

14. 	Cost to the Federal Government

Part A: LABOR COST TO THE FEDERAL GOVERNMENT

	Total Estimated Burden Hours to the Government: 102.
	Total Estimated Cost to the Government: $5,770.

Estimated annual cost to the Government: $5,770 (102 hours at $56.57 per hour). It is estimated that the review and statement will be prepared by a Journeyman Contract Specialist equivalent to a GS-12, step 5. The 2026 OPM salary rate is $41.52. Including a benefits rate of 36.25% per OMB Memo M-08-13 dated March 11, 2008, gives an hourly rate of $56.57 ($41.52 X 136.25%). 

Part B: OPERATIONAL AND MAINTENANCE COSTS

    1) Cost Categories
        a) Equipment: $0
        b) Printing: $0
        c) Postage: $0
        d) Software Purchases: $0
        e) Licensing Costs: $0
        f) Other: $0

    2) Total Operational and Maintenance Cost: $0

Part C: TOTAL COST TO THE FEDERAL GOVERNMENT

    1) Total Labor Cost to the Federal Government: $5,770

    2) Total Operational and Maintenance Costs: $0

    3) Total Cost to the Federal Government: $5,770

15. 	Reasons for Change in Burden 

There is no burden hour change. The cost burden has increased since the previous approval due to higher wage rates. This results in an increase of $1,798 in burden cost as shown below.

Summary of the cost differences between this Summary Statement (SS) and the last SS
SS Block #
Cost This SS
Cost Last SS
Increase (Decrease)
Reason
12
$12,488
$11,094
$1,394
Increase in BLS wage rate. 
14
  $5,770
  $5,366
   $404
Increase in GS wage rate.

16. 	Publication of Results 

The results will not be published.

17. 	Non-Display of OMB Expiration Date 

We are not seeking approval to omit the display of the expiration date of the OMB approval on this collection instrument.

18. 	Exceptions to “Certification for Paperwork Reduction Submissions” 

We are not requesting any exemptions to the provisions stated in 5 C.F.R. § 1320.9.