Supporting Statement A

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    1. Explain the 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.  (Annotate the CFR parts/sections affected).

The Transportation Security Administration (TSA) is requesting approval to renew this collection of information to comply with section 111 of the Aviation and Transportation Security Act, Pub. L. 107-71 (115 Stat. 597; Nov. 19, 2001), as codified at 49 U.S.C. 44935, which requires TSA to establish qualification standards for the employment of security screening personnel.  TSA currently has an Office of Management and Budget (OMB) approved collection for information necessary to validate that qualification standards are met through the Transportation Security Officer (TSO) medical questionnaire.  See ICR Reference No. 202606-1652-003 (June 8, 2026).


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

On June 8, 2026, OMB approved TSA’s request for an emergency revision of this information collection, allowing for the move from a paper-based Security Officer Medical Questionnaire (SOMQ) to an online version of the SOMQ and to introduce a paper-based TSO Medical Clearance Form.  See ICR Reference Number: 202606-1652-003.  The revision was necessary to address urgent hiring requirements for front-line, mission critical TSO positions.  TSA is seeking renewal of this information collection for the maximum 3-year approval period.

This collection of information assists the agency in meeting its statutory obligation to ensure that no individual serves as a TSO who does not “possess basic aptitudes and physical abilities, including color perception, visual and aural acuity, physical coordination, and motor skills.”  See 49 U.S.C. 44935(f)(1)(B).

The online SOMQ enables TSA to collect the information necessary to assist in making determinations regarding candidates’ medical and physical abilities to successfully perform the job.  The scope of this determination provides a candidate’s current and past medical history, including visual and aural acuity, physical coordination, and motor skills to be able to: (a) distinguish on screening equipment monitors the appropriate imaging standard; (b) distinguish each color displayed on every type of screening equipment and explain what each color signifies; (c) hear and respond to the spoken voice and to audible alarms in an active checkpoint environment; (d) perform physical searches by efficiently and thoroughly manipulating and handling baggage containers, and other objects; (e) perform pat-downs or hand-held metal detector searches of individuals with sufficient dexterity and capacity to thoroughly conduct the procedures over an individual’s entire body; and (f) demonstrate a daily fitness for duty without impairment due to illegal drugs, sleep deprivation, medication, or alcohol.

The TSO Medical Clearance Form also helps TSA to ascertain the candidates’ medical and physical abilities to successfully perform the job.  The TSO Medical Clearance Form is completed by a licensed physician or other licensed health practitioner to indicate whether the candidate is able to perform a list of the duties of a TSO.  The physician or health practitioner also uses the TSO Medical Clearance Form to provide the results of the medical examination, including vital signs, visual acuity, peripheral vision, color vision and hearing.  

In this renewal of the collection, TSA is making a non-substantive change to the “Instructions” of the TSO Medical Clearance Form, adding clarifying language about payment and submission.  

    3. 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.  [Effective 03/22/01, your response must SPECIFICALLY reference the Government Paperwork Elimination Act (GPEA), which addresses electronic filing and recordkeeping, and what you are doing to adhere to it.  You must explain how you will provide a fully electronic reporting option by October 2003, or an explanation of why this is not practicable.]

Consistent with the Government Paperwork Elimination Act, TSA routinely considers technology to reduce the burden of this collection.  As such, TSA successfully moved from a paper-based SOMQ to a full electronic version.  Candidates can access the SOMQ via an electronic portal and complete the form electronically.  Candidates must print the TSO Medical Clearance form to take to a licensed physician or other licensed health practitioner for an employment exam.  The physician or health practitioner completes and signs the TSO Medical Clearance Form, which the candidate then emails to TSA for use in the pre-hire medical eligibility determination process.  The TSA Office of Chief Medical Officer reviews the candidate’s electronic SOMQ along with the TSO Medical Clearance Form for final eligibility determination in accordance with the TSO Medical Guidelines.

Usability Testing Requirement: TSA completed a usability test on the SOMQ online form. The purpose for the test was to determine the accuracy of the time burden to complete the collection. The test included nine (9) participants, five (5) of the applicants were familiar with the online form, while four (4) were unfamiliar. TSA found that the average time to complete the online form for the participants was 12.91 minutes, which corresponds to the current generous, estimated time burden of 30 minutes. Overall all the participants found the questions clear and easy to understand, and felt the information they provided was necessary to determine eligibility.  

The participants did not provide any recommendations for the improvement of the form and the test showed that the annual burden was an accurate estimation.

    4. Describe efforts to identify duplication.  Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in Item 2 above.

The SOMQ online form and the TSO Medical Clearance Form are the most effective and appropriate methods for collecting the information necessary to assist TSA in making determinations regarding candidates’ medical and physical abilities to successfully perform the job without being overly intrusive.

    5. If the collection of information has a significant impact on a substantial number of small businesses or other small entities (Item 5 of the Paperwork Reduction Act submission form), describe the methods used to minimize burden.

The collection of information does not have a significant impact on a substantial number of small businesses or other small entities.  As described above, the online SOMQ and the TSO Medical Clearance Form are collected from candidates under employment consideration for TSO positions and reviewed by licensed physicians or other health practitioners.

    6. 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.

The determination that TSO candidates successfully meet the statutory qualification requirements described above is essential to create and maintain a national workforce of skilled and medically qualified employees charged with protecting the Nation’s transportation systems by ensuring the freedom of movement for people and commerce.  The security of the Nation’s transportation systems would be severely compromised if this collection is not conducted or is conducted less frequently.

Without approval, TSA will be unable to hire sufficient TSOs to provide screening at all federalized airports.

    7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5(d)(2).

There are no special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5(d)(2).

    8. Describe efforts to consult 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.  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.

After the approval of the emergency clearance request, TSA invited public comment on this information collection request; a 60-day notice was published in the Federal Register on July 23, 2026 (91 FR 46488).  TSA intends to publish a 30-day notice following the running of the 60-day notice.  

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

TSA will not provide any payment or gift to respondents.

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

TSA will maintain the information according to the Privacy Act, OPM/GOVT-10 System, Employee Medical File of Records of TSO candidates who are hired, or under the OPM/GOVT-5, Recruiting, Examining, and Placement System of Records of TSO candidates who are not hired.  TSA will maintain the information in a secured area with access limited to authorized personnel who have a business need to know the information.  The collection is also covered by SORN – DHS/TSA-022, which reflects TSA’s move from its legacy payroll and personnel system to become a payroll customer of the USDA’s National Finance Center.  DHS published a Privacy Impact Assessment for the HRAccess Program on July 28, 2009.

    11. Provide additional justification for any questions of sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

While some of the questions TSA poses could be considered to be of a private, sensitive nature, TSA deems this collection necessary to evaluate a candidate’s medical suitability for the TSO job.  Consistent with the requirements in 49 U.S.C. 44935, this collection is essential to ensure that individuals performing TSA’s security mission are physically able to perform their duties safely, with minimal risk of injury to themselves or others, and in a manner that does not compromise security.  As noted above, TSA will follow appropriate procedures to protect this information from unauthorized disclosure.

    12. Provide estimates of hour and cost burden of the collection of information.

TSA uses the SOMQ and the TSO Medical Clearance Form to collect the information necessary to assist in making determinations regarding the medical and physical abilities of candidates for the position of TSO to successfully perform the job.  The hour and cost burden calculations assume all candidates for a TSO position complete the required SOMQ and the TSO Medical Clearance Form.1

TSA estimates an average annual number of respondents completing the SOMQ and TSO Medical Clearance Form of approximately 18,000.2  TSA estimates the average time to complete the SOMQ online tool is 30 minutes (0.50 hours).  This results in an annual SOMQ burden hour of 9,000 hours (18,000 respondents x 0.50 hours).

In addition, TSA estimates the average time to undergo the medical examination required to evaluate a candidate using the TSO Medical Clearance form is 30 minutes (0.5 hours).  This results in an annual hour burden of 9,000 hours (18,000 exams x 0.5 hours).3  Printing and subsequent submission (e.g., email) of the TSO Medical Clearance Form is expected to take approximately 5 minutes (0.08333 hours), resulting in an annual hour burden of 1,500 hours (18,000 respondents x 0.08333 hours).

Furthermore, candidates to the TSO position will spend time traveling to their local physician or health practitioner to receive the necessary medical screening.  TSA estimates round-trip travel time to the local physician or health practitioner to be, on average, 34 minutes each way, or 1.13334 hours roundtrip (0.56667 hours x 2 = 1.13334 hours).4  This results in an annual hour travel burden of 20,400 hours (18,000 exams x 1.13334 hours).  Candidates will also spend on average 11 minutes (0.18333 hours) in the waiting room of the physician or health practitioner.5  This results in annual wait time burden of 3,300 hours (18,000 exams x 0.18333 hours).

The total annual hour burden of this collection is 43,200 hours.6  This equates to 129,600 hours over 3 years (43,200 hours x 3 years).  As TSO candidates can be any member of the public, TSA uses the Bureau of Labor Statistics (BLS) all occupations (00-0000) mean wage rate of $32.66 per hour.7  TSA then applies a load factor of 1.4582 to account for non-compensation costs of employment, such as health and retirement benefits.8  This results in a fully loaded applicant compensation rate of $47.63.9  Multiplying the total annual hour burden (43,200 by the all occupation wage rate ($47.63) results in an annual cost of $2,057,616.  See Table 1 for a summary of these calculations.

Table 1: Hour Burden and Costs for TSO Medical Questionnaire
Activity
Number of TSO Medical Screenings
Hour Burden 
Annual Hour Burden
Annual Hour Burden Cost

A
B
C = A x B
D = C x $47.63
Online SOMQ Form
18,000 
0.5
9,000 
$428,670
Travel to/from Doctor's Office

1.13334
20,400 
$971,652
In Office Wait Time

0.18333
3,300 
$157,179
TSO Medical Examination

0.50
9,000 
$428,670
Print/Email Clearance Form

0.08333
1,500 
$71,445
Total
18,000 
 
43,200 
$2,057,616
Note: Totals may not add due to rounding.

    13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.

TSA assumes that TSO candidates will incur out-of-pocket costs to travel to the exam location by vehicle.  It is estimated that candidates will travel 34 minutes each way, or 1.13334 hours round trip (0.56667 hours x 2 = 1.13334 hours) to reach the medical exam.10  TSA assumes the average speed during this round trip is 53.19 miles per hour,11 resulting in a total of 60.28 miles traveled (1.13334 hours x 53.19 miles per hour = 60.28 miles).  TSA uses the General Services Administration’s (GSA) Privately owned vehicle (POV) mileage reimbursement rates of $0.725 per mile to estimate transportation costs.12  Accordingly, the cost of operating a vehicle to the exam location is $43.70 per round trip (60.28 miles x $0.725 per mile = $43.70).  Table 2 summarizes the out-of-pocket travel costs incurred by respondents.

Table 2: Annual Costs of Travel to Medical Examination
Activity
Number of TSO Medical Exams
Miles Traveled
Cost Per Mile
Vehicle Operating Cost
Annual Respondent Cost

A
B
C
D = B x C
E = A x D
Respondent Travel to Medical Exam
18,000
60.28
$0.725
$43.70
$786,680
Total
18,000
 
 
43.70
$786,680

In addition, respondent burden includes out-of-pocket cost for the required pre-employment medical examination.  To estimate the out-of-pocket cost associated with the medical examination, TSA assumes a cost similar to TSA’s previously contracted medical exam rate of $150 per exam which is within current market prices for job-related medical exams (approximately $82 – $150).13  The resulting total annual cost burden to respondents is approximately $2,700,000 (18,000 exams x $150).

The total out-of-pocket cost for candidates to travel to the medical exam and pay fees associated with the exam is estimated at $3,486,680 ($786,680 in travel costs + $2,700,000 in exam fees).

    14. Provide estimates of annualized cost to the Federal Government.  Also, provide a description of the method used to estimate cost, and other expenses that would not have been incurred without this collection of information.

TSA medical staff will review and process the SOMQ and TSO Medical Clearance Forms once they are submitted.  TSA estimates that it takes, on average, about 10 minutes (0.17 hours) for a TSA employee to review and process each respondent’s forms (the SOMQ and the TSO Medical Clearance Form).  TSA uses a fully loaded average hourly wage rate for an I-Band TSA employee involved in the adjudication of $88.39.14  Based on 18,000 annual respondents, TSA estimates that the total annual cost incurred by the Federal government is $270,473 (0.17 hours x $88.39 per hour x 18,000 respondents).

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

There are no program changes or adjustments.  However, TSA is making a non-substantive change to the “Instructions” of the TSO Medical Clearance Form, adding clarifying language about payment and submission.  


    16. For collections of information whose results will be published, outline plans for tabulation and publication.  Address any complex analytical techniques that will be used.  Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

TSA will not publish the information collected.

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

TSA is not seeking such approval and will display the expiration date for OMB approval of the information collection.

    18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

TSA is not seeking any exceptions to the certification statement identified in Item 19, OMB Form 83-I, Certification for Paperwork Reduction Act Submissions.