VMLRP Program Supporting Statement Final

National Institute of Food and Agriculture

U.S. Department of Agriculture

OMB No.

Application Forms and Reporting Requirements for the Veterinary Loan Repayment Program (VMLRP)

SUBJECT: Supporting Statement for Paperwork Reduction Act Submission for the Application Forms and Reporting Requirements for the Veterinary Loan Repayment Program (VMLRP)

A. JUSTIFICATION

1. CIRCUMSTANCES MAKING COLLECTION OF INFORMATION NECESSARY

In January 2003, the National Veterinary Medical Service Act (NVMSA) was passed into law adding section 1415A to the National Agricultural Research, Extension, and Teaching Policy Act of 1997 (NARETPA). This law established a new Veterinary Medicine Loan Repayment Program (7 U.S.C. 3151a) authorizing the Secretary of Agriculture to carry out a program of entering into agreements with veterinarians under which they agree to provide veterinary services in veterinarian shortage situations.

The purpose of the program is to assure an adequate supply of trained food animal veterinarians in shortage situations and provide USDA with a pool of veterinary specialists to assist in the control and eradication of animal disease outbreaks.

The information proposed for collection allows the National Institute of Food and Agriculture (NIFA) to request from VMLRP applicants information related to eligibility, qualifications, career interests, and recommendations necessary to evaluate their applications for repayment of educational indebtedness in return for agreeing to provide veterinary services in veterinarian shortage situations. The information proposed for collection will also be used to determine an applicant’s eligibility for participation in the program. It is particularly important that the information be provided to NIFA in a standardized fashion to ensure equitable treatment for all applicants.

The National Institute of Food and Agriculture (NIFA) is requesting an emergency clearance for the VMLRP application forms. With the enactment of the Food, Conservation, and Energy Act of 2008, it is the expectation of Congress that NIFA would be able to make its first VMLRP agreements by the end of Fiscal Year 2010. NIFA is requesting emergency clearance in order to collect information from interested applicants from April 1 to June 30, 2010. This timeframe is necessary to allow NIFA to execute its first agreements by September 30, 2010.

2. HOW, BY WHOM, AND PURPOSE FOR WHICH INFORMATION IS TO BE USED

NIFA will publish a Request for Applications (RFA) in the Federal Register and on the NIFA website for VMLRP loan repayment applications from individual veterinarians. Interested individuals will submit the necessary information to NIFA using the application forms.

NIFA will convene a peer review panel to review submitted and eligible applications and make recommendations to the NIFA Program Manager. The panelists may be compose of food supply veterinary medicine experts from Federal and state agencies, as well as individuals from institutions receiving Animal Health and Disease Research Program funds under section 1433 of NARETPA, private associations, private citizens, etc.

3. USE OF IMPROVED INFORMATION TECHNOLOGIES

NIFA will provide this form on its website as a PDF-fillable form when the Request for Applications for VMLRP awards is published in the Federal Register. Submissions will be accepted via mail or fax.

4. EFFORTS TO IDENTIFY DUPLICATION

This is the first loan repayment program for NIFA. There is no similar information available which can be used or modified to meet the information needs of this program. The information requested is specific to the program and need only be submitted when applying for a VMLRP award.

5. METHODS TO MINIMIZE BUDGET OF SMALL BUSINESSES OR ENTITIES

Small Businesses are not impacted by this information collection.

6. CONSEQUENCE IF INFORMATION COLLECTION WERE LESS FREQUENT

Individual veterinarians interested in applying for a loan repayment agreement with the VMLRP will submit VMLRP application forms only during the 90-day application cycle. NIFA will normally publish a RFA on an annual basis. The submission of information must be timely in order to receive applications in NIFA, properly examine loan documents for compliance, and to accomplish steps to establish and carry out the review process.

7. SPECIAL CIRCUMSTANCES FOR INFORMATION COLLECTION

 Requiring respondents to report information to the agency more often than quarterly:

Program participants (successful applicants) will be required to verify that the terms of the VMLRP contract are being met on a quarterly basis. Subsequent quarterly loan repayments will not be disbursed until this verification is provided. This report will be due ten business days after the end of each three month interval during the VMLRP contract for the previous three month period. Program participants are responsible for notifying NIFA of any changes in the service being provided in the specified shortage situation during the three-year contract period. Failure to provide the updated information may result in the termination of the VMLRP contract and the program participant may be subject to penalties as outlined in Section C, Paragraph 3 of the contract.

 Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

USDA does not require 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;

USDA does not require 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;

The agency usually does not require respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years following completion of a service agreement.

 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;

This information collection does not include statistical surveys.

 Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

This information collection does not require the use of 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;

This information collection does not require 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.

 Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it instituted procedures to protect the information’s confidentiality to the extent permitted by law.

This information collection does not require respondents to submit proprietary trade secret, or other confidential information.

8. FEDERAL REGISTER NOTICE

The notice for this proposed information collection appeared in the Federal Register on Wednesday, January 20, 2010 (75 FR 3193).

CONSULTATIONS WITH PERSONS OUTSIDE THE AGENCY

NIFA solicited stakeholder input at a public meeting on Monday, September 15, 2008, and through written comments. In addition, NIFA is working with the NIH DLR to provide certain administrative services and support.

9. DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES

The agency does not provide payment or gift directly to respondents.

10. CONFIDENTIALITY PROVIDED TO RESPONDENTS

The information collection will be handled in accordance with the Freedom of Information Act and the Privacy Act.

11. QUESTIONS OF A SENSITIVE NATURE

Information will be requested involving the applicant’s name, address, Social Security number (SSN), service payback obligations, employment data, professional performance and credentialing history of licensed veterinarians; personal, professional, and demographic background information; financial data including loan balances, deferment, forbearance, and repayment/delinquent/default status information. This information will be used to: (1) Identify and select applicants for the VMLRP; (2) monitor loan repayment activities, such as payment tracking, deferment of service obligation, and default; and (3) assist NIFA officials in the collection of overdue debts owed under the VMLRP.

12. ESTIMATE OF BURDEN

It is estimated that it will take each applicant approximately ten hours to complete the forms. It is also estimated that it will take each recommender approximately one hour to complete the recommendation form and a representative from a financial institution approximately fifteen minutes to complete a section of the loan information form. Each application form is PDF-fillable with checkboxes and text-limiting fields to minimize the overall burden.

ANNUALIZED COSTS TO RESPONDENTS

Based on the median salary of an early career veterinarian (1-4 years experience) of $65,000 or an hourly wage of $31.25, NIFA estimates the annual cost burden to applicants for the value of their time to complete and submit an application to be $31,250 ($31.25 x 1,000). A recommender will typically be a veterinarian with 10-20 years experience, which has a median salary of $80,000 or an hourly wage of $38.46, thus NIFA estimates the annual cost burden to recommenders for the value of their time to complete and submit a recommendation to be $11,538 ($38.46 x 300).

Type of Respondent and Form	No. of Respondents	Annual Frequency per Response	Total Annual Responses	Hours per Response	Total Hours
Applicants: Applicant Information Personal Statement List of Recommenders Loan Information Contract Certification for Applications Intent of Employment	100 100 100 100 100 100 100	1 1 1 2 1 1 1	100 100 100 200 100 100 100	1 6 .5 .5 .25 .25 1	100 600 50 100 25 25 100
Applicants subtotal	100	---	---	---	1,000
Recommenders: Recommendation	300	1	300	1	300
Recommenders subtotal:	300	1	300	1	300
Financial Institutions: Loan Information	200	1	200	.25	50
Financial Institutions subtotal:	200	1	200	.25	50
Grand Total	600	---	---	---	1,350

The median salary was derived from PayScale

(http://www.payscale.com/research/US/Job=Veterinarian/Salary).

13. CAPITAL/STARTUP COSTS

There are no capital or startup costs for this activity.

14. ANNUALIZED COST TO THE FEDERAL GOVERNMENT

The staffs responsible for processing applications are full-time employees ranging in grade levels GS-9 and GS-15.

Job Title	Action	Hourly Pay*	Time per Action	Total per Application	Total for Applications
Program Assistant, GS-9	Evaluates applications for preliminary review	$28.04	2 hours	$56.08	$5,608
Program Manager, GS-15	Evaluates applications, coordinates panel members, announces awards	$67.21	6 hours	$403.26	$40,326
TOTALS			8 hours	$459.34	$45,934

*A step 5 was used in determining the hourly pay for the grade level.

15. REASONS FOR CHANGE IN BURDEN

This is a new information collection.

16. TABULATION, ANALYSIS AND PUBLICATION PLANS

USDA has no plans to publish information collected.

17. SEEKING APPROVAL TO NOT DISPLAY OMB APPROVAL DATE ON FORMS

Each VMLRP Application Form (8 total) will display the OMB control number and burden statement.

18. EXCEPTION(S) TO THE CERTIFICATION STATEMENT (19) ON OMB 83-I

USDA claims no exceptions to the certification statement 19 on OMB 83-I.

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