Supporting Statement for Paperwork Reduction Act Submission
3090-00XX – 552.238-60 - Sales Practice Format – Supplies and/or Services with an Established Catalog Price (SPF-1) and 552.238-61- Sales Practices Format – Supplies and/or Services with Market Pricing without an Established Catalog Price (SPF-2)
A. Justification
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.
552.238-60 – Sales Practices Format – Supplies and/or Services with an Established Catalog Price (SPF-1) and 552.238-61 – Sales Practices Format – Supplies and/or Services with Market pricing without an Established Catalog Price (SPF-2). Submission of a Federal Supply Schedule offer or a specific type of modification of an FSS contract requires an Offeror to provide data regarding commercial sales practices (e.g. catalog prices, quantity/volume discounts, concessions, etc).
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.
Prospective FSS Offerors and/or current contractors are required to provide information as outlined in Program solicitations to assist the Contracting Officer in evaluation of the offer as well as formulating negotiation objectives.
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.
We use improved information technology to the maximum extent practicable. Where both the General Services Administration and contractors are capable of electronic interchange, the contractors may submit information requirements electronically.
4. 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 Item 2 above.
The information requested is required in response to every Federal Supply Schedule solicitation for supplies and services. The information is provided in standard clauses without duplication. Similar information is not available elsewhere.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The burden applies equally to small organizations that want a Schedule contract and is the minimum necessary to meet the specific program objectives.
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.
Specific FSS Schedule Program objectives would not be met if the Federal Acquisition Service (FAS) is not able to collect required information in response to its various solicitations from prospective Offerors and/or current contractors.
7. 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;
Prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Submit more than an original and 2 copies of any document;
Retain records, other than health, medical, government contracts, grant-in-aid, or tax records, for more than 3 years;
In connection with a statistical survey, that is not designed to produce valid, reliable results that can be generalized to the universe of study;
Require the use of a statistical classification that has not been reviewed and approved by OMB;
Include 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
Submit proprietary trade secrets, 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.
None.
8. 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 periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
GSA has conducted an internal inquiry for reports covered by this collection. Time and cost estimates are based on a combination of those responses and professional judgment.
The proposed rule published in the Federal Register at 74 FR 4596, January 26, 2009, requested comments. No comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
GSA makes no such payments under this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.
GSA makes no such payments under this collection.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 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.
No sensitive questions are involved.
12. Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.
Annual Recordkeeping Burden and Cost
The estimated number of respondents annually is 18,000, with each respondent responding 3.5 times. The total annual responses are estimated to be 63,000, with each response requiring 5 hours for a total of 315,000 hours.
The estimated annualized cost to the public is $3,415,500 (Using the above reference, 18,000 total annual responses at 5 hours per request = 90,000 hours x $37.95 per hour based on a GS-11, Step 6 salary (SALARY TABLE 2010-DCB) of $72,876 = $3,415,500.
Total Annual Requests: 18,000
Estimated hours/response: 5
Estimated total burden/hours: 90,000
Average Cost/hour: $37.95
Total cost to Public: $3,415,500
13. Provide an estimate for 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 Items 12 and 14.)
The
cost estimate should be split into two components: (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. The estimates should take into account costs
associated with generating, maintaining, and disclosing or providing
the information. Include descriptions of methods used to estimate
major cost factors including system and technology acquisition,
expected useful life of capital equipment, the discount rate(s), and
the time period over which costs will be incurred. Capital and
start-up costs include, among other items, preparations for
collecting information such as purchasing computers and software;
monitoring, sampling, drilling, and testing equipment, and record
storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995; (2) to achieve regulatory compliance with requirements not associated with the information collection; (3) for reasons other than to provide information or keep records for the Government or (4) as part of customary and usual business or private practices.
Given the nature of the requests, reliable cost estimates are not available. Costs are captured in burden hours as shown in paragraph 12.
14. Provide estimates of annualized costs to the Federal Government. Also, provide a description of the method used to estimate cost, which should include qualification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
Annual Reporting Burden and Cost
Estimate of the burden hours to the Federal Government is 315,000 hours. Reviewing and processing each response should take approximately 5 hours; the total number of responses is estimated to be 63,000 each year. 63,000 responses x 5 hours = 315,000 hours.
Based on the 315,000 burden hours to the Federal Government, using the annual salary of a GS-11, Step 6 salary of $72,876, $37.95 per hour x 315,000 hours = $11,954,250.
Reviewing Time: 5
Responses/year: 63,000
Review time/year: 315,000
Average Wages/hr. $37.95
Total Government Cost: $11,954,250
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14.
There are no program changes and adjustments because this is a request for a new information collection.
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.
Results will not be tabulated or published. Data collection will be used for internal administration of contracts.
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.
GSA is not seeking such approval for this collection.
18. Explain each exception to the certification statement identified in the
“Certification for Paperwork Reduction Act Submissions”.
None.
B. Collections of Information Employing Statistical Methods
Statistical methods are not used in this information collection.
JUSTIFICATION_3090-00xx.doc
Blankenship/cd
| File Type | application/msword |
| File Title | JUSTIFICATION |
| Author | STEPHANIEAMORRIS |
| Last Modified By | cherriapday |
| File Modified | 2010-03-03 |
| File Created | 2010-03-01 |