Supporting Statement

OMB Control Number 0704-0225

Supporting Statement

TAB A
A.

Justification

1. This is a request for extension of the expiration date of
the information collection requirement currently approved under
OMB Control Number 0704-0225 for Defense FAR Supplement Part
204, Administrative Matters, and related clauses at 252.204.
The approval for 0704-0225 expires on October 31, 2010. We have
updated the estimates for the number of respondents and the
number of actions to reflect the most current data available
from Federal Procurement Data System (FPDS). As a result of
using the latest available fiscal year 2009 data, the estimated
public burden has increased by 2,317 hours and the estimated
annual cost to the public has increase by $84,319 from the 2007
estimate.
2. This information collection requirement pertains to two
types of information that an offeror must submit to the
Department of Defense (DoD).
a. DFARS 204.404-70(a) (see TAB B) prescribes the use of
the clause at DFARS 252.204-7000, Disclosure of Information,
(see TAB C) when the contractor will have access to or generate
unclassified information that may be sensitive and inappropriate
for release to the public. This clause requires contractors to
obtain contracting officer approval to release unclassified
information outside of the contractor's organization unless the
information is already in the public domain.
In requesting such
approval, the contractor must identify the specific information
that will be released, the medium that will be used, and the
purpose of the release. The Government reviews the information
provided by the contractor to determine if it is sensitive or
otherwise inappropriate for release for the stated purpose. We
normally receive these requests only on research and development
contracts or large dollar systems or operations contracts.
b. DFARS 204.7207 (see TAB D) prescribes the use of the
solicitation provision at 252.204-7001, Commercial and
Government Entity (CAGE) Code Reporting, (see TAB E) when CAGE
codes for prospective offerors are not available to contracting
officers. The provision requires offerors to submit as part of
their offer either a previously assigned CAGE code, or ask the
contracting officer to request a code from the Defense Logistics
Information Service.
In the latter case, the Government will

obtain a CAGE code for the offeror, if it is selected for award,
using the procedures at DFARS 204.7204. The Government uses the
CAGE codes provided by contractors in automated acquisition
systems to identify discrete entities that have been awarded
contracts. The codes support efficient data exchange among
automated systems for contract award, contract administration,
and contract payment.
3. We use improved information technology to the maximum extent
practicable. Where both the DoD and the contractor are capable
of electronic interchange, these information collection
requirements may be submitted electronically. However, we
anticipate that the burden will be the same whether submissions
are made electronically or using a paper format, because
identical underlying analysis must be performed in either case,
as we assume that offerors or bidders will use automated word
processing to prepare paper submissions. Thus, the difference
between the two methods (transmitting information to the
Government electronically or using a paper format) would be in
the transmission time (mailroom, postage, and other related
costs) .
4. The reporting requirements placed on contractors apply
solely to DoD and are not duplicative of any other language in
the FAR.
5. The collections associated with small businesses are the
minimums consistent with prudent businesses practices.
6. DoD specialists who are most knowledgeable of the
requirements and the need for the information reviewed the
information collection frequency.
The consequence of not
collecting this data or collecting less frequently is that it
would impede the effective and efficient management of DoD
public affairs and automated systems operations.
7. There are no special circumstances that require the
collection of information to be conducted in any manner listed
in 5 CFR 1320.5 (d) (2).
8. We solicited public comments in the Federal Register at 75
FR 45104 on August 2, 2010. We received no comments in
response. This information collection is consistent with the
guidelines in 5 CFR 1320.5(d). Public comments will be
solicited in the Federal Register as required by 5 CFR
1320.8(d).

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9.

No payment or gift will be provided to respondents.

10.
The information collected will be disclosed only to the
extent consistent with prudent business practice, current
regulations, and statutory requirements. No assurance of
confidentiality is provided to respondents.
11.

No sensitive questions are involved.

12. Estimated cost to the public.
We used information
generated from FPDS (using fiscal year 2009 data, the latest
full year of data available) and estimates of processing times
from contracting professionals familiar with processing requests
for release of unclassified information and obtaining CAGE codes
from offerors to estimate costs. Fiscal year 2009 data shows a
decrease in the number of prime contract awards and thus,
respondents. However, there is an overall increase in the
estimate of annual public burden. We estimate the total burden
as follows-­

a.

b.

c.

DFARS 252.204-7000:
Number of responses 1
Avg. hours per response
Estimated hours
Cost per hour 2
Total annual public burden
DFARS 252.204-7001:
Number of responses 3
Avg. hours per response
Estimated hours
Cost per hour 4
Total annual public cost

Totals:
Total number of responses:
Total estimated hours:
Average burden per response:

3,087

x

3

9,261
x 30.00
$277,830

7,664
x .25

1,916
x 36.00
$ 68,976

10,751
11,177
1.04

The total estimated cost to the public:

$346,806

Notes:
1. We estimate that about 10 percent of the 30,872
contracts for over $25,000 awarded each year (assuming a flat
trend from the fiscal year 2009 data) will involve a request to
release unclassified information.
These contracts fall mainly

I

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t

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I

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in the R&D and major weapons system categories.
2. Based on 2010 GS-9, step 5 of $22.57} times an overhead
of 32.85 percent, rounded to the nearest dollar ($29.98 rounded
to $30 per hour).
3.
We estimate that about 7,664 contracts issued each year
will require issuance of a new CAGE code.
The cost associated
with submitting a previously assigned code is negligible.
4. Based on 2010 GS-ll, step 5 salary of $27.31 per hour,
times a 32.85 percent burden ($36.28 rounded to $36 per hour).
All cost estimates are rounded to the nearest dollar. Wage
rates used reflect the general schedule ranges published by the
Office of Personnel Management on its Web site and do not
include locality pay adjustments.
We do not estimate any annual cost burdens other than the
burdens we describe in items 12 and 14.
13.

Estimated cost to the Government. We used information
14.
generated from FPDS (using fiscal year 2009 data, the latest
full year of data available) and estimates of processing times
from contracting professionals familiar with processing requests
for release of unclassified information and obtaining CAGE codes
from offerors to estimate costs. Fiscal year 2009 data shows a
decrease in the number of prime contract awards and thus,
respondents. However, there is an overall increase in the
estimate of cost to the Government. We estimate the total cost
as follows-­
a.

DFARS 252.204-7000:
Number of responses l
Avg. hours per response
Estimated Hours
Cost per hour 2
Total annual Government cost

b.

3,087
x
2
6,174
x $30.00
$185,220

DFARS 252.204-7001
Number of responses 3
Avg. hours per response
Estimated Hours
Cost per hour 4
Total annual Government cost

7,664
1

7,664
$36.00
$275,904

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Total estimated annual cost to the Government:

$461,124

Notes:
1.
We estimate that about 10 percent of the 30,872
contracts for over $25,000 awarded each year (assuming a flat
trend from the fiscal year 2009 data) will involve a request to
release unclassified information.
These contracts fall mainly
in the R&D and major weapons system categories.
2. Based on 2010 GS-9, step 5 of $22.57} times an overhead
of 32.85 percent, rounded to the nearest dollar ($29.98 rounded
to $30 per hour).
3.
We estimate that about 7,664 contracts issued each year
will require issuance of a new CAGE code.
The cost associated
with submitting a previously assigned code is negligible.
4. Based on 2010 GS-II, step 5 salary of $27.31 per hour,
times a 32.85 percent burden ($36.28 rounded to $36 per hour).
All cost estimates are rounded to the nearest dollar. Wage
rates used reflect the general schedule rates published by the
Office of Personnel Management on its Web site and do not
include locality pay adjustments.
15. Use of fiscal year 2009 historical data (the last full year
of data available in FPDS at the time of this report) to update
the fiscal year 2007 data used in our previous submission to
compute public burden has resulted in a total estimated public
burden of 11,177 hours. The total estimated annual cost to the
public has increased by $84,319 and the estimated annual costs
to the Government have increased by $213,190. The increase in
the estimated public burden and the increase in the Government's
burden is due to an increase in the number of responses to DFARS
clause 252.204-7000 and does not reflect any program changes.
16. We will not publish the results of this information
collection.
17. We do not seek approval not to display the expiration date
for OMB approval of the information collection.
B.

Collections of Information Employing Statistical Methods.
We will not tabulate results or employ statistical methods.

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