AO34 Justification RI 11-22-13

VA Health Professional Scholarship and Visual Impairment and Orientation and Mobility Professional Scholarship Programs
OMB FORM 2900-0793
VA Forms: 10-0491, 10-0491A, C thru L

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

A collection of information is necessary to implement the Department of Veterans Affairs (VA) Visual Impairment and Orientation and Mobility Professionals Scholarship Program and the VA Health Professional Scholarship Program which were authorized under Public Law 111-163 on May 5, 2010. The passage of this legislation allows VA to provide services to the public by awarding scholarships to non-VA employees who will be required to become VA employees in the professions for which they were educated under these programs. These programs will help address VA health care workforce needs. Legal authority for this data collection is also found under 38 U.S.C., Part I, Chapter 5, Section 527 that authorizes the collection of data that will allow measurement and evaluation of the Department of Veterans Affairs Programs, the goal of which is improved health care for veterans.

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

The information required determines the eligibility or suitability of an applicant desiring to receive an award under the provisions of 38 U.S.C. sections 7601 through 7619, and 38 U.S.C. sections 7501 through 7505. The information is needed to apply for the VA Health Professional Scholarship Program or Visual Impairment and Orientation and Mobility Professional Scholarship Program. The VA Health Professional Scholarship Program awards scholarships to students receiving education or training in a direct or indirect healthcare services discipline to assist in providing an adequate supply of such personnel for VA and for the United States. The Visual Impairment and Orientation and Mobility Professional Scholarship Program awards scholarships to students pursuing a program of study leading to a degree in visual impairment or orientation and mobility in order to increase the supply of qualified blind rehabilitation specialists for VA and the Nation.

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.

VA will allow applicants to submit and update application packages online and via facsimile. This method allows VA to receive, validate submission, and electronically transmit applications to technical reviewers before forwarding to selecting officials for approval. VA is diligently working on a fully automated electronic process to expedite processing and reduce burden.

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 VA Health Professional Scholarship Program contained a collection control number 2900-0352, which expired on April 30, 1997. This collection was not renewed because the sunset date for the VA Health Professional Scholarship Program was reached on December 31, 1998. We propose to establish a new collection control number for the revised VA Health Professional Scholarship Program, which was amend in response to section 603 of the 2010 Act, Public Law 111–163, and for the new Visual Impairment and Orientation and Mobility Professional Scholarship Program, which was established by section 302 of the 2010 Act. On August 20, 2013, 78 FR 51067, AO34 was published as final in the Federal Register. This final rule implements Public Law 111-163.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Since these are applications for individual benefits, no small businesses or other small entities are impacted by the information collection.

6. Describe the consequences 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.

VA would not be responsive to the needs of the student and to the legal requirement to release of information if information were collected less frequently.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; 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 and require the use of a statistical data classification that has not been reviewed and approved by OMB.

There are no such special circumstances.

8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’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 sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The notice of Proposed Information Collection Activity was published in the Federal Register on Tuesday, August 20, 2013 (Volume 78, Number 161, Pages 51067-51073). We received no comments in response to this notice.

b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.

Outside consultation is conducted with the public through the 60- and 30-day Federal Register notices.

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

No payment or gift is provided to respondents.

10. Describe any assurance of privacy to the extent permitted by law provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Information on these forms will become part of a system of records which complies with the Privacy Act of 1974 as set forth in the Compilation of Privacy Act Issuances via online GPO access at http://www.gpoaccess.gov/privacyact/index.html. The original System of Records (73VA14) for the Health Professional Scholarship Program was issued on 10/6/1982. It was updated on 4 other occasions, the last one being on 11/27/2009. VA is actively engaged in updating and amending the Health Professional Scholarship Program System of Records. The amended version (73VA10A2A) will include the Visual Impairment and Orientation and Mobility Professional Scholarship Program.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include 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.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

a. The number of respondents, frequency of responses, annual hour burden, and explanation for each form is reported as follows:

Category of Respondent	No. of Respondents	Participation Time	Burden Hours
VIOMPSP
Individuals (Applicants)	1,500	180 minutes	5,575
Individuals (of Applicants selected to receive scholarship award)	30	95 minutes	43
Total			5,618
HPSP
Individuals (Applicants)	5,000	180 minutes	18,583
Individuals (of Applicants selected to receive scholarship award)	100	95 minutes	141
Total			18,724
GRAND TOTAL for VIOMPSP and HPSP			24,342

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB 83-I.

ESTIMATE OF THE HOUR BURDEN FOR THE COLLECTION OF INFORMATION

APPLICANTS

VA Forms:	# of respondents	x # of responses	Equals	x # of minutes	Equals (minutes)	÷ by 60 =	Number of Hours
10-0491g- Application	1,500	1	1,500	60	90,000		1,500
10-0491- Academic Verification	1,500	1	1,500	60	90,000		1,500
10-0491e- Evaluations & Recommendations (2)	1,500	2	3,000	50	150,000		2,500
10-0491a- Addendum to Application	450 (30%)	1	450	10	4,500		75
TOTAL							5,575

APPLICANTS SELECTED TO RECEIVE A SCHOLARSHIP

VA Forms:	# of respondents	x # of responses	Equals	x # of minutes	Equals (minutes)	÷ by 60 =	Number of Hours
10-0491L- Agreement for the VIOMPSP	30	1	30	15	450		8
10-0491k- VA Scholarship Offer Response	30	1	30	10	300		5
10-0491i- Notice of Change and/or Annual Academic Status Report	30	1	30	20	600		10
10-0491h- Notice of Approaching Graduation	30	1	30	10	300		5
10-0491d- Education Program Completion Notice/ Service Obligation Placement	30	1	30	20	600		10
10-0491j- Request for Deferment for Advanced Education	6	1	6	10	60		1
10-0491c- Annual VA Employment/ Deferment Verification	30	1	24	10	240		4
TOTAL							43
GRAND TOTAL for VIOMPSP							5,618

HEALTH PROFESSIONAL SCHOLARSHIP PROGRAM (HPSP)

APPLICANTS

VA Forms	# of respondents	x # of responses	Equals	x # of minutes	Equals (minutes)	÷ by 60 =	Number of Hours
10-0491g- Application	5,000	1	5,000	60	300,000		5,000
10-0491- Academic Verification	5,000	1	5,000	60	300,000		5,000
10-0491e- Evaluations & Recommendations (2)	5,000	2	10,000	50	500,000		8,333
10-0491a- Addendum to Application	1500 (30%)	1	1500	10	15,000		250
TOTAL							18,583

APPLICANTS SELECTED TO RECEIVE A SCHOLARSHIP

VA Forms:	# of respondents	x # of responses	Equals	x # of minutes	Equals (minutes)	÷ by 60 =	Number of Hours
10-0491f- Agreement for the HPSP	100	1	100	15	1,500		25
10-0491k- VA Scholarship Offer Response	100	1	100	10	1,000		17
10-0491i- Notice of Change and/or Annual Academic Status Report	100	1	100	20	2,000		33
10-0491h- Notice of Approaching Graduation	100	1	100	10	1,000		17
10-0491d- Education Program Completion Notice/ Service Obligation Placement	100	1	100	20	2,000		33
10-0491j- Request for Deferment for Advanced Education	20	1	20	10	200		3
10-0491c- Annual VA Employment/ Deferment Verification	80	1	80	10	800		13
TOTAL							141
GRAND TOTAL for HPSP							18,724
GRAND TOTAL for BOTH VIOMPSP and HPSP							24,342

Note: The estimated 5,000 respondents for HPSP and 1,500 respondents for VIOMPSP include the 130 applicants who will be selected to receive awards.

c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. 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 14.

VA does not require any additional recordkeeping. The cost to the respondents for completing these forms is $559,866 ($23 per hour x no. of burden hours).

13. Provide an estimate of 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).

Cost estimates are not expected to vary widely. The only cost is that for the time of the respondent.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

VIOMPSP

The estimated annual cost to the Federal government, is $827,000 including:

• $265,000 for salaries and fringe benefit multiplier of 27% for 3 new full-time employees (one GS-13/5 Program Manager, one GS-11/5 Program Analyst, and one GS-7/5 Program Assistant),

• $450,000 for 30 scholarship awards at up to $15,000 each, and

• $112,000 for operating costs for leased space, furniture, and computers. Information technology costs including an IT appropriation requirement are for expanding and support of the Education Systems Database to include the new scholarship program.

HPSP

The estimated annual cost to the Federal government, is $4,084,000 including:

• $480,000 for salaries and fringe benefit multiplier of 27% for 6 new full-time employees (one Nurse IV, one GS-13/5 Management Analyst, one GS-13/5 Placement Coordinator, one GS-12/5 Budget Analyst, one GS-8/5 Program Support Assistant, and one GS-5/5 Program Support Assistant),

• $3,500,000 for 100 scholarship awards at up to $35,000 each, and

• $104,000 for operating costs for leased space, furniture, and computers. Information technology costs including an IT appropriation requirement are for expanding and the support of the Education Systems Database to include the new scholarship program.

15. Explain the reason for any burden hour changes or adjustments reported in items 13 or 14 of the OMB form 83-1.

This is a new collection and all burden hours are considered a program increase.

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.

VA does not intend to publish this data.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

VA seeks to minimize the cost to itself of collecting, processing and using the information by not displaying the expiration date. VA seeks an exemption that waives the displaying of the expiration date on this VA Form. The VA Form may be reproduced by the respondents and VA field facilities from the Internet and then stocked. If VA is required to display an expiration date, it would result in unnecessary waste of existing stock of the forms. Inclusion of the expiration date would place an unnecessary burden on the respondent (since they would find it necessary to obtain a newer version, while VA would have accepted the old one).

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

There are no exceptions.

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