Renewal 2013. Supporting Statement

SUPPORTING STATEMENT November 2013

2700- 0089: Acquisition Process Reports Required for Contracts with a Value of more than $500,000

A. Justification.

1. Explain the circumstances that make the collection of information necessary.

Identify any legal or administrative requirements that necessitate the collection.

This information, in the form of reports for contracts with a value more than $500,000, is required to monitor contract compliance in support of NASA’s mission and in response to contractual requirements. This ICR addresses other reports which are required by the NASA FAR Supplement.

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

Contractors must furnish information under their contracts that support authorized programs and projects within NASA. Although there may be some similiarity between contracts, each contract is unique and has its own reporting requirements. Some reporting requirements are routine and some reports are required only if and when specific events occur, such as a mishap report in the wake of a safety event. Consequently, this ICR estimates miscellaneous reporting requirements and the corresponding burden on contractors to submit the reports.

The technical program and contract management personnel use this information to effectively manage and administer contracts, measure the contractor’s performance, evaluate contractor management systems, ensure compliance with mandatory public policy provision, evaluate and control costs charged against contracts, detect and minimize conditions conducive to fraud, waste and abuse, and to form a database for general overview reports to the Congressional and Executive Branches. Without this information, NASA would not be able to gain the insight into contractor acitivity required to effectively manage and meet its Agency mission requirments.

These reports/records will be retained in accordance with the NASA Records Retention Schedule 5.1/Procurement Files.

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. Also describe any consideration of using information technology to reduce burden.

NASA encourages the use of computer technology and is participating in Federal efforts to extend the use of information technology to more processes via the Internet. NASA accepts most reports in electronic format via electronic submission.

4. Describe efforts to identify duplication.

NASA procurement procedures are continually reviewed to determine duplication of effort and other inefficiencies. There is no other known report in existence that collects this information.

5. If the collection of information impacts small businesses or other small entities (Item five of form OMB 83-I, the Paperwork Reduction Act Submission form), describe any methods used to minimize burden.

Small businesses and other small entities are impacted to the extent that they are awarded contracts in excess of $500,000. Because the reports are required to support activity under the contract, it is necessary to require the reports of all contractors regardless of size status. All contractors are reimbursed for preparation and submission of reports in accordance with contract terms, thereby minimizing the cost burden to all. Burden is the minimum necessary consistent with prudent business practices.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.

If any restrictions were placed on the collection of information, NASA would not be able to meet its mission requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in certain manners (as listed).

Not applicable.

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 before submission to OMB.

The 60-day Federal Register Notice 13-135 was published on November 27, 2013. Volume 78, No. 229.

http://www.gpo.gov/fdsys/pkg/FR-2013-11-27/pdf/2013-28494.pdf

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

Not applicable.

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

Reports governed by this ICR do not generally contain confidential information, and generally become the property of NASA. Therefore, there is no assurance of confidentially. However, to the extent that reports contain personally identifiable or proprietary information that is subject to the Privacy Act, the information will be protected as required by the Act.

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.

Questions of a sensitive nature as indicated above will not be asked..

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

Number of respondents submitting reports: 501

Average annual reports per respondent: 2

Total annual responses: 1002

Hours per report: 7

TOTAL ANNUAL HOURS: 7014

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

The estimated annual contractor cost is calculated by multiplying the estimated number of hours in submitting reports (7014) by an estimated cost rate of $39.00 per hour (skill level comparable to GS-12 on Federal pay scale), totaling $273,546.00 It should be noted that contractors are reimbursed by the Government for the preparation of reports produced under cost-type contracts and that the contractor has included the cost of reports required under fixed-price contracts in the total price of the contract.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses, and any other expense that would not have been incurred without this collection of information.

The estimated annual cost to NASA for the review of reports under this ICR is $230,460.00. This estimate is calculated by multiplying the number of reports, 1002, by an average 5 hours of Government review time, at an average rate of $46.00 (GS-14 pay scale).

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

While the number of respondents increased, increased use of performance based contracts and commercial contracts has a slight impact on the number of reports required. Additionally, use of information technology for preparation and submission of reports also results in decrease in the amount of time required to provide reports. The overall result is a decrease in the total burden.

16. For collections of information intended for publication, outline plans for tabulation and publication.

Various levels of vendor information will be available to the public via the NAIS on-line system. However, sensitive information is not intended for publication.

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

NASA fully intends to display the PRA statement as approved through the OMB/OIRA Desk Officer assigned to NASA.

18. Explain each exception to the certification statement identified in item 19, “Certification for Paperwork Reduction Act Submissions” of OMB Form 83-1.

Not applicable.

B. Collections of Information Employing Statistical Methods.

Not applicable.

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