FINAL - PRA Supporting Statement DS-7000 12-8-2016

SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSION

OMB No. 1405-0147

Recording, Reporting and Data Collection Requirements – Student and Exchange Visitor Information System (SEVIS)

Form DS-7000

A. JUSTIFICATION

1. The Bureau of Educational and Cultural Affairs (ECA) of the U.S. Department of State administers the Exchange Visitor Program (J-Visa) under the provisions of the Mutual Educational and Cultural Exchange Act of 1961 (MECEA), also known as the Fulbright-Hays Act, as amended (Public Law 87-256. 22 U.S.C. 2451, et seq.). This program enables U.S. Government agencies and public and private organizations to conduct a variety of educational and cultural exchange activities.

This collection of information required under 22 CFR Part 62, utilizes the Student and Exchange Visitor Information System (SEVIS) (DS-7000), as well as two other forms: DS-3036 - Exchange Visitor Program Application and DS-3037 - Update of Information on Exchange Visitor Program Sponsor.

The Exchange Visitor Program Application and the Update of Information on Exchange Visitor Program Sponsor provide a means for interested organizations to apply for designation by the Department of State to become a sponsor, for designated sponsors to keep the Department abreast of changes in their program, and to request DS-2019 forms and brochures. Without these forms and logs and the information they provide, the activities conducted under the Exchange Visitor Program could not continue. ECA is not requesting any changes to these collections.

Requested changes are only to Form DS-7000, which is a list summarizing Paperwork Reduction Act hour burdens on respondents that are noted in various provisions of 22 CFR 62. Current changes requested to Form DS-7000 apply only to hour burdens associated with 22 CFR 62.32 (Summer Work Travel), so that these hour burdens may be tracked per subpart of the regulations in spreadsheet format.

2. The DS-7000 is a catalogue of all of the information/data collections that occur as part of 22 CFR 62 Subparts A and B and their related numbers of responses and hour/cost burden accounting per applicable provision. This information collection revision applies only to those information/data collections in section 62.32 – Summer Work Travel. The current proposed changes apply to the DS-7000 only.

The Exchange Visitor Program Application (DS-3036) is used by United States Government agencies and public and private organizations to apply to the Department of State to become designated to administer an exchange visitor program. Approximately 60 applications are received each year. The information provided is used to determine whether the interested organization meets the requirements to receive designation as a Sponsor and, if approved, to create a database entry for tracking purposes, The Update of Information on Exchange Visitor Program Sponsor (DS-3037) is used by the approximately 1,415 designated sponsors to notify the Department of changes in the address, telephone numbers, fax numbers, etc., of the organization, and to request a change of the Responsible Officer or Alternate Responsible Officers.

3. The data collections listed on Form DS-7000 are handled partly electronically and party in paper format. Those for which amendment is sought here are handled through paper formats. The Department incorporated Forms DS-3036 and DS-3037 electronically into the Student and Exchange Visitor Information System (SEVIS). SEVIS is administered by the Department of Homeland Security to meet the legislative mandate established by Subtitle D, Section 641 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (P.L. 104-208).

4. No. This collection is not duplicative of any other collection.

5. This collection does not have a significant economic impact on small business entities.

6. If the collection of information is not conducted, the Department could not administer the Exchange Visitor Program. We would not be able to track regulatory respondent numbers, costs, and hour burdens associated with 22 CFR 62 without DS-7000, and without DS-3036 and DS 3037, we would be unable to designate new sponsors to administer exchange visitor programs and provide the Department with essential information to maintain the Exchange Visitor Program database on existing designated sponsors.

7. There are no special circumstances for this collection.

8. The Department will publish a 60-day notice in the Federal Register along with proposed amendments to 22 CFR 62.32 in order to solicit public comments.

9. Respondents are not provided with any gifts or payments.

10. No promises of confidentiality are made.

11. There are no questions of a sensitive nature included in the data required.

12. Form DS-7000 includes all of the Department’s record keeping, reporting, and data collection information required under 22 CFR Part 62 and the many functions performed by program sponsors (either through SEVIS or non-SEVIS-related). A detailed breakdown of the respondents, number of responses, and burden figures are attached in table format. The attached spreadsheet (Attachment 1) contains a detailed burden accounting of data collection and reporting activities conducted through SEVIS; these SEVIS-collected data amounts have been reduced because twice yearly placement reports from sponsors are no longer required. This reduced the number of responses from 21,083 to 20,977 for the Exchange Visitor Program, a reduction of 106 responses, reduced the total number of burden hours from 9,320 to 9,144, a reduction of 176 hours, and total cost burden from $2,856,710 to $2,855,830, a cost burden savings of $880.

Please see the attached spreadsheet (Attachment 2) for all current Non-SEVIS record keeping and data collection activities. These computations would change under the amended Summer Work Travel rule as noted in the current proposed entries under 62.32. Changes to the Summer Work Travel rule are registered on the non-SEVIS spreadsheet only, as the placement reporting requirements on the SEVIS spreadsheet have been eliminated.

The number of responses to the Form DS-3036, which has not changed in this amended information collection, is approximately 60 applications annually. The respondents complete the form if they wish to be considered for designation as an Exchange Visitor Program sponsor. This form takes approximately 1 hour to complete and an additional 7 hours to gather supporting application documentation. The annual burden for this form is estimated to be 480 hours. The average sum for hourly civilian earnings is $22.50, therefore a total wage cost of $15,120.00 ($22.50 x the 1.4 multiplier based on FTE wage scales x 480 hours).

Form DS-3037, which also has not changed in this amended information collection, is used by designated sponsors to notify the Department of any changes in contact information for the sponsor, to request brochures, and to request a change in Responsible or Alternate Responsible officers on their exchange program. This form takes approximately 20 minutes to complete. It is estimated that approximately 1,415 respondents will submit a minimum of two requests annually for a total 2,830 submissions (responses). The annual burden for this form is approximately 943 hours. The average mean for hourly civilian earnings is $22.50, therefore a total wage cost of $29,704.50 ($22.50 x 1.4 x 943 hours). The total hour cost burden for this collection is $15,120 (Form DS-3036) + 20,704.50 (Form DS-3037) = $44,824 (rounded).

Form DS-7000, the SEVIS Electronic Application, includes all the Department’s record keeping, reporting and data collection information required under 22 CFR Part 62 and the many functions performed through SEVIS by program sponsors. A detailed breakdown of the respondents, number of responses, and burden figures are attached in table format. Please see the attached spreadsheet (Attachment 1) for a detailed burden accounting of data collection and reporting activities conducted through SEVIS. Please see the attached spreadsheet (Attachment 2) for Non-SEVIS recordkeeping and data collection activities.

Respondents for this collection include designated program sponsors, applicants/potential sponsors, host families, exchange visitors, and schools and universities, yielding an estimated total for the DS-7000 of 190,200 respondents per year and for the Summer Work Travel Program, as follows:

Respondent	Estimate
Exchange visitor	90,000
Sponsor	41
Host entities	26,000
Total	116,041

(For the particular section under amendment, respondents would include sponsors/host entities and exchange visitors, as noted on the spreadsheet in Attachment 2).

The annual number of responses for proposed DS-7000 is approximately 1,949,765 (20,977 for the SEVIS and 1,928,788 for the non-SEVIS method of gathering responses). The total aggregate annual hour burden for DS-7000 is estimated to be 2,181,095 hours (9,144 hours for the SEVIS and 2,171,951 hours for the non-SEVIS method of computing hour burden).

Table 1 below summarizes both DS-7000 spreadsheets (Attachments 1 and 2),shows the aggregate burden figures for all requirements under 22 CFR Part 62 for DS-7000; the total annual cost to respondents is estimated to be $31,859,748, which is based on an hourly cost burden.

Table 1:

Component	Respondents	Responses	Annual hour burden	Annual Cost burden
SEVIS	200	20,977	9,144 hours	$2,855,830
Non-SEVIS	190,000	1,928,788	2,171,951	$29,003,918
Totals:	190,200*	1,949,765	2,181,095	$31,859,748

(* There is an overlap of respondents for SEVIS and Non-SEVIS component.)

Table 2: Table 2 below summarizes respondents, responses, hour burden, and cost burden for the DS-7000, the DS-3036 and the DS-3037. The estimate of the total proposed new annual cost burden for sponsors within the DS-7000 for the proposed Summer Work Travel regulation is $9,250,629.

The estimate of annual burden for the Exchange Visitor Program is as follows:

	DS-7000	DS-3036	DS-3037	Total
Respondents	190,200	60	1,415	191.675
Responses	1,949,765	60	2,830	1,952,655
Hour burden	2,181,095	480	943	2,182,518
Cost burden	$31,859,748	$15,120	$44,824	$31,919,692

Table 3: The estimate of the total proposed annual cost burden for sponsors within the DS-7000 for the proposed Summer Work Travel regulation is $9,582,273.

Regulatory provision	Calculation	Total cost burden
62.32(d)(9) – Recruitment transparency	41 responses x 1 hour x $26 weighted wage	$1,066
62.32(e)(1)(2) – Screening for eligibility and selection	90,000 responses .0.5 hours x $26	$1,170,000
62.32(f) – Exchange visitor pre-placement at host entities	90,000 responses x 1 hour x $10	$900,000
62.32(g)(1) – Door-to-door sales	1,325 responses x 0.5 x $5	$3,313
62.32(h) - Exchange visitor host re-placement	2,500 responses x 0.5 hours hour x $10	$12,500
62.32(j) – Sponsor vetting of host entities	26,000 responses x 0.5 hours x $26	$338,000
62.32(l) – Exchange visitor housing	90,000 responses x 1 hour x $10	$900,000
62.32(m) – Form DS-7007	92,500 responses x 1.25 x $26	$3,006,250
6.32(n)- Exchange visitor pre-departure orientation and documentation	90,000 responses x 0.5 hours x $26	$1,170,000
62.32(o) – Cross-Cultural activities	26,000 responses x 24 hours x $26	$6,249,000
62.32(p) - Exchange visitor monitoring and assistance	90,000 responses x 0.5 hours x $10	$450,000
62.32(q)-(t) – Sponsor use and vetting of foreign/domestic third parties	1,900 responses x 2 hour x $26	$98,800
62.32(u) – Reporting requirements	41 responses x 2 hours x $26	$2,132

Table 4: Exchange visitors

Provision	Calculation	Total cost burden
62.32(e)(1)(2) – Applicant provision of required eligibility and screening information	90,000 x 1 x $1	$90,000

13. No costs to respondents.

14. The cost incurred by the Department is the time of staff necessary to review and analyze requests and in maintaining information in office files.

The estimated cost to the Federal Government is approximately $288,645.00. This estimate is based on the number of responses (DS-3036 – 60; DS-3037 – 2,830), the average hourly processing time (DS-3036 - 4 hours; DS-3037 – 20 min.), and the average hourly salary (DS-3036 - GS-13/5 $44.00 x 1.4 = $61.60; DS-3037 – GS-9 $25.00 x 1.4 = $35.00). The wage cost for Form DS-3036 is $14,784.00 (60 respondent times 4 hours equals 240, times $61.60). There is an application fee of $3,982.00 for an organization to complete and file an application for designation as an Exchange Visitor Program sponsor (DS-3036) which results in a total cost of $238,920.00 ($3,982.00 x 60 respondents). The printing costs are $1,200.00 (60 responses x $20). The total cost for Form DS-3036 is $254,904.00 ($14,784 wages + $238,920 +$1,200 printing costs). The wage cost for Form DS-3037 is $33,005 (1415 responses x twice 20 minutes equals 943 x $35.00 = $33,005.00). The printing costs are $735.80 (2830 responses x $0.26). The total cost for Form DS-3037 is $33,741 ($33,741 wages + $736 printing costs). The total wage cost to the government for the collection is $288,645 ($ 254,904 DS-3036 + $33,741 DS-3037). These calculations have not changed from previous submissions.

15. The number of respondents under Form DS-7000 is 190,200. The number of responses for the DS-7000 has increased from 1,558,859 to 1,949,765 due to the addition of provisions for sponsors to provide more transparent program information at the time of recruitment , to account for exchange visitors’ providing information to sponsors to prove their eligibility, requiring the Form DS-7007 summarizing the host placement and any housing provided by the placement, requiring an appendix to the DS-7007 for door-to-door sales placements, and requiring sponsors (and/or their host entities) to provide cultural activities for exchange visitors.

16. The Department will not publish the collected information.

17. The Department will display the OMB expiration date.

18. The Department is not requesting any exceptions to the certification.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS.

This collection does not employ statistical methods.