Challenges and Competitions Supporting Statement Part A - Final

Supporting Statement – Part A
For

Challenge and Competition Solicitations

The Office of the Secretary, Department Commerce (DOCS) requests that the Office of Management and Budget (OMB) approve a request for a generic approval of the information collected for challenge and competition solicitations. The request is being sought to implement the use of challenges and prize competitions solicitations, and Challenge competitions as a means to promote innovative solutions to the problems and needs confronting DOC. The approval would enable DOC to collect specific information necessary to evaluate solutions provided by individuals and/or organizations in response to requests by the Federal government.

Strategies are being adopted across DOC to promote the use of challenges and prize competitions as a means to engage a range of communities to develop innovative ideas that address mission-critical issues. The DOC will use an information technology platform known as “challenge.gov” developed by the General Services Administration in many cases. Challenge.gov provides a free, central location for the posting of challenges to the public and serves as a platform for solution providers to submit information about themselves and the information about their solution. In the future, solicitations of interest for challenges and prize competitions will may make use a variety of platforms for engaging solution providers.

This request addresses inclusion of structured information that will uniformly be requested of many challenges to be conducted by DOC.

1. Justification

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

On January 21, 2009, the President issued a memorandum calling for the establishment of “a system of transparency, public participation, and collaboration.” The memorandum required an Open Government Directive to be issued by the Director of the Office of Management and Budget (OMB), instructing “executive departments and agencies to take specific actions implementing the principles set forth in this memorandum.” Among the means to engage in Open Government activities advocated was the use of challenges and competitions mechanisms that would engage the public in new ways to participate in government activities.

With regard to specific initiatives on conducting prizes and challenges, OMB issued Memorandum 10-11 in March 2010 entitled “Guidance on the Use of Challenges and Prizes to Promote Open Government.” http://www.whitehouse.gov/sites/default/files/omb/assets/memoranda_2010/m10-11.pdf

Through this policy, agencies were encouraged to develop challenges and competitions that provide opportunities to engage new communities to help with problem-solving consistent with the approach of a more open government. In 2011, agencies were given additional authorities that enable them to use prize authority for challenges and competitions. The statutory authority for challenges and prize competitions is Section 105(a) of the America Competes Act, adds Section 24 to the Stevenson-Wydler Technology Innovation Act of 1980 (15 U.S.C. 3701 et seq.) that addresses provisions for challenges and competitions with prizes conducted by Federal agencies.  Although the Act does not specify requirements under PRA, however, reference is made to the use of a common platform for managing Federal challenges and competitions.

Challenges and competitions enable DOC to tap into the expertise and creativity of the public in new ways as well as extend awareness of the DOC programs and priorities. Within DOC, several bureaus have developed and implemented policies regarding the use of challenges and prize competitions. For example, the National Institute of Standards and Technology (NIST) has sponsored challenges and prize competitions in a wide variety of areas such as new materials with improved impact resistance, mobile apps to improve use of scientific reference data, and to solicit new ideas on a wide array of topics important to NIST’s mission. DOC’s goal is to engage a broader number of stakeholders who are inspired to work on some of our most pressing issues, thus supporting a new ecosystem of scientists, developers, and entrepreneurs who can continue to innovate in support of the DOC’s mission to create the conditions for economic growth and opportunity.

The generic clearance is necessary for DOC to launch several challenges or prize competitions annually in a short turnaround. The information collected for these challenges and competitions will generally include first name, last name, email, city, state and when applicable other demographic information such as date of birth. This data is necessary to identify contestants as eligible participants, and to collect contact information to follow up if their work is selected as a finalists and/or subsequent winner. DOC may also ask for additional information pertaining to the solver’s engagement in the challenge, such as how they learned about the challenge, their technical background, ethnicity, age range, what they currently understand about the DOC/bureau hosting the challenge, etc. This information will enable the DOC to better understand the diversity of entrants, the effect of the challenge on increasing public awareness of the DOC, and generally to enable the DOC to improve their outreach strategies to ensure a diverse and broad innovator constituency is fostered through the use of challenges and prize competitions.

Upon entry or during the judging process, applicants under the age of 18 may be asked to confirm parental consent, in a format outlined in the specific criteria of each contest. To protect online privacy of minors, birthdate may be required as needed by the website host to ensure the challenge platform meets the requirements of the Children’s Online Privacy Protection Act of 1998, 15 U.S.C. 6501-6505. For certain challenges we may also need to collect data such as types of data sets used in the solution, types of software tools used in the solution, and information regarding uses of proprietary software (i.e., licenses or use agreements). Eligibility to win a cash prize will be outlined in the specific criteria of each contest and will only apply to U.S. citizens, permanent residents or private entities incorporated in and maintaining a primary place of business in the U.S. To administer the cash prize, we will need to collect additional relevant payment information such as Social Security Number and/or Taxpayer ID, and information regarding the winners’ financial institutions in order to comply with financial accounting processes.

2. Explain how, by whom, how frequently, and for what purpose the information is to be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, then explain how the collection complies with all applicable Information Quality Guidelines.

Information obtained from the solutions provider will be used by the program managers (challenge manager), other agency officials (such as general counsel representatives) and in some cases the technical reviewers acting on behalf of the program manager (challenge manager). The information collected will be for the following purposes: verify data sources, understand whether the solution provider has met the technical requirements for the challenge, has completed the challenge to the specifications of the challenge parameters, to assist in technical review and judging of the solutions that are provided. In addition, the information can be used to determine if valid methodology, appropriate approvals for use of data sources, and other resources used in the solution development are valid.

To obtain approval for a collection under this generic, DOC will provide a copy of the requirements and registration to be published on a publically accessible Government website as stipulated in 15 U.S.C. 3719 (f), a standardized form that includes an estimate of the burden, and the instrument (e.g. a questionnaire) to OMB.

As described in the “Guidance for Federal Register Notice Required Under the America COMPETES Act of 2010 for the Requirements and Registration of Challenges and Competitions”, the challenge program manager will be required to publish a Federal Register notice announcing each challenge. In the notice, the challenge program manager will be required to provide answers to the following questions:

1) What action is being taken?

2) Why is this action necessary?

3) What is the objective of the challenge?

4) What is the intended effect of this action?

Additionally, the challenge program manager will be required to fully describe the subject of the challenge, the eligibility requirements, the amount of the prize, and the method of payment.

It is this notice that will be provided to OMB (prior to publication) with information about the burden, a brief description of the questions or other information that will be requested from the entrant, and any screenshots that contain the information. [Note: The submission will focus on the information collected as part of the challenge entry that is subject to the Paperwork Reduction Act.]

The Agency has established a managing entity to ensure compliance with the terms of this clearance.

We are requesting that OMB allow for automatic approval, unless OMB identifies an issue, within 5 business days after submission.

3. Describe whether, and to what extent, the collection of information involves

the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, (e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection). Also describe any consideration of using information technology to reduce burden.

Whenever possible, improved information technologies will be used to reduce burdens on participants. Challenge.gov, along with other challenge and prize platforms, which may be used, employ web-based technology to support the challenge competitions. This minimizes the time and burden to solution providers and reviewers.

4. Efforts to Identify Duplication and Use of Similar Information

As these are challenges that request information to help identify individual submissions, there are no previously existing methods to obtain the same information as requested.

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

The information collected here supports challenges and competitions that represent substantial opportunity for small businesses. Many facets of the challenges are aimed at entrepreneurs and small businesses; therefore, the challenge.gov or related interactive technology platform is an easily accessible resource for small businesses to compete for awards.

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.

If responses to these types of requests are not collected, DOC may not be able to make improvements o mission-critical issues or topics. Each challenge or competition cannot be completed without a collection of data and each will require a one-time collection.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.

The data collection conducted under this generic clearance will be conducted in accordance with the guidelines in 5 CFR 1320.5.

• Requiring respondents to report information to the agency more often than quarterly;
  
  The participants will be required to submit their information one time only in order to participate in the corresponding challenge or competition.

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
  
  The respondents will be required to respond as directed in the respective challenge or competition guidelines.

• Requiring respondents to submit more than an original and two copies of any document;
  
  

Respondent will only submit one original copy for a given challenge or

competition.

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

No records will be retained.

• In connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

N/A

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

N/A

• Includes 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
  
  

N/A

• Requiring respondents to 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.
  
  

This collection is consistent with 5 CFR 1320.5.

8. Federal Register Notice/Outside Consultation

The 60-day Federal Register notice was published on January 25, 2017, 82 FR 8398. There were no comments received. In addition, DOC remains in close contact with the challenge community to obtain their views on the submission of information to the challenge.gov platform.

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

For many challenges, prizes in the forms of cash or material goods are offered as a means for rewarding the best solution(s). The payment or gift is only made upon competing and being selected as a winner in the challenge. There will be no direct inducement to participate in a challenge. Only those who submit and win a challenge competition will receive the award.

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

Individuals will be assured of confidentiality to the extent permitted by law, including the Freedom of Information Act (FOIA).

Participation in a challenge competition is entirely voluntary. The challenge.gov website provides clear parameters for the respondents regarding the type of information that is requested to participate in a challenge. The information collected about a submission is used only for the purposes of conducting the challenge competition or to inform the challenge program of the diversity of participants for use in assessing and improving the success of future challenges, and is not used for any other purpose.

We will not provide an assurance of confidentiality.

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.

No sensitive information is requested

12. Provide an estimate in hours of the burden of the collection of information.

The Department anticipates receiving approximately 200 respondents for each challenge or prize competition under this generic clearance. Each participant will create an entry (e.g., video, essay). The time it takes to create an entry will vary, but the Department estimates that these challenges would, on average, take 5 - 30 hours (or minutes) to create, depending on the complexity of the problem and proposed solution.

1. Estimated Annualized Burden Table.

Type of Respondent	Number of Respondents	Number of Responses per Respondent	Average Burden (in hours) per Response	Total Burden Hours
Individuals or Households	500	1	10/60	83.3
Organizations	500	1	10/60	83.3
Businesses	500	1	10/60	83.3
State, territory, tribal or local governments	30	1	10/60	5
Federal Government	30	1	10/60	5
Total	1560			260

2. Estimated Annualized Burden Costs

Type of Respondent	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
Individuals or Households	83.3	$5.25	$437.33
Organizations	83.3	$5.25	$437.33
Businesses	83.3	$5.25	$437.33
State, territory, tribal or local governments	5	$5.25	$26.25
Total			$900.91

13. Provide an estimate of the total annual cost burden to the respondent or record keepers resulting from the collection (excluding the value of the burden hours in Questions 12 above).

There are no additional costs.

14. Capital Costs (Maintenance of Capital Costs)

DOC incurs no additional charges when using the challenge.gov platform, which is operated free of charge by the General Services Administration. In some cases, DOC may enter into a grant, contract, cooperative agreement, or other agreement with a private sector for-profit or nonprofit entity or State or local government agency to administer the prize competition, which will have associated costs negotiated on an individual basis.

15. Costs to Federal Government

We estimate the burden to the government for the management of the information related to the additional requests for the challenge.gov site will result in approximately 1/10th of an FTE used continuously during the 3-year period. The time required will be to associate the data collection with the submission to the challenges that are received. Estimated costs are $10,150 per year.

16. Program Change or Adjustment

This is a new data collection.

17. Publication and Tabulation of Data

The information collected through this request is for internal DOC review and will not be published.

18. Expiration Date

The approval number and expiration date will be placed at the front of the challenge.gov site or other publically accessible government website or related technology sites that host challenge competitions pending GSA approval or will be included in each of the DOC challenges that request this information.

19. Certification Statement

No exceptions are taken to the certification statement.

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