USDA Proposal Number Letter

NIFA PROPOSAL REVIEW Supporting Statements2018.doc

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USDA Proposal Number Letter

OMB: 0524-0026

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National Institute of Food and Agriculture

U.S. Department of Agriculture

OMB No. 0524-0041

NIFA Proposal Review Process


SUBJECT: Supporting Statement for Paperwork Reduction Act Submission to Revise a Currently Approved Information Collection for the NIFA Proposal Review Process


A. JUSTIFICATION


1. CIRCUMSTANCES MAKING COLLECTION OF INFORMATION NECESSARY


The United States Department of Agriculture (USDA), National Institute of Food and Agriculture (NIFA) administers competitive, peer-reviewed research, education, and extension programs. The reviews are undertaken to ensure that projects supported by NIFA are of a high-quality and are consistent with the goals and requirements of the funding program. These programs are authorized pursuant to the authorities contained in the National Agricultural Research, Extension, and Teaching Policy Act of 1977, as amended (7 U.S.C. 3101), the Smith-Lever Act, and other legislative authorities.


This information collection is authorized under 7 CFR 3430.10 specifically for the Small Business Innovation Research program, and 7 CFR 3430 which governs competition in the awarding of discretionary grants and cooperative agreements for NIFA. Section 33 of 7 CFR 3430 specifies the criteria that are to be used to select reviewers including their relevant training and experience, the variety of specialization and expertise, their location and organization type, and minority representation. Reviewers are to make written comments, as appropriate, for each application. It also specifies that confidentiality of the reviewers and applicants is maintained, and conflicts of interest evaluated with care to remove any actual or perceived conflicts, and that reviewers provide this assurance through the NIFA Peer Review System (PRS). PRS is a web-based system which allows reviewers and potential reviewers to update personal information, provide assurances for confidentiality, and to complete and submit reviews electronically to NIFA. Electronic reviews are included in the application electronic record maintained at NIFA.


NIFA is updating this already approved collection to leverage these reviewer assurances and implement electronic collection of the Conflict of Interest and Confidentiality form that was previously approved, to increase the integrity of the internal electronic record of the application. This electronic approval will be updated within the PRS system to reviewers in its entirety, and reviewers will indicate acceptance by clicking an Agree or Disagree button on the screen to indicate acceptance of the policy, prior to application review.


NIFA is also requesting that reviewer demographics information, not previously updated through the PRS system, be included as question seven on the Reviewer Questionnaire. Demographics are already collected from applicants, including Project Directors and Co-Project Directors, using forms OMB 4040-001, Research & Related Personal Data and the Research & Related Senior/Key Person Profile (Expanded) of the approved R&R Family. Since many applicants may also be reviewers, NIFA is proposing to leverage information collected from these forms to populate the additional question to be presented to reviewers for update, if applicable. If this information is unavailable for a reviewer from a previous application with NIFA, then it will be a new collection from a new reviewer. This criteria for the NIFA Peer-Review process is specified in 7 CFR 3430.33 and 7 CFR 3403.10, and will include gender, race, and ethnicity to ensure that reviewers represent a broad demographic range. This addition will allow NIFA to standardize and leverage the information in our reviewer database to select reviewers more effectively, and allow for the information to be included in the application’s electronic record. The additional question is added to the previously approved Reviewer Questionnaire submitted as question seven, and would be implemented in a future PRS update.


NIFA receives research, education, and extension grant applications each year, of which approximately a quarter are awarded. The majority of these applications are subjected to a rigorous peer-review involving technical experts (scientists, educators, farmers, engineers, extension specialists) located world-wide. Given the highly technical nature of many of these applications, the quality of the peer-review greatly depends on the appropriate matching of the subject matter of the application with the technical expertise of the potential reviewer. NIFA maintains a database of potential reviewers. Information in the database is used to match applications with the most appropriate (potential) reviewers. Therefore, the accuracy and completeness of the database content is integral to the success of the NIFA peer review process.


If this information is not collected, it would be difficult for a review panel and NIFA staff to determine which projects warrant funding, or identify appropriate qualified reviewers. In addition, Federal grants staff and auditors could not assess the quality or integrity of the review, and the writer of the application would not benefit from any feedback on why the application was funded or not. The additional demographics information of this update would standardize how NIFA leverages and updates the information in our database to increase the integrity of the reviewer database and the reviewer selection process. This also would help increase the integrity of our application electronic records by allowing the information to be included. Current processes record this information in manual Management Reports and paper-based records.

2. HOW, BY WHOM, AND PURPOSE FOR WHICH INFORMATION IS TO BE USED

The NIFA Application Review Process is accomplished through the use of the NIFA Peer Review System (PRS). This web-based system allows reviewers and potential reviewers to update personal information, provide assurances for confidentiality, and complete and submit reviews electronically to NIFA.


Information about potential panel and ad hoc reviewers is collected via an electronic Reviewer Questionnaire. New reviewers are prompted via an e-mail message to complete the questionnaire. The information from the completed questionnaire is loaded into a NIFA reviewer database system. The questionnaire collects basic biographical information including address, contact information, and professional expertise. This update will also enable the inclusion of demographics and conflicts of interest information in the database. If a reviewer’s information is already included in the database, then the questionnaire serves as a request for the potential reviewer to update her/his information. Completing this questionnaire does not commit the respondent to review applications for NIFA.

Information in the database system is used to match applications with the most appropriate (potential) reviewers. The purpose of this information is to obtain current potential reviewer expertise, contact information, willingness to review, and other biographical information including their demographics, conflicts, and location. This in turn ensures that the best possible reviewers are assigned to review applications submitted to NIFA. NIFA program officers can search the expertise information in this database when seeking reviewers for applications. The program officers will not only look for specific technical expertise appropriate to an application, but institutional information in assessing conflict-of-interest, geographic location, organization type, demographics information, and expressed willingness of the potential reviewer to review at that time. Once appropriate reviewers have been selected by NIFA and the reviewer agrees to perform a review, the application and associated materials are then made available to her/him through PRS. With respect to the application, a reviewer must assure s/he: (1) will comply with the NIFA Confidentiality Guidelines and (2) does not have a conflict of interest prior to viewing an application.


Upon completion of a review, the reviewer completes a Reviewer Worksheets in PRS evaluating an application against established criterion, providing comments as necessary. If appropriate, a peer panel is convened to review and discuss proposals and make funding recommendations. Once collected, this information is used by a panel of external reviewers from various institutions to determine which applications are fundable based on a series of specified criteria. The information is utilized by NIFA staff in selecting and awarding applications to provide feedback to the writer of the application, and by auditors in ensuring the integrity of the review.


3. USE OF IMPROVED INFORMATION TECHNOLOGIES


This information collection does employ the use of improved information technologies. Reviewers are able to maintain their profile information and have the option of submitting reviews through the NIFA Peer Review System (PRS). This web based submission tool accommodates the selection of reviewers, the instructions for the review, the assignment of applications to reviewers, and permits reviewers to electronically submit ratings and comments. The system is a critical tool supporting the NIFA review process.


  1. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION.

Reviewers may have to prepare reviews for more than one application, however each application is unique and the effort is not duplicated. Efforts are made to minimize the number of applications any one reviewer is asked to prepare written reviews of. In addition, NIFA has taken steps to minimize the number of duplicate accounts in our peer review system through our data governance initiative. Reviewers will only be prompted to update their information once each year as applicable.


  1. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES.

Most reviewers are from colleges and universities, although some employees of small businesses are asked to review for some programs. The Small Business Innovation Programs however does not allow reviewers from for-profit institutions to participate in the review of applications, which has the benefit of reducing burden on small business entities.

Respondents are individuals and all responses are voluntary. Reviewers can decline any request to serve on review panels or review individual applications outside of a panel. In addition, NIFA uses an electronic system to monitor application assignments to ensure individual reviewers are not over burdened.


Therefore, this collection should have trivial impact on small businesses or entities.


6. CONSEQUENCES IF INFORMATION COLLECTION WERE LESS FREQUENT.

To ensure the highest quality of funded research, NIFA must collect reviews in a timely manner and on an individual application basis. If this information was not collected and documented, the decision to fund a particular application could be questioned.


In addition, because of the rate of change of science and thus scientific expertise, the need to have correct contact information, and the need to update willingness to review (which can be fluid based on events in the potential reviewer’s life and career), respondents must be asked to complete a questionnaire annually.


  1. SPECIAL CIRCUMSTANCES FOR INFORMATION COLLECTION.


There are no special circumstances for this information collection. This collection is consistent with the regulation of 7 CFR 3430 authorizing its use.



Requiring respondents to report information to the agency more often than quarterly:


The agency does not require respondents to report information more often than quarterly.


 Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.


Response is voluntary and respondents have more than 30 days to reply.


 Requiring respondents to submit more than an original and two copies of any document:


Only one response is requested and is collected electronically.


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


Respondents are not required to retain records in response to this request.


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;


This information collection does not include statistical surveys. Analysis of the information provided by reviewers is to ensure compliance with requirements when selecting reviewers, and to monitor the operation of our review and award process to identify and address any inequities based on gender, race, or ethnicity.


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


This information collection does not require the use of statistical data classification that has not been reviewed and approved by OMB.


 That 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;


This information collection does not require 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.


Requiring respondents to submit proprietary trade secret, 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 information collection does not require respondents to submit proprietary trade secret, or other confidential information.


8. FEDERAL REGISTER NOTICE, SUMMARIZATION OF COMMENTS AND CONSULTATION WITH PERSONS OUTSIDE THE AGENCY.


Notice of intent to revise this information collection was published in the Federal Register on Tuesday, July 31, 2018, Vol. 83 No. 147. No comments were received on this notice.


The names and contact information for 3 people surveyed for the burden estimates are below.


Michael Barber

Michael.barber@utah.edu


Arthur Gold

agold@uri.edu


Laura M. McCann

McCannL@missouri.edu



9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS.


Payments or gifts are not given to any respondents for completing the information collection. Participation in this collection is voluntary. However, panelists are compensated with an honorarium for the time they spend in panel.


10. CONFIDENTIALITY PROVIDED TO RESPONDENTS.


Verbatim but anonymous copies of review comments are sent to the principal project director for each application. Subject to NIFA policy and applicable laws, reviewers’ comments and names will be kept confidential to the extent permitted by law. The notice requesting respondents to complete the questionnaire includes a privacy information notice.


Every reviewer assures, in the Peer Review System, prior to preparing a review that they do not have a conflict of interest with a particular application and will maintain its confidentiality.




11. QUESTIONS OF A SENSITIVE NATURE.


This collection proposes that NIFA be permitted to collect/update reviewer demographics information not previously included on the Reviewer Questionnaire through the PRS system. Demographics are already collected from applicants, including Project Directors and Co-Project Directors, using forms OMB 4040-001, the Research & Related Personal Data form and the Research & Related Senior/Key Person Profile (Expanded) form of the approved R&R Family. Since many applicants may also be reviewers, NIFA is proposing to leverage information collected from these forms to add question number seven to the Reviewer Questionnaire presented to reviewers for update each year, if applicable. If this information is not already collected by NIFA for a reviewer, then the reviewer response will serve as the source of the information to enable NIFA to effectively ensure minority representation of reviewers according to the criteria in 7 CFR 3430.


12. ESTIMATE OF BURDEN.

The burden estimates for the three components to the NIFA review process are as follows.


Transaction Name

Estimated # of Respondents

Estimated # of Responses per Respondent

Estimated # of annual responses

Estimated burden in hours per response

Estimated total annual burden in hours

Proposal Review Sheet

18,400

1

1

5

92,000

Reviewer Questionnaire

50,000

1

1

.2 hours or 12 minutes

10,000

Conflict of Interest and Confidentiality Certification Form

2000

1

1

.2 hours or 12 minutes

400

Totals

70,400




102,400


TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS.


Based on an average faculty hourly wage of $39.83, NIFA estimates the total annual cost burden to respondents for the value of their time to participate in the NIFA review process to be $4,078,592.


The hourly wage was derived from the American Association of University Professors 2016-2017 Faculty Salary Report data. The average annual associate level professor salary of $79,654 was used, with an average of 2000 hours worked per year.

13. START-UP COSTS


There are no start-up or capital costs incurred by respondents of this collection.


14. PROVIDE ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT.

NIFA estimates the total annual cost to the agency for the collection of this information to be $4,000,000 which includes staff time in reviewing and managing the information, panel costs, and system maintenance.


15. REASONS FOR CHANGES IN BURDEN.


This is a revision of a currently approved collection with two updates. The electronic assurance for Confidentiality and Conflicts of Interest is already approved in the PRS system. NIFA has updated the estimated number of reviewers for this form to 2000 to correct previous estimates, and added 2 minutes to compensate for the additional approval for the electronic record. The additional demographics question on the Reviewer Questionnaire should not significantly increase the burden on reviewers, and has been updated to include an additional two minutes of burden.


16. TABULATION, ANALYSIS AND PUBLICATION PLANS.


The information collected is not planned for publication. It is used solely to administer NIFA programs.


17. REASONS DISPLAY OF EXPIRATION DATE OF OMB APPROVAL IS INAPPROPRIATE.

NIFA will display the OMB approval number on the Peer Review System. To prevent from having to modify system screens exemption is requested to not display the expiration date of this collection.


18. EXCEPTIONS TO 83-I CERTIFICATION STATEMENT.


A certification of exception is not requested.


B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS


Information to be collected does not employ statistical methods.

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