SUPPORTING STATEMENT - PART A
(Federal Write-In Absentee Ballot – 0704-0502)
Summary of Changes
The SF Form 186 has been redesigned for the forthcoming 2020 election cycle.
1. Need for the Information Collection
The Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA), 52 U.S.C. § 203, requires the Presidential designee (Secretary of Defense) to prescribe an official backup ballot for use by the States to permit absent uniformed services voters and overseas voters to participate in general, special, primary and runoff elections for Federal office. The authority for the States to collect personal information comes from UOCAVA. The burden for collecting this information resides in the States. The Federal government neither collects nor retains any personal information associated with these forms.
2. Use of the Information
The collected information will be used by State and local election officials to process uniformed service members, spouses and overseas citizens who submit their information to register to vote or receive an absentee ballot. The collected information will be retained by election officials to provide election materials, including absentee ballots, to the uniformed services, their eligible family members and overseas voters during the form’s eligibility period provided by State law. No information from the Federal Write-In Absentee Ballot (FWAB) is collected or retained by the Federal government. The FWAB is completed in hardcopy or via the Federal Voting Assistance Program’s (FVAP) online assistant (fvap.gov), and then submitted by the voter to an Election Official through mail, email, or fax (depending on State instructions). Per the law, FVAP regularly reaches out to UOCAVA citizens in order to raise awareness of its voting assistance services, primarily via its website, FVAP.gov.
3. Use of Information Technology
The Federal Voting Assistance Program does not collect responses to the FWAB (0%). Neither does any other federal entity. The individual States set standards and legislate for the possibility of electronic submission.
4. Non-duplication
The information obtained through this collection is unique and is not already available for use or adaptation from another cleared source.
5. Burden on Small Businesses
This information collection does not impose a significant economic impact on a substantial number of small businesses or entities.
6. Less Frequent Collection
The applicant is required to update and resubmit the information annually, whenever they change their mailing address or as otherwise required by State law. If the information is not submitted annually or whenever they change their mailing address, the applicant may not receive ballots for elections for Federal office in that calendar year.
7. Paperwork Reduction Act Guidelines
This collection of information does not require collection to be conducted in a manner inconsistent with the guidelines delineated in 5 CFR 1320.5(d)(2).
8. Consultation and Public Comments
Part A: PUBLIC NOTICE
A 60-Day Federal Register Notice for the collection was published on Wednesday, November 21, 2018. The 60-Day FRN citation is 83 FRN 58764.
31 comments were received during the 60-Day Comment Period. They are included on a separate document with our Agency’s response to the comments. The spreadsheet containing the comments reflects the structure of the newly designed FWAB. Since this was a partial redesign of the form, many of the commenters had numerous suggestions on multiple components of each section. As a result, there were hundreds of unique comments collected for the FWAB during the public review period. FVAP provided an answer of Accepted, Rejected, or Non-substantial to each comment, and included a rationale for all rejected and non-substantial comments. The comments themselves varied widely as a result of the feedback from election officials, designers, and end users. Overall, the feedback was very positive and constructive. All of the comments were evaluated by subject-matter experts. The criteria for doing so were based on legality under UOCAVA and the likelihood of a voter completing the form correctly according to extensive usability testing.
A 30-Day Federal Register Notice for the collection was published on Monday, March 25, 2019. The 30-Day FRN citation is 84 FRN 11079.
Part B: CONSULTATION
A thorough battery of usability testing was conducted to determine the clarity of the form and whether it is achieving its intended use. This collection represents the final product of numerous design iterations, user feedback and subject matter expert comments.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
There is a precedent of providing a Privacy Act Statement to the respondent on this form. It is located beside the instructions, below the Agency Disclosure Statement. It is important to note that the information is collected and retained by individual States, counties and municipalities. It is not in the possession of the Federal government.
A System of Record Notice (SORN) is not required for this collection because records are not retrievable by PII.
A Privacy Impact Assessment (PIA) is not required for this collection because PII is not being collected electronically.
The information is collected and retained by individual States, counties and municipalities. It is not in the possession of the Federal government.
11. Sensitive Questions
The respondent’s complete or partial Social Security Number is required to meet certain State voter registration requirements. The purpose and use of this information is determined by the States. FVAP does not collect or use this information.
12. Respondent Burden and its Labor Costs
a. Estimation of Respondent Burden
1. [Federal Write-In Absentee Ballot]
a. Number of Respondents: 1,200,000
b. Number of Responses Per Respondent: 1
c. Number of Total Annual Responses: 1,200,000
d. Response Time: 0.25 hours
e. Respondent Burden Hours: 300,000 hours
2. Total Submission Burden
a. Total Number of Respondents: 1,200,000
b. Total Number of Annual Responses: 1,200,000
c. Total Respondent Burden Hours: 300,000 hours
b. Labor Cost of Respondent Burden
1. [Federal Write-In Absentee Ballot]
a. Number of Total Annual Responses: 1,200,000
b. Response Time: 0.25 hours
c. Respondent Hourly Wage: $22.52
d. Labor Burden per Response: $5.63
e. Total Labor Burden: $6,756,000
2. Overall Labor Burden
a. Total Number of Annual Responses: 1,200,000
b. Total Labor Burden: $6,756,000
The Respondent hourly wage was determined by using the Department of Labor Wage Website (http://www.dol.gov/dol/topic/wages/index.htm)
13. Respondent Costs Other Than Burden Hour Costs
There are no annualized costs to respondents other than the labor burden costs addressed in Section 12 of this document to complete this collection.
14. Cost to the Federal Government
The information is not collected and processed by the Federal government. The cost of collecting and processing the information is borne by the individual State and local election offices as part of providing voter registration and election services to citizens claiming their state as legal residence.
FVAP purchases hardcopy forms from GSA for distribution to installations, organizations, and individuals that request them for use in trainings and as ballot requests. Some of the Services purchase hardcopy forms for distribution to individuals who are unable to access the electronic version.
a.
Labor Cost to the Federal Government
1. [Federal Write-In Absentee Ballot]
a. Number of Total Annual Responses: 0
b. Processing Time per Response: 0 hours
c. Hourly Wage of Worker(s) Processing Responses: $0
d. Cost to Process Each Response: $0
e. Total Cost to Process Responses: $0
2. Overall Labor Burden to Federal Government
a. Total Number of Annual Responses: 0
b. Total Labor Burden: $0
b. Operational and Maintenance Costs
Equipment: $0
Printing: $64,000
Postage: $0
Software Purchases: $0
Licensing Costs: $0
Other: $0
g. Total: $64,000
1. Total Operational and Maintenance Costs: $64,000
2. Total Labor Cost to the Federal Government: $0
3. Total Cost to the Federal Government: $64,000
15. Reasons for Change in Burden
This is a revision of a currently approved collection. There is no requested change in burden.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
We are requesting continued approval to omit the expiration date. This form is stocked by Federal and non-government agencies for distribution to and use by uniformed services, their eligible family members and overseas voters. If the form contains the OMB expiration date, voters may believe they will continue to receive absentee ballots beyond what is allowed by State law. This confusion would disenfranchise citizens. Additionally, requiring the form to be revised and reissued on a triennial basis would incur unnecessary expense where previous versions of the form meet UOCAVA requirements. Furthermore, voters who only have access to an “expired” form may not realize it can be used for voter registration and ballot request purposes, and would thus be disenfranchised.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
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