Final - Supporting Statement 11-20

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Request for Department of State Personal Identification Card
OMB Number 1405-XXXX
DS-1838 and DS-7783

A. JUSTIFICATION

1. Why is this collection necessary and what are the legal statutes that allow this?

The collection of the information requested on the DS-1838 and DS-7783 is necessary to comply with:

• Homeland Security Presidential Directive 12 (HSPD-12) was issued August 27, 2004 to set policy for a common, reliable, and secure identification standard for federal employees and contractors for accessing federally-controlled facilities and federal information systems. In order to keep Federal and other facilities where there is potential for terrorist attacks secure, wide variations in the quality and security of forms of identification need to be eliminated.

• Federal Information Processing Standard Publication 201 (FIPS 201) is a United States federal government standard that specifies Personal Identity Verification (PIV) requirements for Federal employees and contractors. The NIST (National Institute of Standards and Technology) Computer Security Division initiated a new program for improving the identification and authentication of Federal employees and contractors for access to Federal facilities and information systems.

2. What business purpose is the information gathered going to be used for?

The information solicited on this form (including the applicant’s social security number) is required to comply with HSPD-12 and FIPS-201 identity card issuance standards; this information will be used to conduct appropriate national agency checks (Un-Cleared Contractors) prior to issuing a Department of State Personal Identification Verification (PIV) Card and provide a required unique identifier for our ID Management System (IDMS). New Department Contractors will have their Contracting Officer Representative (COR) as the Department sponsor to complete the DS-1838/ABR application. Current Department Contractors may complete the applicant section via DOS Open-net and forward to COR for approval/completion.

3. Is this collection able to be completed electronically (e.g. through a website or application)?

Currently, the DS-1838 used domestically and DS-7783 used outside the continental United States is not able to be processed electronically; however, the Department is piloting the Automated Badge Request (ABR) to improve process efficiency and reduce paperwork. ABR currently provides an electronic badge request platform to enable the Department sponsor(COR), required Department approvers and applicant to complete this application process digitally. ABR’s currently account for an average of 15% of applications. New Department Contractors will have their Contracting Officer Representative (COR) as the Department sponsor to complete the DS-1838/ABR application. Current Department Contractors may complete the applicant section via DOS Open-net and forward to COR for approval/completion.

4. Does this collection duplicate any other collection of information?

This collection does not duplicate any other collection of information.

5. Describe any impacts on small business.

Collecting this information does not impact small businesses.

6. What are consequences if this collection is not done?

Without this information Diplomatic Security cannot issue identification cards to Department of State employees and contractors, as mandated by HSPD-12.

7. Are there any special collection circumstances?

There are no special collection circumstances.

8. Document publication (or intent to publish) a request for public comments in the Federal Register

The Department published a 60 day notice in the Federal Register (83 FR 30211) on June 27, 2018 soliciting public comments. No comments were received.

9. Are payments or gifts given to the respondents?

There are no payments of gifts given to respondents.

10. Describe assurances of privacy/confidentiality

There are no assurances of confidentiality. The data will be protected by the Privacy Act, to the extent authorized by law.

11. Are any questions of a sensitive nature asked?

A Social Security Number is required as a means to verify the identity of the applicant requesting the badge.

12. Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection

All Department employees and contractors are required to submit the application for Personal Identification Card (DS-1838 domestically or DS-7783 overseas) or Automated Badge Request (ABR) at the time of hire. DS-1838 or DS-7783 application completion is estimated at 5 minutes. With an average of 13,500 contractor applicants annually, the time burden equals to 1,125 hours per year.

Time burden; 13,500 applicants per year X 5 minutes/60 = 1,125 hours per year.

Cost burden; $47.03ⁱ ($40.20 mean hourly earnings based on estimated income per hour from the Bureau of Labor Statistics, The Department used the 2018 median pay for “Management Analyst” to apply for the Diplomatic Security Identification Services Operator. These hourly wage rates include benefits. The Department adjusted the wage to increase by 17% to account for overhead costs such as rent, utilities and office equipment) $47.03 x 1.4 (weighted wage multiplier) = $65.84 weighted wage.

Total hour burden cost; 1,125 (annual hours) x $65.84 (the 2018 weighted wage) = $74,072.25 (hour burden cost).

13. Describe the monetary burden to respondents (out of pocket costs) needed to complete this collection.

There is no cost to respondents.

14. Describe the cost incurred by the Federal Government to complete this collection.

Cost to Federal Government; $31.40 per reviewed application X 13,500 applicants = $423,980.00 annual cost

This includes a Total hour burden cost – 1,125 (annual hours) X mean hourly weighted wage of $65.84 for the Diplomatic Security Identification Services Operator / by 13,500 applicants =$5.48 per applicant

The Department purchases $350,000 of badging equipment and printing consumables (PIV card stock, printer ribbon/laminate, shielded badge holders) annually to support 13,500 applicants. $350,000 / 13,500 applicants = $25.92 per applicant

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

This is a new collection, however, the information was used without an OMB control number.

16. Specify if the data gathered by this collection will be published.

Data will not be published

17. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date.

The Department will display the OMB expiration date.

18. Explain any exceptions to the OMB certification statement below.

The Department is not seeking exceptions to the certification statement.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

i Source: Data from the U.S. Bureau of Labor Statistics May 2017 National Occupational Employment and Wage Estimates for all occupations (https://www.bls.gov/oes/2017/may/oes_nat.htm#00-0000).