PIF Renewal Supporting Statement

USAID Supporting Statement for Paperwork Reduction Act Submission

Partner Information Form

OMB 0412-0577 (AID 500-13)

A. JUSTIFICATION

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

USAID utilizes the Partner Information Form (AID 500-13, or PIF) in conjunction with the Partner Vetting System (PVS), its information technology (IT) system of records, to collect and maintain records for vetting purposes to help ensure that USAID funds, USAID-funded activities, or other resources will not be used to provide support to entities or individuals deemed to be a risk to national security.

The PIF is completed by organizations, entities, or individuals applying for USAID contracts, grants, or other funding. In addition to collecting data on entities applying for funding and the type and purpose of the award, USAID utilizes the PIF to collect data on key individuals of prospective awardees and subawardees. Information collected on such key individuals includes the following: name; other names used; date and place of birth; gender; citizenship(s); government-issued photo identification number, type of identification, and country of issuance; address; phone number(s); email address(es); current employer and project title; organizational rank or title; occupation; and professional licenses and certifications.

USAID derives its authority to collect information for vetting purposes from, among other sources, Executive Order 13224; Section 7034(e) of the Consolidated Appropriations Act, 2018 (P.L. 115—141), and subsequent appropriations acts; and 18 U.S.C. 2339A, 2339B, and 2339C.

2. Indicate how, by whom, and for what purpose the information is to be used. Indicate the actual use the agency has made of the information received from the current collection.

Based on information provided on the PIF, USAID personnel analyze information collected from public and U.S. government databases to determine the risk that the organization, entity, or individual applying for Agency funding could divert Agency resources to those deemed to be a risk to national security.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology (IT). Also describe any consideration of using IT to reduce burden.

To reduce burden on the Agency’s implementing partners and personnel, USAID encourages prospective awardees to submit information in an automated, electronic format through USAID’s Partner Vetting System secure portal, unless Internet access is unavailable, in which case a PIF may be submitted to USAID. Information provided to USAID should be the same regardless of whether it is submitted via the portal or the PIF.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

USAID does not have any other means to collect the information requested on the Partner Information Form. USAID personnel use the information collected on this form to identify entities or individuals who are a risk and to help mitigate the risk that USAID funds, USAID-funded activities, or other resources could be diverted to those deemed to be a risk to national security.

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

This information collection does not have a significant economic impact on a substantial number of small businesses or other small entities.

6. Describe the consequence 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 this information collection is not conducted, then USAID may not be able to mitigate the risk that Agency funds, Agency-funded activities, or other resources could purposefully or inadvertently benefit individuals or entities deemed to be a risk to national security.

7. Explanation of special circumstances

No special circumstances exist.

8. Solicitation of public comments

USAID has published a 60-day notice in the Federal Register in accordance with 5 CFR 1320.8(d) to solicit public comments for the information collection and has notified the public that this currently approved collection will be submitted to the Office of Management and Budget for review and approval.

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

USAID does not provide any payment or gift to respondents.

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

This form includes a Privacy Act Statement explaining the routine uses of the information collected under the Act. Other than provisions for confidentiality in the Privacy Act, no assurances of confidentiality have been made to the respondent.

11. Provide additional justification for any questions of a sensitive nature.

No questions of a sensitive nature are included on the information collection form.

12. Provide estimates of the hour burden of the collection of information.

USAID estimates that at least 5,800 PIFs will be completed annually and that the average form will include information on five key individuals. Based on feedback from our implementing partners and on our experience implementing vetting programs, we estimate that requirements for partner vetting will add 90 minutes to an USAID acquisition or assistance award application. The estimated annual burden to applicants amounts to 8,700 hours (5,800 forms multiplied by 90 minutes per form, divided by 60 minutes). We calculated this burden estimate under the assumptions that the average form submitted will include information on five key individuals and that it would take approximately 90 minutes to gather the necessary information, complete the form, submit the form to USAID, and respond to requests by USAID for additional information, if necessary. This burden estimate includes the amount of time for proposed awardees to inform proposed subawardees of their responsibility to complete and submit the form and for those proposed subawardees to complete and submit the form to USAID. This burden estimate does not include the amount of time required for an implementing partner to provide additional vetting information on new key individuals or new subawardees.

USAID estimates the cost per submission to be $66.40. This amount is based on the average hourly wage of an Executive Administrative Assistant employee in the Washington, D.C. Metro area, as calculated by the U.S. Department of Labor, Bureau of Labor Statistics, multiplied by the time required for the administrative support employee to collect the information, complete the form, submit the form to USAID, and follow up with USAID on information related to the form (hourly wage rate of $34.05, multiplied by a loaded wage factor of 1.3 to account for benefits, excluding indirect labor costs), multiplied by 90 minutes per form, divided by 60 minutes).

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
USAID estimates that the total annual cost burden to respondents resulting from the collection of information amounts to $385,105.50 (5,800 forms completed annually multiplied by $66.40, the estimated labor cost for a respondent to complete and submit each form). No start-up, capital, or maintenance costs to respondents are anticipated as a result of this collection. The PIF can be forwarded to USAID via mail or electronically; USAID believes access to web connectivity and possible postal charges are negligible. No other costs are attributable to this information collection.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

USAID estimates that its annualized costs related to this information collection amount to $5,265,000. This amount includes costs to maintain the information technology system used for vetting, in addition to the salaries, benefits, indirect costs, and overhead attributed to Washington-based and field-based personnel supporting USAID’s vetting programs.

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

USAID proposes to update the form previously approved by OMB by (1) simplifying the format; (2) improving the instructions to make the document easier to read and complete; and (3) providing the following modifications:

Part 1: Information about Award

• Proposed Fields to be Deleted

  • Name of Parent Company (if any)

  • Company Website URL

  • 3^rd Phone [Number]

  • 2^nd Fax [Number]

• Proposed Fields to be Added

  • Solicitation/Award Number

Part 2: Information about Subaward (NEW SECTION)

• Proposed Fields to be Added

  • Name of Prospective Subawardee (if applicable, including identifying whether the prospective subawardee is a parent organization, branch, or subsidiary)

  • Website URL of Prospective Subawardee (if applicable)

  • Address of Prospective Subawardee (if applicable)

  • Phone Number(s) of Prospective Subawardee (if applicable)

  • Fax Number of Prospective Subawardee (if applicable)

  • Email Address(es) of Prospective Subawardee (if applicable)

  • Type of Subaward (if applicable)

  • Value of Total Subaward (if applicable)

  • Purpose of Subaward (if applicable)

Part 3: Certification (formerly Part 2)

• Proposed deletion of “Submission details” section to be completed by USG official

Part 4: Key Individual Information

• Proposed Fields to be Added

  • Within existing “Citizenship” field, if dual citizen, list both countries

  • U.S. Passport or Permanent Resident Card Number (if applicable]

  • Government-Issued Photo ID Type (additional field for dual citizens only)

  • Government-Issued Photo ID Number (additional field for dual citizens only)

  • ID Country of Issuance (additional field for dual citizens only)

  • Primary and Alternate Phone Numbers (confirm if cell phone number)

16. Published results

Results of this collection will not be published.

17. Waiver of display of expiration date.

The expiration date for OMB approval of the information collection will be displayed on the form.

18. Exception to the certification statement

USAID does not request any exceptions to the certification of this information collection.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods.

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