0704-0502_ssa_7.9.21

0704-0502_SSA_7.9.21.docx

Federal Write-In Absentee Ballot (FWAB)

OMB: 0704-0502

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SUPPORTING STATEMENT - PART A

Federal Write-In Absentee Ballot0704-0502

Summary of Changes from Previously Approved Collection


  • The increase in burden is due only to an increase in DOL’s hourly wage index.

  • The SF Form 186 has been redesigned for the forthcoming 2022 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. 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 Monday, March 29, 2021. The 60-Day FRN citation is 86 FR 16337 FRN 16337.


65 comments were received during the 60-Day Comment Period. They are included on a separate document with our Agency’s response to the comments.

A 30-Day Federal Register Notice for the collection published on Wednesday, July 7, 2021. The 30-Day FRN citation is 86 FR 35760 FRN 35760.

Part B: CONSULTATION


Through usability testing from the previous form redesign and past comments from field testing of the previous form, we have made minor changes in this redesign.


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 Advisory 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: $25.72

d. Labor Burden per Response: $6.43

e. Total Labor Burden: $7,716,000.00


2. Overall Labor Burden

a. Total Number of Annual Responses: 1,200,000

b. Total Labor Burden: $7,716,000.00


The Respondent hourly wage was determined by using the Department of Labor Statistics Occupational Employment Statistics Website (https://www.bls.gov/oes/current/oes_nat.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

  1. Equipment: $0

  2. Printing: $64,000

  3. Postage: $0

  4. Software Purchases: $0

  5. Licensing Costs: $0

  6. 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

The increase in burden is due only to an increase in DOL’s hourly wage index.


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.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
AuthorKaitlin Chiarelli
File Modified0000-00-00
File Created2021-07-16

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