SUPPORTING STATEMENT - PART A
Exchange Credit Program – 0702-0137
Summary of Changes from Previously Approved Collection
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1. Need for the Information Collection
Title 10 U.S.C. §2481, “Defense Commissary and Exchange Systems: Existence and Purpose,” requires that the Secretary of Defense operate a world-wide system of exchange stores intended to enhance the quality of life for members of the uniformed services, retired members, and dependents of such members. The Army and Air Force Exchange Service (Exchange) is a Non-Appropriated Fund (NAF) instrumentality of the United States of America. Army Regulation 215-8/Air Force Instruction 34-211(I), “Army and Air Force Exchange Service Operations” charges the Army and Air Force Exchange Service with the dual and enduring mission of supplying quality merchandise and services to its customers at competitively low prices which generate earnings supporting Family, Morale, Welfare and Recreation (FMWR) programs.
The information collection is the basis for deciding Exchange patron credit eligibility, enhancing the patron’s shopping experience, determining the patron’s suitability to cash checks at Exchange facilities, and collecting government debts. Allowing patrons to use credit in their shopping experience supports the efficiency and effectiveness of the Exchange’s marketing programs and the mission to support FMWR programs.
Army Regulation 215-8/AFI 34-211(I) authorizes criteria to obtain identity as an Exchange patron. The Secretary of the Army and the Secretary of the Air Force of the military departments may grant deviations of authorized patron access for individuals or classes and groups of persons at specific garrisons and installations. Delegation of this authority outside the Secretariat is prohibited. Deviations may be granted when based on alleviating individual hardships. Patrons include individuals who are members of the uniformed services, retired members, authorized veterans, and dependents of members of the Armed Forces, commissioned officers of the Public Health Service, and commissioned officers of the NOAA. A dependent is defined as “a dependent or former dependent entitled to transition compensation under 10 USC 1059, if not eligible under another provision of law, while receiving payments for transition compensation.” Other individuals may meet the requirements of being patrons as mandated by regulation.
The prescribing directive which governs and authorizes the Exchange for mission activities is Title 10 U.S.C. §7013, Secretary of the Army and 10 U.S.C. §9013, Secretary of the Air Force. The authority to collect and recover funds relative to debts is governed by the Federal Claims Collection Act of 1966 (Pub.L. 89-508, as amended), Debt Collection Act of 1982 (Pub.L. 97-365, as amended), as codified in 31 U.S.C. §3711, Collection and Compromise, 31 CFR 285.11, Administrative Wage Garnishment, DoD Instruction 1330.21, Armed Services Exchange Regulations, DoD 7000.14-R, Department of Defense Financial Management Regulation Volume 13, Nonappropriated Funds Policy and Volume 16, Department of Defense Debt Management. Army Regulation 215-8/Air Force Instruction 34-211(I), Army and Air Force Exchange Service Operations and E.O. 9397 (SSN), as amended allows the exchange to collect Social Security Numbers associated with a patron’s Exchange account.
2. Use of the Information
The Exchange offers “personal credit” accounts to service members for purchases of military clothing and to all authorized patrons a private label Military Star credit card for retail purchases. Established credit is acceptable at any participating Army and Air Force, Navy, Marine Corps, and Coast Guard Exchanges or online at shopmyexchange.com and mynavyexchange.com. Authorized patrons of the Exchange include individuals who defined in Army Regulation 215-8/AFI134-211(I), Tables 7-1 and 7-2 or designated by Congressional action. This includes individuals who are members of the uniformed services, retired members, veterans who are discharged as honorable or general under honorable conditions, and dependents of members of the Armed Forces, commissioned officers of the Public Health Service, and commissioned officers of the National Oceanic & Atmospheric Administration (NOAA). Other individuals may meet the requirements of being patrons as mandated by regulation.
Patrons deciding to apply for credit may voluntarily complete the “on-line” application form through https://www.myecp.com/, or through a local Exchange facility by completing the Exchange paper form CRC 7429395 “Military Star Credit Paper Application”, or by supplying information to an authorized Exchange cashier at the Point of Sale (POS). Exchange facilities may aid patrons by allowing them access to a company owned computer for completion of the on-line application.
Account holders requesting to update information on their account may do so electronically by visiting https://www.myecp.com/, or by contacting the Exchange MILITARY STAR® department at 1-877-891-7827. In the past, Exchange Form 6450-005, “Exchange Credit Program Update Account” has been utilized by patrons seeking to make these updates. However, upon review, the form has been determined to be obsolete and is no longer being utilized. It has been removed from this information collection request.
Information collected from the patron allows the Exchange to address their credit worthiness, and supply monthly statements and debt communication, to include wage garnishments. To establish this credit worthiness, Exchange Military Star personnel review the application and obtain an electronic credit history report requiring the patron’s SSN. Patrons, whose credit is acceptable, will receive a credit card and a specified credit limit. Patrons, who present an unacceptable credit risk, will receive a denial letter following applicable regulations sent either electronically, through the mail, or both. Sample of templates of the denial letters are provided with this package for OMB’s review.
The completed application is provided to an Exchange associate either by hand or through electronic means. If the application is completed in a paper format, an Exchange associate scans the document and protects and encrypts the application to send electronically to the Exchange Headquarters in Dallas, Texas for processing. The information is then entered into an electronic database and kept in the Exchange secured and protected Financial Management System. Once scanned, the paper form is destroyed by cross shredding. If obtained through electronic means, the application is saved in the same system.
3. Use of Information Technology
The use of technology enhances the ability of the Exchange to collect confidential information securely, promptly, and accurately. Approximately 98% of all applications and changes to account information are completed on-line by patrons through https://www.myecp.com/, through an authorized/designated Exchange point of sale register, or with assistance from an Exchange Associate. Information only needs to be given once, lessening the burden of the individual. Patrons, supplying applications by electronic means, may receive results immediately. The system is readily available for disclosure to the patron or their designee upon their written request in compliance with the Privacy Act of 1974, as amended, Title 5 U.S.C. §552a.
The electronic system allows immediate access to the required data for purposes of addressing account inquiries, updating accounts, corresponding with financial institutions and/or Internal Revenue Service, and collecting debt from other Employers (Wage or salary garnishments). The SSN collection is used to obtain data for these purposes.
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
Information is collected from members of the public on a voluntary basis. The collection is triggered by the patron’s desire to obtain credit with the Exchange, i.e., “as needed” or “on occasion”. Less frequent collection is not possible.
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 (FRN) for the collection published on Tuesday, March 15, 2022. The 60-Day FRN citation is 87 FRN 14519.
No comments were received during the 60-Day Comment Period.
A 30-Day Federal Register Notice (FRN) for the collection published on Tuesday, August 30, 2022. The 30-Day FRN citation is 87 FR 52940.
Part B: CONSULTATION
Significant input and information were received from the Exchange Credit Program directorate in relation to the continued use and burden for this collection of information. Information is only maintained in one database and used accordingly as outlined in section 2 of this Supporting Statements.
9. Gifts or Payment
No payments or gifts are being offered to respondents as an incentive to participate in the collection.
10. Confidentiality
The information collected and maintained in this system is protected under the Privacy Act of 1974, as amended. Respondents are assured confidentiality through the Privacy Act Statement(s) available for reading on the applicable collection documents, available in the Military Star Terms and Conditions, or posted at point-of-sale terminals.
A draft copy of the SORN (DoD 000x SORN, “DoD Patron Authorization, Retail, Services, and MWR Recreational Activities)” has been provided with this package for OMB’s review.
The Privacy Impact Assessment (PIA) for the Exchange Credit Program electronic collection may be viewed at https://www.aafes.com/images/AboutExchange/FOIA-PIA.pdf and has been provided with this package for OMB’s review.
Records deposition for documents within this system is in guidance with DAA-GRS-2013-0001 & 0002. Records are cut off at the close of the fiscal year in which the case is fully paid. Records are then destroyed 6-years after the cutoff by either shredding or deletion from the electronic database.
11. Sensitive Questions
Respondents may be asked to supply their social security number. Collection of social security number is authorized under DoDI 1000.30 “SSN Instruction Use Case” Enclosure 2 sections 2.c.(4) and (7). Justification for use of the SSN is provided.
12. Respondent Burden and its Labor Costs
Part A: ESTIMATION OF RESPONDENT BURDEN
Collection Instruments
CRC 7429395 “Military Star Card Paper Application”
Number of Respondents: 15,236
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 15,236
Response Time: 2 minutes
Respondent Burden Hours: 508 Hours
https://www.myecp.com/ “Exchange Credit Program Account Update”
Number of Respondents: 429,855
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 429,855
Response Time: 2 minutes
Respondent Burden Hours: 14,329 Hours
https://www.myecp.com/ “Military Star Card Online Application”
Number of Respondents: 53,997
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 53,997
Response Time: 2 minutes
Respondent Burden Hours: 1,800 Hours
Account Services “Associate Assisted Military Star Account Update”
Number of Respondents: 308,522
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 308,522
Response Time: 2 minutes
Respondent Burden Hours: 10,284 Hours
Retail Point of Sales “Military Star Card Point of Sale Application”
Number of Respondents: 61,621
Number of Responses Per Respondent: 1
Number of Total Annual Responses: 61,621
Response Time: 2 minutes
Respondent Burden Hours: 2,054 Hours
Total Submission Burden
Total Number of Respondents: 869,231
Total Number of Annual Responses: 869,231
Total Respondent Burden Hours: 28,975 Hours
Part B: LABOR COST OF RESPONDENT BURDEN
Collection Instruments
CRC 7429395 “Military Star Card Paper Application”
Number of Total Annual Responses: 15,236
Response Time: 2 minutes
Respondent Hourly Wage: $7.25
Labor Burden per Response: $0.24
Total Labor Burden: $3,682
https://www.myecp.com/ “Exchange Credit Program Account Update”
Number of Total Annual Responses: 429,855
Response Time: 2 minutes
Respondent Hourly Wage: $7.25
Labor Burden per Response: $0.24
Total Labor Burden: $103,882
https://www.myecp.com/ “Military Star Card Online Application”
Number of Total Annual Responses: 53,997
Response Time: 2 minutes
Respondent Hourly Wage: $7.25
Labor Burden per Response: $0.24
Total Labor Burden: $13,049
Account Services “Associate Assisted Military Star Account Update”
Number of Total Annual Responses: 308,522
Response Time: 2 minutes
Respondent Hourly Wage: $7.25
Labor Burden per Response: $0.24
Total Labor Burden: $74,559
Retail Point of Sales “Military Star Card point of Sale Application”
Number of Total Annual Responses: 61,621
Response Time: 2 minutes
Respondent Hourly Wage: $7.25
Labor Burden per Response: $0.24
Total Labor Burden: $14,892
Overall Labor Burden
Total Number of Annual Responses: 869,231
Total Labor Burden: $210,064
We based our hourly burden on the current Federal Minimum Wage (2009) posted at the Department of Labor Wage Website https://www.dol.gov/general/topic/wages/minimumwage.
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
Part A: LABOR COST TO THE FEDERAL GOVERNMENT
Collection Instruments
CRC 7429395 “Military Star Card Paper Application”
Number of Total Annual Responses: 15,236
Processing Time per Response: .08/Hour (5 minutes)
Hourly Wage of Worker(s) Processing Responses: $20.79
Cost to Process Each Response: $1.66
Total Cost to Process Responses: $25,340.52
https://www.myecp.com/ “Exchange Credit Program Account Update”
Number of Total Annual Responses: 429,855
Processing Time per Response: .03/Hour (2 minutes)
Hourly Wage of Worker(s) Processing Responses: $20.79
Cost to Process Each Response: $0.62
Total Cost to Process Responses: $268,100.56
https://www.myecp.com/ “Military Star Card Online Application”
Number of Total Annual Responses: 53,997
Processing Time per Response: .03/Hour (2 minutes)
Hourly Wage of Worker(s) Processing Responses: $20.79
Cost to Process Each Response: $0.62
Total Cost to Process Responses: $33,677.93
Account Services “Associate Assisted Military Star Account Update”
Number of Total Annual Responses: 308,522
Processing Time per Response: .03/Hour (2 minutes)
Hourly Wage of Worker(s) Processing Responses: $20.79
Cost to Process Each Response: $0.62
Total Cost to Process Responses: $192,425.17
Retail Point of Sales “Military Star Card point of Sale Application”
Number of Total Annual Responses: 61,621
Processing Time per Response: .03/Hour (2 minutes)
Hourly Wage of Worker(s) Processing Responses: $20.79
Cost to Process Each Response: $0.62
Total Cost to Process Responses: $38,433.02
Overall Labor Burden to Federal Government
The hourly wage of workers was determined by using the rounded lower wage of NF pay band level 3 associates as displayed in the March 14, 2022 152 DFW Pay Band Schedule 036-57 listed at https://wageandsalary.dcpas.osd.mil/Content/NAF%20Schedules/survey-sch/152/152-036-57-NF.pdf for Dallas, Texas (Maximum Hourly Rate – Minimum Hourly Rate) / 4 + (Minimum Hourly Rate.)
Part B: OPERATIONAL AND MAINTENANCE COST
1) Cost categories
Equipment: $11,536
Printing: $27,000
Postage: $33,386
Software Purchases: $27,143
Licensing Costs: $62,465
Other: $62,500 (IT System Support, overhead)
Total Operational and Maintenance Cost: $224,030
Part C: TOTAL COST TO THE FEDERAL GOVERNMENT
Total Operational and Maintenance Costs: $224,030
Total Labor Cost to the Federal Government: $557,977.20
Total Cost to the Federal Government: $782,007
15. Reasons for Change in Burden
The collection of applications has significantly increased due to Congressional actions authorizing Purple Heart recipients, disabled and honorably discharged veterans, and Commissary and MWR customers to utilize the Exchange and apply for a MILITARY STAR® credit card. However, due to continued concerns over the conditions resulting from the COVID pandemic, manual applications and those applied for at point-of-sale locations have decreased. Additionally, the estimated response time for the CRC 7429395 Military Star Card Paper Application was revised from 6 minutes to 2 minutes based on consultation with the custodian.
Maintenance of this system remains constant while labor costs have increased due to pay raises for long-term associates and patron desires to shop on-line.
16. Publication of Results
The results of this information collection will not be published.
17. Non-Display of OMB Expiration Date
We are not seeking approval to omit the display of the expiration date of the OMB approval on the collection instrument.
18. Exceptions to “Certification for Paperwork Reduction Submissions”
We are not requesting any exemptions to the provisions stated in 5 CFR 1320.9.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Kaitlin Chiarelli |
| File Modified | 0000-00-00 |
| File Created | 2022-08-31 |