General Services Administration
Information Collection
Construction Payrolls and Basic Records
OMB Control Number 3090-XXXX
Justification – Part A Supporting Statement
1. Overview of Information Collection.
Provide a brief overview of the information being collected, disclosed, or the recordkeeping requirement imposed by the agency.
The information being collected is required by the Department of Labor (DOL) and the Federal Acquisition Regulation (FAR) clause 52.222-8 Payrolls and Basic Records which requires all contractors awarded construction contracts in excess of $2,000 for work performed in the United States to provide weekly payroll data to the appropriate contracting officer. The Department of Labor (DOL) provided a WH-347 form for contractors to use in their weekly payroll report. The information being collected includes: 1. contractor and subcontractor name, address and identifying number, 2. the contract/task order number, 3. Project and Location, 4. payroll number, 5. work week ending date, 6. employee name, 7. number of withholding exemptions, 8. work classifications, 9. hours worked, 10. rate of pay (overtime and straight time), 11. gross amount earned (overtime and straight time), 12. fringe benefits, and 13. Statement of Compliance. GSA is proposing to deviate from the FAR clause to require these construction contractors to use the GSA Electronic Payroll Template and its portal to submit the required weekly payroll data. GSA will not impose any additional record keeping information for payrolls. All recordkeeping must be in compliance with appropriate laws for record retention and inspection.
Identify whether this is a request for approval of a New Collection, a Revision to an Existing Collection, an Extension, or a Reinstatement.
This request is for approval of an agency supplement to existing information collections for DOL, Office of Management and Budget (OMB) Information Control No. 1235-0008, Davis-Bacon Certified Payroll and 1235-0018, Records to be kept by Employers—Fair Labor Standards Act. Recently DOL has published a proposed revision to the OMB 1235-0008 ICR to remove the identifier and add two data fields (e.g. telephone number and email address). If DOL’s ICR is approved, GSA will make changes to its electronic template, as necessary.
If a form is not being used (i.e., no collection instrument accompanies this statement), list what information is being collected or disclosed, or the recordkeeping requirement imposed by the agency.
The General Services Administration will require the direct entry of the payroll data into the GSA Electronic Payroll Template portal to collect the information. The data being collected is the same as that currently covered by existing information collections and no other fields have been added.
If this request is related to a previously approved collection, please summarize any existing changes to instruments (e.g., forms, questions, instructions), method of collection, burden estimates, or other material changes of importance that have occurred since the last approval/request and provide a redline markup or a table to show the questions and/or other information that the agency has changed.
GSA is making the following changes to the previously approved DOL data collections (OMB 1235-0008 and 1235-0018):
GSA will require construction contractors and subcontractors to use the GSA Electronic Payroll Template to report the required weekly payrolls records using a GSA specified portal. This is a change from the existing FAR clause which allows optional use of the Form WH-347 for contractors to submit the required weekly payroll records.
GSA’s automation of the data collection process for payroll
collection, submission and certification required changes to the FAR
Clause 52.222-8 Payrolls and Basic Records, as noted below.
52.222-8 Payrolls and Basic Records.
Payrolls and Basic Records (JUL 2021)
(a) Payrolls and basic records relating thereto shall be maintained by the Contractor during the course of the work and preserved for a period of 3 years thereafter for all laborers and mechanics working at the site of the work. Such records shall contain the name, address, and social security number of each such worker, his or her correct classification, hourly rates of wages paid (including rates of contributions or costs anticipated for bona fide fringe benefits or cash equivalents thereof of the types described in 40 U.S.C. 3141(2)(B) (Construction Wage Rate Requirement statute)), daily and weekly number of hours worked, deductions made, and actual wages paid. Whenever the Secretary of Labor has found, under paragraph (d) of the clause entitled Construction Wage Rate Requirements, that the wages of any laborer or mechanic include the amount of any costs reasonably anticipated in providing benefits under a plan or program described in 40 U.S.C. 3141(2)(B), the Contractor shall maintain records which show that the commitment to provide such benefits is enforceable, that the plan or program is financially responsible, and that the plan or program has been communicated in writing to the laborers or mechanics affected, and records which show the costs anticipated or the actual cost incurred in providing such benefits. Contractors employing apprentices or trainees under approved programs shall maintain written evidence of the registration of apprenticeship programs and certification of trainee programs, the registration of the apprentices and trainees, and the ratios and wage rates prescribed in the applicable programs.
(b) (1) The Contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the Contracting Officer. The payrolls submitted shall set out accurately and completely all of the information required to be maintained under paragraph (a) of this clause, except that full social security numbers and home addresses shall not be included on weekly transmittals. Instead, the payrolls shall only need to include an individually identifying number for each employee (e.g., the last four digits of the employee’s social security number). The required weekly payroll information shall be submitted using the GSA Electronic Payroll Template. Contractors must submit the certified payroll data directly onto the template on the GSA Google Portal. For subsequent submissions of the certified payroll data, contractors can create a system generated payroll record that automatically populates. The GSA Electronic Payroll Template may be obtained from the GSA website. The Prime Contractor is responsible for the submission of copies of payrolls by all subcontractors. Contractors and subcontractors shall maintain the full social security number and current address of each covered worker, and shall provide them upon request to the Contracting Officer, the Contractor, or the Wage and Hour Division of the Department of Labor for purposes of an investigation or audit of compliance with prevailing wage requirements. It is not a violation of this section for a Prime Contractor to require a subcontractor to provide addresses and social security numbers to the Prime Contractor for its own records, without weekly submission to the Contracting Officer.
(2) Each payroll submitted shall be accompanied by a "Statement of Compliance," signed by the Contractor or subcontractor or his or her agent who pays or supervises the payment of the persons employed under the contract and shall certify-
(i) That the payroll for the payroll period contains the information required to be maintained under paragraph (a) of this clause and that such information is correct and complete;
(ii) That each laborer or mechanic (including each helper, apprentice, and trainee) employed on the contract during the payroll period has been paid the full weekly wages earned, without rebate, either directly or indirectly, and that no deductions have been made either directly or indirectly from the full wages earned, other than permissible deductions as set forth in the Regulations, 29 CFR Part 3; and
(iii) That each laborer or mechanic has been paid not less than the applicable wage rates and fringe benefits or cash equivalents for the classification of work performed, as specified in the applicable wage determination incorporated into the contract.
(3) The weekly submission of a properly executed certification set forth in the GSA Electronic Payroll Template shall satisfy the requirement for submission of the "Statement of Compliance" required by paragraph (b)(2) of this clause.
(4) The falsification of any of the certifications in this clause may subject the Contractor or subcontractor to civil or criminal prosecution under Section 1001 of Title 18 and Section 3729 of Title 31 of the United States Code.
(c) The Contractor or subcontractor shall make the records required under paragraph (a) of this clause available for inspection, copying, or transcription by the Contracting Officer or authorized representatives of the Contracting Officer or the Department of Labor. The Contractor or subcontractor shall permit the Contracting Officer or representatives of the Contracting Officer or the Department of Labor to interview employees during working hours on the job. If the Contractor or subcontractor fails to submit required records or to make them available, the Contracting Officer may, after written notice to the Contractor, take such action as may be necessary to cause the suspension of any further payment. Furthermore, failure to submit the required records upon request or to make such records available may be grounds for debarment action pursuant to 29 CFR 5.12.
(End of clause)
There is additional burden for this GSA payroll submission process based on the time required to enter the data via electronic means. However, there is no change to the burden associated with collecting the data since the data fields are all the same. GSA’s change in the submission methodology does not increase the existing burden DOL reported in OMB 1235-0008 and 1235-0018.
2. Need & Method for the Information Collection.
Explain the circumstances that make the collection of information necessary.
The data collection information is necessary to comply with various statutes and regulations, see paragraph 2.C. of this supporting statement. Contracting agencies have the duty to ensure compliance by engaging in periodic audits or investigations of contracts, including examinations of payroll data. Contracting officers throughout the Government receive weekly payroll records and due to time constraints, workloads, and competing priorities may perform inconsistent reviews of the payroll information. As a result most errors in payrolls are reported by the contractor employees to DOL investigators in the form of a complaint. GSA is seeking to proactively mandate the use of an automated solution for submitting payroll records to GSA contracting officers. GSA will use the electronic template to ensure the weekly payroll records are consistently being analyzed in detail, increase the accuracy of the review and improve the use of limited contractor and government resources.
Identify any legal or administrative requirements that necessitate the collection.
The legal and administrative requirement necessitating the data collection is outlined in the DOL OMB Information Control 1235-0008 and 1235-0018l and FAR clause 52.222-8 which requires all construction contracts in excess of $2,000 and performing work in the United States to submit the weekly payroll data.
Provide the citation and a copy of the appropriate section of each statute / regulation mandating or authorizing the collection of information as a supplementary document.
The collection of the weekly payroll data is mandated in several statutes and regulations including:
The Copeland Act (Pub.L. 73–324) § 3.3 (b).
Each contractor or subcontractor engaged in the construction, prosecution, completion, or repair of any public building or public work, or building or work financed in whole or in part by loans or grants from the United States, shall furnish each week a statement with respect to the wages paid each of its employees engaged on work covered by this part 3 and part 5 of this title during the preceding weekly payroll period. This statement shall be executed by the contractor or subcontractor or by an authorized officer or employee of the contractor or subcontractor who supervises the payment of wages, and shall be on the back of Form WH 347, “Payroll (For Contractors Optional Use)” or on any form with identical wording…
The Davis-Bacon and Related Acts (DBRA) (sec. 1-7, 46 Stat. 1949, as amended; Pub. L. 74-403).
Contractors and subcontractors must certify their payrolls by attesting that persons performing work on DBRA covered contracts have received the proper payment of wages and fringe benefits.
The Department of Labor Regulations 29 C.F.R., Subtitle A § 3.4 Submission of weekly statements and the preservation and inspection of weekly payroll records.
“(a) Each weekly statement required under § 3.3 shall be delivered by the contractor or subcontractor, within seven days after the regular payment date of the payroll period, to a representative of a Federal or State agency in charge at the site of the building or work, ….”
The FAR clause 52.222-8 Payrolls and Basic Records (b) (1)
The Contractor shall submit weekly for each week in which any contract work is performed a copy of all payrolls to the Contracting Officer. The payrolls submitted shall set out accurately and completely all of the information required to be maintained under paragraph (a) of this clause, except that full social security numbers and home addresses shall not be included on weekly transmittals. Instead the payrolls shall only need to include an individually identifying number for each employee (e.g., the last four digits of the employee’s social security number).
Explain what the statute/regulation requires. Is there a deadline? If so, explain how you will meet the deadline.
All of the statutes and regulations listed in paragraph 2.C. of this document require all construction contractors with contracts exceeding $2,000 and are subject to the DBRA to submit weekly payroll for any contract work performed during that specific week to the appropriate contracting officer or agency designee. GSA’s changes to the collection and submission process will not affect the deadline set in the regulation. The Contractor's requirement for submission of the weekly payroll data remains unchanged.
Describe how the information will be collected (e.g., written forms, telephone, online, electronically). Also, describe who will oversee the collection of information (e.g. independent evaluator, trained moderator, self-administered).
The method of collection will be changed from a paper mail or PDF email submission to an automated solution using an electronic version of the WH-347. Contractors would continue to be responsible for submitting weekly payroll data through the GSA Google Portal. Contractors will directly input data into the electronic template on the portal. For subsequent payroll submissions, contractors will have the option of creating a payroll record which automatically populates. Once received, the automated process would take the submitted data and verify that the labor categories are consistent with the corresponding prevailing wage determination rates identified in the contract. Labor categories found not to be in compliance will be flagged and an email alert will be sent to the appropriate contracting officer of any wage or fringe benefit rates below the appropriate prevailing wage. Electronic activity logs will retain records of all compliant verifications that have been processed and file them in the contract’s electronic contract file. The automated process will also alert the contracting officer upon a contractor’s failure to timely submit payroll data. GSA will self-administer the collection of payroll information.
Consequences if collection is not conducted. Describe the consequence to a Federal program or policies if the collection is not conducted or is conducted less frequently, and describe any technical or legal obstacles to reducing burden.
The consequences for not collecting the data are 1) GSA and its contractors would not be compliant with the statutes and regulations listed in paragraph 2.C.; 2) employees may continue to be paid incorrect wages and fringe benefits, and 3) if an error is found, contractors can suffer large monetary penalties such as being required to pay the negatively impacted employees the highest prevailing wage in the job classification. The weekly collection of the payroll data is required by statute and can only be changed by Congress (e.g., The Copeland Act precludes the collection of the payroll data less frequently than weekly).
GSA’s automated solution will have no impact on the collection of the data as it is currently being collected using various methods. The consequences to not using the automated solution is that the reviews of the weekly payroll data will remain labor-intensive, prone to human error and continue to be an ancillary function due to the contracting officer’s workload and GSA’s mission needs. Legal obstacles to reducing the burden of collecting the data weekly include a permanent court injunction ordering the Secretary of Labor to cease from attempting to reduce the weekly burden through the use of the attestation process. On January 16, 1984, the U.S. Supreme Court declined to review the decision, allowing the appellate decision to become final and precluding DOL from eliminating this aspect of the information collection.
3. Use of the Information.
Indicate how, by whom, and for what purpose the information is to be used (e.g., program administration, application for benefits or services, regulatory compliance, inform policy development).
The payroll information is used in contract and program administration to ensure all of GSA’s applicable construction contracts are in compliance with the DBRA, as well as other applicable statutes and regulations. If the contract and program is out of compliance this means that the employee is not earning the correct pay and the contractor or subcontractor will need to retroactively pay the employee the appropriate amount or an amount higher as determined by DOL.
For an existing collection, describe the use (or principal uses if there are more than one) of the previously collected information, whether by the agency or by other entities.
The collected payroll data is an essential tool used by GSA and other federal agencies to meet the statutory obligation of ensuring construction workers receive no less than the minimum wage required by the appropriate wage determination. The collected payroll data is compared with the specific DBRA wage determinations to determine if each contractor or subcontractor employee is being paid the appropriate wage and fringe benefits per the job classification. If it is determined that the employee is not being paid the legally required wages and fringe benefits, GSA must ensure the contractor retroactively pays the employee the difference in the amount paid, or a higher amount determined by DOL, and use the new wage determination for future payroll disbursements to the employee. GSA is not the enforcement agency and will report any contractor non-compliance with the statute to the DOL for resolution.
Address whether this information will be used by other Federal agencies or not. If so, for what purposes? Are they any privacy concerns related to this information sharing? If so, how have these been addressed?
As required by statutes and regulations, Federal agencies’ contracting officials and DOL’s Wage and Hour Division (WHD) staff use the records and certified payrolls to verify that contractor's employees are being paid the required wages for the work performed. Although a contractor may have multiple contracts with multiple Federal agencies, the applicable wage determination or prevailing wage is specific to the contract award date which will vary from one agency to the other. The sharing of information is usually limited to the Federal agency and DOL investigators. The process for collecting the data is an existing process that began in the Secretary of Labor’s Reorganization Plan No. 14 of 1950. All privacy concerns were vetted and resolved in the information collections request for OMB 1235-0008 and 1235-0018. In general any privacy concerns surrounding the sharing of an employee’s social security number were addressed through the allowance of an individual identifying number (e.g., last four digits of the worker's social security number) and limiting the submission of Personally Identifiable Information from subcontractors such as employee addresses and social security numbers to the Prime Contractor for its own records, without weekly submission to the Contracting Officer. GSA’s proposed automated process will provide additional safeguards to prevent the improper accessing of payroll data through the use of password protections to log into the system using personal identification and password.
4. Use of Information Technology.
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, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The payroll verification process will be 100% automated by completing and entering the electronic template directly into the GSA portal. GSA has built in an information retrieval mechanism to reduce the contractor’s burden by allowing subsequent payroll data submission fields to auto-populate from the previous week. This will reduce the data entry time and allow the contractor to focus on certifying and updating the information, as necessary.
5. Non-Duplication.
Describe efforts to identify duplication.
GSA is aware that entering information from regular payrolls onto the electronic template and maintaining a copy of the certified payrolls may result in the duplication of work already being performed. This is not a new issue; the existing data collections require this same duplicative effort to meet specific Copeland Act requirements using Form WH-347. GSA explored many options for contractors to use in submitting the payroll data but because of the various formats in which contractors submit the payroll data, the use of the electronic template was the most viable option.
Describe the steps taken to ensure that this information is not
collected elsewhere and that it could not be otherwise obtained. If
the information has already been collected by your agency, another
Federal agency, a component of State or local government, or other
public or private non-governmental entity, explain whether your
agency could obtain the information from these sources.
The
data collected is Agency-specific, project-based and requires
information that only the original contractor or subcontractor
payroll data can provide and is not available from any other source.
In addition, the mandate to receive the weekly payroll is statutory
and cannot be changed.
Describe specifically why any similar information that is already available cannot be used or modified to be used for the purposes described.
The current information being collected cannot be used because of the different methods in which the data is submitted (i.e., PDF, excel sheets, and hard copy payroll ledgers). GSA explored the use of various software products to read the various documents but all failed to accurately read the documents. GSA determined that the best solution was to automate Form WH-347 into a standard electronic template which would allow the contractor to enter the data directly into the system. The data, once received, would be compared to the appropriate DBRA wage determination data to verify that the correct wages were paid or flag those that are different.
6. Burden on Small Business.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. Did the agency consider any exemptions, alternate options, or partial or delayed compliance options for small businesses?
The burden applies equally to both large businesses, and small businesses and other small entities awarded construction contracts exceeding $2,000 and subject to DBRA. Information generated from the SAM.gov, formerly Federal Procurement Data System (FPDS), for Fiscal Year (FY) 2021 was used as the basis for estimating the impact of the change on small businesses. An examination of this data revealed there were 154 small business prime contractors and 10 small business subcontractors involved in GSA construction projects during FY2021. GSA does not expect the change in the methodology for collecting the payroll data to significantly impact the small businesses. The change will not initiate or impose any new administrative or performance requirements on small business contractors because the statutes and regulations requirements are already being followed.
7. Less Frequent Collection.
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.
The frequency of collection is limited to the extent necessary to comply with applicable Statutes and regulations which explicitly state the frequency in which these reports should be provided to the GSA contracting officer. The information is provided by construction contractors and their subcontractors as part of the contract terms and conditions to ensure payments to contractor employees are consistent with the appropriate wage determinations. The requested data is currently covered under other information collections (OMB 1235-0008 and 1235-0018). For example, construction contractors subject to DBRA must submit payroll information using the fields in the WH-347 form. GSA has not added any fields not already required by the other information collections.
Legal obstacles to reducing the burden of collecting the data weekly include a permanent court injunction ordering the Secretary of Labor to cease from attempting to reduce the weekly burden through the use of the attestation process. On January 16, 1984, the U.S. Supreme Court declined to review the decision, allowing the appellate decision to become final and precluding DOL from eliminating this aspect of the information collection.
8. Paperwork Reduction Act Guidelines.
Explain any special circumstances that would cause an information collection to be conducted in a manner:
Requiring respondents to report information to the agency more often than quarterly;
Statutes and federal regulations explicitly require contractors and subcontractors to submit the payrolls weekly to the contracting officer or federal representative (see paragraph 1.C. for listing of statutes and regulation). Contractors and their subcontractors must provide these reports weekly on the day and time communicated by the contracting officer. Failure to provide the weekly payrolls would be in violation of statutes, regulations, and contract terms and conditions and can lead to corrective actions including contract termination.
9. Consultation and Public Comments.
Provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.
A 60-day notice published in the Federal Register at 87 FR 27148 on May 6, 2022. One comment was received. The comment was in response to a final rule regarding identifying survey crews not being considered as laborers or mechanics. No change was made to the information collection requirements or supporting statement as a result of the public comment, because it was not applicable to the policy. Specifically, the ICR does not pertain to a final rule nor did it contain information concerning survey crews.
GSA coordinated with DOL Wage Hour Division to provide the wage data and assist with the development of the automated system. In addition, GSA worked with industry through stakeholder meetings to obtain the views and to test the automated GSA Electronic Payroll Template to ensure it is Section 508 compliant and user friendly. The feedback allowed GSA to provide accurate estimates of the time it will take to enter the payroll data and assisted GSA in developing a comprehensive portal that increases the clarity of instructions, record retention, and privacy and safety protocols. GSA collaborated with the various stakeholders involved in the automated process from its inception including DOL which is the agency that provides the wage determination which is the starting point of the payroll verification process. GSA also engaged with the Public Buildings Service contracting activity which is responsible for the agency’s compliance with the various statutes to ensure that those who receive the information provide feedback in its design to ensure useability. GSA also engaged with industry, specifically construction contractors, to test the proposed automated system and provide realistic estimates on the burden.
A 30-day notice published in the Federal Register at 87 FR 48481 on August 9, 2022.
10. Gifts or Payment.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Not applicable.
11. Privacy & Confidentiality.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Provide the exact language of any statement(s) that will be read or provided to respondents that explain how their information will be handled and protected by the agency.
If the agency is pledging to keep the information “confidential,” then provide the citation for the statute that the agency is using as the basis of its confidentiality pledge. Include the appropriate excerpt from the statute here or as a supplementary document. Note: if the statutory basis for assuring confidentiality does not exist, the term “confidentiality” cannot be used. Instead, the document should explain any procedures that will be in place to protect respondent data.
If the Privacy Act applies, the agency should discuss how the data will be managed under the Privacy Act.
The current and proposed regulations explicitly exclude such private data such as full social security numbers and addresses from the weekly payroll submission.
Are respondents required to submit proprietary trade secrets, or other confidential information? Explain the procedures that the agency will implement to protect the information’s confidentiality to the extent permitted by law.
GSA will only disclose information collected internally on a need-to-know basis and in accordance with the provisions of the Freedom of Information Act, 5 U.S.C § 552; the Privacy Act, 5 U.S.C. § 552a; and related regulations, 29 C.F.R. Parts 70, 71. In January 18, 2009, the information collection requirements in 29 CFR 3.3(b), 5.5(a) (3)(ii)(A) and 5.5(a)(a)(3)(ii))(B)(1) were revised to better protect the personal privacy of laborers and mechanics employed on covered construction contracts. See Final Rule published on December 19, 2009 (73 FR 77504-12) and OMB approval of information collection requirements published on January 16, 2009 (74 FR 2862).
Will the agency collect any personally identifiable information?
GSA is not collecting any data that is not already required by statute and regulation. The FAR
Data Collection System contains records related to prime contractors, subcontractors and their
employees who are performing on federal contract awards. Categories of records related to
employees of prime and subcontractors include, but are not limited to: name, unique identifier
assigned by the prime or subcontractor, work classification, regular and overtime hours worked
by day/date, total hours worked, fringe benefits, whether paid as hourly rate in cash amounts or
as an employer-paid benefit, and federal projects gross earnings. The link to the Federal
Register, published at 82 FR 12352 on March 2, 2017:
Will the agency use information technology to collect, maintain, or disseminate information that is subject to the E-Government Act of 2002 (44 U.S.C. 3501 note)?
No.
12. Sensitive Questions.
Provide additional justification for any questions of a sensitive nature.
Is the agency proposing any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, income, immigration status, or other matters that are commonly considered sensitive? (Note that the term “sensitive information” is distinct from the term “personally identifiable information,” although information may fall into both categories.)
No.
13. Burden Estimate.
Provide estimates of the burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates.
GSA will require contractors and subcontractors to enter the payroll data directly into the GSA Electronic Payroll Template portal to collect the information. The practice of entering the data into a form such as the WH-347 is a common practice and is required under the Copeland Act; therefore GSA is not adding to the current burden. This one-time keying in of the data in full, according to the DOL, will take an estimated 55 minutes to complete their WH-347 form. Using the DOL estimate for the initial keying in of the payroll data and the estimated minutes for subsequent payroll data review and updating, as necessary, the annual estimated total burden hours for this information collection is 5,205.
Respondents: 182 new prime construction contracts (170 number of prime Davis-Bacon contracts plus 12 subcontractor)
Responses per Respondent : 52 (1 for each week of the year)
Total Annual Responses: 9,464 (182 respondents x 52 responses)
Hours per Response: 33 minutes (weighted average of 56 minutes (DOL estimated time to input information plus 1 minute recordkeeping for initial entry) + 31 minutes (estimated time to certify payroll in new system plus 1 minute recordkeeping))
Total Burden Hours: 5,205 ((9,464 annual responses x 33 minutes)/60 minutes)
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under ‘Annual Cost to Federal Government’.
The annual estimated total cost burden to the public resulting from this information collection is $306,638. This is based on the following:
Total estimated response burden hours 5,205
Estimated cost per hour* x $58.72
Estimated total cost burden to the public $305,638
*The estimated cost per hour is based on the task being accomplished by mid level contractor personnel equivalent to a GS-12, Step 5 rate of $43.10 (Base Pay and Rest of US Locality Pay) (Salary Table 2018-GS, Effective January 2022), with fringe of 36.25% ($15.62) (OMB Memo M-08-13) for a total cost per hour of $58.72.
Explain the reason for any changes to the burden and fill out the tables below (*or another table that explains the changes, as appropriate). These could involve one of the following.
Changes Due to Adjustment in Agency Estimate: An “adjustment” to a burden estimate is made for two purposes: (1) when more (or fewer) individuals or entities respond to an information collection as a result of factors outside an agency’s control. In either situation, the agency has not made any change to the collection itself, and thus there has been simply an adjustment to a previously approved burden estimate.
GSA adjusted the existing burden estimates in the information collections for DOL, OMB Information Control No. 1235-0008, Davis-Bacon Certified Payroll from the 55 minutes burden for 12 months to only a 1-month period for the initial entry and 30 minutes for subsequent months. The proposed automated system will retain the previous record which will reduce their review and certification time to nearly half of the DOL estimated burden.
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Burden per Response:
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Annual Burden:
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The estimated total annual cost burden to the public is $264,475. This estimate is based on the following:
Estimated # of respondents (year) 182
Estimated # of submissions per respondent x 52
Estimated total # of submissions (year) 9,464
Estimated hours per request (minutes) x 33
Estimated total burden hours 5,205
Estimated cost per hour* $58.72
Estimated total annual cost burden to the public $305,638
The estimated cost per submission is approximately $30.34. This number was calculated by multiplying the estimated cost per hour ($58.72) by estimated hours per submission (i.e. 31 minutes).
*The estimated cost per hour is based on the Office of Personnel Management (OPM) GS-12, Step 5 salary of $43.10 per hour (see OPM Salary Table 2022-GS, Effective January 2022), plus a fringe factor of 36.25% ($15.62) (see OMB Memo M-08-13 for use in public-private competition), which results in an hourly rate of $58.72.
15. Estimated cost to the Government.
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. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
The estimated total cost to the Government is $18,497. This estimate is based on the following:
Estimated total # of submissions (year) 9,464
Estimated review time per submission (minutes) x 2
Estimated total review time per year (hours) 315
Estimated cost per hour* x $58.72
Total estimated annual cost to the Government $18,497
*The estimated cost per hour is based on the Office of Personnel Management (OPM) GS-12, Step 5 salary of $43.10 per hour (see OPM Salary Table 2022-GS, Effective January 2022), plus a fringe factor of 36.25% ($15.62) (see OMB Memo M-08-13 for use in public-private competition), which results in an hourly rate of $58.72.
16. Reasons for changes.
Explain the reasons for any program changes or adjustments reported on the burden worksheet.
This is a new information collection. GSA adjusted the existing burden estimates in the information collections for DOL OMB Information Control No. 1235-0008, Davis-Bacon Certified Payroll from the 55 minutes burden for 12 months to a more accurate weighted average of 33 minutes. The reduction in the burden is due to the use of the proposed automated system to retain the previous record and allow for the auto population of subsequent weekly payroll data. The automated system will reduce the amount of new data that needs to be entered weekly and will reduce their review and certification time considerably.
17. Publicizing Results.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Not applicable, results of this information collection will not be published. Information collected is used for internal purposes only, unless the contractor is not complying with the statute and regulatory requirements. In the case of noncompliance, GSA may be required to share information with DOL investigators.
18. OMB Not to Display Approval.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Not applicable, GSA is not seeking such approval for this information collection.
19. Exceptions to "Certification for Paperwork Reduction Submissions."
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
Not applicable, GSA is not seeking such approval for this information collection.
20. Surveys, Censuses, and Other Collections that Employ Statistical Methods.
If this request includes surveys or censuses or uses statistical methods (such as sampling, imputation, or other statistical estimation techniques), a Part B supporting statement must be completed.
Not applicable, GSA is not seeking such approval for this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2022-08-17 |