DS-5520_Expires 022924_OMB No 1405-0215_30-day FRN_PRA Supporting Statement

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

Supplemental Questionnaire to Determine Identity for a U.S. Passport
OMB Number 1405-0215
DS-5520

A. JUSTIFICATION

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

The Supplemental Questionnaire to Determine Identity for a U.S. Passport, form DS-5520, is used to supplement an application for a U.S. passport when the applicant submits identity evidence that is insufficient or of questionable authenticity. Passport Specialists and Consular Officers will use this form to collect additional information to further establish the identity of a passport applicant who has not submitted adequate evidence with their initial passport application.

The DS-5520 solicits data necessary for Passport Services to issue a U.S. passport in the exercise of responsibilities granted to the Secretary of State in 22 U.S.C. 211a et seq. and Executive Order 11295 (August 5, 1966) for the issuance of passports to U.S. citizens and non-citizen nationals. Such responsibilities require the determination of identity and nationality with reference to the provisions of Title III of the Immigration and Nationality Act (8 U.S.C. sections 1401 – 1504) and the 14^th Amendment to the Constitution of the United States, and compliance with 22 U.S.C. 212 and 213.

By definition, a passport is a travel document issued under the authority of the Secretary of State attesting to the identity and nationality of the bearer (22 C.F.R. 51.1 (d)). An applicant bears the burden of establishing their identity and citizenship, and the Department of State (the Department) may require an applicant to submit such additional evidence of identity and/or citizenship as it deems necessary (22 C.F.R. §§ 51.23, 51.40, 51.45). The requirements for establishing an applicant’s identity and citizenship are outlined in 22 C.F.R. Parts 50 and 51.

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

The Department uses this information to verify the respondent’s identity for purposes of determining eligibility for a U.S. passport. The information is also used to combat passport fraud and misuse. This form is used to supplement an existing passport application and solicits information relating to the respondent’s employment and residence that is needed to corroborate an applicant’s identity claim prior to passport issuance. Without adequate information about an applicant, the Department cannot issue that applicant a U.S. passport. Furthermore, inaccurate evidence or information could possibly result in issuance of a passport to a non-U.S. citizen or to a U.S. citizen using an assumed identity. In addition to this primary use of the data, the DS-5520 may be used as evidence in the prosecution of any individual who makes a false statement on the application and for other uses as set forth in the Department’s Prefatory Statement of Routine Uses, the Passport System of Records Notice (State-26) and the Overseas Citizens Services System of Records Notice (State-05).

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

If the information on the DS-5520 is needed, a passport agency will mail the form directly to the applicant for completion and return or the applicant can download and complete a fillable PDF version found at travel.state.gov.

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

The information collected does not duplicate information collected elsewhere.

5. Describe any impacts on small business.

The collection of information does not involve small businesses or other small entities.

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

The information cannot be collected less frequently. It must be collected to issue a passport, document, or render a service. Eliminating the Department’s ability to solicit vital identity information from knowledgeable sources in connection with passport services could result in unnecessary passport denials and/or issuance of passports to ineligible applicants.

7. Are there any special collection circumstances?

No such special circumstances exist.

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

On December 26, 2023, the Department published a 60-day notice in the Federal Register to solicit public comments (Public Notice: 12287). No comments were received.

9. Are payments or gifts given to the respondents?

This information collection does not provide any payments or gifts to respondents.

10. Describe assurances of privacy/confidentiality

There are no assurances of privacy or confidentiality. The form includes a Privacy Act Statement explaining the routine use and other exceptions to the Act. (5 U.S.C. § 552a). Passport applicants are required to submit their Social Security number with the passport application and failure to provide a Social Security number may result in processing delays.

11. Are any questions of a sensitive nature asked?

The DS-5520 does not ask questions of a sensitive nature.

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

Respondent Hour Time Burden and Hour Cost Burden:

The DS-5520 is sent to applicants, along with an Information Request Letter, when applicants need to provide additional information to establish their identity.

The projected average number of annual respondents from FY 2023-25 is 10,000.

The estimated number of minutes per response is based on a sampling of the time required to search existing data sources, gather the necessary information, provide the information required, review the final collection, and submit the collection to Passport Services for processing. Passport Services estimates that the average time required for this information collection is 45 (minutes) per response. Therefore, the estimated total annual respondent hour burden is 7,500 hours.

(10,000 respondents x 45 minutes / 60 = 7,500 annual hours)

The estimated cost to respondents is based on the civilian hourly wage listed in the Employer Costs for Employee Compensation released by the Bureau of Labor Statistics in 2021. The base hourly wage is estimated to be $28.01ⁱ. We also incorporate a benefit multiplier of 1.3 and the total hourly wage is calculated to be $36.41. The total hourly wage of $36.41 is then multiplied by the annual time burden of 7,500 hours. Therefore, the estimated total annual respondent hour cost burden is $273,075.

($36.41 total hourly wage x 7,500 annual hours = $273,075)

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

There is no cost to the respondent.

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

Government Adjudication Cost:

To calculate the cost to the Federal Government, we use the hourly wage for a FY 2023 domestic Civil Service GS-11 step 10 (the highest level of a passport adjudicator), which is $36.95ⁱⁱ - along with a weighted wage rate multiplier. Department employees have access to many resources, so we use two (2) as the weighted wage rate multiplier - as suggested by the Office of Management and Budget. Therefore, the hourly wage is set as $73.90.

($36.95 x 2 = $73.90)

Passports Services estimates that reviewing the DS-5520 requires 25 minutes of a passport adjudicator’s time. Dividing $73.90/hr. by 60 minutes yields a processing time cost of $1.23 per minute, and that cost multiplied by 25 (minutes) totals $30.75. Multiplying the projected number of annual respondents (10,000) by $30.75 yields $307,500. This adjudication cost will be added to the cost to the Federal Government to print the form and publish the Federal Register Notices (FRNs).

Government Printing Cost:

Hard copies of form DS-5520 are only available from Department facilities. When a passport agency requires this information, it mails a physical copy of the form to the applicant. The cost of printing this form in-house (it is not printed in bulk like other passport forms) is approximately $0.025 per page, or $0.075 per form. Multiplying the projected number of respondents (10,000) by $0.075 yields an annual printing cost of $750.

Government Federal Register Notice Cost:

The cost to publish one Federal Register Notice (FRN) is $795. A 60-day FRN and a 30-day FRN is published for this form with a total cost of $1,590.

Cost to Federal Government

Adjudication cost	10,000 x $30.75 =	$307,500
Printing cost	10,000 x $0.075 =	$750
Federal Register Notice cost	2 x $795 =	$1,590
TOTAL		$309,840

15. Explain any changes/adjustments to this collection since the previous submission

In addition to general format changes, the following content changes have been made to the form:

There are no substantive changes to the form.

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

The collection of information will not be published for statistical use.

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

The expiration date for OMB approval will be displayed.

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

No exceptions to the OMB certification statement are requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

i Source: Bureau of Labor Statistics, “Employer Costs for Employee Compensation – May 2021,” https://www.bls.gov/oes/current/oes_nat.htm#00-0000

ii Source: Office of Personnel Management, “Pay & Leave,” https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2023/general-schedule