Justification for a Non-Material/Nonsubstantive Change to OMB 1105-0030

JUSTIFICATION FOR A NON-MATERIAL/NONSUBSTANTIVE CHANGE TO OMB 1105-0030,
Electronic Applications for the Attorney General’s Honors Program and the Summer Law
Intern Program
1.

Circumstances of the Change: In 89 FR 22182, March 29, 2024, the Office of Management
and Budget announced revisions to OMB's Statistical Policy Directive No. 15: Standards
for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15).
The revised SPD 15 replaces and supersedes OMB's 1997 Revisions to the Standards for
the Classification of Federal Data on Race and Ethnicity. OMB took this action to meet its
responsibilities to develop and oversee the implementation of Government-wide
principles, policies, standards, and guidelines concerning the development, presentation,
and dissemination of statistical information. These revisions to SPD 15 are intended to
result in more accurate and useful race and ethnicity data across the Federal government.

2.

Effective Date: The provisions of these standards were effective March 28, 2024, for all
new record keeping or reporting requirements that include racial or ethnic information.
OPM directed that all existing record keeping or reporting requirements should be made
consistent with these standards through a non-substantive change request to the Office
of Information and Regulatory Affairs (OIRA), or at any time a collection of information is
submitted to OIRA for approval of either a revision or extension under the Paperwork
Reduction Act of 1995 (PRA), as soon as possible, but not later than March 28, 2029.

3.

Office of Attorney Recruitment and Management (OARM) Action: The previous
demographic form offered respondents the opportunity to select one category or
multiple categories. With this revision, the instructions for the Electronic Applications for
the Attorney General’s Honors Program and the Summer Law Intern Program voluntary
demographic information advise the applicant to select the “category or categories” with
which they most closely identify, advising that for equal opportunity reporting purposes,
the data is aggregated and that individual who check more than one box will be reported
in the category of “Multiracial and/or Multiethnic.” OARM also revised the list of
racial/ethnic groups to display them alphabetically, formatted using the race and ethnicity
questions with minimum categories and examples, as illustrated in Figure 2, 89 FR 22182,
22194. Due to space constraints, the examples are presented in the form of an
informational pop-up by each racial/ethnic category. OARM determined that the
potential benefit of more detailed data would not justify the additional burden to the
agency and the public or the additional risk to privacy or confidentiality. This change is
limited to the format of an optional demographic information provided by eligible
applicants to the Attorney General’s Honors Program and the Summer Law Intern
Program and will be effective with the 2024 hiring cycle. There is no impact on the public
burden or cost.