Background Investigations for Child Care Workers, GSA Form 176

Forms and Documents

Document Name	Status
Form GSA Form 176 Background Investigations for Child Care Workers, GSA Form 176 Form and Instruction	Unchanged
3090-0287_Supporting Statement A -2024.docx Supporting Statement A	2024-11-07

IC Document Collections

IC ID	Document Title	Status
190281	Background Investigations for Child Care Workers, GSA Form 176 Form and Instruction	Unchanged

ICR Details

OMB Control No: 3090-0287	ICR Reference No: 202411-3090-002
Status: Received in OIRA	Previous ICR Reference No: 202110-3090-001
Agency/Subagency: GSA	Agency Tracking No:
Title: Background Investigations for Child Care Workers, GSA Form 176
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 11/07/2024

	Requested	Previously Approved
Expiration Date	36 Months From Approved	11/30/2024
Responses	3,060	3,060
Time Burden (Hours)	1,530	1,530
Cost Burden (Dollars)	0	0

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Abstract: Homeland Security Presidential Directive (HSPD) 12 “Policy for a Common Identification Standard for Federal Employees and Contractors” (the Directive) requires the implementation of a government-wide standard for secure and reliable forms of identification for Federal employees and contractors. OMB’s implementing instructions requires all contract employees requiring routine access to federally controlled facilities for greater than 6 months to receive a background investigation. The minimum background investigation is the Tier 1 and the Office of Personnel Management offers a Tier 1C for childcare. However, there is no requirement in the law or HSPD-12 that requires childcare employees to be subject to the Tier 1C since employees of childcare providers are neither government employees nor government contractors. The childcare providers are required to complete the criminal history background checks mandated in the Crime Control Act of 1990, Pub. L. 101-647, dated November 29, 1990, as amended by Pub. L. 102-190, dated December 5, 1991. These statutes require that each employee of a childcare center located in a Federal building or in leased space must undergo a background check that is: 1) based on fingerprints taken by a law enforcement officer and on other identifying information, 2) conducted through the FBI's Identification Division and through the State criminal history repositories in each state in which the childcare employee has been a resident or has listed in an employment application, and 3) initiated through the personnel program of the applicable employing agency. According to GSA policy childcare workers (as described above) will need to submit the following: 1. An original signed copy of a Basic National Agency Check Criminal History, GSA Form 176; and 2. Two (2) sets of fingerprints on Form SF-87 and /or electronic prints from an enrollment center 3. Electronically submit the e-QIP (SF85) application for completion of the Tier 1C

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 59099	07/22/2024
30-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 88050	11/06/2024
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Background Investigations for Child Care Workers, GSA Form 176	GSA Form 176	Basic National Agency Check Criminal History (Child Care Workers)

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	3,060	3,060	0	0	0	0
Annual Time Burden (Hours)	1,530	1,530	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $43,529

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     Yes

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 11/07/2024

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