Information requested of contractors
is specific to each contract and is required for Treasury to
properly evaluate the progress made and/or management controls used
by contractors providing supplies or services to the Government,
and to determine contractors' compliance with the contracts, in
order to protect the Government's interest.
The Department of the
Treasury requests emergency processing under 5 CFR 1320.13 for two
Information Collection Requests (ICRs) supporting the draft
Acquisition Procedures Update (APU) 26-01, Mandatory Staffing Plan
for All Small Business Preference Program Awards and Solicitations.
Treasury seeks approval by November 4, 2025 to enable immediate
collection of contractor workforce data in response to urgent
government-wide concerns regarding small-business subcontracting
compliance and transparency in contract performance. Recent
government-wide investigations by the Small Business Administration
Office of Inspector General (SBA OIG) and the Government
Accountability Office, coupled with widespread media coverage of a
Treasury contractor subcontracting scandal, have exposed systemic
risks of improper pass-through contracting and noncompliance with
FAR 52.219-14, Limitations on Subcontracting, across the federal
acquisition landscape. The absence of standardized, data-driven
reporting on prime versus subcontractor labor utilization has been
identified as a vulnerability throughout government. Treasury’s
draft acquisition policy introduces two standardized
deliverables—the Staffing Plan (pre-award) and Monthly Workforce
Report (post-award)—to increase visibility, strengthen internal
surveillance, and reinforce public trust through proactive
corrective measures. Delaying implementation until completion of
normal Paperwork Reduction Act clearance procedures would undermine
these efforts and perpetuate risk during active oversight
investigations. Treasury’s ability to document and monitor
contractor performance in real time is essential to ensuring that
small-business set-aside awards meet self-performance requirements
and maintain program integrity. The requested emergency clearance
will allow Treasury to pilot and refine the collection methodology,
gather baseline data, and support interagency coordination with SBA
and OMB to inform a permanent, government-wide solution. The
information collection involves minimal burden and privacy risk.
Contractors will report aggregated staffing data using secure,
standardized templates that rely on information already maintained
in existing HR or timekeeping systems. No Social Security Numbers
or dates of birth are collected, and all submissions are encrypted,
marked CUI//SP-PRVCY, and transmitted only to authorized
acquisition officials. Treasury respectfully requests OIRA’s
expedited six-month approval under 5 CFR 1320.13(c), with waiver of
the Federal Register notice, to enable immediate implementation and
support the Department’s leadership in restoring accountability and
transparency across the federal small-business contracting
community.
There is an increase in burden
due to agency discretion as a result of reinstating this OMB
approval, however estimates have been updated based on recent
contract award information, resulting in a lower total burden than
had been previously approved due to a reduction in the total number
of contractors. The new monthly workforce report form will not
result in an increase in burden as the minimal additional time
required to complete this form is reasonably accounted for within
the existing per response estimate of 24 hours.
$0
No
No
No
No
No
No
No
Alan Monico 202 570-3493
alan.monico@treasury.gov
No
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:
(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;
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.
Post-Contract Award Information