The U.S. AbilityOne Commission® has required participating nonprofit agencies (NPAs) to submit an Annual Certification, through their respective Central Nonprofit Agency (CNA) for more than 30 years. This certification has two purposes, (1) to assure that the NPAs are complying with the Commission's regulations for maintaining qualification to participate in the AbilityOne® Program, and (2) to gather Program level data that the Commission can use to analyze, report on and further grow the Program. The Representations and Certifications (hereafter "Reps and Certs") being proposed for use beginning in 2015 are an expansion of the current certification (Forms 403/404) to more closely match the Commission's regulatory requirements and gather additional information on Federal procurement requirements that could affect a nonprofit agency's eligibility to hold AbilityOne contracts.
The requirement of Reps and Certs is drawn from the Federal Acquisition Regulation (FAR) and introduces a well-established Federal practice to the AbilityOne® Program. By aligning ourselves with other Federal requirements and adapting proven business practices, we increase the AbilityOne Program's credibility, accountability and stability. The use of Reps and Certs for AbilityOne information reporting is the result of a collaborative and robust effort to improve the Program's critical business processes.
This is a new form requiring the submittal of new information and thus requires more time to complete. In addition, the number of participating nonprofits has decreased since 2012 when the previous annual certifications were approved
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Amy Jensen 703 603-2132
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This single form will replace the two current annual certifications and be used by the Committee to ensure compliance with the Act and the implementing regulations. Without this information the Committee would be unable to assure that the participating nonprofit agencies meet the requirements of the JWOD Act and the implementing regulations. The data on the form is also used to collect information so that the Committee can report on the status and changes in the AbilityOne Program to the President as required in the Act.
Section 6 of the form contains 17 questions that are directly related to the requirements that the nonprofit agencies must meet to maintain their qualification to participate in the Program (41 CFR 51-4.3). Section 7 contains seven questions that deal with ensuring that the participating nonprofit agencies are meeting general stewardship requirements and that the Committee is aware of management changes. Section 8 contains 5 questions that are identical with questions asked of all Federal contractors via the System Award Management to ensure that the Committee is aware of any potential issues that would prevent contracts being issued to nonprofits.
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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:
(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.