Representations and Certifications

OMB Control No: 3037-0013	ICR Reference No: 202411-3037-002
Status: Received in OIRA	Previous ICR Reference No: 201505-3037-001
Agency/Subagency: CPBSD	Agency Tracking No: 0013
Title: Representations and Certifications
Type of Information Collection: Reinstatement with change of a previously approved collection	Common Form ICR:  Yes
Type of Review Request: Regular	Date Submitted to OIRA: 11/20/2024

	Requested	Previously Approved
Expiration Date	36 Months From Approved
Responses	404	0
Time Burden (Hours)	8,080	0
Cost Burden (Dollars)	402,142	0

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Abstract: The data is integral to the Commission’s ability to ensure the integrity of the AbilityOne Program, which allows qualified NPAs employing people who are blind or have significant disabilities to collectively deliver $4 billion worth of products and services to the U.S. Government each year. The JWOD Act requires the Commission to monitor and validate several NPA performance outcomes. Additional data is needed to validate the effect and effectiveness of the AbilityOne Program in creating employment opportunities for people with disabilities and providing those individuals with the significant job supports and accommodations necessary for them to be successful.

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Authorizing Statute(s): US Code: 41 USC Chapter 85 Name of Law: JWOD Act

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 36770	05/03/2024
30-day Notice:	Federal Register Citation:	Citation Date:
	89 FR 90271	11/15/2024
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 Annual Representations and Certification Reps and Certs Annual Reps and Certs NPA Annual AbilityOne Representations and Certifications (ARC) Form 3 NPA Annual AbilityOne Representations and Certifications (ARC)

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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	404	0	0	-155	0	559
Annual Time Burden (Hours)	8,080	0	0	3,608	0	4,472
Annual Cost Burden (Dollars)	402,142	0	0	223,262	0	178,880

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: The Agency revised its burden estimate from the sixty-day notice in response to two commenters’ estimate that completion of the proposed form requires either ten (10) or twenty (20) hours to complete. After further revisions and adjustments based upon other comments received, the Agency revised its burden estimate to the most conservative hour burden offered by commenters – twenty (20) hours. The Agency estimates that it will take a human resources staff person (or an equivalent staff person) nine (9) hours to complete some sections of the form; a financial specialist nine (9) hours to complete other sections of the form, and two (2) hours by the Principal Officer to review and certify the form. To calculate the cost burden for this average annual burden, the Commission used national average pay data from the U.S. Bureau of Labor Statistics, using the May 2023 National Occupational Employment and Wage Estimate of $36.57 as the mean hourly wage for a Human Resources Specialist (OC 13–1070), $46.37 as the mean hourly wage for a Financial Specialist (OC 13–2000), and $124.47 as the mean hourly wage for a Chief Executive Officer (OC 11–1011). See https://www.bls.gov/news.release/ocwage.t01.htm.

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Annual Cost to Federal Government: $0

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.     No

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.     No

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

Agency Contact: Donald Rose 703 615-6281 [email protected]

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Common Form ICR:  Yes

Description/Changes for Common Form Usage:  The previous form had OMB No. 3037-0013 with an estimated burden of 8 hours for 570 NPAs (4,560 hours) at estimated $40 an hour ($182,400) with responses collected electronically as a signed .pdf. Note: recent public comment suggests actual burden is between 10-20 hours for the current 404 NPAs. The total NPA performance reporting/disclosure is reduced from approximately 154 mandatory responses to approximately 75 mandatory responses. Previous form contained 33 Yes/No response questions, requiring the NPA to affirm each of the AbilityOne qualification requirements of 41 CFR 51-4.2 and 4.3. If answered no, then the NPA must provide an explanation statement. Previous form required reporting of 101-104 numerical values (including zero) of NPA total year performance. The proposed form reorganizes and reduces the previous form collection as spelled out in the Supporting Statement.

Approved RCFs using this ICR

Agency/Sub Agency RCF ID RCF Title RCF Status IC Title

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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: 11/20/2024

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