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. Treasuryâs draft acquisition policy introduces two standardized deliverablesâthe Staffing Plan (pre-award) and Monthly Workforce Report (post-award)âto 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. Treasuryâs 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 OIRAâs expedited six-month approval under 5 CFR 1320.13(c), with waiver of the Federal Register notice, to enable immediate implementation and support the Departmentâs 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.
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