1. Public Collections Training Paperwork Reduction Act
Washington Headquarters Services Executive Services Directorate Directives Division
Office of Information Management (OIM) DoD Information Collection Program
Public Collections Training Paperwork Reduction Act
Monday, September 19,

2. Agenda Paperwork Reduction Act
What is the Paperwork Reduction Act (PRA)?
Public Clearance & OMB Control Number 101
Members of the Public
PRA Exemptions
Know Your Component
Component Information Management Control Officers (IMCOs)
Component Coordination Point of Contacts
PRA Timeline & Process
Expectations for the PRA timeline
PRA process: Step by Step
Elements of a PRA Package
Calculating Burden
Questions, Comments, Concerns

3. What is the Paperwork Reduction Act? It’s all about the people!

4. Paperwork Reduction Act (PRA) of 1995: Overview
Public Information Requirements
The purpose of the PRA is to minimize paperwork burden on members of the public resulting from the collection of information by or for the Federal Government
Federal agencies shall not collect information from the public without first obtaining OMB approval, and should not seek to enforce or request compliance with disapproved or expired public information collections
Authority
Chapter 35 of Title 44 U.S.C. and its implementing regulation 5 CFR 1320 cover the policy for collecting information from the public
DoD Instruction and DoD Manual Volume 2 provides DoD policy and procedure for collecting information from the public
Enclosure 4 of DoD Manual Volume 2 provides the details of the submission process
Office of Information Management (OIM)
DoD CIO is Senior Official responsible for the PRA
DoD Clearance Officer resides in the WHS/ESD/DD Office of Information Management (OIM)
Mr. Frederick Licari
Information Management Analysts at OIM complete the final review of all DoD public collections

5. Paperwork Reduction Act (PRA):
PRA Public Protection Clause
Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information that is subject to the PRA if:
--The collection of information does not display a valid OMB Control Number assigned by OMB in accordance with the PRA.
--The Agency fails to inform the person who is to respond to the collection of information that such person is not required to respond to the collection of information unless it displays a valid OMB Control Number.
The protection provided by the PRA may be raised in the form of a complete defense, bar, or otherwise at any time during the agency administrative process or judicial action applicable thereto.
PRA Agency Disclosure Notice (ADN)
The public reporting burden for this collection of information is estimated to average XX [Insert the time in minutes/hours, as appropriate] minutes per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing the burden, to the Department of Defense, Washington Headquarters Services, Executive Services Directorate, Office of Information Management, 4800 Mark Center Drive, East Tower, Suite 02G09, Alexandria, VA (XXXX-XXXX)[Insert OMB Control Number]. Respondents should be aware that notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information if it does not display a currently valid OMB control number.
3 required elements on a public collection instrument – OMB Control Number, OMB Control Number Expiration Date, and Agency Disclosure Notice
[ADN has all these elements, but OMB Control Number / Expiration Date should go on everything the respondent sees]

6. Paperwork Reduction Act (PRA):
Failure to Comply
Failure to gain OMB approval, or to properly protect the public’s information can lead to several negative outcomes for the Department:
The Information Collection Budget (ICB) is an annual report to Congress required by law which includes all PRA violations for DoD – High visibility.
If collecting information without approval, the OMB, DoD CIO, or DoD Clearance Officer can order a cease and desist of the collection, and destruction of all information or systems used thus far.
Potential litigation can result from collecting this information without OMB approval or proper protection of the information

7. OMB Control Number 101
In most circumstances, OMB Control Numbers are valid for 3 years. When a Control Number nears expiration, DoD must reapply for OMB's approval or cancel the collection in order to prevent violations of the Paperwork Reduction Act.
OMB Control Numbers are comprised of two sets of four numbers, and all Control Numbers for DoD collections begin with 07.
The first four digits (0701) identify to which Component the collection belongs. The last four (0100) identify the specific collection belonging to that Component. In the above example, this would be the 100th collection belonging to the Department of the Air Force.
DoD OMB Control Number Prefix Key:
Air Force
Army
Navy
Most OSD Components
Army Corps of Engineers
Defense Health Agency
Comptroller
Rule-Related collections for OSD (rare)
To verify whether a public collection is valid, you can search by it’s OMB Control Number on the IC System ( or on RegInfo.gov (
Surveys must be cleared seperately

8. WHO ARE MEMBERS OF THE PUBLIC?
Contractors?
Applicants?
WHO ARE MEMBERS OF THE PUBLIC?
Retired military?
Veterans?
Spouses?

9. IDENTIFICATION Who are Members of the Public?
Individuals not employed by the Federal Government or Active Duty Military*
Partnerships, Associations, Corporations, Business Trusts or Legal Representatives
Not for Profit Organizations
Organized Groups of Individuals
State, Tribal, or Local governments
Members of Industry
Government Contractors
Foreign Nationals (Local Nationals)
Former/Retired Military
Veterans
Former/Retired Federal Employees
Spouses**
Dependents**
Other family members (parents, grandparents, aunts/uncles, cousins, siblings)* *
Guardians
Caregivers (any of the above, neighbor, friend, nurse)
Private sector doctors and nurses
Private sector attorneys
Banks
Credit Unions
* Federal Employees and Military Members can be considered members of the public if the collection of information is addressed to them in their capacity as private citizens (i.e., the Census).
** These populations can be considered “Internal” when information is being collected in survey format per 10 USC 1782 and tied to a Federal Program.

10. EXEMPTIONS BY STATUTE
10 U.S.C. Chapter 88, Sec “Surveys of Military Families”
Must be used to determine the effectiveness of Federal programs relating to military families and the need for new programs.
Members of the armed forces (active duty, active status, or retired);
Family members of such members; and
Survivors of deceased retired members and of members who died while on active duty.
Responses must be voluntary.
10 U.S.C. 503 “Enlistments: Recruiting Campaigns; Compilation of Directory Information”
The Secretary of Defense shall act on a continuing basis to enhance the effectiveness of recruitment programs of the Department of Defense through an aggressive program of advertising and market research targeted at prospective recruits for the armed forces and those who may influence prospective recruits.
The Secretary of Defense may collect and compile directory information pertaining to each student who is 17 years of age or older who is enrolled in a secondary school in the United States or its territories, possessions, or the Commonwealth of Puerto Rico. 13

11. ITEMS GENERALLY NOT CONSIDERED TO BE INFORMATION COLLECTIONS
Items Generally Not Considered To Be A Collection of Information
Affidavits, oaths, affirmations, certifications, receipts, changes of address, consents, or acknowledgments, provided that they entail no burden other than that necessary to identify the respondent, the date, the respondent's address, and the nature of the instrument.  (By contrast, a certification would likely involve the collecting of "information" if it were conducted as a substitute for a collection of information, to collect evidence of, or to monitor compliance with regulatory standards.)
Samples of products or of any other physical objects.  (This category includes requests for information that is already available in a form suitable for distribution and is provided in that form to all requesters.)
Facts or opinions obtained through direct observation by an employee or agent of the sponsoring Agency or through non-standardized oral communication in connection with such direct observations
Facts or opinions submitted in response to general solicitations of comments from the public, published in the Federal Register or other publications, provided that no person is required to supply specific information pertaining to the respondent, other than that necessary for self identification, as a condition to the Agency's full consideration of the comment
Facts or opinions, obtained initially or in follow-up requests, from individuals (including individuals in control groups) under treatment or clinical examination in connection with research on, or prophylaxis to prevent, a clinical disorder; direct treatment of that disorder; or the interpretation of biological analyses of body fluids, tissues, or other specimens; or the identification or classification of such specimens.  This includes medical records established as a result of this type of action
A request for facts or opinions addressed to a single person
Examinations designed to test the aptitude, abilities, or knowledge of the persons tested and the collection of information for identification or classification in connection with such examinations
Facts or opinions obtained or solicited at, or in connection with, public hearings or meetings
Facts or opinions obtained or solicited through non-standardized follow-up questions designed to clarify responses to approved collections of information
Like items so designated by OMB

12. EXEMPTIONS Exemptions
During the conduct of Federal criminal investigation or prosecution, or during the disposition of a particular criminal matter
During the conduct of a civil action to which the United States is a party, or during the conduct of an administrative action, investigation, or audit involving an Agency against specific individuals or entities
By compulsory process pursuant to Sections 41 and 1311 of Title 15 U.S.C.
During the conduct of intelligence activities, or during the conduct of cryptologic activities that are communications securities activities

13. EXEMPTIONS BY STATUTE
10 U.S.C. Chapter 88, Sec “Surveys of Military Families”
Must be used to determine the effectiveness of Federal programs relating to military families and the need for new programs.
Members of the armed forces (active duty, active status, or retired);
Family members of such members; and
Survivors of deceased retired members and of members who died while on active duty.
Responses must be voluntary.
10 U.S.C. 503 “Enlistments: Recruiting Campaigns; Compilation of Directory Information”
The Secretary of Defense shall act on a continuing basis to enhance the effectiveness of recruitment programs of the Department of Defense through an aggressive program of advertising and market research targeted at prospective recruits for the armed forces and those who may influence prospective recruits.
The Secretary of Defense may collect and compile directory information pertaining to each student who is 17 years of age or older who is enrolled in a secondary school in the United States or its territories, possessions, or the Commonwealth of Puerto Rico.

14. KNOW YOUR COMPONENT

15. POINT OF CONTACT FOR REVIEW & COMMUNICATION
Information Management Control Officer (IMCO): Each component has an individual (or team of individuals) specifically designated to act as liaison for OIM. It is the IMCO’s responsibility to track Component collections to ensure non-duplication, and timely renewal of collections.
Tracks the Component’s Active OMB Control Numbers and Expiration Dates.
Reviews SORNs and collaborates with Privacy Officers to identify PRA requirements.
Reviews the PRA package completed by the Action Officer prior to submitting to WHS/OIM for review.
Need to know who your Component IMCO is?
OIM maintains an IMCO POC list on their website

16. POINT OF CONTACT FOR REVIEW & COMMUNICATION
Component Privacy Officer (Privacy Act Statements, SSN Justifications, SORNs)
Component Records Manager (Records Retention Schedule)
Component CIO (Privacy Impact Assessment - PIA)
Component Forms Manager (Draft Form and Instructions, Final Instrument)
Component General Counsel (Sensitive Matters, Use of Incentives)
DMDC (Survey Review Memorandum)
HRPP (Sensitive Matters, Information Collections from Minors)

17. What is the main purpose of the Paperwork Reduction Act?
KNOWLEDGE CHECK
What is the main purpose of the Paperwork Reduction Act?
To minimize paperwork burden on members of the public resulting from the collection of information by or for the Federal Government.

18. Agency Disclosure Notice
KNOWLEDGE CHECK
What are the three elements required to be on all collection instruments?
_________________________________
OMB Control Number
OMB Expiration Date
Agency Disclosure Notice

19. PRA Timeline & Package Elements
BREAK
UP NEXT:
PRA Timeline & Package Elements

20. PRA:
Timeline and Process

21. PRA Timeline: Provide Sufficient Notice to the Public
Timeline is dictated mainly due to Federal Register requirements for proposed and submitted collections.
60 Day and 30 Day Comment Period
With these required comment periods, the process takes at minimum FOUR MONTHS.
Coordination
Each collection is different, and various offices may need to be involved in the development of this OMB package. We will touch more on this in a later slide. Not all coordinations are needed in every collection, but based on the method of collection, the storage of data, and use of the information, several offices could be involved.
Records Management
Privacy (Will discuss Privacy’s role a bit later)
Forms Management
CIO for PIAs
DMDC for surveys
General Counsel for high visibility, highly sensitive, or politically connected subject matters
HRPP regarding research
Internal Collections
An average collection takes SIX MONTHS to complete all the various coordinations and finalize documentation.
Planning ahead and early notification is the key to making this process more efficient.

22. PRA Timeline: STEP ONE: 60 Day Notice
This document starts the timeline. We ask Action Officers to complete this document first so that we can publish this and have the clock ticking. The document is mainly standard language, but there are highlighted sections in the template we ask the Action Officer to complete. Once this publishes in the Federal Register, the public has 60 days to submit comments for our review and adjudication.
STEP TWO: Supporting Documentation
While the Proposed Collection is out for comment, we encourage Action Officers to work on the supporting documentation during those 60 days. The supporting documentation will be reviewed by your IMCO and finally by OIM. There may be comments or revisions needed, so the earlier this process begins the better.
STEP THREE: Coordination
Also during these 60 days, the Action Officer can touch base with all the necessary offices for their collection. After discussing the collection with the IMCO and/or OIM, we should have a good idea of what coordinations are needed and can facilitate that collaboration.
STEP FOUR: 30 Day Notice & OMB Submission
Once the 60 day comment period has ended, coordination has been concluded, and both the IMCO and OIM have reviewed and approved the package as final, the 30 Day Notice can be published. This document is completed by OIM and WILL NOT be published until the PRA package is in its final form.
The date the 30 day notice publishes, OIM will submit the entire PRA package to OMB for review.
STEP FIVE: OMB Review and Approval
All comments received during the 30 day comment period will go directly to OMB. The DoD Desk Officer may come back with questions, or request changes to the documentation which we will have approximately one week to resolve. Once the 30 day comment period has closed, the Desk Officer has up to 30 additional days to make a determination. DoD will receive a Notice of Action stating the (expected) Approval and the new expiration date for the collection.

23. Elements of a PRA Package:
60 Day FR Notice – This document contains mostly standard language. The template has highlighted sections that need to be completed with information specific to this collection. The Component IMCO can assist the Action Officer with completing the burden section.
Supporting Statement, Part A – The Supporting Statement, Part A is required of all collections. This is the main document used by OMB to assess the collection and understand our Authority, Purpose, and Means of collecting the information from the public. The Template provides general instructions in each section to explain what OMB is looking for.
Supporting Statement, Part B – Part B is only required when a Survey is being used as the collection instrument. Part B specifically addresses the survey methods used, expected response rates, and analysis of the data gathered.
83-I Form – This is the “snapshot” view of the information gathered in the Supporting Statement Part A, which is more of a narrative explanation. The 83-I Form requires final signature before being submitted to OIM. Mr. Licari, as the Clearance Officer, will sign Section 19B before we submit to OMB for review.
Collection Instrument – OMB would like to see how/what you are collecting. This could be a form, survey, list of questions for an interview, focus group facilitator’s guide, respondent s, etc. We also clear systems, so screenshots of databases, online systems, or websites would also apply. OMB is making sure that all the appropriate notices are presented to the Respondent in addition to reviewing our method of collection.
Coordination Supporting Documentation – This will vary based on the collection, but some examples of this include: SORNs, PIAs, Privacy Act Statement, SSN Justification, a DoDI, DMDC review of surveys, a records management schedule, etc.
30 Day FR Notice – OIM writes and submits this document once the package is finalized. This notifies the public the collection is no longer proposed, it will be submitted to OMB for approval, and executed upon approval. Comments received go directly to the OMB Desk Officer.
MINIMUM Package Requirements for OIM Review: Collection instrument, 83-I, Supporting Statement Part A

24. KNOWLEDGE CHECK
What is the first step in beginning the public information collection clearance process?
60-Day FRN

25. KNOWLEDGE CHECK
What Coordination Points would be needed if you are conducting an online survey on Federal Employees, Spouses, and Contractors? The survey collects:
Name
Address
SSN
Phone Number
Privacy (PAS, SSN JM)
Records
CIO (PIA)
DMDC (Survey Review)
Corresponding Internal Information Collection

26. Estimation of Respondent Burden Hours
Burden Calculation
Table A:
Estimation of Respondent Burden Hours
Number of Respondents
(ONLY PUBLIC POPULATIONS!)
Number of Responses per Respondent (How many times does one individual provide this information on an annual basis?)
Number of Total Annual Responses
= Number of responses X Number of Responses per Respondent
Response Time (Amount of time needed to complete the collection instrument)
How long does it take each individual to read the instructions, gather appropriate information, and provide a response?
Respondent Burden Hours = Number of Total Annual Responses X Response Time
Form #1: 40  1
0.5 hours 20
Form #2:
 60  2
 120
 1 hour
120
Total
140
Total Annual Burden Hours

27. Burden Calculation 40 0.5 hours $7.25 120 1 hour $870 $1,015.20
Table B:
Labor Cost of Respondent Burden
Number of Responses
(This is the same as Number of Total Annual Responses in Table A)
Response Time per Response
(This is the same number as Response Time in Table A)
Respondent Hourly Wage
(Be sure to cite your source!)
Labor Burden per Response = Response Time per Response X Respondent Hourly Wage
Total Labor Burden
= Number of Responses X Labor Burden Per Response
Form #1: 40
 0.5
hours
$7.25
 $3.63
 $145.20
Form #2:
120
1 hour
$870
Total
$1,015.20
Total Annual Labor Cost of Respondent Burden
Source for Hourly Wage Information:

28. Questions on the PRA Paperwork and Process
Discussion:
Questions on the PRA Paperwork and Process

29. Contact Information / Helpful Websites
Directives Division Org. Box
Information Collections Org. Box
Information Collections Website
IC System

30. Class Evaluations / Feedback