Washington Headquarters Services Executive Services Directorate Information Management Division

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Washington Headquarters ServicesExecutive
Services DirectorateInformation Management
Division OMB Collection Number Paperwork
Reduction Act DoD Public Collections Presented
to the Defense Privacy Board Patricia
Toppings DoD Clearance Officer
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• Paperwork Reduction Act (PRA)
• 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
• OMB approval is for a maximum of three years
• 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 8910.1 provides DoD policy and
  procedure for collecting information from the
  public
• Chapter 3 of DoD 8910.1-M provides the details of
  the submission process
• Background
• DoD CIO is Senior Official responsible for the
  PRA
• WHS/ESD Information Management Division
  implements PRA within DoD for the DoD CIO
• DoD Clearance Officer resides in the WHS/ESD
  Information Management Division

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• Paperwork Reduction Act (PRA) Public
  Information Requirements
• Information Collection Budget (ICB)
• ICB required by the Act (annual requirement)
• OMB provides ICB to Congress
• WHS/ESD Information Management Division submits
  annual ICB to OMB via the DoD CIO
• ICB report includes status of PRA violations
• Violations are due to failure to review active
  collections before their expiration dates, or to
  collecting information without OMB approval
• DoD is taking active steps to achieve zero PRA
  violations

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• Paperwork Reduction Act (PRA) Public
  Information Collections
• Process Requirements
• Two notices required to be published in Federal
  Register prior to OMB review
• 60-day notice, published by sponsoring agency,
  seeking public comment on proposed collection
• Submit via Component IMCO to osd.federal.register
  _at_whs.mil
• 30-day notice, published by WHS/ESD/IMD,
  announcing to public that the proposed collection
  has been sent to OMB and affording the public a
  second chance to comment
• Comments on 60-day notice go to the sponsoring
  agency
• Comments on 30-day notice go directly to the OMB
  Desk Officer
• OMB Desk Officer has a 30-day review period after
  the end of the comment period for the 30-day
  notice
• DoD has three OMB Desk Officers One assigned to
  collections for the Army Corps of Engineers, one
  assigned to collections for OASD(Health Affairs),
  one assigned to collections for the DARS (DFARS
  collections) as well as all other DoD
  collections.
• Entire process takes approximately 150 days (120
  days mandated by the PRA and 5 CFR 1320)
• Agencies need to plan ahead

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• Paperwork Reduction Act (PRA) Public
  Information Collections
• Public Information Collection Package
• OMB 83-I form
• Supporting Statement consisting of 19 elements
  that require answers
• (5 additional elements for surveys)
• Relevant portions of applicable laws and
  regulations that authorize the information
  collection
• Instrument of collection (form, survey, database
  screen shots etc.)
• Instructions or guidelines that accompany the
  instrument of collection
• DoD Clearance Officer will add the following
  documents to the package
• Copy of 60-day Federal Register Notice
• Copy of 30-day Federal Register Notice

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• Paperwork Reduction Act (PRA) Public
  Information Collections
• Emergency Public Information Collections
• DoD CIO must approve and make request to OMB to
  authorize emergency processing
• Requires written determination that agency cannot
  reasonably comply with normal processing because
• Public harm is likely to result if normal
  clearance procedures are followed
• An unanticipated event has occurred (natural
  disaster)
• Normal clearance procedures is likely to prevent
  or disrupt collection of information, or cause a
  statutory or court-ordered deadline to be missed
• Sensitive political issues may necessitate
  emergency processing
• Insufficient planning or administrative oversight
  do not warrant emergency processing
• Federal Register notice may or may not be
  required
• If Federal Register notice is required, the
  public is afforded a short comment period of two
  weeks
• Approval of an emergency package is good for 180
  days
• A regular submission package must follow, and all
  normal process procedures observed
• Process takes approximately 40 to 60 days

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• Paperwork Reduction Act (PRA) Public
  Information Collections
• Major Functions of the DoD Information Management
  Program
• Ensure that sufficient information is available
  to accomplish agency missions, to improve agency
  performance, and to achieve military
  effectiveness and management efficiency.
• Minimize and control the burden associated with
  the collection and reporting of information.
• Ensure that information requirements are valid,
  accurate, and essential to the mission of the
  requiring DoD Component.
• Avoid both duplication and unnecessary generation
  of data.
• Subject each new or revised information
  requirement to a cost estimate.
• Standardize data used to support DoD operations
  and decision-making.
• Ensure that recurring information requirements
  are assessed for validity, necessity, and
  adequacy no less than every three years.