Office of the Assistant Secretary for Administration and
Management (OASAM)

300 Introduction to the Departmental Information Management Program

301 Purpose. To establish policy, assign responsibilities, and provide general procedures for the Department of Labor (DOL). The Information Collections Management Program is designed to ensure effective, economical, and efficient information collections in compliance with the Paperwork Reduction Act and 5 CFR 1320.

302 Scope. The provisions of this chapter apply to all DOL components responsible for developing and implementing public-use and interagency collections and reporting activities in order to implement their programs.

303 Objectives. The Departmental Information Collections Management Program is designed to improve the quality and economy of information collections, and help DOL managers implement information collection responsibilities in an effective, uniform, and efficient way. To meet these objectives, the program seeks to:

1. Provide needed information to managers in the most efficient format possible.
2. Eliminate nonessential information collections through careful identification of information needed at every organizational level.
3. Limit the number, frequency, and scope of information collections.
4. Ensure compliance with the statutes and regulations governing Federal information collections and information collection systems through the conduct of objective reviews.

304 Definitions. For purposes of this chapter, the following definitions apply:

1. DOL Agency. An organizational component within DOL for which there is an Assistant Secretary or other senior official with similar responsibilities (e.g., the Employment Standards Administration).
2. Information Collection. The obtaining, causing to be obtained, soliciting, or requiring the disclosure to an agency, third parties or the public of information by or for an agency by means of identical questions posed to, or identical reporting, recordkeeping, or disclosure requirements imposed on, 10 or more persons, whether such collection of information is mandatory, voluntary, or required to obtain or retain a benefit.
3. Information Collection Reporting System. Any organized and systematic method, either manual or automated, used to collect, organize, process, transmit, and retain data or information.
4. Information Collections Management Program. A formally established agency function that is authorized and funded to fulfill information collections management objectives.
5. Persons. Includes individuals, partnerships, associations, corporations (including operations of government-owned contractor-operated facilities), business trusts, legal representatives, organized groups of individuals, State, territorial, tribal, or local governments or branch thereof, or political subdivisions of a State, territory, tribal, or local government or a branch of a political subdivision. Any recordkeeping, reporting, or disclosure requirement contained in a rule of general applicability is deemed to involve ten or more persons.
6. Interagency Information Collection. Any information collection required by one agency from one or more other agencies, including Federal, State, or Local governments, and subject to review and clearance by GSA as provided in section 340 in this chapter.

310 Authority, Policy, and Responsibilities

311 Authority

1. Public Law 104-13, the Paperwork Reduction Act of 1995 (44 United States Code (USC) Chapter 35). Its predecessors are the Paperwork Reduction Reauthorization Act of 1986 and the Paperwork Reduction Act of 1980.
2. Title 5, Part 1320, of the Code of Federal Regulations (5 CFR 1320). Executive Order 12866 of September 30, 1993.
3. Government Paperwork Elimination Act (GPEA), Public Law 105-277, Title XVII.
4. Secretary's Order 1-2000 Authority and Responsibilities for Implementation of the Paperwork Reduction Act of 1995 (P.L. 104-13) and the Clinger-Cohen Act of 1996 (Information Technology Management Reform Act of 1996) (Division E of P.L. 104-106)

312 Policy. To establish and administer an effective, efficient, and economical Information Collection Management Program in DOL in order to ensure that collected data are adequate, timely and have practical utility.

313 Responsibilities:

1. The Chief Information Officer (CIO) pursuant to the authority and responsibility specified S.O. 1-2000, section 3506(a) of the Paperwork Reduction Act of 1995 (P.L 104-13), Clinger-Cohen Act of 1996 (40 U.S.C. 1425), and the Information Technology Management Reform Act of 1996 (Division E of P. L. 104-106) must:
   1. Ensure compliance by all DOL agencies with the prompt, efficient, and effective implementation of the information resource management responsibilities and the reduction of information collection burdens on the public. To fulfill this responsibility, the CIO will:
      1. review the need, function, plan, and burden of each information collection;
      2. ensure that each information collection is inventoried, displays a control number, and discloses all necessary information, as described at 44 U.S.C. 3506(c)(1)(B);
      3. assess the information collection impact of proposed legislation affecting DOL.
   2. Ensure that proposed collections of information covered by section 3506(c)(2)(A), 44 U.S.C. 3506(c)(2)(A) are published in the Federal Register in order to solicit comments from members of the public and affected agencies with regard to each collection to:
      1. evaluate whether the proposed collection of information is necessary and has practical utility.
      2. evaluate the accuracy of the DOL program agency’s burden estimate;
      3. enhance the quality, utility, and clarity of the information collected; and
      4. minimize the burden of the collection of information.
   3. Ensure that DOL program agencies provide notice and an opportunity to comment specifically on any collections of information contained within notices of proposed rule making, interim final rules, and final rules published in the Federal Register.
   4. Certify and provide supporting documentation, for each collection of information submitted to the Office of Management and Budget (OMB) for review under 44 U.S.C. 3507, that the DOL program agency has fully complied with all PRA provisions, as described at 44 U.S.C. 3506(c)(3).
   5. Designate an individual to serve as the Departmental Clearance Officer.
   6. Maintain liaison with the Office of Management and Budget (OMB) and General Services Administration (GSA) on information collection management activities.
   7. Develop, establish, and publish departmental information collections management policy and objectives.
   8. Develop and issue departmental standards and guidelines for the establishment and use of information collections, in accordance with governing statutes, regulations, policies, and procedures.
   9. Advise and assist DOL Agencies in establishing and administering an effective information collection management program.
   10. Direct and coordinate periodic reviews of DOL Agency information collections management activities.
   11. Ensure that all information collections subject to the Paperwork Reduction Act of 1995 (PRA 95) receive appropriate clearances.
   12. Identify categories of information exempt from information collections clearance procedures and approving exemption as evidenced in 41 CFR, section 101-11.204 and 5 CFR 1320.4
   13. Maintain current inventories of interagency and public-use information collections.
   14. Inform an Agency Clearance Officer at least 150 days in advance of an expiring collection and request an information collection request if the agency intends to extend the collection beyond the current expiration date.
   15. Inform DOL Agency Clearance Officers of any departmental policies or procedures pertaining to information collections not explicitly covered by 5 CFR 1320 (for example, generic clearances or bundled ICRs).
2. DOL Agency Heads are responsible for:
   1. Establishing and implementing an effective Agency Information Collections Management Program within their respective organizations.
   2. Ensuring that information collection requests for collections that are to be extended after the current expiration date enter the clearance process at least 120 days prior to the date the collection is scheduled to expire and are submitted to the Departmental Clearance Officer no later than 75 days prior to the expiration date.
   3. Designating an individual to serve as their Agency Clearance Officer and notifying Departmental Clearance Officer in writing of the name, title, location, and telephone number of the designee, including subsequent changes of designees.
   4. Establishing and implementing agency standards and procedures for the establishment and use of information collections in accordance with governing regulations and DOL policy.
   5. Establishing procedures for periodic reviews of approved information collections in terms of need, adequacy, design, economy of preparation, use, and processing.
   6. Ensuring that agency information collection activities comply with departmental policy, procedures, standards, and applicable statutes and regulations.
   7. Ensuring data collected through information collection activities are preserved in accordance with DLMS 1, Chapter 400; Federal laws and regulations relative to the preservation and destruction of Federal records; and applicable guidance from the National Archives and Records Administration (NARA).
   8. Delegating to the Agency Clearance Officers responsibilities for:
      1. Coordinating information collection management activities with the Departmental Clearance Officer and administering information collection clearance procedures.
      2. Reviewing agency information collections to improve the information collection quality, and providing information collections analysis services to agency organizational components.
      3. Monitoring agency information collection activities to ensure compliance with applicable statutes, regulations, policies, procedures, and standards, and maintaining accurate and complete historical case folders on all information collections.
      4. Managing records including disposition schedules relative to agency information collection activities in accordance with DLMS 1, Chapter 400; Federal laws and regulations relative to the preservation and destruction of Federal records; and applicable guidance from NARA.
3. Regional DOL Agency Heads are responsible for information collection management functions as delegated by their respective Agency Heads in the National Office.
4. The Commissioner, Bureau of Labor Statistics (BLS) has overall responsibility for:
   1. Reviewing proposed, revised, or reinstated statistical surveys and plans to ensure statistical adequacy of the survey methodology.
   2. Providing technical assistance in the design of statistical information collection plans and forms (see Attachment B).

320 Information Collection Budget (ICB).

Annually, OMB issues a data request via an OMB Bulletin to all Federal agencies, which contains instructions for agency preparation of their ICB submissions. All collections of information currently approved, as well as new collections projected during the upcoming fiscal year, are listed on the ICB. The ICB serves as a mechanism to implement the paperwork reduction program and to helps Executive Branch departments in better management and control the use of Federal information collections. OCIO will establish a timeframe for DOL Agency submissions to the ICB based on OMB's timeframe of issuance.

DOL Agencies will ensure that their respective fiscal year ICB submissions are properly reviewed, updated, and modified based on program input. Agencies will subsequently submit their proposed ICBs to the OCIO for review and approval. A comprehensive DOL ICB will then be prepared and forwarded to OMB with copies to each agency head.

330 Information Collection Requirements

331 General: DOL Agencies will ensure that their information gathering activities and rulemakings impose no more than the minimum burden on the public consistent with the need for information. OMB Form 83-I, "Paperwork Reduction Act Submission," and the “Supporting Statement for Paperwork Reduction Act Submissions,” are used for clearance and authorization under the Paperwork Reduction Act of 1995 (PRA 95).

332 Obtaining OMB Forms. The OMB 83-I (Paperwork Reduction Act Submission), OMB 83-C (Paperwork Reduction Act Change Worksheet), and the OMB 83-E (Paperwork Reduction Act Emergency Extension) can be found on the OMB Internet site. Included with the OMB-83-I are the instructions for filling out the form and for developing a Supporting Statement for Paperwork Reduction Act Submissions. Additionally, the DOL LaborNet site has electronic versions of the OMB 83-I and OMB 83-C.

333 DOL Agency Clearance. When a new information collection is developed or an existing one is to be revised or extended, the DOL Agency Clearance Officer, in consultation with the Office of the Solicitor as appropriate, is responsible for:

1. Ensuring that an information collection is necessary for the proper performance of the agency’s functions and has practical utility.
2. Ensuring the information collection is conducted in a manner that minimizes public burden.
3. Reporting on the use of improved technology for the purpose of information collection activities, including compliance with GPEA (Public Law 105-277, Title XVII).
4. If applicable, ensuring compliance with OMB’s Statistical Policy Directive No. 15, Race and Ethnic Standards for Federal Statistics and Administrative Reporting (see Federal Register, Part II, October 30, 1997).
5. If the collection employs statistical methodologies, ensuring that BLS input has been obtained before the information collection request is submitted for clearance and that the BLS concurrence sheet is forwarded with the ICR (see Attachment B).
6. Ensuring compliance with the Privacy Act of 1974 as Amended 5 U.S.C. 552a.
7. Ensuring that all factors outlined in OMB’s guidance on estimating paperwork burden and as well as instructions for completing the supporting statements of an information collection request are given appropriate consideration when estimating Federal and public costs and determining burden hours of information collections.
8. Reviewing the PRA submission package for substance and completeness, and clearing PRA submission packages within the organization to ensure against duplication or overlap.
9. Reviewing the pre-clearance Federal Register notice for accuracy and statutory authority.
10. Ensuring that pre-clearance Federal Register notices are published in accordance with the 20 CFR 1320.8(d).
11. Ensuring pre-clearance Federal Register notices are published at least 120 days prior to the expiration date of an existing collection seeking an extension.
12. Forwarding an original and two copies of the complete information collection request to Departmental Clearance Officer along with burden estimates and description as outlined in Attachment A of this Chapter.
13. Information collection requests are to be submitted to the DOL PRA control desk to be logged into the departmental information collection requests tracking system. Exiting collections seeking an extension, should be logged in no later than 75-days prior to the current expiration date.

334 Departmental Clearance. The Departmental Clearance Officer will review information collection requests to determine whether the:

1. DOL Agency Clearance Officer has reviewed and submitted a signed original and two copies of the OMB 83-I and Supporting Statement in the proper format.
2. b. Information collection complies with legal requirements of the PRA and GPEA to reduce, minimize and control burdens and maximize the practical utility and public benefit of the information created, collected, disclosed, maintained, used, shared, and disseminated by or for the Federal government.
3. OMB 83-I and Supporting Statement are complete and the proposal does not overlap, or duplicate any existing collections; information collections impose no more than a minimum burden upon the public and estimates of respondent cost and hour burdens are reasonable.
4. Information collection request complies with the general requirements of 5 CFR 1320.5 and that any special circumstances contained in 5 CFR 1320.9 and 5 CFR 1320.8(b)(3) are adequately justified in the supporting statement.
5. Agency has consulted with BLS on the use of statistical methodologies and will use OMB approved statistical data classifications.
6. Pledge of confidentiality included by an Agency will be supported by authority established in statute or regulation, supported by disclosure and data security policies that are consistent with the pledge, and will not impede sharing data with other agencies for compatible confidential use.
7. Agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law when respondents submit proprietary, trade secret, or other confidential information.

335 OMB Clearances. Normally, DOL and OMB reviews require a lead-time of 75 days prior to the expiration date of an existing information collection. OCIO requires 15 working days and OMB 60 calendar days for clearance under usual circumstances. When requesting OMB clearance for a collection of information, the Departmental Clearance Officer is responsible for:

1. Analyzing information collection requests for completeness, accuracy, compliance with 5 CFR 1320 and all other applicable statutes (see section 311), duplication, statutory authority, and soundness of burden calculation methodologies.
2. Forwarding the signed OMB 83-I and information collection to OMB.
3. Publishing a 30-day comment period notice in the Federal Register to advise the public that OMB clearance is being sought.
4. Notifying DOL agencies when OMB has provided comments or questions regarding the information collections. Upon resolution of changes, or any challenges to suggested changes, the information collection request will follow regular clearance procedures.
5. Ensuring that the sponsoring agency receives an OMB Notice of Action within 24-hours from receipt by DOL.
6. If OMB fails to issue a Notice of Action within 60-days of its receipt of an information collection request, asking the sponsoring agency whether it wishes to request that OMB assign a control number valid for not more than a year, and making such request to OMB.
7. Managing all departmental information collection requests activity that is covered by the Paperwork Reduction Act and 5 CFR 1320.

336 Collections of Information Contained in Regulatory Actions (e.g., Final Rule, Interim Final Rule, or Notice of Proposed Rulemaking).

Regulatory actions that involve paperwork burdens are subject to both the procedures set forth in DLMS 3-2 and the procedures set forth in this chapter. In this regard:

1. An agency, through counsel, has the primary responsibility for ensuring that the preamble of any regulatory action contains all required information about paperwork burdens, and the primary responsibility for communications with OMB about paperwork burdens associated with a regulatory action when such regulatory action is under OMB review.
2. The Departmental Clearance Officer has the primary responsibility for ensuring that the formal information collection request (ICR) contains all required information and the primary responsibility for communications with OMB concerning the ICR.
3. If the regulatory action involves paperwork burden as described in 5 CFR 1320.3, the sponsoring agency must prepare, clear with its Associate Solicitor, and submit, in accordance with the procedural requirements of this chapter, three copies of the ICR to the Departmental Clearance Officer at least 15 days prior to the publication of the regulatory action. This will ensure that the ICR reaches OMB on or before the date the regulatory action is published in the Federal Register. The Departmental Clearance Officer will either transmit the ICR to OMB or return it to the sponsoring agency if the ICR does not contain all required information. If OMB raises concerns about the ICR, it will schedule a meeting through the Departmental Clearance Officer, who will contact the sponsoring agency. The Departmental Clearance Officer will notify the sponsoring agency of OMB approval or disapproval of the ICR.
4. The sponsoring agency will publish a notice about the information collection in the Federal Register informing the public of OMB's decision on the information collection: 1) after receiving notification of OMB's approval or disapproval; and 2) prior to the effective date of the regulatory action. The agency may include the notice in the regulatory action, provided OMB approval or disapproval has been received prior to publication. The Federal Register notice will include the OMB approval number and the expiration date.

337 Notice of Discontinuance. When an approved information collection is to be discontinued, the sponsoring DOL Agency will notify the Departmental Clearance Officer, at least 30 days prior to the discontinuance, with the form OMB 83-C (Change Worksheet), so that the Departmental Clearance Officer can notify OMB.

338 Notification of Violations. The failure of a sponsoring agency to meet the paperwork obligations outlined in this chapter places the Department at risk of incurring a potential paperwork violation. The Departmental Clearance Officer will notify the Chief Information Officer of the potential violation in a timely manner.

340 Interagency Information Collections

341 Clearance Requirements. DOL must clear its interagency information collection requirements as provided in this section and 41 CFR section 101-11.204.

1. The Departmental Clearance Officer serves as the DOL interagency reports liaison with GSA for interagency information collection matters.
2. DOL Agencies initiating new, revised, or extended interagency forms should seek assistance from GSA, through the Departmental Clearance Officer, in defining and assessing related interagency information collection requirements.
3. Interagency information collections that also are public information collections require OMB clearance and should be forwarded to OMB and GSA concurrently.

342 Clearance Procedures. Request for Extension or Clearance of New, Revised, or Extended Interagency Information collections.

1. Submission. DOL Agencies must submit the following documents and materials to the Departmental Clearance Officer:
2. Original and two copies of SF-360, for Clearance of an Interagency Reporting Requirement, with supporting documents, and the proposed information collection.
3. Justification statement - original and two copies. Each information collection requirement must be justified in terms of its value to management, which includes demonstrated need, cost effectiveness, systems design, capability to streamline/reduce paperwork, and coordination with other clearance authorities. Costs should be justified in terms of increased productivity, improved service, better-output, quality, and/or reduced costs.
4. Departmental Clearance. The Departmental Clearance Officer will review each new or modified information collection proposal for extension of existing information collection and notify the sponsoring DOL Agency of departmental approval or disapproval. Disapproved proposals will be returned in writing to the sponsoring Agency.
5. GSA Clearance. The Departmental Clearance Officer will forward approved proposals to GSA for clearance. GSA, in turn, will notify the Departmental Clearance Officer of its action. A copy of the signed SF360 will be returned to the sponsoring DOL Agency within 24-hours after receipt by DOL.
6. Discontinuance. When an interagency information collection is no longer needed, the sponsoring DOL Agency must notify all other responding Agencies of this fact by letter, directive, or other instructional form. Two copies of the notification must also be forwarded to the Departmental Clearance Officer who will notify GSA of the discontinuance.
7. Interagency Information Collection Coordination with Standard and Optional Forms Approved by GSA. The procedures outlined above should be followed in addition to submitting a Standard Form 152, for Clearance Procurement, for Cancellation of Standard and Optional Forms (Attachment C), which is available on-line. For specific guidance on developing in interagency information collection requests, contact the GSA Interagency Reports Coordinator at 202-501-4469. Guidance is also available on-line.
8. Supporting Directives. DOL Agencies are required to issue directives prescribing their interagency information collection requirements. The supporting directive must include such information as the purpose of the interagency information collection, information collection title, GSA approval number, and other requirements as stated in 41 CFR 101-11.204.
9. Cost Estimates. GSA requires cost estimates to determine if the expected value of the information proposed for collection is worth the cost of obtaining it. Criteria for costing alternatives used to develop cost estimates are contained in the GSA Information Resources Management Handbook/Guidelines⁽¹⁾. Supporting documentation and worksheets for all cost estimates must be available for GSA review and may include a determination of the agency costing alternative selection.

ATTACHMENT A

Format for Submitting Burden Breakdown and Description for an Information Collection Request:

Agencies must use the format shown below to provide the burden breakdown that is to accompany an information collection request submitted to the Departmental Clearance Officer. Agency Clearance Officers must ensure that this information is accurate and complete. The Department Clearance Officer will use this information to publish the Notice of Proposed Information collection in the Federal Register.

Type of Review:

Agency:

Title:

OMB Number:

Affected Public:

Frequency:

Number of Respondents:

Number of Annual Responses:

Estimated Time Per Response:

Total Burden Hours:

Total Annualized Capital/Startup Costs: $

Total Annual Costs (operating/maintaining systems or purchasing services): $

Description

ATTACHMENT B

Guidelines for Writing and Submitting OMB Clearance Packages for BLS Statistical Review:

Agencies should adhere to the following guidelines when writing and submitting OMB packages to the Office of Survey Methods Research (OSMR), Bureau of Labor Statistics (BLS) for review. Each package must include the following three parts:

1. A written document detailing the statistical methods used in the survey and data analysis.
2. A clearance form filled out with the name of the survey and the person(s) submitting the package for review, and a sign-off signature from the submitting agency’s clearance officer.
3. The proposed data collection instrument.

Guidelines for the written description are provided below, and a sample clearance form is attached.

Description of Statistical Methods Used

If the survey is to be a census of the target population, this fact should be stated explicitly. In this case, no further information on statistical methods is needed. If statistical sampling is to be used, the following information is needed:

1. Description of Sampling Methods

   Examples:

   • Simple random sampling
   • Stratified random sampling — list stratification variables
   • Systematic sampling — list variables used to sort units prior to sample selection
   • Multi-stage sampling — describe units to be used for each stage of sampling
   • Judgment sampling — explain why a probability sample will not be selected
2. Description of estimators
   Indicate the statistics of interest (sample means, medians, quantities, etc.) to be computed from the survey data.
3. Reliability requirements
   • List all variables for which reliability requirements are specified.
   • Indicate reliability measures specified in requirements, e.g., confidence interval, coefficient of variation, standard error, etc.
4. State all sample sizes and formulae used for computing sample sizes.

   Example:
   For simple random sampling, the sample size needed for estimating a proportion p is

   where

   If stratified sampling is being used, explain how the sample will be allocated among the strata.

5. Describe all methods to be used for maximizing response rates, e.g., mail or telephone follow-up of nonrespondents. State the expected response rate.
6. Describe any planned sample weighting. (If probabilities of selection are not constant across the sample, weighted analyses are recommended.)
7. Discuss all estimation techniques to be used for reducing nonresponse bias. For example, if imputation will be used to correct for item nonresponse, describe the imputation method. If a weighting class adjustment is to be applied, explain how the adjustment cells will be defined.
8. Describe any additional estimation methods planned, e.g., ratio adjustments, model-based weighting adjustments, etc.
9. Discuss the goals of the planned data analyses and briefly describe any statistical tools to be used.

Filling Out the Clearance Form

You must submit the attached clearance form or a similar form with your survey description. The clearance form must be completed with your name (or the name of the responsible person) after the word “TO:” and must include your fax number. Provide the identification number and the title of the report or survey for which you are requesting clearance. Additionally, the submitting agency’s clearance officer must review the package to ensure the guidelines above have been addressed and sign the clearance form. (Note: This does not attest to statistical methodology, BLS will review for methodological soundness.) The lines indicating “Approved” and “Disapproved” should be left blank: the reviewer will check the appropriate line after reading the description of the statistical methods. If sufficient identifying information is not provided on the form, the form will not be returned to you. (This does not indicate approval of your clearance request.)

Submitting a Package for Clearance

Packages should be faxed or sent through the submitting agency clearance officer to the Office of Survey Methods Research (OSMR) within the BLS (202-691-7399). OSMR will forward the name and number of the reviewer to the Agency Clearance Officer or designee.

ATTACHMENT C

GSA Forms Used for Interagency Reporting:

SF 360 — Request to Approve an Interagency Reporting Requirement

SF 152 — Request for Clearance or Cancellation of a Standard or Optional Form

___________________________________

¹ GSA expects to issue new guidance on interagency reporting (information collections) by mid-2001. For the most current guidance on this topic, go on-line.

• Guidelines

• Correction Requests
• DOL Peer Review Agenda