View Information Collection Request (ICR) Package
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Please note that the OMB number and expiration date may not have been determined when this Information Collection Request and associated Information Collection forms were submitted to OMB. The approved OMB number and expiration date may be found by clicking on the Notice of Action link below.
View ICR - OIRA Conclusion
OMB Control No:
1505-0080
ICR Reference No:
202511-1505-001
Status:
Active
Previous ICR Reference No:
201206-1505-001
Agency/Subagency:
TREAS/DO
Agency Tracking No:
Title:
Post-Contract Award Information
Type of Information Collection:
Reinstatement with change of a previously approved collection
Common Form ICR:
No
Type of Review Request:
Emergency
Approval Requested By:
11/04/2025
OIRA Conclusion Action:
Approved without change
Conclusion Date:
11/04/2025
Retrieve Notice of Action (NOA)
Date Received in OIRA:
11/04/2025
Terms of Clearance:
Inventory as of this Action
Requested
Previously Approved
Expiration Date
05/31/2026
6 Months From Approved
Responses
6,304
0
0
Time Burden (Hours)
151,296
0
0
Cost Burden (Dollars)
0
0
0
Abstract:
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.
Emergency Justfication:
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. Treasury’s draft acquisition policy introduces two standardized deliverables—the Staffing Plan (pre-award) and Monthly Workforce Report (post-award)—to 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. Treasury’s 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 OIRA’s expedited six-month approval under 5 CFR 1320.13(c), with waiver of the Federal Register notice, to enable immediate implementation and support the Department’s leadership in restoring accountability and transparency across the federal small-business contracting community.
Authorizing Statute(s):
US Code:
41 USC 251
Citations for New Statutory Requirements:
None
Associated Rulemaking Information
RIN:
Stage of Rulemaking:
Federal Register Citation:
Date:
Not associated with rulemaking
Other Documents for OIRA Review
Federal Register Notices & Comments
Did the Agency receive public comments on this ICR?
No
Number of Information Collection (IC) in this ICR:
1
IC Title
Form No.
Form Name
Post-Contract Award Information
N/A
ICR Summary of Burden
Total Approved
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
6,304
0
0
0
-2,909
9,213
Annual Time Burden (Hours)
151,296
0
0
0
-69,816
221,112
Annual Cost Burden (Dollars)
0
0
0
0
0
0
Burden increases because of Program Change due to Agency Discretion:
No
Burden Increase Due to:
Burden decreases because of Program Change due to Agency Discretion:
No
Burden Reduction Due to:
Short Statement:
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.
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:
Alan Monico 202 570-3493 alan.monico@treasury.gov
Common Form ICR:
No
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:
11/04/2025
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