Case Studies

Navigating the Information Collection Request (ICR) Process with Minimal Hassle

The U.S. federal government requires federal agencies to obtain approval from the Office of Management and Budget (OMB) before collecting information from 10 or more members of the public, including voluntary program participants. This extended approval process requires the submission of an Information Collection Request (ICR) describing details about the information to be collected, the means of collection, and a detailed estimate of the time and cost for the public. An ongoing collection must be approved by OMB at least once every three years.

Fidelium Consulting, an expert in the OMB ICR process, was approached by a renowned consultancy to support the renewal of an ICR for a U.S. federal agency. Fidelium’s team devised an approach which focused on the agency’s previous submission to minimize complications among agency staff, while discreetly introducing improvements based on industry best-practice and lessons learned across Fidelium’s other submissions.   Throughout the process, Fidelium remained committed to meticulously recording each step and decision point to ensure all necessary details will be readily available in the future.

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5 steps

Planning and Recommendations

Fidelium began by drafting a comprehensive plan and schedule, outlining the tasks to be accomplished throughout the ICR renewal process. The team’s first objective was to review all existing data collection instruments and decide whether any should be retired, updated, or if new forms were required. This review ensured that the data collection process was efficient, accurate, and aligned with the agency’s goals and requirements.

Updating the Supporting Statement

A critical aspect of the ICR renewal was the review and update of the previous Supporting Statement. Fidelium’s team meticulously assessed the previous version and proposed recommendations for necessary updates, considering regulatory changes and evolving program goals. Through detailed analysis and collaboration with designated agency and contractor staff, the team led meetings to review proposed changes and finalize edits to the Supporting Statement.

Preparing the Federal Register Notices

Fidelium undertook the responsibility of drafting the 60-Day and 30-Day Federal Register Notices (FRN) for submission by the agency. These notices are necessary for informing the public and relevant stakeholders about the proposed data collection activities, providing an opportunity for public comment and input. Fidelium’s team ensured that the FRNs accurately reflected the objectives, methodologies, and timelines of the ICR renewal, complying with the regulatory requirements.

Completing the Supporting Statement and ICR Package

The Supporting Statement explains the purpose, necessity, and anticipated benefits of the data collection effort. Fidelium’s team worked to finalize the Supporting Statement, incorporating all relevant updates and improvements identified during the process. We also prepared an accompanying spreadsheet which laid out detailed estimates for all time and cost burdens and presented the final materials to the agency for submission.

Throughout the process, Fidelium Consulting was able to reduce the burden on the federal agency end client, while arming our teaming partner with a process and materials it will benefit from well into the future.