OMB Approves First Responder Communities of Practice ICR

Friday, the OMB’s Office of Information and Regulatory Affairs (OIRA) announced that it had given a short term approval (1 year) to the DSH S&T’s information collection request renewal for their First Responder Communities of Practice (FRCoP) program. This covers the registration information collected by S&T for that program.

This is not in response to the 60-day ICR notice that I wrote about last week. Apparently S&T knew about the short term renewal that was going to be published and was trying to get an early start on that renewal.

This renewal contains the same ‘Terms of Clearance’ notice as did the previous approval from March of last year:

“If DHS submits a renewal of this collection, it should include a report with the following information: • How the First Responders Community of Practice is being used. Has the intended audience been reached? • An analysis by DHS of the practical utility of the collection. • An analysis by DHS of other similar platforms currently in use by first responders.”

So apparently S&T is being given a second chance to get this information right.

First Responders Community of Practice ICR Notice – Again

Today the DHS Science and Technology Directorate (S&T) published a 60-day ICR renewal notice in the Federal Register (79 FR 34545) for their First Responders Community of Practice Program (FRCoP). I wrote about the previous submission of this ICR to OMB last year; that submission has not yet been acted upon by OMB. This ICR notice completely ignores that previous submission.

I noted in my earlier blog that the previous approval of this ICR (which expired last October) was a short term approval because OMB wanted additional information about the program and its efficacy. I noted that S&T had not included that information in its published ICR notices. Looking back now at the actual ICR submission supporting documents there is an attempt [Word® download link] by S&T to fulfill that requirement. There is no indication on the OMB site if that was considered to be an adequate response.

One interesting item of information from that S&T document is the report that there are 5,000 active members of the FRCoP. Since this ICR only covers the submission of registration information that is supplied on a one time basis, it would seem that there is a pretty good retention of site members. The site has been active since somewhere in 2010 and S&T indicates that there have been an average of 2000 registrations per year. That means that between 6,000 and 8,000 registrations have taken place. Retaining 5,000 members from that number would seem to be a pretty high success rate.

One other interesting administrative note; this ICR notice uses the same docket number as the ICR submission that was withdrawn last year. It seems that everyone, both at DHS and OMB, is ignoring the ICR that was submitted last year. That seems to be more than a little strange.

Anyway, S&T is soliciting public comments on this ICR submission. Public comments may be made via the Federal eRulemaking Portal (www.Regulations.gov; Docket # DHS-2012-0013). Comments need to be submitted by August 18^th, 2014.