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Nov 4 -- The National Center for Science and Engineering Statistics (NCSES) within the National Science Foundation (NSF), as the Standard Application Process (SAP) Program Management Office designated by the Office of Management and Budget (OMB), invites comments to OMB by December 5, 2022 regarding SAP Portal information collection as a Common Form to permit other federal agency users to streamline the information collection in coordination with OMB.

Title III of the Foundations for Evidence-Based Policymaking Act of 2018 (hereafter the Evidence Act) mandates that OMB establish a Standard Application Process (SAP) for requesting access to certain confidential data assets. While the adoption of the SAP is required for statistical agencies and units designated under the Confidential Information Protection and Statistical Efficiency Act of 2018 (CIPSEA), it is recognized that other agencies and organizational units within the Executive Branch may benefit from the adoption of the SAP to accept applications for access to confidential data assets. The SAP is to be a process through which agencies, the Congressional Budget Office, State, local, and Tribal governments, researchers, and other individuals, as appropriate, may apply to access confidential data assets held by a federal statistical agency or unit for the purposes of developing evidence. With the Interagency Council on Statistical Policy (ICSP) as advisors, the entities upon whom this requirement is levied are working with the SAP Project Management Office (PMO) and with OMB to implement the SAP. The SAP Portal is to be a single web-based common application designed to collect information from individuals requesting access to confidential data assets from federal statistical agencies and units.

This information collection request is on behalf of the following federal statistical agencies and units, which may use the Common Form:

Bureau of Economic Analysis (Department of Commerce)
Bureau of Justice Statistics (Department of Justice)
Bureau of Labor Statistics (Department of Labor)
Bureau of Transportation Statistics (Department of Transportation)
Census Bureau (Department of Commerce)
Economic Research Service (Department of Agriculture)
Energy Information Administration (Department of Energy)
National Agricultural Statistics Service (Department of Agriculture)
National Center for Education Statistics (Department of Education)
National Center for Health Statistics (Department of Health and Human Services)
National Center for Science and Engineering Statistics (National Science Foundation)
Office of Research, Evaluation, and Statistics (Social Security Administration)
Statistics of Income Division (Internal Revenue Service)
Microeconomic Surveys Unit (Federal Reserve Board)
Center for Behavioral Health Statistics and Quality (Department of Health and Human Services)
National Animal Health Monitoring System (Department of Agriculture)

The objective of the SAP Portal is to broaden access to confidential data for the purposes of evidence building and reduce the burden of applying for confidential data, which currently involves separate processes with each of the federal statistical agencies and units. The new process will be implemented while maintaining stringent controls to protect confidentiality and privacy, as required by law.

Many applicants will be academic research faculty or students at U.S. universities or other types of research institutions. Other applicants are likely to include analysts at nonprofit organizations and research groups in U.S. Government organizations (Federal, State, local, and Tribal). Scientific research typically results in papers presented at scientific conferences and published in peer-reviewed academic journals, working paper series, monographs, and technical reports. The scientific community at large benefits from the additions to knowledge resulting from research with statistical agencies and units’ data.  Results inform both scientific theory and public policy and can assist agencies in carrying out their missions.

Approved applicants using confidential data can provide insights on how statistical agencies and units may improve the quality of the data collected or acquired; identify shortcomings of current data collection programs and data processing methods; document new data needs; and develop methods to address survey nonresponse or improve statistical weights.

The following bullets outline the major components and processes in and around the SAP Portal.

• SAP Policy: At the recommendation of the ICSP, the SAP Policy establishes the SAP to be implemented by statistical agencies and units and incorporates directives from the Evidence Act. The SAP Policy was submitted to the public for comment in January 2022 (87 FR 2459). The policy is currently under review and has not yet been finalized.

• The SAP Portal: The SAP Portal is an application interface connecting applicants seeking data with a catalog of metadata for data assets owned by the federal statistical agencies and units. The SAP Portal is not a new data repository or warehouse; confidential data assets will continue to be stored in secure data access facilities owned and hosted by the federal statistical agencies and units. The Portal will provide a streamlined application process across agencies, reducing redundancies in the application process. This single SAP Portal will improve the process for applicants, tracking and communicating the application process throughout its lifecycle. This reduces redundancies and burden on applicants who request access to data from multiple agencies. The SAP Portal will automate key tasks to save resources and time and will bring agencies into compliance with the Evidence Act statutory requirements.

• Data Discovery: Individuals begin the process of accessing restricted use data by discovering confidential data assets through the SAP metadata catalog, maintained by federal statistical agencies at www.researchdatagov.org.

• SAP Portal Application Process: Individuals who have identified and wish to access confidential data assets will be able to apply for access through the SAP Portal when it is released to the public in late 2022. Applicants must create an account and follow all steps to complete the application. Applicants begin by entering their personal, contact, and institutional information, as well as the personal, contact, and institutional information of all individuals on their research team. Applicants provide summary information about their proposed project to include project title, duration, funding, and timeline. Other details provided by applicants include the data asset(s) they are requesting and any proposed linkages to data not listed in the SAP metadata catalog, including non-federal data sources. Applicants then enter detailed information regarding their proposed project, including a project abstract, research question(s),

• Submission for Review: Agencies approve or reject an application within a prompt timeframe. Agencies may also request applicants to revise and resubmit their application.

• Criteria for Review: Providing an applicant access to confidential data is a multi-dimensional, risk management decision. Critical dimensions that warrant careful consideration within the application process are whether the applicant(s) can be placed in a trusted category to use the data in an appropriate manner; whether the data use is appropriate and consistent with current legal, policy, ethical, and other relevant restrictions; whether there are disclosure risks in the proposed use of the data; whether the data access setting can limit unauthorized use; and whether the statistical results or outputs are non-disclosive.

The Evidence Act requires standardized criteria for statistical agencies and units to determine whether to grant an applicant access to a confidential data asset. The SAP Policy outlines the criteria for evaluating a project proposal and applicant(s), and the SAP Portal standardizes the approach by which agencies and units determine whether to grant an applicant access to a confidential data asset. For applications, agencies have three options for determination: approve, reject, and revise and resubmit. “Revise and resubmit” provides the applicant with an opportunity to amend the application with additional information necessary for the agency to make a determination.   

• Appeals Process: Applicants receiving an adverse determination have the option to submit an appeal for reconsideration by the data-owning agency or agencies. Applicants may also file an appeal for noncompliance with the SAP Policy.

• Access to Restricted Use Data: Approved applicants are notified through the SAP Portal that their proposal has been accepted. This concludes the SAP Portal process. Agencies will contact approved applicants to initiate completion of their security documents.

The expected number of applications submitted to NCSES in a given year may vary. Overall, NCSES estimates it may receive 20 application submissions within the SAP Portal per year.
  
SAP webpage: https://ncses.nsf.gov/about/standard-application-process
SAP submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202211-3145-002 Click IC List for research application questions, View Supporting Statement for technical documentation. Submit comments through this webpage.
FRN: https://www.federalregister.gov/d/2022-24009

For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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