Comment from Anonymous

Re: Renewal of an Existing Information Collection: Optional Form 306 The proposed estimated completion timeframe within the Public Burden Statement appears too low. It should be increased to 15 to 30 minutes. Five minutes is too short of a time frame for completion of this form especially as accuracy is critical. On the Federal Register website for this Notice, it states at the bottom under "Analysis" that, "Estimated Time per Respondent: 15 minutes." 15 minutes should therefore be the shortest time range for the Public Burden Statement. As this form appears to have been last revised pre-COVID (October, 2019), OPM should strongly consider revising this form in its entirety due to many agency application materials and on-boarding documents being electronic. This form has, for the most part, been the same with minimal substantive changes for over a decade (at minimum). An Adobe pdf version of this form does not allow the respondent to provide explanatory responses or written context for a response even if their question selection may not necessitate one. On page one, paragraph three it states "If you need additional space, attach letter-size sheets (8.5" X 11"). Include your name, Social Security Number, and item number on each sheet." This is simply not possible based on the current edition especially if the OF-306 is being completed electronically. Inserting additional pages would only be possible if the respondent takes it upon themselves to edit this form to insert blank pages within Adobe (the respondent should not have to do this). To conclude, this Notice should have the Public Burden Statement timeframe revised and then be published. I also encourage OPM to then begin the process of modernizing and revising the OF-306 in its entirety.