Identity Proofing

From Regulations 

Identity proofing can be accomplished for 
customers in two ways: (1) By visiting a local registration authority 
at a USDA Service Center, or (2) through a new on-line identity 
proofing service. The new on-line identity proofing service will 
provide registrants with a more efficient mechanism to have their 
identity proofed. The on-line identity proofing requires responses to 
at least four randomly selected identity questions that are verified by 
a third party identity proofing service in an automated interface. Once 
an account is activated, customers may use the associated user ID and 
password that they created to access USDA resources that are protected 
by eAuth.

 Estimate of Burden: Public reporting burden for this collection of 
information is estimated to take eight (8) minutes to complete the self 
registration process for a Level 1 Access account. A Level 2 Access 
account registration is estimated to be completed in one hour 40 
minutes when travelling to a USDA Service Center to visit a local 
registration authority (expected to be approximately 30% of the 
registrants), or 50 minutes when using the on-line identity proofing 
service (expected to be approximately 70% of the registrants).
    Respondents: Individual USDA Customers.
    Estimated Number of Respondents: 114,841 Level 1 and 14,860 Level 2 
for an estimated total of 129,701 respondents.
    Estimated Number of Responses per Respondent: 1.
    Estimated Total Annual Burden on Respondents: 31,077 hours. 

This is from USDA's Information Collection Notice.    Some comments:  I assume USDA/OCIO will do the same sort of thing as Treasury has done with their Treasury Direct customers: ask things like what the customer's address, phone number, date of birth, years in house, etc. etc. are--that's the "third party identity proofing service" referred to.  The theory is that such data is publicly available and has been collected by the credit rating people, and other entities, so if I give answers which match that set of data, I must be me.  It makes sense to me.

I wonder how OCIO came up with the time estimates in the document.  When I did this sort of thing with Treasury it was more like 5 minutes than 50--maybe the third party service they use is less efficient than the Treasury's?  I'm assuming, perhaps wrongly, the identity proofing is only for Level 2, seems like bureaucratic overkill to require it for Level 1.

 I'm most fascinated though by the estimated number of respondents. Only 15K Level 2's, which are the people who want to do real business with FSA* online??  Elsewhere I've noted, I think, the big plans USDA/FSA has for moving to online business; I think this figure is inconsistent with those plans being successful.  Trying to construe them as favorably as possible, if I had been writing this document I would have used only the new FSA customers I anticipated over the period of the collection.  I'd assume there's some period OMB says to use for this, though usually you're talking about an annual collection, not an open-ended one.  

Finally I wonder if USDA/OCIO has run this process through a user review, as pushed by Prof. Sunstein.  If the good professor had been bureaucratically sharp, he would have changed the OMB guidance for these documents to specify the extent they were tested with users.

* I don't know that other USDA agencies use the e-Auth process.