DOD-2026-OS-0958 Proposed Collection; Comment Request - Occupational Medicine Physician Comments

Sep 21, 2026

Uploaded by Riley

Comments submitted by an Occupational Medicine Physician and lawyer regarding the Department of Defense’s proposed information collection and associated DD Form 3207. The author argues the Federal Register burden estimates are implausibly low, inconsistent with the form’s own Public Burden Statement, and diverge sharply from prior versions without adequate explanation. The submission also contends the proposal violates multiple federal laws and creates significant medical and administrative problems, citing concerns about accuracy, utility, clarity, and minimizing respondent burden.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages12

Reading Time30 min

AccessFree to download

Background

Summary and Key Claims

Itemized Comments on Burden Estimates

Annual burden hours and respondent assumptions

Public Burden Statement versus notice estimate

Estimated number of responses and practical workload

Average burden per response

Divergence from previous burden estimates

Scope of "information collection" (paper and EHR entries)

Comments RE: Docket ID: DoD-2026-OS-0958 Proposed Collection; Comment Request AGENCY: Office of the Under Secretary of Defense for Personnel And Readiness (OUSD(P&R)), Department of Defense (DoD) Background: I am an Occupational Medicine Physician with decades of experience practicing my specialty with the US Military. I am also a Lawyer, with years of practice experience. Comments addressing “whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; the accuracy of the agency's estimate of the burden of the proposed information collection; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the information collection on respondents, including through the use of automated collection techniques or other forms of information technology.” Summary: The proposed DD Form 3207 and the associated Federal Register Proposed Collection; Comment Request (2026-08802 (91 FR 24530) ; Docket ID: DOD-2026-OS-0958]) violate multiple Federal laws, contain serious errors, miss opportunities, and create significant medical and administrative problems. Itemized Comments: 1. The agency's estimate of the burden of the proposed information collection, as set forth in the Federal Register notice, is ludicrously low, and is also inconsistent with both the proposed collection instrument’s own Public Burden Statement by a factor of 200-300% and previous burden estimates. a. Agency’s estimate (from Federal Register notice, FR Doc. 2026-08802 (91 FR 24530) : “Annual Burden Hours: 9,200 . Number of Respondents: 9,200 . Responses per Respondent: 1. Annual Responses: 9,200 . Average Burden per Response: 1 hour. Frequency: As required.” To summarize, the agency estimates that 9,200 forms will be completed annually, and that the average time to complete the form (by all parties, i.e., employee or applicant, agency human resources official(s), and occupational medicine personnel) will average 1 hour per form. b. Proposed form’s Public Burden Statement estimate: “The public reporting burden for this collection of information is estimated to average 2-3 hours per response.” c. Actual number of responses (forms): (1) The Department of Defense employs 700,000-800,000 Civilian employees ( [https://www.gao.gov/assets/gao-26-108100.pdf](https://www.gao.gov/assets/gao-26-108100.pdf) ; [https://news.clearancejobs.com/2025/08/13/the-u-s-federal-workforce-by-the-numbers-who](https://news.clearancejobs.com/2025/08/13/the-u-s-federal-workforce-by-the-numbers-who)they-are-what-they-do-and-why-it-matters/ ; [https://www.fedweek.com/armed-forces-news/how-many-people-make-up-the-us-military](https://www.fedweek.com/armed-forces-news/how-many-people-make-up-the-us-military)workforce/ ; [https://www.dodciviliancareers.com/whyworkfordod](https://www.dodciviliancareers.com/whyworkfordod) ; [https://comptroller.war.gov/Portals/45/Documents/afr/fy2024/1-](https://comptroller.war.gov/Portals/45/Documents/afr/fy2024/1-)About_the_DoD_Agency_Financial_Report-DoD_At_A_Glance_Table_of_Contents. pdf ) The estimate of 9,200 exams constitutes ~1 .2% of the DoD Civilian workforce – a percentage that is facially absurd, given constant turnover (new hires), along with periodic examinations required for a substantial proportion of incumbent personnel. (2) The absolute absurdity of the under-estimate is made strikingly clear by the fact that DoD employs ~8,800 Civilian Firefighters ( [https://files.gao.gov/reports/GAO-25-](https://files.gao.gov/reports/GAO-25-)[ ](https://files.gao.gov/reports/GAO-25-)[107288/index.html](107288/index.html) ), each of whom requires an annual medical examination. Thus, the annual number of exams of incumbent DoD Civilian Firefighters, alone, approximately equals the estimated number of annual exams for all DoD employees and

FAQs

What does the submission challenge about the proposed information collection?

It argues the Federal Register burden estimates are unrealistically low, internally inconsistent with the form’s Public Burden Statement, and insufficiently explained compared with prior estimates.

What is the cited difference between the Federal Register estimate and the form’s Public Burden Statement?

The Federal Register notice states an average of about 1 hour per response, while the proposed form’s Public Burden Statement estimates 2–3 hours per response.

How does the author justify a higher burden estimate?

The author relies on decades of DoD Occupational Medicine experience and claims that, given actual DoD civilian workforce needs and required medical exams, the estimated number of responses and workload are far understated.

Sep 21, 2026

Uploaded by Riley