Supporting Statement for Paperwork Reduction Act Submissions
A Reporting System for Pub. L. 102-477 Demonstration Project
OMB Control Number 1076-0135
Terms of Clearance: None.
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 of the OMB Form 83-I is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.
Specific Instructions
A. Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Public Law 102-477 authorizes tribal governments to integrate federally funded employment, training and related services programs into a single, coordinated, comprehensive delivery plan. The goal of the legislation is to reduce unemployment, improve services, and reduce administrative costs. The programs under the responsibility of the Secretary of the Interior, Secretary of Labor, and Secretary of Health and Human Services are all included within this authorization. The Bureau of Indian Affairs, (BIA) is legislatively required to serve as lead agency. A copy of the relevant statute is attached.
Section 11 of this Act, “Federal Responsibilities,” and sub-parts (a)(1) and (2) require the Secretary of the Interior to make available a single universal report format which shall be used by a tribal government to report on integrated activities undertaken within their project. It also requires that the Secretary make available a single universal report format related to the projected expenditures for the individual project which shall be used by the tribal government to report on all project expenditures.
These universal single page, one-sided report forms and the narrative with a total of six pages, (due annually) replaces 166 pages of instructions and applications representing three (3) different agencies and eleven (11) differently funded but related programs. Most of these eleven different program reports were completed quarterly. This 95% reduction in the number of reports and the reduced size of the required reports is consistent with the Paperwork Reduction Act and consistent with the National Performance Review.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. [Be specific. If this collection is a form or a questionnaire, every question needs to be justified.]
(a.) The statistical report will be used to demonstrate how well a tribal plan was executed in comparison to its proposed goals. This one page, single sided, universal report form satisfies the very basic statutory requirements for the three participating federal agencies. It will help the funding agencies determine the quality of the employment, training, child care and related services provided to individual participants in the program. It will help determine the level of program activity in which the tribes are engaged. In accordance with standard regulations governing the administration of grants, the Common Rule, certain sanctions will be imposed on grantees if they do not report thoroughly and timely.
These reports are subdivided into three components. The statistical report identifies the number of participants enrolled in the program, the number that successfully completed the program, those that were not successful, the characteristics and barriers to employment faced by participants and the types of activities and services the participant received while enrolled. This information helps to determine the success of current employment and training programs.
(b) The financial status report is used to track cash flow, compare program activity with expenditures, compare general expenditures with approved intent and budget and to avoid over expenditures and identify savings. The form is a slightly modified SF-269A (short form). An addendum is added to the standard form to seek assurances required by the Job Training Partnership Act, as amended. This report will identify the tribes applying for grants, the period of operation, and total resources committed to the plan. The form includes a “previously reported” column, a “current expenditures” (this period) column and a “cumulative” column. This report is acceptable to all the participating federal agencies.
(c) The Narrative Report allows tribes to go beyond numbers and report goals and objectives against accomplishments and describe problems or unmet needs toward addressing employment and training issues.
We have deleted the requirement for grantees to report on child care during non-traditional hours, (e.g., nights, weekends and work related child care that is for 24 hours or more). The Administration for Children and Families, Child Care Bureau does not collect this data for other grantees and have determined that at this time, the extra information is not needed.
We have also clarified that grantees should report the type of child care provided (e.g., center-based care, group home care, family home care and care in the child’s own home) by the number of children receiving care. Previously, some respondents were reporting this data by number of families and other respondents were reporting this data by number of children resulting in inconsistent data elements.
The forms were developed by all three participating Federal agencies and directly in collaborative efforts with tribes. The agencies use all of the above data collected to ensure statutory compliance, report to the Congress, the Office of Management and Budget, and to report to the respective agency administration. These reports may include a discussion of the use of funds, activities engaged in by tribes and the extent to which tribes are successful. The goal of the program is to find unsubsidized employment for Indians either through direct referrals or assisted through training, education and other supportive services such as child care.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden [and specifically how this collection meets GPEA requirements.].
During December 2001, Indian Affairs (IA) was forced to disconnect from the internet by a court order issued by the judge in the Cobell litigation. Hence, IA cannot implement GPEA until reconnection to the internet is completed.
The reports were designed to provide tribes the opportunity to collect, maintain and report the data using technological collection techniques. Some tribes have automated the data to such an extent that they are able to meet their own day-to-day needs, (i.e., identify candidates for employment meeting specific qualifications while meeting with prospective employers), as well as complete the annual reports. The use of technology at the tribal level depends upon the extent to which each tribe has developed an integrated intake and reporting system.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
While three different federal agencies representing eleven different programs do collect the information, comprising an estimated 166 pages of reports and instructions annually, we have consolidated that into one set of forms including seven (7) pages annually through this reporting mechanism. Terms used in the reports have been standardized among the three federal agencies. Duplication has been eliminated.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
Tribal entities worked with the federal agencies to develop a streamlined plan that met everyone’s needs and avoided duplication as cited in paragraph 3 of number 1 and reiterated in number 4.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Grant funds are dependent upon filing the necessary reports. If the reports are not completed annually by the grantee, additional payments to the grantee will not be made. Once reports are submitted, payments will resume.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
* requiring respondents to report information to the agency more often than quarterly;
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
* requiring respondents to submit more than an original and two copies of any document;
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
* in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
* requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
Not Applicable. Regulatory compliance indicates annual reports are sufficient; tribes control the content of the information and normally do not deal in sensitive information when compiling this report. Any copies needed by other agencies are made by the Bureau.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice [and in response to the PRA statement associated with the collection over the past three years] and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
The following Federal partners to this initiative were consulted on the review of these forms:
Ms. Ann Bowker, Native Employment Works Program Specialist,
Department of Health and Human Services, Administration of Children and Families
370 L’ Enfant Promonade, Aerospace Bldg.
Washington, DC 20447
(202) 401-5308
Mr. Ray Apodaca and Mr. Ray Shelbourne
Temporary Assistance to Needy Families
Department of Health and Human Services, Administration for Children and Families
370 L’Enfant Promenade, Aerospace Bldg.
Washington, D.C. 20447
Ms. Evangeline Campbell, ICWA Specialist
DOI/OTS, Division of Human Services
1849 C. Street, NW, MS-4513-MIB
Washington, DC 20240
(202) 513-7623
Ms. Dawn Anderson
Department of Labor
Division of Indian and Native American Programs,
Washington, D.C.
Mr. Chris Redman
Office of Indian Education
Department of the Interior
Washington, D.C.
We have also met with and consulted with Pub. L. 102-477 Tribal Work Group during the past 12 months. The revised forms were on the agenda each time. The group consists of:
Aleutian Pribilof Island Association
Mr. Ken Selby
201 E. 3rd Avenue
Anchorage, Alaska 99501
Telephone: (907) 276-2700 Fax: 907-279-4351
Association of Village Council Presidents
Mr. John Owens
P.O. Box 219
Bethel, Alaska 99559
Telephone: (907) 543-7321 Fax: (907) 543-3569
1-800-478-3921 extension-7300
Bristol Bay Native Association
Mr. Mark Hiratsuka
P.O. Box 310
Dillingham, Alaska 99576
Telephone Number (907) 842-2262 Fax: (907) 842-5932
Chugachmiut
Mr. Tim Anderson
4201 Tudor Center Drive, Suite 210
Anchorage, Alaska 99508
Telephone: (907) 562-4155 Fax: (907)- 563-2891
Citizen Potawatomi Tribe
Ms. Carol Levi (Margaret Zientek)
1901 S. Gordon Cooper Drive
Shawnee, Oklahoma 74801
Telephone: (405) 275-5269 Fax: (405) 878-4668
E-mail: cclaylevi@potawatomi.org
Cherokee Nation of Oklahoma
Mr. Chad Smith, Principle Chief
Ms. Penny Norseworthy
P. O. Box 948
Tahlequah, Oklahoma 74465
Telephone: (918) 456-0671 x2375 Fax: (918) 458-7666
Cheyenne River Sioux Tribe
Mr. Harold Frazier, Chairman
P. O. Box 837
Eagle Butte, South Dakota 57625
Contact: Kathleen Lafferty
Telephone: (605) 964- 6415 Fax: (605) 964-6416
Chickasaw Nation
Mr. Bill Anoatubby, Governor
Ms. Angie Gilliam, Program Manager
P. O. Box 1548/ 520 E. Arlington
Ada, Oklahoma 74821-1548
Telephone: (580) 436-2603 x7512, Fax: (580) 436-7257
angieg@chickasaw.com
Confederated Tribes of the Colville Reservation
Ms. Sheilah Cleveland
State Hwy 155 & Cache Creek Road
Nespelem, Washington 99155
Telephone: (509) 634-8841/2730/2729 Fax: (509) 634-2734
Cook Inlet Tribal Council
Ms. Carrie McMillan
2700 Gambell Street, Suite 442
Anchorage, Alaska 99503
Telephone: (907) 793-3419 Fax: (907) 793-3422
Copper River Native Association
Mile 104 Richardson Highway, P. O. Box H
Copper Center, Alaska 99573
Contact: Susan Voyles
Telephone: (907) 822-8841, Fax (907) 822-8801
Eastern Shoshone Tribes
Mr. John Wadda
P.O. Box 538/ 647 Blue Sky Hwy.
Fort Washakie, Wyoming 82514
Telephone: (307) 332-8052, Fax: (307)332-8055
Fort Belknap Community Council
Mr. Ben Speakthunder, President
Ms. Tesha Hawley, (406) 353-8382
Mr. Ken Shawl, Finance
RR 1, Box 66,
Harlem, Montana 59526
Telephone: (406) 353-2205 Ext. 427 or 1-800 859-2794 Ext. 382
Confederated Tribes of the
Grand Ronde Community
Ms. Kathryn Harrison, Chairperson
9615 Grand Ronde Rd
Grand Ronde, OR 97347
Contact: David Fullerton
Telephone: (503) 879-2036 Fax: (503) 879-5127
Ho Chunk Nation
Mr. Kenneth LeMieux
P.O. Box 667, W. 9814 Airport Rd.
Black River Falls, Wisconsin 54615
Telephone: (715) 284-5877 Ext. 1137, Fax: (715)-284-1520
Kawerak, Inc.
Ms. Dawn Salesky
Contact: Jerry Trainor, Vice President
P.O. Box 948
Nome, Alaska 99762
Telephone: (907) 443-4351 Fax: (907) 443-4452
Knik Tribal Council
Mr. Michael Tucker
477 Contact: Christina Flowers
P.O. Box 871565
Wasilla, Alaska 99687
Telephone: (907) 373-7991 Fax: (907) 373-2161
Kodiak Area Native Association
Ms. Margie Bezona
3449 Rezanof Drive, East
Kodiak, Alaska 99615
Telephone: (907) 486-9816 Fax: (907) 486-9898
Pueblo of Laguna Tribe of Indians
Mr. Roland E. Johnson, Governor
P.O. Box 207
I-40 West, Exit 114, Bldg. 1125
Laguna, NM 87026
Telephone: (505) 552-6008 x 17/ 7242
Marilyn Johnson, (505)-552-6008 x 11, Fax :(505) 552-6398
E-mail: gsan021998@aol.com
Menominee Indian Tribe of Wisconsin
Lisa Waukau, Chairwoman
P.O. Box 910, Tribal Office Loop Rd., Hwy 47-55
Keshena, WI 54135
Contact: Ann Marie Johnson, 477 Coordinator
Telephone: (715) 799-4419, Fax 715-799-4525
Metlakatla
Ms. Mae Williams and Frankie Nelson
P.O. Box 8
Metlakatla, Alaska 99926
Telephone: (907) 886-5872, Fax: (907) 886-4469
Miami Tribe of Oklahoma
Mr. Floyd E. Leonard, Chief
477 Contact: Ms. Barbra Mullin
P. O. Box 1326
Miami, Oklahoma 74355
Telephone: (918) 542-1445, Fax: (918) 542-7260
Mille Lacs Band of Chippewa Indians
477 Contact: Don Novak
43408 Oodena Drive
HRC-67, Box 194
Onamia, Minnesota 56539
Telephone: (320) 532-4181, Fax: (320) 532-3785
Nez Perce Tribe
Samuel N. Penny, Chairman
Contact: Ronald T. Halfmoon or Kay Kidder
Main Street & Beaver Grade
P.O. Box 365
Lapwai, ID 83540
Telephone: (208) 843-7363 x 2320, (208) 843-7365: Fax: (208) 843-7365
Orutsaramuit Native Council (ONC)
Ms. Bing Santamore
P.O. Box 927, 835 Richcrest Dr.
Bethel, Alaska 99559
Telephone: (907) 543-2608 Fax: (907) 543-2639
jayde@gci.net
Osage Nation
Mr. Ted Moore
1333 Grandview
Pawhuska, OK 74056
Telephone: 1-800-390-6724, (918) 287-4525 or 5302 (Ted), Fax: (918) 287-5567
Pawnee Nation of Oklahoma
Robert L. Chapman, President
Pawnee Business Council
P. O. Box 470
Pawnee, Oklahoma 74058
Debra Echohawk, Director of Education
Telephone: (918)-762-2541, Fax: (918)-762-6446
Port Gamble
Ms. Marilyn Olson
31912 Little Boston Road, NE
Kingston, WA 98346
Telephone: (360) 297-2646/9636 Fax: (360) 297-7097
Red Lake Band of Chippewa Indians
Mr. Darrell Seki, Tribal administrator
Contact: Mr. Ronald Turney
P.O. Box 550
Red Lake, Minnesota 56671
Telephone: (218) 679-3341/3350 Fax: (218) 679-3367
Reno-Sparks Indian Colony Tribal Council
Mr. Arlan D. Melendez, Tribal Chairman
1900 Prosperity Street
Reno. NV 89502
Contact: Mr. Michael Hill, Education Director
Telephone: (775) 329-6114, Fax: (775) 785-9161
Rosebud Sioux Tribe
Mr. William Kindle, Chairman
P.O. Box 430: Tribe
Legion 1 Ave., Red Log Bldg.
Rosebud, South Dakota 57570
Contact: Laurie Bordeaux
Telephone: (605) 747-2393, Fax: (605) 747-5177
Confederated Salish and Kootenai Tribes
of the Flathead Nation
Ms. Anna Whiting-Sorrell or Teresa Wall-McDonald
P.O. Box 278
Pablo, Montana 59855
Telephone: (406) 675-2700 Ext. 1026 or 1049 Fax: (406) 675-2806
Seneca Nation of New York
Ms. Debbie Cooper
1530 Route 438
Irving, New York 14081
Telephone: (716) 532-1033 Fax: (716) 532-6178
Shonaq’ Tribe of Alaska
Mr. Robert L. Polasky
312 W. Marine Way
Kodiak, Alaska 99615
Contact: Arlene ?
Telephone: (907) 486-4449, Fax: (907) 486-3361
Plan Dates: July 1, 2004 to June 30 2007
Shoshone-Bannock Tribe
Ms. Ida Hidalgo
P.O. Box 306, Pima Dr.
Fort Hall, Idaho 83203
Telephone: (208) 478-3737, Fax: (208) 478- 3852
Shoshone-Paiute Tribes of Duck Valley
Mr. Marvin Cota, Chairman
P.O. Box 219
Owyhee, Nevada 89832-0219
Contact: Carol Jones
Telephone: (775) 757-3211 x 224, Fax: (775) 757-2219
Confederated Tribes of the Siletz Indians
Mr. Bob Jensen / contact: Nancy McCrary
P.O. Box 549
Siletz, Oregon 97380
Telephone: 1-800-922-1399 Fax: (541) 444-2307
Sisseton-Wahpeton Sioux Tribe
Mr. Richard Keeble
Lake Traverse Reservation
P.O. Box 509, Veteran Memorial Dr.
Agency Village, South Dakota 57262
Telephone: (605) 698-3911, Fax: (605) 698-7907
Spirit Lake Sioux Tribe
Ms. Jolene Crosswhite
Community Center, Main Street
Fort Totten, North Dakota 58335
Telephone: (701) 766-1200 Fax: (701) 766-1236
Spokane Tribe of Indians
Gregory Abrahamson, Tribal Chairman
Luanne Ferguson, Employment and Training
6195 Ford/Wellpinit Rd.
P. O. Box 100
Wellpinit, Washington 99040
Telephone: (509) 533-1360, Fax: (509) 533-0899
Stockbridge-Munsee Community
477 Contact: Ms. Misty Cook
P.O. Box 70
N8476 MohHeConNuck Rd.
Bowler, Wisconsin 54416
Telephone: (715) 793-4060, Fax: 715-793-4083
Tanana Chiefs Conference, Inc
Ms. Deborah McCarter or Mr. Don Shircel
122 First Ave., Suite 600
Fairbanks, Alaska 99701
Telephone: (907) 452-8251 Ext. 3229 Fax: (907) 459-3883
Three Affiliated Tribes
Mr. Leo Cummings
P.O. Box 220, 304 Main St.
New Town, North Dakota 58763
Telephone: (701) 627-2520 Fax: (701) 627-4496
Tulalip Tribes of Washington
Stanley G. Jones, Chairman
Ed Parris or Charlene James, TANF
6700 Totem Beach Road
Tulalip, Washington 98271
Telephone: (360) 651-4381, Fax: (360) 651-3920
Central Council of Tlingit & Haida Indians
Ms. Sharon Olsen
320 West Willoughby, Suite 300
Juneau, Alaska 99801
Telephone: (907) 463-7134, Fax: (907) 463-7312
White Earth Reservation Tribe
Mr. Robert C. Goodwin
P.0. Box 70
2531 310th Avenue
Naytahwaush, Minnesota 56566
Telephone: (218) 935-5554, ext.3213 Fax: (218) 935-2593
Winnebago Tribe of Nebraska
Mr. Matt Cleveland
Accounting: Cheryl Painter: (402)-878-3140
P.O. Box 723 or P.O. Box 687
St. Augustine Mission Hill Dr.
Hwy. 77 North
Winnebago, Nebraska 68071
Telephone: (402) 878-2379 Fax: (402) 878-2228
Yakutat Tlingt Tribe
Mr. Bert Adams, Sr., Council President
P.O. Box 418
Yakutat, AK 99689
Contact: Ms. Shelly Bremner
Telephone: (907) 784-3401, Fax: (907) 784-3595
Pueblo of Zuni
Mr. Arlen Quetawki, Sr., Governor
P.O. Box 339
Zuni, NM 87327
Contact: Joan Shocky
Telephone: (505) 782-7186, Fax: (505) 782-7223
The Federal Register notice requesting comments on the reporting requirements for Public Law 102-477 grantees was published on October 18, 2006 (71 FR 61505). No comments were received; The Bureau of Indian Affairs meets with the grantees once each quarter. We have discussed these specific reporting requirements and the forms presented here are a product of those discussions. There are minor modifications to reflect legislation creating new Federal employment and training programs, including the Welfare to Work and Temporary Assistance to Needy Families programs. We met with the federal and tribal stakeholders on April 11, 2006 to discuss Government wide common performance measures for all employment and training programs which standardizes measures that the White House has implemented for FY 2004.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts are made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Not applicable; the annual report deals with totals and summaries, not with individual applicants.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
Questions of a sensitive nature are not collected and, therefore, not applicable to this collection.
12. Provide estimates of the hour burden of the collection of information. The statement should:
* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
The collection of data necessary to complete the forms is completed by administrators of the grant to determine eligibility and to report to tribal councils. No additional data collection is required to complete the P.L. 102-477 forms. These reports will be retained for the life of the grant.
The reporting requirements currently used will affect approximately fifty-one grantees. We estimate that fewer hours are needed to complete the forms than previously estimated in previous years This estimate is based upon three years of experience implementing the P.L. 102-477 program and working directly with respondents on the completion of forms. Many of the grantees state that their reporting requirement to their respective tribal councils is more stringent than the reports required by this program, is reported more frequently and the data is already collected. This allows easier completion of the forms for respondents.
The “Financial Status Report” requires an estimated two (2) hours to complete. Estimating the salary costs at $35/hour, this report costs $35 X 2 X 51 equals an annual sum of $3,570.00.
The “P.L. 102-477 Demonstration Project Statistical Report,” requires approximately sixteen (16) hours to complete. The estimated salary cost is $35/hour for each grantee, times sixteen (16) hours per grantee or $560. All 51 grantees cost will be $28,560 to complete the statistical form.
We estimate it requires 40 hours to complete the program narrative for each grantee or $35.00 per hour X 40 hours = $1,400 each grantee. There are 51 grantees X $1,400 equals $71,400. The total cost for the Statistical Report and the Narrative totals $99,960.
Not all 51 grantees include TANF funds in their Pub. L. 102-477 grants. We estimate 30 grantees will participate in TANF resulting in 2 hours per grantee to complete the forms at $35.00 per hour or $70.00 per grantee times 30 grants equal $2,100 for all grantees. The following table explains the burden.
Form Information |
Number of Respondents |
Hourly Burden |
Total Annual Burden Hours |
Total Annual Cost: HrX$35 |
O&M annual cost: $5X51 |
Total Federal Cost: HrX$40 |
Financial Report |
51 |
2 |
102 |
$3570. |
|
160 hours |
Statistical Report & Narrative |
51 |
56 |
2856 |
$99,960. |
$255. |
|
TANF |
30 |
2 |
60 |
$2,100.00 |
|
|
Totals |
|
|
3018 |
$105,630 |
$255. |
$6400.00 |
13. Provide an estimate of the total annual [non-hour] cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).
* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information [including filing fees paid]. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no additional costs to grantees reported in #12 above; any automation has probably been done by grantees for use in managing the tribal government and would have occurred regardless of this report. An estimated $5.00 per grantee for the cost of paper and file maintenance, times 51 grantees equals $255.00 for all.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
Approximately 160 hours annually is spent on the collection, verification of forms, summarizing data, printing and distribution of data to other federal agencies and to bureau management for policy decisions. This estimated does not include cost to the Department of Labor Department of Health and Human Services which receives copies of the data.
The estimated annual cost is based on $40/hour X 160 hours per year or $6,400. per year. This estimate is based on five (5) years of experience implementing the program.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
There are an additional 2 new tribes that were added since 2003 from 49 tribal grantees to 51 tribal grantees. We are reporting 6762 hours to reinstate and an adjustment downwards of 3744 hours based on improved estimates.
16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The Bureau of Indian Affairs does not intend to publish the annual reports; we will distribute the summary to each of the other two Federal agencies involved in the project.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
We will display the OMB Control number and expiration date on the forms.
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
The requirements for certification for the Paperwork Reduction Act submissions are fully met with no exceptions requested.
P.L.
102-477 Page
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | Ruth Bajema |
| Last Modified By | Indian Affairs User |
| File Modified | 2007-07-03 |
| File Created | 2007-07-03 |