Supporting Statement 1660-0061 2-26-09 (2)(IHP Edits) final

June 30, 2008

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0061

Title: Federal Assistance to Individuals and Households Programs

Form Number(s): FEMA Form 90-153 Administrative Option Selection

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 or 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. Provide a detailed description of the nature and source of the information to be collected.

Section 206(a) of the Disaster Mitigation Act of 2000 (DMA 2000), Public Law 106-390, consolidated into one section of the Robert T. Stafford Disaster Relief and Emergency Assistance Act two previously existing programs, the “Temporary Housing Assistance” and the “Individual and Family Grant Programs” into a single program called the “Federal Assistance to Individuals and Households” (IHP). To implement this consolidation, which streamlined the provision of assistance to disaster victims, FEMA published rule 44 CFR Part 206 which included this collection of information under the purview of the Paperwork Reduction Act. This information collection provides: 1) disaster victims the opportunity to request approval of late applications, continued assistance, and appeal program decisions and, 2) States with a better opportunity to be active participants in the “Other Needs” provision of the IHP through the review of an administrative option agreement and the development of an administrative plan.

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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

Individuals requesting approval of late application, request for continued assistance or appealing a program decision would be required to submit such a request in writing via mail or fax to FEMA’s Maryland National Processing and Service Center. A FEMA appeals officer will review the information submitted in accordance with established program criteria and procedures.

States opting to participate in the administration or management of the Other Needs provision of IHP must submit via mail a signed Administrative Option Agreement establishing the State’s proposed level of support and participation in the delivery of assistance under Section 408 of the Stafford Act. The FEMA Regional Director or designee and the State will use the agreement for planning and developing program implementation procedures to be used during the next calendar year in the implementation of programs under Section 408 of the Stafford Act.

In order to accomplish the objectives stated above, this collection consists of the five elements as follows:

1. Request for Approval of Late Registration. After the registration period ends, 60 days from date of declaration, FEMA will accept late registrations for an additional 60 days. FEMA will process late registrations for those applicants who provide justification for the delay in their registration. In order for FEMA to effectively review the late registration request, it is necessary that we have the request be in writing explaining the reason(s) for the delay in registering.

2. Request for Continued Assistance. After the initial assistance, FEMA may provide continued assistance, based on need. In order for FEMA to effectively evaluate the continuing need, it is necessary that we have the applicant submit documentation on their pre-disaster and current housing costs, pre-disaster and current income and verifiable documentation of income, current lease/cancelled checks, and mortgage payment information. FEMA determines the appropriateness of assistance and the establishment of criteria, standards, and procedures for determining eligibility for assistance. The submission of the required information will be mandatory to be considered for continued assistance.

3. Appeal of Program Decision. After the initial eligibility decision is made, FEMA provides the applicant with the opportunity to inquire or appeal any determination of eligibility for assistance made under the Federal Assistance to Individuals and Households Program. In order for FEMA to effectively respond to an applicants appeal, it is necessary that we have the applicant provide, in writing, what they are appealing, and the reason for the appeal.

4. FEMA Form 90-153, Administrative Option Agreement (for the Other Needs provision of IHP). The purpose of an Administrative Option Agreement between FEMA and the State is to establish a plan for the delivery of assistance under Section 408 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), as amended. In order for FEMA to effectively coordinate program activities with the State, it is necessary that we have the State sign an agreement, which establishes a partnership with FEMA and inscribes the plan for the delivery of disaster assistance. The agreement is used to identify the State’s proposed level of support and participation during disaster recovery.

5. Development of State Administrative Plan for the Other Needs provision of IHP. When the State’s request for a grant from FEMA to provide financial assistance to individuals and households in the State under the Other Needs provision of IHP has been approved, the State will need to address the level of managerial and resource support necessary to complete the State role. In order for FEMA to effectively account for the program costs and to ensure the equitable and timely delivery of assistance, it is necessary that we have the State provide an administrative plan to address the financial and grants management mandates. FEMA is required to monitor the cost effectiveness of the assistance.

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.

In an effort to ease the burden and expedite the review of applicants’ request for approval of late application, request for continued assistance or an appeal of a program decision, FEMA will accept all of the above information in person, via mail, or by fax. The forms that are part of this collection are available electronically. FEMA requires applicants to provide a signature for documents they submit. The Administrative Option Agreement and the State Administrative Plan for the Other Needs provision of IHP, are documents requiring original signatures.

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.



This information is not collected in any form, and therefore is not duplicated elsewhere.

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.

This information collection does not have an impact on small businesses or small entities.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

If the information collection from an applicant is not conducted it will have a negative impact on the applicant’s ability to request: Approval of a Late Application; Continued Assistance, and Appeal a program decision. The negative impacts could include the following; (1) Applicants who fail to apply within the fixed time frame will not be able to receive disaster assistance; (2) Applicants who have a continuing disaster need will not be able to receive additional assistance; (3) Applicants who disagree with FEMA program eligibility decisions will have no recourse to have their application reviewed.

If the information collection from a State is not conducted or is reduced (conducted less frequently) it will have a negative impact on FEMA’s ability to implement the Other Needs provision of IHP. The information to be collected is used in the decision-making process, which includes determining staffing levels and allocation of resources. The information to be collected allows FEMA to understand the requirements and capabilities of States, which includes being able to determine level of federal dedication the State will be expecting from FEMA. Failure to collect this information may result in delay or rejection of a State request to administer the Other Needs provision of IHP.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

This information collection is conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

1. Requiring respondents to report information to the agency more

often than quarterly.



 (b) Requiring respondents to prepare a written response to a

collection of information in fewer than 30 days after receipt of it.



(c) Requiring respondents to submit more than an original and two

copies of any document.



(d) Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.

(e) 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.



 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.

 (g) 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.



 (h) Requiring respondents to submit proprietary trade secret, 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.



8. Federal Register Notice:



 a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.



A 60-day Federal Register Notice inviting public comments was published on April 28, 2008, Volume 73, Number 82, pp. 22964. No comments were received. See attached copy of the published notice included in this package.

 b. 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.

FEMA consults with States, local and private entities including, the National Emergency Management Associations (NEMA) Response and Recovery Subcommittee, the International Association of Emergency Managers and the State Governors’ Washington representative. FEMA receives feedback on the processes employed to gather the information required as per this collection.

FEMA also consults with individuals who would complete other collection instruments within this collection. A survey conducted under OMB No. 1660-0036 questions all aspects of the of the process that is utilized in this collection of information and the results are compared against the program and appropriate modifications are implemented.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

FEMA has had extensive consultations with representatives of a number of States, local and private entities including, the National Emergency Management Associations (NEMA) Response and Recovery Subcommittee, the International Association of Emergency Managers and the State Governors’ Washington representative. Based on our consultations, we have determined that this collection will not have negative effect on individuals or States.

Consultations with individuals responding to this collection are accomplished with a survey on program effectiveness that is approved for use under OMB No. 1660-0036. These surveys are randomly administered to a sample population within each disaster and occur after each disaster.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

10. Describe any assurance of confidentiality provided to respondents. Present the basis for the assurance in statute, regulation, or agency policy.



All provisions of the Privacy Act of 1974, 5 U.S.C. 552a, apply to FEMA. FEMA may not disclose an applicant’s record except in response to a release signed by the applicant that specifies the purpose of the release, to whom the release is to be made, and who authorizes the release and/or a published routine use. The information collected that is personally identifiable is required for the review of decisions made in OMB collection 1660-0002, Disaster Assistance Registration, and a Privacy Impact Assessment has previously been completed for this collection.

11. Provide additional justification for any question 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.

There are no questions of a sensitive nature.

 12. Provide estimates of the hour burden of the collection of information. The statement should:



 a. 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 desired. 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.

Request for Approval of Late Registration – The number of respondents for this collection instrument is 6,389 and the frequency of completing this instrument is once annually. There are guidelines in place that allow for a limited opportunity to file a late application for assistance, and based on historical data, only a limited number of respondents will qualify to file for consideration

Request for Continued Assistance – The number of respondents for this collection instrument is 80,000 and the frequency of completing this instrument is four times annually. The need for continued assistance is determined from the information provided on this form, and it circumstances beyond the normal scope of FEMA’s involvement in disaster recovery would necessitate the need for this assistance. The number of respondents is based on the historical information regarding applications received.

Appeal of Program Decision – The number of respondents for this collection instrument is 234,591 and the frequency of completing this instrument is once annually. This instrument allows for respondents to appeal a decision of an award resulting from disaster occurrence. The number of respondents for this instrument is based on historical data providing the level of appeal activity estimated to occur in an average year.

FEMA Form 90-153, Administrative Option Agreement (for the Other Needs provision of IHP) – The number of respondents for this collection instrument is 56 and the frequency of completing this instrument is once annually. No all respondents to this collection instrument are required to submit the State Administration Plan. This instrument is completed by each of the States, possessions and Territories on a yearly basis as this information is required for any of the respondents to make a request for post-disaster assistance, and the number of respondents is based on the yearly number of instruments received.

Development of State Administrative Plan for the Other Needs provision of IHP – The number of respondents for this collection instrument is 6 and the frequency of completing this instrument is once annually. The number of respondents is based on the estimated 6 states that will request to participate in the administration and management of IHP.

b. 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.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for all civilian workers is estimated to be $19.29 per hour, therefore, the estimated burden hour cost to respondents all civilian workers is estimated to be $9,659,178.15 annually. According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for Executive, Administrator or Manager positions is estimated to be $30.79 per hour; therefore, the estimated burden hour cost to respondents Executive, Administrator or Manager positions is estimated to be $2093.72 annually.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

There are no recordkeeping, capital, start-up or maintenance costs associated with this information collection.

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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]
Staff Salaries [200 of GS 9 Step 1 employees spending approximately 10% of time annually processing the information received for this data collection, 12 of GS 12 Step 5 employees spending approximately 8.2% of their time reviewing the information from the states]	$886,334.52
Facilities [cost for renting, overhead, etc. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel
Printing	$67,418.82
Postage [Approximately 585,000 annual number of data collection instruments x .225]	$131,625.00
Other
Total	$953,884.97

Explanation of how staff salaries are calculated:

• For the workload of 321,042 respondents, there will be a staff of 200 (GS 9/1) spending 10% of their time processing the information. The current hourly basic rate of a GS 9/1 is $17.92 or $39,795 annually. The cost is calculated by multiplying the basic annual rate of a GS 9/1 by the number of staff (20). Total Cost = $795,900.00.

Additionally, for the information received from the states (62 respondents) there also will be a staff of 12 (GS 14/5) spending 8.2% of their time reviewing the information collected. The current hourly basic rate of a GS 14/5 is $44.04 or $91,905 annually. The cost is calculated by multiplying 8.2% of the basic annual rate of a GS 14/5 by the number of staff (12). Total Cost = $90,434.52.

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A "Program increase" is an additional burden resulting from an federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
FEMA Form 90-153 / Administrative Option Selection	56	56	0
Total(s)	56	56	0

Explain: There are no changes to the burden. The addition of the second page to FEMA Form 90-153 has consolidated the background material that respondents need to properly make a selection of administrator. The Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 93-288, as amended, 42 U.S.C. 5121-5207, and Related Authorities, allows for State involvement of the administration of Other Needs Assistance in Section 408 (42 U.S.C. 5174). Title 44 CFR 206.120 addresses the three choices States have in regards to the administration of ONA, which FEMA form 90-153 lists. The second page of the instructions (approval for which is requested in this change request) lists the 10 Functional Elements and where the responsibilities lie depending upon the option selected. This has always been a part of the collection, but the instructional information is now listed for ease of reference when the respondent completes the form.

The first page also has a checkbox that provides a physical response point for information already collected in the current process. There is no additional burden as this question is currently answered by the respondents as part of the collection.

The third page provides a place to provide information already collected as part of the Administrative Option selection process. As a matter of practice, states send this information to FEMA at the start of each disaster. The third page allows the state to submit the required information at the same time that they select the Administrative Option. By including the third page in the form, FEMA is providing the state a standard method to provide the required information currently submitted by respondents as a part of this collection.



Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
FEMA Form 90-153 / Administrative Option Selection	$1,724.24	$1,724.24	0
Total(s)	$1,724.24	$1,724.24	0

Explain There is no change to the annual hours burden and because of this, there is no change to annual cost burden.

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.



FEMA does not intend to employ the use of statistics or the publication thereof for this information collection.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

FEMA will display the expiration date for the OMB approval of this information collection.



18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

FEMA does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.



When Item 17 on the Form OMB 83-I is checked “Yes”, the following documentation should be included in the Supporting Statement to the extent it applies to the methods proposed:

There is no statistical methodology involved in this collection.

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