Narrative of Revisions

Changes to Collection OMB No. 1660-0073

The following questions have been updated since the last OMB Approval:

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. Changes are that FEMA Form numbers are now assigned to the program forms – forms approved under 1660-0025 have not changed. Also, descriptions are more detailed.

Narrative Statement (FEMA Form 089-10): FEMA uses narrative statements to evaluate a grantee’s proposed use of funds and is a requirement in order to receive Federal funding. Examples of information a grantee needs to provide FEMA for readiness and response cooperative agreements are descriptions of the types of eligible activities the grantee will undertake and a plan for expending and monitoring funds. Sponsoring Organizations make this information available to FEMA only when we request it. If a Sponsoring Organization has remaining preparedness or response cooperation agreement funds after completing specific disaster or preparedness work, we will require a second narrative statement describing the grantee’s proposed use of the remaining funds.

Performance Reports (FEMA Form 089-11): FEMA program officers use progress reports to monitor overall progress on managing FEMA grant programs. FEMA does not prescribe a particular format; however, we ensure that the OMB standard elements outlined in the common rules, 44 CFR Part 13 and 2 CFR Part 215, are in any report or suggested format.

Extension /Budget Changes (FEMA Form 089-12): Grantees that want FEMA to consider changing or extending the time or the performance period of the preparedness or response cooperative agreement will need to request such changes or extensions in writing. FEMA will use the information to ensure that the Sponsoring Organization spends funds consistent with the intent of the appropriations and in accordance with applicable laws and guidance. This type of information is available to FEMA only when we request it.

Self-Evaluations (FEMA Form 089-14): The Task Force Self-Evaluation is a preparatory measure to the Operational Readiness Evaluations conducted each year to ensure all Task Forces are ready to deploy to an incident when they receive a Federal activation.

Task Force Deployment Data (FEMA Form 089-15): To prepare for an event outside the continental United States (OCONUS), or a scenario where alternative transportation may be required, the program office requires each Task Force to report weights and cubes of their cache, as well as hazardous materials to provide to appropriate loadmasters, etc, for possible air/sea transport.

Memoranda of Agreement Revisions (MOA) (FEMA Form 089-13): FEMA and the Sponsoring Organizations of US&R task forces have entered into 28 separate MOAs. MOAs are signed by DHS, the Sponsoring Agency and the State, and describes the relationship of the parties with respect to the National Urban Search and Rescue Response System.

The following forms were approved under OMB approval number 1660-0025:

SF 424 - FEMA uses the SF 424, Application for Federal Assistance, for all of its grants and cooperative agreements. FEMA will enter into two types of cooperative agreements with each of the existing 28 US&R teams (and any other teams that may qualify in the future): (1)Readiness Cooperative Agreements and (2) Response Cooperative Agreements. Funds under Preparedness Cooperative Agreements will be available to Sponsoring Organizations to administer the Task Forces, provide initial and recurrent training, and to acquire and maintain a uniform cache of equipment and supplies. Funds under Response Cooperative Agreements will reimburse Sponsoring Organizations for actual direct costs and indirect costs incurred when FEMA activates US&R teams in response to a major disaster or emergency.

FEMA Form 20-20 -Grantees use FEMA Form 20-20, Budget Information –Non-construction Programs and Budget Narrative, to submit budget data when applying for grants where the major purpose is not construction. The information includes a budget narrative that relates items to program activities and justifies and explains budget items. Grantees make budget narrative information available to FEMA upon request. This form compiles the information necessary to fill out the SF 424 face sheet. Like the SF 424, both preparedness and response cooperative agreement grantees must submit a revised FEMA Form 20-20 when they know the final grant award amount.

FEMA Form 20-16 A, B, and C - Grant recipients use FEMA Forms 20-16, Summary Sheet for Assurances and Certifications, 20-16A, Assurances – Non-construction Programs, and 20-16C, Certifications Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; and Drug-Free Workplace Requirements to certify their compliance with important Federal Requirements.

FEMA Form 76-10A –Obligating Document for Award/Amendment must be signed by the State representative and returned to FEMA.

SF LLL - Grantees must complete SF LLL, Disclosure of Lobbying Activities, if expending Federal funds in attempts to influence Federal agency employees or members of Congress or their representatives.

FEMA Form 20-10 - Sponsoring Organizations will use FEMA Form 20-10, Financial Status Reports, to report the status of financial expenditures for both preparedness and response grants. FEMA uses this report for all of its grant and cooperative agreement programs. To maintain consistency among FEMA grant programs and alleviate paperwork burdens on grantees, we will use FEMA Form 20-10 for financial reporting rather than the SF 269.

Audits of States, Local Governments and Non-profit Organizations - In accordance with OMB circular A-133, recipients that expend $500,000 or more in a year in Federal funds must have an independent auditor perform a single or program-specific audit for that year.

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. The information regarding the percentage of electronic responses is updated.

FEMA also provided Sponsoring Organizations with user manuals and CDs to facilitate templates, spreadsheets, reports and applications for the collection, maintenance, and out use of the data. US&R grant forms can be downloaded from the GSA website. The US&R Task Forces are required to submit all information via email. Nearly 100% of US&R cooperative agreement information is handled electronically using email.

FEMA US&R uses the Department of Health and Human Service’s SMARTLINK web-based payment system. SMARTLINK permits reporting requirements to be completed on –line, and will permit access to the Sponsoring Agencies to cooperative agreement funds on an as-needed basis.

12. Provide estimates of the hour burden of the collection of information. The statement should: PLEASE NOTE: All changes are detailed in Question 15 (below).



 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). 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.

FEMA Urban Search and Rescue Response System is currently comprised of 28 Sponsoring Organizations which are required to submit approximately 16 burden hours (each Task Force) to prepare for the collection of financial, program and administrative information for US&R Sponsoring Organizations relating to preparedness and response Cooperative Agreement awards.

The Narrative Statement (FEMA Form 089-10) is completed once annually by 28 grantees with an average burden per response of 4 hours and the total annual burden is 112 hours..

The Performance Reports (FEMA Form 089-11) are completed semi-annually by 28 grantees with an average burden per response of 2 hours and the total annual burden is 112 hours.

The Extensions/Budget Changes (FEMA Form 089-12) are completed semi-annually by 28 grantees with an average burden per response of 1 hour and the total annual burden is 56 hours.

The Memorandum of Agreement (FEMA Form 089-13) is completed once annually by grantees with an average burden per response of 4 hours and the total annual burden is 112 hours.

The Self Evaluations (FEMA Form 089-14) are completed once annually by 28 grantees with an average burden per response of 2 hours and the total annual burden is 56 hours.

The Task Force Deployment Data (FEMA Form 089-15) are completed once annually by 28 grantees with an average burden per response of 1 hour and the total annual burden is 28 hours.

 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.

Table A.12: Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate ($)	Total Annual Respon-dent Cost ($)
State, Local or Tribal Government (US&R Task Forces)	Narrative Statement / FEMA Form 089-10	28	1	4	112	$32.67	$3,659
State, Local or Tribal Government (US&R Task Forces)	Performance Reports / FEMA Form 089-11	28	2	2	112	$32.67	$3,659
State, Local or Tribal Government (US&R Task Forces)	Extensions/Budget Changes / FEMA Form 089-12	28	2	1	56	$32.67	$1,830
State, Local or Tribal Government (US&R Task Forces)	Memorandum of Agreement Revisions / FEMA Form 089-13	28	1	4	112	$32.67	$3,659
State, Local or Tribal Government (US&R Task Forces)	Self Evaluations / FEMA Form 089-14	28	1	2	56	$32.67	$1,830
State, Local or Tribal Government (US&R Task Forces)	Task Force Deployment Data / FEMA Form 089-15	28	1	1	28	$32.67	$915
Total		28			476		$15,552

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category, using figures derived by taking the average salary of every full-time employee within each task force, the estimated burden hour cost to respondents is $32.67 per hour. This is based on the following respondent occupational categories: job titles for these individuals are Program Manager ($37.47), Grant Manager ($41.97), Logistician ($34.62) and Administrative Support ($16.62).

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. Costs are updated to more accurately reflect those associated with this collection.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]
Staff Salaries 2 of GS 13 employees spending approximately 70 % of time annually reviewing and analyzing information collected for this data collection, 1 of GS 9 employees spending approximately 90 % of time annually reviewing and analyzing information collected for this data collection	$171,000
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 [number of data collection instruments annually]
Postage [annual number of data collection instruments x postage]
Other
Total	$171,000

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. See descriptions below each chart for changes.

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
Narrative Statement / FEMA Form 089-10				224	112	-112
Performance Reports / FEMA Form 089-11				112	112	0
Extensions/Budget Changes / FEMA Form 089-12				5	56	+51
Memorandum of Agreement Revisions / FEMA Form 089-13				112	112	0
Self Evaluations / FEMA Form 089-14				0	56	+56
Memorandum of Agreement / No Form				8	0	-8
Task Force Deployment Data / FEMA Form 089-15				0	28	+28
Total(s)				461	476	+15

Explain: The change to the narrative statement (FEMA Form 089-10) burden hours results from the fact that it is now requested only once. The performance report (FEMA Form 089-11) burden hours remain the same. The extension/budget changes (FEMA Form 089-12) are now received of all applicants and the burden hours reflect this as a result of the increase in number of respondents. The memo of agreement (FEMA Form 089-13) burden hours remain the same. Self Evaluations (FEMA Form 089-14) were not part of the prior collection and are now a part of the collection. The task force deployment data (FEMA Form 089-15) was not part of the prior collection and is now a part of the collection. There are no new memorandums of agreement received for this program, so the burden is removed.

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
Narrative Statement / FEMA Form 089-10				$13,440	$3,659	-$9,781
Performance Reports / FEMA Form 089-11				$6,720	$3,659	-$3,061
Extensions/Budget Changes / FEMA Form 089-12				$300	$1,830	+$1,530
Memorandum of Agreement Revisions / FEMA Form 089-13				$480	$3,659	+3,179
Self Evaluations / FEMA Form 089-14				0	$1,830	+1,830
Memorandum of Agreement / No Form				$6,720	0	-$6,720
Task Force Deployment Data / FEMA Form 089-15				0	$915	+$915
Total(s)				$27,660	$15,552	-$12,108

Explain: Part of the overall change in the annual cost burden is attributed to a reduction in the per-hour wage-rate category that resulted from a more exact average cost calculated from the respondent categories. The remaining change results from: The narrative statement (FEMA Form 089-10) is now requested only once. The performance report (FEMA Form 089-11) annual cost burden remains the same. The extension/budget changes (FEMA Form 089-12) are now received of all applicants and the annual cost burden reflects this as a result of the increase in number of respondents. The memo of agreement (FEMA Form 089-13) reflects the receipt of information from all respondents. Self Evaluations (FEMA Form 089-14) were not part of the prior collection and are now a part of the collection. The task force deployment data (FEMA Form 089-15) was not part of the prior collection and is now a part of the collection. There are no new memorandums of agreement received for this program, so the burden is removed.