Paperwork Reduction Act Submission
Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.
1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of Public and Indian Housing, Office of Native American Programs |
2. OMB Control Number: a.
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years form approval date b. Other (specify) Expedited Review-180 Days |
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7. Title: Native American Housing Block Grant (NAHBG) Information Collection
8. Agency form number(s): (if applicable)
SF-424, SF-LLL, HUD- 2880, HUD-2993 and new HUD forms HUD 4123-A and HUD 4125-A.
9. Keywords:
Housing, Indians, NAHASDA, Low-income Housing, Native American Housing Block Grant, American Recovery and Reinvestment Act of 2009.
10. Abstract:
Native American Housing Block Grant (NAHBG) funding was appropriated by the American Recovery and Reinvestment Act of 2009 (Recovery Act) to provide Indian tribes or their tribally designated housing entities (TDHEs), eligible to receive funding under the Native American Housing Assistance and Self Determination Act (NAHASDA), with economic stimulus funds. The NAHBG provides competitive funding to eligible entities for the development and operation of low-income housing in Indian areas with priority given to projects that will spur construction and rehabilitation and will create employment opportunities for low-income and unemployed persons.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. x Individuals or households e. Farms b Business or other for-profit f. Federal Government c. Not-for-profit institutions g. P State, Local or Tribal Government |
12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. Voluntary b. P Required to obtain or retain benefits c. X Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 366 b. Total annual responses 766 Percentage of these responses collected electronically 52% c. Total annual hours requested 24,880 d. Current OMB inventory 0 e. Difference (+,-) 24,880 f. Explanation of difference: 1. Program change: 0 2. Adjustment: |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs $0.00 b. Total annual costs (O&M) $0.00 c. Total annualized cost requested $0.00 d. Total annual cost requested $0.00 e. Current OMB inventory 0 f. Explanation of difference: 1. Program change: 0 2. Adjustment: 0 |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. P Application for benefits e. Program planning or management b. Program evaluation f. Research c. General purpose statistics g. x Regulatory or compliance d. Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure b. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe) Final Report
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Deborah Lalancette Phone: (303) 675-1625 |
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19. Certification for Paperwork Reduction Act Submissions
On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.
The following is a summary of the topics, regarding the proposed collections of information that the certification covers:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
Signature of Program Official:
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Date: |
Supporting Statement for Paperwork Reduction Act Submissions
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.
The “American Recovery and Reinvestment Act of 2009” (Recovery Act) was enacted on February 17, 2009 to provide economic stimulus for the U.S. economy. The Recovery Act appropriated $510 million for “Native American Housing Block Grants,” (NAHBG) as authorized under Title I of the Native American Housing Assistance and Self-Determination Act of 1996 (NAHASDA) 25 U.S.C. 4101 et seq. (copy attached) to remain available until September 30, 2011. The Department of Housing and Urban Development (HUD), Office of Public and Indian Housing (ONAP), is directed by the Recovery Act to provide $242,250,000 of this amount for competitive grants to eligible entities that receive NAHASDA funds. Eligible entities are comprised of approximately 579 native entities throughout the country, which includes Indian tribes, pueblos, Alaska Native Regional Corporations, and Alaska Native Villages. These entities may designate a housing entity to oversee all of their housing programs. These designated housing entities may represent one or many native entities. Currently, there are 366 NAHASDA housing entities funded through the Indian Housing Block Grant (IHBG) program eligible to apply for the NAHBG competitive grants created by the Recovery Act. NAHBG provides competitive funding to these eligible entities for the development and operation of low-income housing in Indian areas with priority given to projects that will spur construction and rehabilitation and will create employment opportunities for low-income and unemployed persons. HUD expects to fund approximately 80 Indian tribes or their tribally designated housing entities (TDHEs) under the NAHBG Recovery Act Notice of Funding Availability (NOFA). Eligible applicants will be invited to submit grant applications through the NAHBG NOFA which will be published in the Federal Register. Applicants will be selected based on the information they provide in an application in response to this NOFA.
The collection of this information is necessary because it provides descriptions of how a tribe or TDHE will use Recovery Act funds to provide affordable housing units and how individual plans meet the intent of the Recovery Act. NAHASDA is a formula-driven program whereby eligible recipients receive an equitable share of funds as appropriated by Congress. The NAHASDA statute does not provide for a competitive funding process. As a result, application forms for the NAHBG competitive funds have not been developed. The NAHBG Recovery Act competitive funding application is adapted from the Indian Community Development Block Grant (ICDBG) program; an existing competitive grant program administered by HUD ONAP for eligible Indian tribes. The following existing HUD forms will be part of the NAHBG application information collection:
SF-424, Application for Federal Assistance. This form includes a Dun and Bradstreet Universal Numbering System (DUNS) number.
SF-LLL, Disclosure of Lobbying Activities. This form must be submitted by state recognized Indian tribes and tribally designated housing entities established only under state law.
HUD-2880, Applicant/Recipient Disclosure/Update Report. Applicant provides information in accordance with Section 102 of the HUD Reform Act.
HUD-2993, Acknowledgement of Application Receipt. This is relevant only to applicants submitting paper applications.
This request is for two new application forms adapted from the ICDBG program that HUD will use for the NAHBG competitive funding process:
Form *HUD-4123 A, Cost Summary, requires respondents to provide data in the following categories: (1) Name of applicant; (2) Application/grant number (to be assigned by HUD upon submission); (3) Check boxes indicating if the submission is original, a revision or an amendment along with the date of application; (4) Project name & project category with a breakout of NAHBG funds and source of other funds; (5) Administration and planning costs; (6) Sub Total (totals of columns b and c; and (7) Grand Total (sums of column b and c).
Form *HUD-4125 A, Implementation Schedule, requires respondents to provide data in the following categories: (1) Name of applicant; (2) Application/grant number (to be assigned by HUD); (3) Check boxes indicating whether the submission is original, a revision or an amendment along with the date of application; (4) Name of project (as shown on form HUD-4123 A, item 4; (5) Effective Date; Expected completion date and expected closeout date; (6) Environmental Review Status checkboxes; (7) Tribal fiscal year; (8) Task list; (9) Schedule; (10) Planned drawdowns by quarter; and (11) Cumulative drawdown.
The following forms may be used for the grantee reporting requirements, however, HUD anticipates that OMB will develop reporting forms specific for the Recovery Act programs that will replace these forms:
SF 425, Federal Financial Reporting Form
HUD 52735-AS, Annual Reporting Form
*The collection of information refers to the whole NAHGB application which is estimated to take 40 hours to complete.
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.
HUD ONAP will use the information to ensure that statutory and regulatory requirements are met prior to entering into grant agreements, including information regarding distribution and obligation of funds when spending this one time allocation. Respondents are eligible Indian tribes or tribally designated housing entities (TDHEs). The information is collected during the application process. Collection of this data will serve two purposes:
a) It will enable HUD to select grantees under a competitive selection process with the assurance that the grantee has the capacity to quickly and effectively implement economic stimulus projects in Indian country.
b) It will enable the Office of Native American Programs Grants Management Specialists and Grants Evaluation Specialists to monitor each grantee's performance according to their projected budget and implementation schedules.
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.
Applicants submit their applications packages to the Office of Native American Programs Headquarters through a paper application mailed to ONAP Headquarters.
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 program does not duplicate any existing government program. No similar information is available.
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.
The NAHBG program does not involve small businesses or other small entities.
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.
If the requested information were not collected during the application process, HUD would not have qualitative and quantitive criteria for selecting applicants with the capacity to implement the Recovery Act projects in a timely manner. If information were not collected for monitoring purposes, HUD would not be able to ensure that federal dollars were being spent wisely and appropriately and in accordance with the NAHBG Recovery Act criteria to obligate 100 percent of their funds within 1 year of the date the funds are made available, expend at least 50 percent of such funds within 2 years of fund availability and expend 100 percent of such funds within 3 years of fund availability.
Information collected pursuant to submitting applications is requested only once per application cycle, the minimum amount of time possible. Information collected for monitoring purposes is submitted quarterly during the three year grant performance period. To require less frequent submission would mean that no action could be taken to correct administrative problems before the end of the grant period nor would timely information on project progress be made available for Recovery Act reporting purposes.
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 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 than 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 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.
Respondents are not required to report information to the agency more than quarterly;
Respondents are not required to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Respondents are not required to submit more than an original and two copies of any document;
Respondents are not required to retain records other than health, medical, government contract, grant-in-aid or tax records for more than three years;
The information collection does not require the use of statistical survey that is not designed to produce valid and reliable results than can be generalized to the universe of study;
The information collection does not require the use of a statistical data collection that has not been reviewed and approved by OMB;
The information collection does not include a pledge of confidentiality not supported by statutory or regulatory authority et al;
The information collection does not require respondents to submit proprietary trade secrets or other confidential information.
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 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 the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.
Not Applicable.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.
HUD ONAP does not have unique confidentiality policies or other privacy polices applicable to the collection of this information. There is no assurance of confidentiality. This information is available under the Freedom of Information Act.
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.
There are no questions of a sensitive nature included in the information 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 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; and
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 13.
There are approximately 579 native entities throughout the country, which includes tribes, pueblos, Alaska Native Regional Corporations and Alaska Native Villages. The native entities may designate a housing entity to oversee all of their housing programs. These designated housing entities may represent one or many native entities. The 366 NAHASDA housing entities funded through the Indian Housing Block Grant (IHBG) program are eligible to apply for the NAHBG competitive grants created by the Recovery Act.
Pre-Award
HUD estimates that each applicant will spend approximately 40 person-hours to complete a NAHBG competitive grant application. HUD estimates the mean hourly rate at $18. For 366 applications, the computation is as follows: 366 applications X 40 hours X $18 per hours= $263,520.
Description of Information Collection |
Number of Respondents |
Responses per Year |
Total Annual Responses |
Hrs per Response |
Total Hours |
SF424 |
366 |
1 |
366 |
0 |
0 |
HUD 4123 A |
366 |
1 |
366 |
2 |
732 |
HUD 2880 |
366 |
1 |
366 |
2 |
732 |
HUD 4125 A |
366 |
1 |
366 |
2 |
732 |
SF-LLL |
366 |
1 |
366 |
0 |
0 |
HUD 2993 |
366 |
1 |
366 |
0 |
0 |
Rating factor 1 |
366 |
1 |
366 |
8.50 |
3111 |
Rating factor 2 |
366 |
1 |
366 |
8.50 |
3111 |
Rating factor 3 |
366 |
1 |
366 |
8.50 |
3111 |
Rating factor 4 |
366 |
1 |
366 |
8.50 |
3111 |
Total |
366 |
1 |
366 |
40.00 |
14,640 |
2) Post-Award
HUD anticipates that OMB will develop Recovery Act reporting requirements for the Recovery Act programs. In the interim, HUD is providing the estimates used for the Post-Award Reporting requirements for the Indian Housing Block Grant program. HUD estimates that each grantee will spend approximately 128 hours a year maintaining records. HUD estimates that each grantee will spend approximately 8 hours a year preparing monitoring reports and 120 hours during each funding cycle's final grant year preparing a final report. Clerical staff will prepare the Post-Award reports. HUD estimates the applicable hourly rate at $18. The computation is as follow: 80 grantees x 128 hours x $18 an hour = $184,320.
Description of Information Collection |
Number of Respondents |
Responses per Year |
Total Annual Responses |
Burden Hours |
Total Hours |
Federal Cash Transaction Reports (SF-425) |
80 |
4 |
320 |
2 |
640 |
Annual Performance Reports (HUD-52735-AS) |
80 |
1 |
80 |
120 |
9600 |
Total |
80 |
|
400
|
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10240 |
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers 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 purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. 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 is no capital/start-up or ongoing operation/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 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.
1) Pre-Award.
Three hundred and sixty-six applications are expected to be submitted during this one time competitive funding cycle. The review process will be similar to the review of Indian Community Development Block Grant (ICDBG) applications. In general, the review of a single, average ICDBG application is estimated to take approximately 4 to 8 hours to review from beginning to end. This review is conducted by one person, having an average grade of GS-12 (step 5) at an hourly rate of $32.36. Averaging the review time to 6 hours, the annual review process will take approximately 2,196 hours. The computation is as follows: 366 applications x 1 person x 6 hours x $32.36 = $71,062.56.
2) Post-Award
HUD will award approximately 80 grants pursuant to NAHBG Notice of Funding Availability. With annual reporting, HUD would receive 80 progress reports for each grant cycle, requiring a total review time of 120 hours per grant per report, for a total of 9,600 hours. Assuming a GS-12 (step 5) conducts the reviews, the cost is computed as follows: 120 hours x 80 reports x $32.36 an hour = $310,656.
15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the OMB Form 83-I.
This is a new collection.
16. For collection 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 1989 Reform Act requires that all funding awards be published in the Federal Register.
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.
The OMB approval number and the expiration date will be shown on all the HUD forms..
18. Explain each exception to the certification statement identified in item 19.
There are no exceptions to the certification statement, item 19 of OMB Form 83i. .
B. Collections of Information Employing Statistical Methods
The information collection will not use statistical methods. .
OMB 83-I 10/95
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Paperwork Reduction Act Submission |
| Author | HUD |
| File Modified | 0000-00-00 |
| File Created | 2021-02-03 |