Paperwork Reduction Act Submission DRAFT
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 Assistant Secretary for Housing Office of Single Family – Program Support Division |
2. OMB Control Number: a. 2502-0261
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b. None
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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 from approval date b. Other (specify)
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7. Title:
Housing Counseling Program
8. Agency form number(s): (if applicable)
HUD-9900, HUD-424-CB, HUD-27300, HUD-2880, HUD-2990, HUD-2991, HUD-96010, HUD-9902, HUD-9908, HUD-9910, SF 424, SF LLL, SF 424 SUPP, HUD 2994
9. Keywords:
Housing, Community Development, Counseling, Support Services
10. Abstract:
Information allows HUD to contract with organizations that provide tenant and homeowner counseling. Counseling aids tenants and homeowners in improving their housing conditions and in meeting the responsibilities of tenancy and homeownership. HUD-approved agencies can compete for program funds.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. x Individuals or households e. Farms b. X Business or other for-profit f. x Federal Government c. P Not-for-profit institutions g. x 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. Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 12,450 b. Total annual responses 39,980 Percentage of these responses collected electronically 61% c. Total annual hours requested 36,320 d. Current OMB inventory 29,448 e. Difference (+,-) +6,872 f. Explanation of difference: 1. Program change: 2. Adjustment: +6,872 |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs 0 b. Total annual costs (O&M) 0 c. Total annualized cost requested 0 d. Total annual cost requested 0 e. Current OMB inventory 0 f. Explanation of difference: 1. Program change: 2. Adjustment: |
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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. x Program planning or management b. x Program evaluation f. x Research c. x General purpose statistics g. x Regulatory or compliance d. x Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennially 8. Other (describe)
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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: George H. Grotheer or Brian N. Siebenlist Phone: 202-708-0317 ext. 2294 or ext. 5415
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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) appears 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:
X Mike Winiarski, Director, Organizational Policy, Planning and Analysis Division, HROA |
Date: |
Signature of Senior Officer or Designee:
X Lillian Deitzer, Departmental Reports Management Officer |
Date: |
Housing Counseling Program – Automated Client Management Data System
OMB No. 2502‑0261
(HUD-9900, HUD-9902, HUD-9904, HUD-9908, HUD-9910)
A. Justification:
1. Overview of Housing Counseling Program
One of HUD’s major goals is to increase homeownership rates nationwide, particularly for low- and moderate-income and minority households. Homeownership education and counseling plays a central role in the achievement of this objective. Housing Counseling will significantly contribute to the goals of expanding homeownership and helping homeowners remain in their homes through foreclosure prevention strategies. Housing Counseling also supports innovative and aggressive efforts to combat predatory lending, another key priority.
The Single Family Program Support Division is responsible for administration of the Department’s Housing Counseling Program, authorized by Section 106 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701w and 1701x). A final housing counseling rule was published in the Federal Register in September 2007 and is codified at 24 CFR Part 214. The Housing Counseling Program supports the delivery of a wide variety of housing counseling services to homebuyers, homeowners, low- to moderate–income renters, and the homeless. The primary objectives of the program are to expand homeownership opportunities and improve access to affordable housing. Counselors provide guidance and advice to help families and individuals improve their housing conditions and meet the responsibilities of tenancy and homeownership. Counselors also help borrowers avoid predatory lending practices, such as inflated appraisals, unreasonably high interest rates, unaffordable repayment terms, and other conditions that can result in a loss of equity, increased debt, default, and foreclosure.
To participate in HUD’s Housing Counseling program, a housing counseling agency must first be approved by HUD. Approval entails meeting various requirements relating to experience and capacity, including nonprofit status, a minimum of one year of housing counseling experience in the target community, and sufficient resources to implement a housing counseling plan. Eligible organizations include community‑based non-profit organizations, national and regional intermediaries, and state housing finance agencies. The application for approval is found at http://www.hud.gov/offices/hsg/sfh/hcc/hccprof13.cfm .
Approximately 2,650 HUD-approved agencies provide housing counseling services nation-wide currently. HUD maintains a list of these agencies so that individuals in need of assistance can easily access the nearest HUD-approved housing counseling agency, via HUD’s website or an automated 1-800 Hotline. HUD-approved housing counseling agencies are required to annually submit form HUD-9902, the data collection instrument for the Program, electronically through HUD’s Housing Counseling System (HCS).
a. Client Level Data and Agency Profile Data
HUD is seeking approval for the collection of client level and agency profile data through an automated interface between HUD’s databases and client management systems (CMS) agencies utilize in order to build electronic files and transfer required agency, activity and client information into HCS. A CMS is an existing online tool that housing counselors are currently using that automates much of the housing counseling process, including client intake, file maintenance, financial and credit analysis, outreach and client notification, and reporting. The list of required client level and agency profile data fields is located on HUD’s website at the following link:
http://www.hud.gov/offices/hsg/sfh/hcc/debasicdescr3-1.pdf
HUD-approved housing counseling agencies already use one of the several CMSs that are available through the private sector. A final housing counseling rule published in the Federal Register on September 2007 and codified at 24 CFR Part 214 requires all HUD-approved counseling agencies to utilize a CMS, but gives them the flexibility to choose from competing products in the market. HUD issues specifications, including required data and other requirements, which a CMS vendor must meet to successfully interface with HCS.
Improve Counseling Quality
Universal CMS use will improve the quality of counseling offered by HUD-approved agencies by giving counselors immediate access to powerful tools, information and other resources. For example, CMSs must provide financial and credit analysis tools to help counselors analyze a client’s unique financial situation, for example, to evaluate readiness for homeownership. They must also be able to produce side-by-side comparisons of several mortgage products, including an FHA-insured mortgage, so that potential homebuyers can compare the costs and benefits of the loan products. CMSs are also programmable to recommend downpayment, closing cost, and other assistance programs if they meet a client’s needs.
Increase Efficiency
Universal CMS use improves the efficiency with which counseling and education is provided by HUD-approved agencies and with which HUD administers the Program. For example, record keeping is greatly simplified for counseling agencies by the automated intake and file creation possible through universal CMS. Counselors simply create and update client files through the CMS. Electronic files should take a fraction of the time it currently takes to create and maintain paper files, in addition to saving space.
Electronic files and the collection of client level data will also make HUD more efficient by reducing the cost of agency monitoring. HUD will have access to electronic client files, including client information, purpose of visit, counseling activity, and a record of the action plan agreed to by the counselor and client. This will allow desk reviews, minimizing the need for Housing staff to travel as frequently to visit counseling agencies on-site to fulfill monitoring requirements. Currently, HUD staff travel biennially to the counseling agency to sample files, among other activities.
Universal CMS use greatly expands and improves the quality and types of data available to HUD without increasing the reporting burden for counseling agencies. Counselors simply create and update client files through the CMS and required data is submitted to HUD. CMSs collect, and submit to HUD, required data fields.
Counseling agencies and HUD will benefit from the data sharing facilitated by CMS use and the reporting of client level data. For example, CMS use and client level data reporting will eventually eliminate the need for counseling agencies to manually complete and submit the form HUD-9902, the data collection instrument for the program, at the end of the fiscal year, reducing the time burden associated with reporting. Counseling agencies will submit to standardized reporting, such as the form HUD-9902, electronically in quarterly intervals. Program managers and grant administrators benefit from having accurate data available during the year, for example, to compare grantee progress against the benchmark outputs and outcomes projected in the Logic Model, form HUD-96010, submitted with the grant application.
HCS has functionality that automatically converts client level data populating form HUD-9902 and form HUD-96010, the Logic Model, as the housing counselor electronically builds and maintains a client’s file. This automation minimizes the chance for human error and subjective interpretation of the form instructions by the counseling agencies, vastly improving data quality.
New Data
HUD will have access to client level data for the first time, facilitating a more effective evaluation of the program and the impact of counseling. The lack of client-level data has long been a barrier to effective program evaluation and performance measurement. The form HUD-9902, which collects aggregate data, lacks sufficient detail to permit analysis of counseling results by subgroups or demographic characteristics. By contrast, client level data will allow HUD to finally be able to sort, by demographic characteristics, results data such as the number of clients receiving pre-purchase counseling that actually purchase a home. This represents a fundamental improvement in the quality of data available to program managers and evaluators, allowing for new and improved performance goals, enhanced agency monitoring, and more effective targeting of outreach, training and other resources. Because clients will be uniquely identified by a portion of their social security number, HUD will be able to link to FHA, Fannie Mae, and Freddie Mac databases to track clients long-term.
CMS and Client Level Data Responsive to Mandates
The collection of client level data and universal CMS use for the Housing Counseling Program are intended to be responsive to mandates from the Congress and the Office of Management and Budget (OMB) that HUD improve upon Housing Counseling Program data collection and performance measurement, and to automate reporting and other requirements. For example, in response to OMB’s Program Assessment Rating Tool (PART) review on the Housing Counseling Program in 2005, FHA committed to adopting standards for housing counseling programs and establishing efficiency measures to show cost effectiveness in achieving program goals. The client level data is critical to achieving these goals. Moreover, OMB found that the Housing Counseling Program’s lack of independent evaluations make it difficult to assess the program’s full impact. In response to this finding, the Office of Housing and the Office of Policy Development and Research (PD&R) agreed to jointly fund a study to evaluate the program’s impact, performance, and ability to achieve established goals. The client level data will facilitate this research.
CMS use and client level data collection is also responsive to the Government Paperwork Elimination Act (GPEA), which requires Federal agencies to allow the option of submitting information or transacting business with an agency electronically. The Office of Management and Budget (OMB) has made similar requests to HUD to improve management of reporting processes, including a more paperless environment, and to streamline data collection for the Housing Counseling Program.
b. Form HUD-9902
In conjunction with client level data collection, the existing form HUD-9902, the traditional performance data collection instrument for the Program, will continue to be collected and can be automatically populated by HCS based on submitted client level data.
c. Housing Counseling NOFAs
Annually, HUD issues two Notices of Funding Availability (NOFAs), grant competitions making available the majority of appropriated funds for the purpose of supporting the direct provision of Housing counseling services. The Housing Counseling Program issue two specific NOFAs – Housing Counseling and Housing Counseling Training. Eligible applicants generally include HUD-approved counseling agencies and State Housing Finance Agencies (SHFAs) and agencies with extensive training experience.
In 2009, HUD has 2,650 approved Housing Counseling agencies. To participate in HUD’s Housing Counseling program, a housing counseling agency must first be approved by HUD. Approval entails meeting various requirements relating to experience and capacity, including nonprofit status, a minimum of one year of housing counseling experience in the target community, and sufficient resources to implement a housing counseling plan. Eligible organizations include community‑based non-profit organizations, national and regional intermediaries, and state housing finance agencies. HUD Field Office staff monitor the activities of the HUD-approved housing counseling agencies. Desk monitoring is accomplished by means of information available within that office. A HUD biennial performance review is required for every approved agency to determine if HUD should renew its approval of the agencies.
Application to Become a HUD-Approved Agency
Form HUD-9900, Application for Approval as a Housing Counseling Agency. A one time document that any non-profit housing counseling agency uses when applying to join HUD’s Housing Counseling program. Approximately 200 agencies apply for HUD approval annually.
Data Collection
Form HUD-9902, Housing Counseling Agency Fiscal Year Activity Report. This form is submitted by all agencies participating in the program (2650 agencies) 4 times per year.
Required client level and agency profile data fields are attached.
Agency profile information will include the standard contact information HUD will use to update the web list of HUD-approved housing counseling agencies and corresponding interactive voice response system. The interface will allow for corrections and changes to the contact data to ensure the accuracy and currency of information. It will also include budget information regarding an agency’s housing counseling program to help HUD determine what percentage of an agency’s counseling and education activities should be attributed to HUD housing counseling grants, and to verify leveraged resources claimed in a grant application. Agency profile data will also include counselor profile information, including experience and training.
Client level data include individual identifying data so the counseling recipient can be uniquely identified.
Additionally, contact information, ethnicity, race, income, gender, family size, language, and other characteristics
will be captured. Counselors will identify whether clients are involved in predatory lending cases, migrant farm workers, Homeownership Voucher users, Colonias residents, and/or victims of Fair Housing Act violations, vastly improving HUD’s data collection and reporting capabilities in these areas. The type and duration of assistance will also be recorded, as is how the client was referred to the agency. Mortgage transaction information will also be recorded, such as interest rate, closing costs, and whether a sales contract has been signed.
The existing form HUD-9902 will continue to be collected. The form uses plain, coherent, and unambiguous language that is understandable to respondents.
The form HUD-9902 can be automatically completed by HCS based on client level data, effectively minimizing the chance for human error, and reducing the reporting burden for the agencies. Counselors simply create and update client files through the CMS. The benefit to HUD is that the form’s instruction will only need to be correctly applied by HUD’s HCS system, instead of all 2,650 HUD-approved agencies.
Housing Counseling Notice of Funding Availability (NOFAs) – Grant applications
HUD averages 500 grant applicants per year for the Housing Counseling and Housing Counseling Training NOFAs. Applicants may apply as Local Housing Counseling Agencies (LHCAs), National and Regional Intermediaries (Intermediaries), Multi-state Organizations (MSOs) or State Housing Finance Agencies (SHFAs).
Each agency submits a summary proposal and a detailed proposal, which includes the following forms and narrative statements, addressed below.
Form SF-424, Application for Federal Assistance. Once a year submission for agencies requesting grant funding.
Form SF-424 Suppl, Survey on Ensuring Equal Opportunity for Applicants. Once a year submission for agencies requesting grant funding (1890-0014).
Form HUD 424 CB, Grant Application Detailed Budget Worksheet. Once a year submission for agencies requesting grant funding (2501-0017).
Form SF-LLL, Disclosure of Lobbying Activities. Once a year submission for agencies requesting grant funding.
Form HUD-27300, Questionnaire for HUD’s Initiative on Removal of Regulatory Barriers. Once a year submission for agencies requesting grant funding (2510-0013).
Form HUD-2880, Applicant/Recipient Disclosure Update Report. Once a year submission for agencies requesting grant funding (2510-0011).
Form HUD-2990, Certification of Consistency with the RC/EC/EZ-II Strategic Plan. Once a year submission for agencies requesting grant funding where RC/EC/EZ-II applies (2510-0013).
Form HUD-2991, Certification of Consistency with the consolidated plan. Once a year submission for agencies requesting grant funding where the consolidated plan applies.
Form HUD-2994, Client Comments and Suggestions. Once a year submission for agencies requesting grant funding. Voluntary form; not all agencies submit.
Form HUD-96010, Program Outcome Logic Model. Agency completes initially when applying to HUD’s Housing Counseling NOFA, updates projection if grant amount differs from requested amount, and reports activity under the grant updates quarterly throughout the year (2535-0114).
Form HUD-9902, Housing Counseling Agency Fiscal Year Activity Report. This form is submitted by grant applicant if no form HUD-9902 exists for the agency in HCS system, example for a new agency. All Program participants submit 4 times per year.
In addition to the forms listed below, the Housing Counseling NOFA requires written narratives addressing the following 5 rating factors:
Rating Factor 1 – Capacity of the Applicant and Relevant Organizational Staff
Rating Factor 2 – Need / Extent of the Problem
Post Award Submission
HUD awards approximately 390 Housing Counseling grants per year.
Form HUD-96010, Program Outcome Logic Model. Agency completes initially when applying to HUD’s Housing Counseling NOFA, updates projection if grant amount differs from requested amount, and reports activity under the grant updates quarterly throughout the year (2535-0114).
Updated budget, if actual award differs from requested amount.
Code of Conduct is submitted only by new grantees, and there are approximately 20 of these per year.
Grant Management
Quarterly Reports: grantees must file quarterly invoices, mid-term performance reports, and a final report.
Forms for Biennial Review
Form HUD-9908, Housing Counseling Session Evaluation. Voluntary client evaluation required only when conducting agency biennial performance review and used as a performance tool. Submitted by agency clients, there are approximately 9,600 of these annually.
Form HUD-9910, Biennial Performance Review, is completed by the Field Office to record the findings of the on-site review. Approximately 800 reviews are conducted annually.
Universal CMS use automates client intake and file maintenance, capturing essential data on clients and counseling activities. The nature of this information collection is such that the use of improved information technology will reduce the burden on agencies while HUD collects more, and better quality, data.
HCS can build the form HUD-9902 report automatically based on client level data submitted, reducing the need for agencies to actually input data or to aggregate at the end of the year. Many CMSs have similar functionality to build form HUD-9902 from client level data. HUD estimates that this reduces, perhaps by half, the workload associated with the form.
c. Housing Counseling NOFAs
Beginning with the FY 2005 NOFA, all applicants were required to submit their applications electronically through Grants.gov. Electronic submission eliminates the burden on applicants to print, organize and ship multiple copies of their application. Additionally, the Grants.gov auto populates common elements of many forms, so that standard information about the applicant that appears on several forms only needs to be entered once.
4. Duplication of Information
a. Client Level Data and Agency Profile Data
HCS is the only system at HUD designed specifically to interface with CMSs, and to collect client level housing counseling activity data. Information collected will be unique and is not duplicated by other systems.
b. HUD-9902 Report
This form is the only instrument to collect performance activity reports from HUD-approved housing counseling agencies.
c. Housing Counseling NOFAs
The NOFAs are designed to avoid duplication of information. For example, performance data from the HUD-9902 factors into the scoring. However, agencies that have already submitted the form to HUD are instructed not to re-submit with the NOFA application.
5. Effects on Small Entities
The information collection is the same for all entities, regardless of size, but is considered to be the minimal information needed for HUD to effectively administer this program. The electronic grant application process eliminates the burden on all applicants to print, organize, and mail multiple copies of their application. Grants.gov automatically populates common elements of many forms, so that standard information about the applicant that appears on several forms only needs to be entered once. CMS use automates client intake and file maintenance, capturing essential data on clients and counseling activities. CMS use will reduce the burden on all agencies while HUD collects more and better quality, data.
6. Failure to Collect Information
Client Level Data and Agency Profile Data
Failure to collect the information described in this submission would leave HUD without the client level data and quality aggregate data necessary to adequately and convincingly demonstrate the positive impact of housing counseling. It would also make it very difficult to create more meaningful performance indicators, and to effectively evaluate the program, goals that HUD and OMB share. In failing to automate form HUD-9902 completion through CMS use and CARS, an excellent opportunity would be missed to standardize and improve the quality of aggregate data available to HUD, and to make corresponding analysis much more meaningful.
HUD-9902 Report
Failure to renew the form HUD-9902 as proposed would force HUD to not collect critical data justifying the benefits and impact of the counseling program.
c. Housing Counseling NOFAs
The narratives and forms requested through the NOFAs are the means through which HUD ranks and rates applicants, in order to competitively distribute awards. Failure to collect this information would prevent HUD from distributing approximately $50 million a year in support of critical housing counseling services.
7. Special Circumstances
Client Level Data and Agency Profile Data
The information is collected automatically and compiled in compliance with Housing Counseling Program requirements. Respondents will conduct normal business practices as before in using this application. Respondents will maintain the same records on clients as they currently do. Instead of maintaining paper records, the information will be entered and stored electronically.
HUD-9902 Report
Counselors simply create and update client files through the CMS. HCS will automatically interpret the form’s instructions and populate the form.
c. Housing Counseling NOFAs
Beginning with the FY 2005 NOFA, all applicants were required to submit their application electronically through Grants.gov.
8. Solicit Public Comments
a. Client Level Data and Agency Profile Data
This collection of information is in accordance with the requirements of 5 CFR 1320.8(d) and was announced in the Federal Register on January 12, 2009 (Vol. 74, No. 7, pages 1227). In addition, HUD solicited input from housing counseling agencies and Homeownership Centers on how to improve data collection. The majority of comments agreed that the system should be fully automated with a centralized database. In general, comments recommended using existing commercial applications that satisfy their needs.
b. HUD-9902 Report
This proposal renews the existing form. To create it, HUD relied on feedback from the national and regional intermediaries, as well as from HUD staff across the country.
c. Housing Counseling NOFAs
The information collection requirements contained in the Housing Counseling and Housing Counseling Training grant applications will be described in each year’s published NOFAs. Every year the Housing Counseling NOFAs contain Form HUD-2994, Client Comments and Suggestions, which is optional. Through this form, HUD receives feedback on the NOFAs that the Department carefully considers when making yearly improvements.
9. There are no payments to respondents, other than to grantees under the NOFA.
10. The client level information provided is subject to the Privacy Act and may be made available only to the appropriate Federal, State, and local agencies.
11. Sensitive Information
HUD is taking the standard precautions regarding the electronic transfer of sensitive information such as client level data, including firewall protection, encryptions, and access security.
Information collected is aggregate data that does not contain sensitive information.
c. Housing Counseling NOFAs
Some sensitive information may be submitted with the application, for example resume type information. HUD and Grants.gov, which is administered by the Department of Health and Human Services, are taking the standard precautions regarding the electronic transfer of information, including firewall protection, encryptions, and access security. Additionally, the information provided is subject to the Privacy Act and may be made available only to the appropriate Federal, State, and local agencies.
12. Annual Reporting Burden
HUD proposes that client level data be submitted on a quarterly basis, which should take two minutes per submission. No additional burden exists as counselors simply perform standard intake and maintain client files online through the CMS.
b. HUD-9902 Report
HUD proposes that form HUD-9902 continue to be submitted to HCS on a quarterly basis. No additional burden exists as counselors simply perform standard intake and maintain client files online through the CMS, which in many cases will build their form HUD-9902 reports automatically, eliminating the need for agencies to actually input data, or to aggregate at the end of the year. HCS also has functionality to derive from-9902 from client level data.
c. Housing Counseling NOFAs
In order to collect sufficient information to meaningfully rate and rank applicants, a significant amount of information, in the form of narrative statements, is requested through the NOFAs. However, the NOFAs generally remains the same from year to year, so applicants are often able to simply edit and update existing language developed for previous NOFAs, and for other sources of funding. Consequently, we believe that the 8 hours per factor estimated in the table below is very conservative, and that the actual amount, which varies by agency, could be significantly lower.
The following table summarizes estimated costs to housing counseling agencies participating in the Program.
Information Collection |
Number of Respondents |
Responses per Year |
Total Annual Responses |
Hours per Response |
Total Hours |
Hourly Cost |
Annual Cost |
Application to become a HUD-approved agency |
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HUD-9900 |
200 |
1 |
200 |
8.00 |
1,600 |
$20* |
$32,000 |
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Grant Applications |
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Summary Proposal |
500 |
1 |
500 |
1.17 |
585 |
$20 |
$11,700 |
SF-424 |
500 |
1 |
500 |
0.75 |
375 |
$20 |
$7,500 |
SF-424 Supp. (1890-0014) |
500 |
1 |
500 |
0.75 |
0 |
0 |
0 |
HUD-424 CB (2501-0017) |
500 |
1 |
500 |
0.75 |
0 |
0 |
0 |
SF-LLL |
500 |
1 |
500 |
0.17 |
85 |
$20 |
$1,700 |
HUD-27300 (2510-0013) |
500 |
1 |
500 |
0 |
0 |
0 |
0 |
HUD-2880 (2510-0011) |
500 |
1 |
500 |
0 |
0 |
0 |
0 |
HUD-2990 (2501-0013) |
500 |
1 |
500 |
0 |
0 |
0 |
0 |
HUD-2991 |
500 |
1 |
500 |
0 |
85 |
$20 |
$1,700 |
HUD-2994 |
500 |
1 |
500 |
0 |
85 |
$20 |
$1,700 |
HUD-96010 (2535-0114) |
500 |
1 |
500 |
0 |
0 |
0 |
0 |
HUD-9902** |
30 |
1 |
30 |
0.50 |
15 |
$20 |
300 |
Total Application w/Narratives |
500 |
1 |
500 |
40.00 |
20,000 |
$20 |
$400,000 |
Post Award Submission |
390 |
1 |
390 |
3.00 |
1,170 |
$20 |
$23,400 |
Grant Management |
390 |
4 |
1,560 |
5.00 |
7,800 |
$20 |
$156,000 |
Total – Grant Applications |
500 |
|
8,180 |
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30,200 |
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$604,000 |
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Data Collection |
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HUD-9902
|
2,650 |
4 |
10,600 |
0.03*** |
318 |
$20 |
$6,360 |
Client Level Data and Agency Profile Data |
2,650 |
4 |
10,600 |
0.03*** |
318 |
$20 |
$6,360 |
Total – Data Collection |
2,650 |
|
21,200 |
|
636 |
|
$12,720 |
|
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Biennial Review |
|||||||
HUD-9908 |
9,600 |
1 |
9,600 |
0.08 |
768 |
$20 |
$15,360 |
HUD-9910 |
800 |
1 |
800 |
0.17 |
136 |
$20 |
2,720 |
Total |
9,600 |
|
10,400 |
|
904 |
|
$18,080 |
|
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Grand Totals |
12,450 |
|
39,980 |
|
31740 |
|
$634,800 |
* This hourly cost, applied when the burden cost relates to a housing counseling agency, is an average hourly salary of housing counseling agency employees and, for form HUD-9908, the average annual salary of agency clients.2
** This HUD-9902 reference applies only to those newly approved counseling agencies that are applying for a grant through the NOFA but were not required to submit an electronic HUD-9902 for the previous fiscal year.
***With universal CMS use, the HUD-9902 will be populated automatically based on electronic client files. Consequently, the estimated burden hour per response includes only the time necessary to send the document electronically (estimated time: 2 minutes). Client Level Data submission is also just a simple push of a button, as electronic files are created routinely.
13. There are no additional costs to respondents.
14. Cost to the Federal Government
Client Level Data and Agency Profile Data
The initial cost to HUD to develop HCS database cost approximately $900,000, which included:
Purchase of application
Developmental cost to modify the COTS application to support HUD’s unique business requirements
Initial training program
The annual cost to HUD to maintain this application on an ongoing basis is approximately $600,000 and includes:
System Maintenance
Staff Assistance for Customer Service
Development Costs for the next 2 years is estimated to be $1.2 million.
Salary cost for Federal Employees is based on an average of GS-12 and is estimated at ¾ of an employee workload.
Number of Employees |
Hrs per Year per employee |
Number of Hrs per Year |
Average Pay per Hr |
Annual Cost |
2 |
520 |
1,040 |
$33 |
$33,320 |
In FY 2003 HUD discontinued a long-term $1 million a year contract for the Housing Counseling Clearinghouse. The Clearinghouse was responsible for: (1) the operation of a toll free number by which individuals in need of counseling find a HUD-approved agency; (2) the website listing through which individuals in need of counseling find a HUD-approved agency; and (3) the collection of agency performance data. Client Level will allow HUD to accomplish these tasks without the Clearinghouse, and at a fraction of the cost. Agency profile changes, such as changes in contact information, will be made by the agencies themselves and transferred to HUD via CMS.
c. Housing Counseling NOFAs – Review of Applications
Information Collection |
Number of Applications |
Hrs per Review |
Total Hrs |
Average Pay per Hr |
Annual Cost |
NOFA Applications - Intermediaries |
22 |
8 |
176 |
$41 |
$7,216 |
NOFA Applications – All others |
477 |
4 |
1,908 |
$33 |
$62,964 |
TOTAL |
500 |
|
2,084 |
|
$70,180 |
HUD personnel review the NOFA applications. The hourly rate is based on GS-13 for reviews of Intermediary applications in Headquarters, and on GS-12 for reviews in the field offices.
15. Currently Approved Collection
This is an extension of a currently approved collection. The increase in respondents, responses and burden hours is due to an increase in the number of new approved housing counseling agencies and new NOFA applicants. The differences and total cost are explained below.
Respondents: This submission reports the following:
Respondents |
Number Annually |
Current HUD-approved Housing Counseling agencies |
2,650 |
New applicants to be HUD-approved Housing Counseling Agency |
200 |
NOFA grant applicants, 500 per year, all counted above |
0 |
New grantees, 390 per year, all counted above |
0 |
Agency clients completing form HUD-9908 |
9,600 |
Total |
12,450 |
Responses: This submission report includes responses from the total number of forms submitted and the NOFA applications, as follows:
Responses |
Number Annually |
Applications to be HUD-approved Housing Counseling Agency, submitted individually |
200 |
NOFA grant applications, post award |
8,180 |
All agencies, quarterly reports, HUD-9902 only, 2,650 x 4 |
10,600 |
Biennial review, approximately 800 annually |
800 |
Client Level Data and Agency Profile Data |
10,600 |
Agency clients completing form HUD-9908 |
9,600 |
Total |
39,980 |
Percentage Collected Electronically. All NOFA applications form HUD-9902, client level data and agency profile data are submitted electronically. 61% (percent) of information is collected electronically.
Burden Hours: The last submission incorrectly listed the burden associated with only a few collections and did not account for the grant application or other processes. This submission reports 36,320 total hours.
Annual Cost: The client level data and agency profile data, has been added to the reporting burden hours. Several other response rates increased, and the resultant cost is currently $726,400 - an increase of $142,500.
The difference in burden hours is an increase of 7,125. This submission reports the following:
Responses |
Change |
Hour Change |
Explanation |
All agencies, HUD-9902 4 x annually |
Increased agencies from 2,156 to 2650 |
+59 |
Adjustment |
NOFA grant applications |
Added 80 applications, 10 grants |
+6,748 |
Adjustment |
Client Level Data and Agency Profile Data |
New data being reported |
+318 |
Program Change |
Net change |
|
7,125 |
|
The increase in respondents, responses and burden hours is due to an increase in the number of new HUD approved housing counseling agencies and new NOFA applicants.
One HUD form name was changed to better serve the respondents completing the form. This is not a change to the program but a formatting edit. The HUD form is 9908.
16. HUD will publish the names of the grantees. Additionally, HUD maintains a web site listing all Housing Counseling agencies.
17. HUD is not seeking approval to avoid displaying the OMB expiration date.
18. There is no exception to Item # 19 “Certification of Paperwork Reduction Act Submission.”
B. Collections of Information Employing Statistical Methods.
The collection of information does not employ statistical methods.
| File Type | application/msword |
| File Title | Paperwork Reduction Act Submission |
| Author | WAYNE EDDINS |
| Last Modified By | h15356 |
| File Modified | 2009-07-23 |
| File Created | 2009-04-24 |