Supporting Statement - A

Supporting Statement for Paperwork Reduction Act Submissions

Assisted Living Conversion Program, ALCP

&

Emergency Capital Repair Program

OMB Number 2502-0542

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 Assisted Living Conversion Program (ALCP) is authorized by Section 202(b) of the Housing Act of 1959 (12 U.S.C. 1701q-2) and was initially funded through the Fiscal Year 2000 HUD Appropriations Act (P.L. 106-74, 113 Stat. 1047, approved October 20, 1999) as amended by the Section 202 Supportive Housing for the Elderly Act of 2010 (Pub. L. 111-372, codified at 12 U.S.C 1701 q-2(g). In Fiscal Year 2004, the Appropriations Act expanded the ALCP to include the Emergency Capital Repair Program (ECRP) for multifamily housing projects designated for occupancy by the elderly. A percentage of the appropriated funds for ALCP are set aside for the ECRP.

The ALCP provides funds for the physical conversion of eligible multifamily assisted housing projects or portions of projects to assisted living facilities (ALF) or service-enriched housing (SEH). This includes unit configuration and the remodeling of any related common space and service space.

The purpose of this submission is to request a reinstatement, without change, of the previously approved collection which approval has expired.

Section 202(b) of the Housing Act of 1959 (12 U.S.C. 1701q-2) require applicants to submit an application to the department in order to receive grant funds.

Applicants shall submit the following:

1. a description of the substantial capital repairs or the proposed conversion activities for either an assisted living facility or service-enriched housing for which a grant under this section is requested;

2. the amount of the grant requested to complete the substantial capital repairs or conversion activities;

3. a description of the resources that are expected to be made available, if any, in conjunction with the grant under this section; and

4. such other information or certifications that the Secretary determines to be necessary or appropriate.

In evaluating the applications for award, the selection of the application shall be based upon the selection criteria:

1. in the case of a grant for substantial capital repairs, the extent to which the project to be repaired is in need of such repair, including such factors as the age of improvements to be repaired, and the impact on the health and safety of residents of failure to make such repairs;

2. in the case of a grant for conversion activities, the extent to which the conversion is likely to provide assisted living facilities or service-enriched housing that are needed or are expected to be needed by the categories of elderly persons that the assisted living facility or service-enriched housing is intended to serve, with a special emphasis on very low-income elderly persons who need assistance with activities of daily living;

3. the inability of the applicant to fund the repairs or conversion activities from existing financial resources, as evidenced by the applicant's financial records, including assets in the applicant's residual receipts account and reserves for replacement account;

4. the extent to which the applicant has evidenced community support for the repairs or conversion, by such indicators as letters of support from the local community for the repairs or conversion and financial contributions from public and private sources;

5. in the case of a grant for conversion activities, the extent to which the applicant demonstrates a strong commitment to promoting the autonomy and independence of the elderly persons that the assisted living facility or service-enriched housing is intended to serve;

6. in the case of a grant for conversion activities, the quality, completeness, and managerial capability of providing the services which the assisted living facility or service-enriched housing intends to provide to elderly residents, especially in such areas as meals, 24-hour staffing, and on-site health care; and

7. such other criteria as the Secretary determines to be appropriate to ensure that funds made available under this section are used effectively.”

HUD’s Notice of Funding Availability for the ALCP requires the submission of an application to be evaluated for the receipt of grant funds. The ALCP Grant Agreement implements the statutory and administrative reporting requirements.

The Department has drafted regulations for this program that is currently not available for

publishing.

The authorizing statute does not contain reporting requirements.

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.

The ALCP and the ECRP application submission requirements are necessary to assist HUD in determining an applicant’s eligibility and capacity to carry out a successful conversion of the project or make the necessary emergency repairs. A careful evaluation of the application is conducted to ensure that the Federal Government’s interest is protected and to mitigate any possibilities for fraud, waste or misuse of public funds. The purpose of collecting the application submission information is for the Department to assess the applicant’s worthiness, whether the projects meet statutory and regulatory requirements, or make sound judgments regarding the potential risk to the Government. There has been a decrease in the number of responses and in burden hours due to limited funding available for both programs especially the ECRP since no new applications will be submitted but there are still a few grants remaining that will continue to submit performance and financial reports as well as requisition forms. Below is program specific description of the necessary information collection for each program:

ALCP

HUD Field office and Headquarters staff will use grant applications to determine an applicant’s need for and capacity to administer grant funds. Staff will evaluate applications through the use of statutory and administratively designated selection criteria. HUD staff must receive eligible and complete applications in order to award grant funds. More specifically, the application package must be structured as follows:

1. Application Summary for the Assisted Living Conversion Program (Form HUD-92045). This form is necessary to assist HUD in determining applicant eligibility and ability to convert multifamily housing projects into assisted living facilities.

2. Narrative demonstrating the applicant’s community support. The applicant must submit a description of their links to the community at large and to the minority and elderly in particular; and a description of their efforts to involve elderly persons, including minority elderly persons and person with disabilities, and persons with limited English proficiency in:

1. The development of the application;

2. The development of the ALF operating philosophy;

3. Review of the application prior to submission to HUD; and

4. The intent of the applicant to involve or not involve ALF residents in the operation of the project.

A description of the applicant’s involvement in their community’s Consolidated Planning and Analysis of Impediments to Fair Housing (AI) process including

1. Identification of the lead/facilitating agency that organizes and/or administers the process;

2. A listing of the Consolidated Plan/AI issue areas in which the applicant participates; and

3. The level of participation in the process, including active involvement with any neighborhood-based organizations, associations, or any committees that support programs and activities that enhance projects or the lives or residents of the projects, such as the one proposed in your application.

3. Narrative demonstrating the evidence of need. The applicant must provide a description the

of evidence of need for the ALF or SEH by current project residents:

1. The description must provide the demographic characteristics of the elderly residents currently living in the project, including the current number of residents, distribution of residents by age, race, and sex, an estimate of the number of residents with frailties/limitations in activities of daily, an estimate of the number of residents in need of assisted living services or service-enriched housing services, and an estimate of the number of residents who have limited English proficiency.

2. The description of the services currently available to the residents and/or provided on or off-site and what services are lacking;

3. The description should include the trend in elderly and disable population and household changes; data on demographic characteristics of the very low-income elderly in need of assisted living services and extent of residents with frailty/limitations in existing federally assisted housing for the elderly; and an estimate of the very low-income elderly and disabled in need of assisted living taking into consideration any available state or local data.

4. The description should include the extent, types, and availability and cost of alternate care and services locally, such as home health care; adult day care; housekeeping services; meals programs; visiting nurses; on-call transportation services; health care; and providers of supportive services who address the needs of the local low-income population.

5. The description should include how information in the community’s Consolidate Plan and Analysis of Impediments to Fair Housing Choice was used in documenting the need for the ALF or SEH and the specific steps the applicant plans to undertake in affirmatively furthering fair housing.

4. Narrative describing the physical construction aspects of the ALF conversion.

1. The description should provide how the proposed physical conversion will be conducted (including a timetable and relocation planning).

2. The narrative should state the number of units, special design features, community and office space/storage, dining and kitchen facility and staff space, and the physical relationship of these proposals to the rest of the project. The narrative should also include how this design will facilitate the delivery of services in the most integrated setting to accommodate the needs of the residents for least 10 years.

3. A description should be provided to display how the project will incorporate e energy and water efficiency standards.

4. A description of the conversion must clearly address how the units will conform to the accessibility requirements of Section 504, the Fair Housing Act, and the American Disabilities Act, as applicable.

5. A budget must be submitted show the estimated costs for materials, supplies, fixtures, and labor.

6. A description of the relocation plan must include the identification of all tenants to be moved temporarily to another unit within the development or from the development during the period that the physical conversion of the project is underway; estimated cost of temporary relocating payments and other related services, and the basis for the estimate; the source of funds to be used to pay relocation costs; identification of staff that will carry out the relocation activities; indicate the temporary relocation will not extend beyond one year; identification of the residents that will be relocating that do not need or seek ALF or SHE services; and indicate that all persons occupying units to be converted have been issued the appropriate required General Information Notice and advisory services information at the time the application is submitted.

7. A description needs to be provided addressing how training, employment, and economic opportunities will be directed to low- and very low-income persons that receive government assistance for housing.

5. Narrative describing the retrofitting or renovation. The applicant must submit a description of any retrofit or renovation that will be done at the project that is separate and distinct from the ALF conversion.

6. Supportive Services Plan. The applicant must submit a Supportive Services Plan (SSP) for the services and coordination of the supportive services that will be offered in the ALF or SEH to the appropriate state or local organization, which are expected to fund those supportive services.

1. A description of the supportive services needed for the ALF or SEH is expected to serve. . For service-enriched applicant must include a description of how the residents will be informed in a timely-matter of the services available to them; the right of residents to accept, decline, or choose such services of provider; and the identity of the services that will be offered, the rates for the services, and the rights and responsibilities of residents relating to the services.

2. A description of how the supportive services will be provided to those who are frail and have disabilities, or have a functional limitation. This should include an explanation of how the service coordination role will facilitate the adequate provision of such services to ALF or SEH residents, and how the services will meet the identified needs of the residents. The description should indicate intentions to fund the service coordinator role.

3. A description of how the operation of the ALF or SEH will be conducted. In the description should address the general operating procedures, ALF or SEH philosophy, service coordination function, and the day-to-day operations.

4. An estimate of the monthly individual rate for board and supportive services for the ALF or SEH.

5. List who will pay for the board and supportive services and the amount.

6. A support/commitment letter from each agency providing supportive services listed in the application.

7. A support letter from each governmental agency that provides licensing for ALFs in that jurisdiction.

8. A description of your relevant experience in arranging for and delivering supportive services to frail residents, elderly persons with functional limitations, and persons with disabilities.

7. Application for Federal Assistance (SF 424) and Executive Order 12372. This standard form (including the continuation sheet) required for use as a cover sheet for submission of preapplications and applications and related information under discretionary programs.

8. Survey for Ensuring Equal Opportunity for Application (SF-424 Supplemental). This form ensures that all qualified applicants, small or large, non-religious or faith-based, have an equal opportunity to compete for Federal funding.

9. Grant Applications Detailed Budget (HUD-424-CB). This form is used to provide detailed budget information regarding the proposed ALCP program.

10. Applicant/Recipient Disclosure/Update Report (HUD-2880). This form is used by applicants to disclose any assistance from other government sources received in connection with the project.

11. Certification of Consistency with the Consolidated Plan (HUD-2991). This form is to certify that the proposed activities/projects in the application are consistent with the jurisdiction’s current, approved Consolidated Plan.

12. Disclosure of Lobbying Activities (SF-LLL). Required if receiving any federal money to disclose any lobbying activities.

13. Program Outcome Logic Model (HUD-96010). This form is completed by the applicant to show how their proposed program will undertake specific activities and propose strategic outcomes that will assist the Department in implementing its policy priorities and achieving its goals.

14. Certification of Consistency with Sustainable Communities Planning and Implementation (HUD-2995) This form certifies that applicants are working with communities that have received Preferred Sustainability Status under FY2010/2011 and/or the FY2010-2011 HUD funded Challenge Grant Program.

15. Third Party Documentation Facsimile Transmittal (HUD-96011). This form is used as a cover page to transmit third party documents and other information.

HUD Field staff will review annual program Performance Reports, to evaluate the effectiveness and efficacy of grant-funded activities. The staff will compare proposed programs and objectives with realized results. If Performance Reports indicate poor administration of funds or activities, funds spend on ineligible activities, or failure to comply with terms and conditions of the Grant Agreement, the Field staff may take enforcement action. Such action may require sanctions including recapturing funds or levying other administrative or legal penalties.

HUD Field staff will review semi-annual Financial Status Reports, SF-425, in order to monitor the proper use of the grant funds. The Field staff will then use the report to evaluate funds expenditure both during program activity and in cumulative form at program conclusion. If the funds have been improperly used, sanctions may be impose such as recapture or repayment. If reports indicate poor accounting practices, the staff will work with the Grantee to improve accounting procedures according to appropriate OMB Circulars and Government Accounting Office (GAO) standards.

HUD Field staff will also review the LOCCS Payment Voucher (HUD-50080-ALCP) in order to monitor use of funds on eligible activities. Grantees submit these forms on a quarterly basis. This allows the Field staff to track expenses and draw-down of funds for eligible activities at intervals within the grant term. These funds are taken as reimbursements and are obtained through use of a telephone voice response system. Grantees normally submit this form following their call to and receipt of funds from the voice response system. If this form indicates unusual, delinquent, or improper use of funds, the staff can block the Grantee from obtaining future grant funds until such problems are corrected.

ECRP

The ECRP submission requirements are necessary to assist HUD in determining the validity of an owner’s request for emergency capital repair needs. A thorough evaluation of an applicant’s qualifications, capabilities, and need is critical in protecting the Federal Government’s financial interest and mitigate any possibility of fraud, waste, or mismanagement of public funds.

The Owner’s request must clearly identify all repairs of an emergency nature for which funding is requested, the basis for the emergency declaration and how it impacts upon the health and safety of the tenants, as well as what would happen if the emergency repair were not done. More specifically, the application package must be structured as follows:

I. Narrative demonstrating the applicant’s need for ECRP funding. The narrative must be in accordance with the procedures described below:

1. The narrative must clearly identify all repairs of an emergency nature for which funding is requested, the basis for the emergency declaration and how it impacts the health and safety of the tenants, as well as what would happen if the emergency repair were not done immediately.

2. The narrative must describe the scope of work to be performed, provide an estimate of the cost of the work to be performed, and explain the basis for the estimate.

3. The request must demonstrate that repairs cannot be corrected at a cost that can be absorbed within the operating budget or use of the reserve for replacement and/or residual receipts funds.

4. The narrative must detail a project plan for completing the repairs within six months but no longer than one ear from the date of the grant award.

5. The narrative must describe whether the tenants were notified of the project owner’s plans to apply for the grant. If applicable, any comments received from the tenants must be submitted to the local HUD field office along with the repair request.

6. The narrative must provide a description of any unsuccessful attempts the owner has made to acquire funds from other sources, including letters of denial from funding sources, to complete the outstanding emergency capital repairs.

7. The narrative must provide a description of any previous grants or loans received by the project for repairs.

II. Affirmative Fair Housing Marketing Plan (AFHMP). The owner must submit a copy of the approved AFHMP. If the owner does not have an approved AFHMP, one must be submitted for HUD approval along with request for funds.

III. Evidence of Compliance Agreement. If the Grantee was found to be in noncompliance with all applicable fair housing and civil rights requirements in 24 CFR 5.105(a), but resolved a matter, the Grantee must submit evidence of the resolution. Example of such evidence includes a voluntary compliance agreement, a HUD-approved conciliation agreement, a consent order or consent decree or an issuance of a judicial ruling, or a HUD Administrative Law Judge’s decision.

IV. Rental Use Agreement (HUD-92046). If there are less than 10 years remaining on the existing mortgage, the applicant must enter into a Use Agreement that would extend the remaining affordability of the project for up to 10 years.

V. Grant Agreement (HUD-92047). This agreement outlines the terms and conditions of the assistance awarded to the Grantee.

VI. Assistance Award/Amendment (HUD-1044) This form is completed by HUD staff, signed by the recipient of the grant, and returned to HUD. This form is a certification and HUD ascribes no burden to its use.

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 Department has an on-going commitment to identify ways to simplify the process by which the many grant programs are administered so that it can be less costly and more consumer-friendly. The Department requires that all grant applications be submitted and received electronically through www.grants.gov. Unless a waiver of the electronic delivery process is approved by HUD.

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 available through any other source. The Department will use existing program reviews, financial statements, and audit reports in evaluating the capacity of the applicant to effectively administer the program. The explanation of need for an Assisted Living Program, description of proposed conversion activities and service plans, and documentation of matching resources provided by community agencies is not currently available to HUD. The Department will use existing program reviews, financial statements, and audit reports in evaluating the capacity of the applicant to effectively administer the program.

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.

This collection will not have a significant economic impact on small businesses or 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.

Since the authorizing statute requires the submission of an application, this is a significant legal obstacle to reducing burden. The reports required by the Department provide the minimum information needed to enable HUD staff to effectively monitor program operation. Without these reports, the Department’s program management capability would be seriously impaired.

The statute and NOFA mandate application selection criteria and content. These are then also legal obstacles to reducing burden hours for completion of grant applications. If application content was reduced, HUD staff’s ability to select those applicants most in need of funds and most capable of administering funds could be impaired.

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

• requiring respondents to report information to the agency more 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.

None.

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.

In accordance with 5 CFR 1320.6, the agency’s notice soliciting public comments was announced in the Federal Register on Friday, January 18, 2013; Vol. 78, No. 13, Page 4156. No comments….

In 2012, HUD consulted with field office staff that reviews the application and manages the application submission process for the ALCP and the ECRP. The selected field office staff were asked to answer several questions concerning their views about the availability of data, frequency of collection, the clarity of instructions, the format for recordkeeping, disclosure, or reporting, and the data elements to be collected. The general consensus of the field office staff that the data is accessible to applicants and the instructions provided is lucid. Field office staff did conclude that should be more provisions for reporting among applicants.

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

HUD does not provide any payment or gift to respondents, other than the award of grant funds for those Owners selected for funding.

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

There are no assurances of confidentiality provided to respondents.

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.

The application submission requirements do not contain any sensitive questions.

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 14.

For ECRP, the grants will be awarded on an as-submitted basis, as well as the fact that upon the exhaustion of funds the Department will stop accepting applications, it is estimated that the total number of respondents will not exceed 60 for the ECRP as long as there is funding available. As for the ALCP, the grants will be awarded on a competitive basis and the estimated total of the number respondents will not exceed and 30 for the ALCP program. The estimated number of burden hours is based on discussions with HUD Field staff, consultations with housing professionals and Sponsors, and past program activity.

Assisted Living Conversion Program, ALCP
Description of Information Collection	Number of Respondents	Responses per Annum	Total Responses	Hours per Response	Total Hours	Cost per Hour	Total Cost
SF-424, Application for Federal Assistance (OMB Control No. 4040-004)	25	1	25	0.75
SF-424 Supplemental, Survey on Ensuring Equal opportunity for Applicants (OMB Control No. 1890-0014)	25	1	25	0.25
HUD-424CB, HUD CBW, Applicant Assurances and Certifications (2501-0017)	25	1	25	0.25
Disclosure of Lobbying Activities, SF-LLL (OMB Control No. 0348-0046)	25	1	25	0.15
Applicant/Recipient Disclosure/Update Report, HUD-2880 (OMB Control No. 2502-0118)	25	1	25	0.15
Form HUD-2530, Previous Participation Certificate (OMB Control No. 2502-0118)	10	3	30	1
Form HUD-96010, Program Outcome Logic Model (OMB Control No. 2535-0114)	25	2	50	1
HUD-96011, Third Party Documentation, Facsimile Transmittal (2535-0118)	25	2	50	0.15
Certification of Consistency with the Sustainable Communities Planning and Implementation, HUD-2995 ((OMB Control No. 2535-021)	25	1	25	0.25
Exhibit 3, Narrative of Community Support	25	1	25	6	150	$20	3,000
Exhibit 5, Narrative Detailing the Scope of Work	25	1	25	6	150	$20	3,000
Exhibit 6, Narrative Description of Physical Conversion	25	1	25	6	150	$20	3,000
Exhibit 7, Narrative Description of Retrofitting or Renovation	25	1	25	6	150	$20	3,000
Exhibit 8, Narrative Detailing the Services	25	1	25	6	150	$20	3,000
ALCP Application Summary Sheet, HUD-92045	25	1	25	1	25	$20	500
LOCCS/VRS Payment Voucher, HUD-50080-ALCP	10	4	40	0.25	10	$20	200
Financial Status Report, SF-425	10	2	20	2
Subtotal	25		490		785		$15,700

Emergency Capital Repair Grant Program
Description of Information Collection	Respondents	Responses per Annum	Total Responses	Burden Hours	Total Hours	Cost per Hour	Total Cost
Narrative	0	0	0	0	0	0	0
AFHMP (copy)	0						0
AFHMP (new)	0						0
Voluntary Compliance Agreement, Conciliation Agreement, Consent Order or Consent Decree; or Judicial Ruling or HUD Administrative Law Judge’s Decision.	0
Rental Use Agreement (HUD-92046)	0
Grant Agreement (HUD-92047)	0
Performance Report	6	1	6	2	12	20	240
LOCCS/VRS Payment Voucher, HUD-50080-ECRP	6	4	24	0.25	6	20	120
Financial Status Report, SF-425	6	2	12	2
Subtotal	6		42		20		$360
Grand Total, Both Programs	31		532		805		$16,060
The hourly cost is based on an average annual salary of $40,000.

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.

The estimate of the total annual cost burden to respondents does not vary from the numbers presented in item #12. There is no capital and start-up cost component in the ALCP program.

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.

Collection	Annual Responses	Hours per Response		Total Hours		Cost per Hour*		Total Cost
Assisted Living Conversion Program, ALCP
Grant Application	25	31		775	$33.00			$ 25,575
LOCCS Payment Voucher	40	0.25		10	33.00			330
Financial Status Report, SF-425	20	2		40	33.00			1,320
Subtotal	85			825				$27,225
Emergency Capital Repair Program, ECRP
Performance Report	6		2	12	33.00				396
LOCCS Payment Voucher	24		0.25	6	33.00				198
Financial Status Report, SF-425	12		2	24	33.00				792
Subtotal	42			42					$1,386
Grand Total, Both Programs
Total	127			867			$28,611

The hourly cost is a blended rate based on an average salary at the GS-12/5 level, except for the General Counsel and the Clerical Assistant, which are at the GS-14/5 and GS-7/5 levels, respectively.

Most applicants will receive their NOFAs which includes all submission materials, via the internet. However, some applicants will be handed copies of the NOFA at the HUD-held workshops.

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 extension of a currently approved collection. There has been a decrease in the number of responses and in burden hours due to limited funding available for both programs especially the ECRP since no new applications will be submitted but there are still a few grants remaining that will continue to submit performance and financial reports as well as requisition forms.

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.

Collection of this information will not be published. Each application will be maintained with the HUD Program Office in individual project files.

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.

HUD is not seeking approval to avoid displaying the OMB expiration date.

18. Explain each exception to the certification statement identified in item 19.

There are no exceptions to the certification statement identified in Item 19 of the OMB 83-I.

B. Collections of Information Employing Statistical Methods

None

OMB 83-I 10/95