Supporting Statement for State Cemetery Data, VA Form 40-0241 and Cemetery Grant Documents, 40-0895 Series
A. Justification
1. The State Cemetery Data form, VA Form 40-024, and the Cemetery Grant Document Forms, 40-0895 series, are required to provide data regarding the number of interments conducted at State Veterans cemeteries and support grant applications each year. This data is necessary for budget, oversight and compliance purposes associated with existing and establishment of new State and Tribal government veteran cemeteries. In addition, the Department of Veterans Affairs (VA’s) Veterans Cemetery Grants Service needs this data to answer questions which arise during the course of the year to respond to Congressional correspondence and to project and predict the need for burial space and the demand for state grants. Burial data tells us usage rates and helps in the prediction of when a cemetery needs to develop additional acreage (request a grant to expand) or if a cemetery is going to close. The amount of acreage used helps the Veterans Cemetery Grants Service and National Cemetery Administration (NCA) anticipates the closing and the requirement for additional cemeteries (either State or national). Lower burial rates may indicate problems such as ineffective outreach or poor maintenance that should be investigated. The data is used in conjunction with the data gained from the national cemeteries to consider where to place national or state cemeteries. 38 CFR, Part 39.3 states that “the Secretary and any authorized representative (in this case the Veterans Cemetery Grants Service) will have access to and the right to examine all records, books, papers or documents related to the grant.” Part 39.5 discusses follow-up procedures once a cemetery is established and states the need for audits, etc. See 38 CFR Extracts. The Cemetery Grant Document forms are used to document and evaluate state submissions in compliance with grant preapplications in 38 CFR, Part 39.
2. The data gathered annually is used by the Veterans Cemetery Grants Service to conduct studies and award State and Tribal government Veteran cemetery grants. For example, the Service uses this data to demonstrate to the States (especially those without State Veterans’ cemeteries) not only the viability of the program, but to demonstrate that they have a need. The Veterans Cemetery Grants Service data shows that in 2012, for example, State Veterans cemeteries provided for burial of over 31,000 veterans and eligible family members. The Service can demonstrate that State veterans cemeteries are needed and a demand exists for the services provided. The Veterans Grants Service is a user of this data as is the Office of the Deputy Under Secretary for Field Programs and the Budget and Planning Service in the Office of the Deputy Under Secretary for Finance and Budget in NCA. States use this data as well as congressional offices, veteran’s organization and interested citizens.
3. The agency is considering electronic collection of most of the data requested on the forms. New State Veteran’s cemeteries, for example, are being connected during construction to the NCA’s Burial Operations Support System (BOSS), an automated management information system. New preapplications are required to be submitted through grants.gov. Existing cemeteries are being connected as feasible, but the connection requires new software, training, and in some cases, hardware and data transmission infrastructure. The State Cemetery Data form, with an explanation to fill it out, is relatively simple. It is designed to be simple for a person to fill-out and the user (Veterans Cemetery Grants Service) to extract data (see attached form). The State Cemetery Data form and the Cemetery Grant Document forms are available on the VA’s forms website.
4. There is no duplication. The State Cemetery Data form and the Cemetery Grant Document Series are the only reports required from the State veterans cemeteries to determine current usage and support future grant applications.
5. The forms do not impact small businesses.
6. If this data were not collected, the Veterans Cemetery Grants Service would be hampered in its ability to document cemetery usage andensure compliance with grant award requirements, convince States and Tribal Governments to apply for grants and to accept the burden of operating and maintaining these cemeteries in perpetuity. It is in the interest of the federal government to encourage States and Tribal governments to share the burden of developing, operating and maintaining these cemeteries. Without the forms, the Service could not answer various congressional or State correspondence or internal inquiries within VA to support the usage at the cemeteries or the documentation to support future grant awards. The budget process would be hampered by our inability to provide objective data required of us to justify and explain the program. We could not compare the state grants program to other similar programs, which data is periodically asked for. Without the data, we could not anticipate the need for new or additional burial space.
7. We know of no special circumstances that make the collection of information inconsistent with 5 CFR 1320.6, or that would cause this information collection to be conducted in a manner that would be inconsistent with the restrictions listed in the 10/95 instructions for completing Paperwork Act Submissions.
8. The Veterans Cemetery Grants Service officials regularly visit the State veterans’ cemeteries, at least every three years. Service personnel are in more frequent contact by phone, usually as often as once a quarter or more. This data collection effort is discussed and there has never been a problem as a result of asking for such data regarding gravesite usage or to complete the grant award requirements. In promoting a grant or the idea of a need to build a State veterans cemetery with grant money, the data from the states is a key part of the effort. It demonstrates a requirement. It helps the Service and the States determine when to begin development of additional acreage for burial space and, in so doing, to anticipate when to provide money to expand or improve these cemeteries. State veterans cemeteries relieve the Federal Government of the need to build and maintain additional new national cemeteries. It is in the interest of the Federal Government to effectively promote the Veterans Cemetery Grants Program.
The Department notice for comments was published in the Federal Register on June 5, 2013, page 33894. There were no public comments received during in response to this notice.
9. There is no payment or gift to respondents for completing the State Cemetery Data form or the Cemetery Grant Document forms.
10. There are no assurances of confidentiality in connection with these forms. The result of studies gained from the data is passed back to the States in a generic form. We do produce a “ranking” of the most active State veterans’ cemeteries, but do not produce a ratio expressing the relationship between operating costs and numbers of burials. Too many variables, including climate and local expectations, would tend to make such comparisons unproductive. Data is generally aggregated on a national or multi-state basis or the data is used to respond to a specific question that does not include such comparisons. Nonetheless, there is no assurance of confidentiality offered or implied.
11. The questionnaire contains no questions of a sensitive nature.
12. The estimated number of response and burden hours for the collections of the information for State Cemetery Data and the Cemetery Grant Document forms is determined as follows:
VA Form 40-0241, State Cemetery Data. (88 response x 60 minute = 88 hours)
VA Form 40-0895-2: Certification of Compliance with Provisions of the Davis-Bacon Act (21 responses x15 minutes = 5.25 hours)
VA Form 40-0895-3: State or Tribal Government Cemetery Grants Service Space Program Analysis - Buildings (21 responses x 3 hours = 63 hours)
VA Form 40-0895-6: Certification of State or Tribal Government Matching Architectural and Engineering Funds to Qualify for Group 1 on the Priority List (21 responses x 30 minutes = 10.50 hours)
VA Form 40-0895-7: Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion – Primary Covered Transactions (State or Tribal Governments) (21 responses x15 minutes = 5.25 hours)
VA Form 40-0895-8: Certification Regarding Drug-Free Workplace Requirements for Grantees Other Than Individuals (21 responses x15 minutes = 5.25 hours)
VA Form 40-0895-9: Certification Regarding Lobbying (21 responses x15 minutes = 5.25 hours)
VA Form 40-0895-10: Certification of Compliance with Federal Requirements – State or Tribal Government Construction Grant (21 responses x15 minutes = 5.25 hours)
VA Form 40-0895-11: Memorandum of Agreement for a Grant to Construct or Modify A State or Tribal Government Veterans Cemetery (21 responses x 2 hours = 42 hours)
VA Form 40-0895-12: Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion – Primary Covered Transactions (Contractor) (21 responses x 15 minutes = 5.25 hours)
VA Form 40-0895-13: Certification Regarding Documents and Information Required for State or Tribal Cemetery Construction Grants – Post Grant Requirements (21 responses x 2 hours = 42 hours)
VA Form 40-0895-15: Certification of Cemetery Maintained in Accordance with National Cemetery Administration Standards (21 responses x 15 minutes = 5.25 hours)
VA Form 40-0895-16: State or Tribal Government Cemetery Plan Preparation (39.32 and 39.83) (21 responses x 640 hours = 13,440 hours)
VA Form 40-0895-17: State or Tribal Government Cemetery Documentation of Grant Accomplishments (39.120) (21 responses x 16 hours = 336 hours)
Each respondent completes one of each form once a year.
13. No record keeping is required on the part of respondents. At the Veteran Cemetery Grant Service level, it takes two or three hours to file this State Cemetery Data and the Grant Document Series is an ongoing grant award function of this office. The State Cemetery Data submission is a once a year requirement. The costs are minimal to produce the form and to fill it out, as all forms are available on VA’s forms website. They can also be economically photocopied since small numbers of forms are required.
14. The annual cost to the Federal Government for administering the State Cemetery Data form is estimated at $10,108 based on 361responses annually. This amount is based on a processing time of one (1) hour per response in the Veterans Cemetery Grants Service, NCA, using a salary of a GS 9/5 ($28 per hour). If this form were not used, Federal costs would be much higher because staff would have to spend many hours on an ad hoc basis interviewing state cemeteries and responding to questions as they arise rather than being able to review collected data to answer questions. The Cemetery Grant Document forms are essential in properly developing proposed projects and for the Federal Government to ensure compliance with 38 U.S.C. 501, 2408 and 38 CFR Part 39. Grants would not be awarded without the documentation.
15. The increase in burden hours of is due to the inclusion of the Cemetery Grant Documents forms and number of respondents for VA Form 40-0241. (Burden hours were previously reported erroneously due to entry error, therefore, 14,058.25 is the correct number of burden hours).
16. There are no plans to publish the results of this collection of information.
17. We are not seeking approval to display the expiration date.
18. There are no exceptions to the certification statement.
B. Collection of information Using Statistical Methods
No statistical methodology or estimation procedures are necessary to collect this information.
| File Type | application/msword |
| File Title | Supporting Statement for VA Form 40-0241 |
| Author | cemcopowelm |
| Last Modified By | Rennie, Crystal |
| File Modified | 2013-08-29 |
| File Created | 2013-08-29 |