83-i

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. 2577-0218 b. None
3. Type of information collection: (check one) New Collection X Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No X 6. Requested expiration date: a. Three years form approval date b. Other (specify)      

7. Title:

Indian Housing Block Grant (IHBG) Program Reporting

8. Agency form number(s): (if applicable) HUD-52737, HUD-4117, HUD-4119

9. Keywords: Housing, low and moderate income housing, housing and community development, NAHASDA, Native American housing, Indians

10. Abstract: The Native American Housing Assistance and Self Determination Act (NAHASDA) requires recipients (tribes and tribally designated housing entities) to submit specific information that is necessary for the implementation of low income housing programs using Indian Housing Block Grant funds (IHBG). Recipients of IHBG funds submit Indian Housing Plan/Annual Performance Reports (HUD-52737), Formula Response Forms (HUD-4117), and Formula Challenge Forms (HUD-4119). Recipients of IHBG funds submit an Indian Housing Plan/Annual Performance Report (HUD-52737) annually using a Word version. HUD intends to make available an Excel and EPIC version of the form that requests exactly the same information as does the Word version. The automated capabilities of the Excel EPIC versions improve the quality of the submission and simplify the completion of the form, while reducing paperwork burden.

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
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 366 b. Total annual responses 1,047 Percentage of these responses collected electronically 60 c. Total annual hours requested 48,028 d. Current OMB inventory 54,578 e. Difference (+,-) -6,550 f. Explanation of difference: 1. Program change: 2. Adjustment: -6,550		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) 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 $729,585 e. Current OMB inventory $982,404 f. Explanation of difference: Less time and cost to complete the Excel version of HUD-52737. 1. Program change:       2. Adjustment: -$252,819
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.   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. X On occasion 2. Weekly 3. Monthly 4. X Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe)      
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Jennifer Bullough Phone: (202) 402-4274

19. Certification for Paperwork Reduction Act Submissions

On behalf of this Federal Agency, 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:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. 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);

1. It uses effective and efficient statistical survey methodology; and

2. 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 Rodger Boyd, Office of Native American Program (ONAP)	Date:
Signature of Senior Officer or Designee: X Colette Pollard, Departmental Reports Management Officer Office of Chief Information Officer	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 Native American Housing Assistance and Self-Determination Reauthorization Act (NAHASDA) authorizes funding for the Indian Housing Block Grant (IHBG) program that supports the development, management, and operation of affordable homeownership and rental housing; infrastructure development; and other forms of housing assistance intended for low-income persons. Federally-recognized Native American and Alaska Native tribes, tribally-designated housing entities, and the Department of Hawaiian Home Lands are eligible to receive IHBG funds. NAHASDA is a formula-driven program whereby eligible recipients receive an equitable share of funds as appropriated by Congress.

Within 75 days of the beginning of its program year, a recipient of IHBG funds is required to submit HUD-52737, Indian Housing Plan/Annual Performance Report (IHP/APR), which consists of two components. The Indian Housing Plan (IHP) component describes the eligible IHBG-funded, affordable housing activities the recipient plans to conduct for the benefit of low and moderate income tribal members and identifies the intended outcomes and outputs for the upcoming 12-month program year. At the end of the 12-month period, the recipient submits the Annual Performance Report (APR) component to describe (1) the use of grant funds during the prior 12-month period; (2) the actual outcomes and outputs achieved; (3) program accomplishments; and (4) jobs supported by IHBG-funded activities. (NAHASDA §§ 102 and 404).

The IHP/APR is currently available in a Word version. With this submission HUD intends to make available a revised Word version, an Excel version, and a version on HUD’s Energy and Performance Information Center (EPIC) website. All three versions of the IHP/APR request the same information and a recipient may elect to submit to HUD either the Word, Excel, or EPIC versions; however, the Excel and EPIC versions are preferred because of their automated capabilities and reduced burden. The Word, Excel, and EPIC versions differ from the current version of HUD-52737 with the elimination of Line 1 (Planned Grant-Based Budget for Eligible Programs) in Section 5 (Budgets) because collection of this information served no valid purpose.

IHBG recipients are responsible for notifying HUD of changes to the Formula Current Assisted Stock (FCAS) component of the IHBG formula. HUD is notified of changes in the FCAS through the Formula Response Form (HUD-4117). IHBG recipients or HUD may challenge the data from the U.S. Decennial Census or provide an alternative source of data by submitting the Guidelines for Challenging U.S. Decennial Census Data Document. Census challenges (HUD-4119) are due to HUD by March 30^th of each fiscal year, as stipulated at 24 CFR § 1000.336.

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.

IHBG recipients are required to submit periodic information to demonstrate compliance with eligibility and other requirements of NAHASDA and for HUD’s annual report to Congress. The quality assurance of data reported is a very important issue in maintaining HUD’s databases used to monitor a recipient’s performance, determine program compliance, and to ensure fair and equitable IHBG allocations. HUD uses IHP data to verify that planned activities are eligible, expenditures are reasonable, and recipient certifies compliance with related requirements. HUD uses APR data to audit the program accurately and monitor recipient progress in completing approved activities, including reported expenditures, outputs, and outcomes. HUD conducts statistical analysis of APR data to compare a recipient’s prior performance and conduct regional and national data analysis for internal use and Congressional reporting. APR data has been effective in documenting ineligible uses of IHBG funds that HUD determined were disallowed costs and recaptured. HUD uses the Formula Correction form and Formula Challenge form to ensure that IHBG funds are allocated accurately. Updated FCAS information addressing the conveyances and conversion of units has resulted in the recapture of funds.

In conducting statistical analysis of each recipient’s data, HUD compares a recipient’s Annual Performance Report data with what the recipient planned to accomplish as described in its Indian Housing Plan.  The purpose of this analysis is to verify whether the recipient is making timely progress in completing the activities described in the Indian Housing Plan.  Specifically, HUD analyzes outputs including the number of housing units completed, number of households served, and number of acres acquired for low income housing development.  HUD also analyzes expenditure data for reasonableness compared to the accomplishments, and compares the planned uses of Indian Housing Block Grant and Native Hawaiian Housing Block Grant funds with actual uses of these funds. 

HUD calculates summary performance data on the regional and national levels.  Data includes total number of houses rehabilitated, constructed, and acquired; total  number of households served; and total number of acres acquired for low income housing development.  HUD also calculates the amount of Indian Housing Block Grant and Native Hawaiian Housing Block Grant funds expended and unexpended, as well as the volume of loan guarantees and leveraged funds. 

The results of the statistical analysis are used for annual Congressional reporting and for internal planning and evaluation purposes.

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.

Approximately, 60% of IHBG recipients submit information electronically. HUD’s Office of Native American Programs (ONAP) explicitly encourages recipients of IHBG funds to submit the Word version of the IHP/APR electronically either by facsimile or by scanning the document and attaching it to electronic mail.  ONAP expects 90% of the Excel version of the form to be submitted electronically. All IHP/APRs submitted on the EPIC website will be electronic.

The Excel and EPIC versions of the IHP/APR contain numerous automated enhancements such as drop-down menus, check boxes, auto-filling data fields, columns and rows that total automatically, and data quality checks. These automated enhancements make the Excel and EPIC versions easier and faster to complete than the Word version.

The Formula Response and Census Challenge forms are most frequently submitted by facsimile or as an electronic mail attachment.

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.

There is no duplication of information. IHBG recipients must submit the IHP portion of the IHP/APR annually describing the recipient’s planned activities, outputs, and outcomes using IHBG funds, the APR portion of the IHP/APR annually describing how the grants were used and the activities, outputs, and outcomes achieved. There are no other sources of information that are being submitted to HUD that duplicate the information in the IHP/APR. IHBG recipients do not have to challenge formula data and, if a recipient opts not to challenge the formula data, HUD will rely on the currently available data for determining a recipient’s allocation.

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.

Most IHBG recipients are small in population numbers. HUD has minimized the burden on all recipients by allowing the recipient to determine the complexity of the program being offered within their area of responsibility. The program offered by the recipient determines the complexity of the IHP/APR. HUD has provided extensive training for recipients on how to design a program and complete the IHP/APR. Additionally, ONAP staff is available to provide one-on-one assistance if needed. If a recipient opts to challenge the formula data, HUD will make every effort to provide guidance and technical assistance to the recipient on how to challenge and/or correct the formula data as easily as possible while still maintaining the integrity of the data.

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.

The IHP/APR is required by NAHASDA to be submitted annually. If the IHP or APR is not submitted as required, then the recipient may be denied grant funds for that year, prohibited from expending prior grant funds, and denied future grants. Given the quality of the data being used, if a recipient cannot or does not make corrections or challenge the formula data, it will decrease the fairness of the formula allocation system. In addition, HUD, the recipient, and the grant beneficiary are involved with program monitoring and auditing activities. HUD has the responsibility to challenge the validity of data used to allocate IHBG funds.

The Formula Response are Census Challenge forms may be submitted at any time.

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.

There are no special circumstances associated with this information collection. IHBG recipients may submit the Formula Response or Census Challenge form to challenge or make corrections at any time. Recipients receive a copy of the data at least 30 days before the recipient needs to make corrections or submit a challenge that would be acceptable for that fiscal year’s formula allocation. IHBG recipients are not required to submit more than the original information collection document. Financial and programmatic records, supporting documents, and statistical records of the recipient must be retained for a period of 3 years according to 24 CFR § 1000.550. IHBG recipients may submit data to challenge the U.S. Decennial Census data, but by regulation, that information must be collected in a uniform manner that be confirmed and verified (24 CFR § 1000.330). Data must be gathered, evaluated, and presented in a manner acceptable to HUD and the standards for data acceptability must be applied consistently (24 CFR § 1000.334). IHBG recipients are not requested to submit proprietary trade secrets or other confidential information.

8. This information collection was announced in the Federal Register, Volume 77; Page 49005 on August 15, 2012. One comment was received and is attached.

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

There are no provisions to provide any payments or gifts to respondents, other than remuneration of contractors or recipients.

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

The information collection is public information; therefore, there is no assurance of confidentiality.

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 to be collected.

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 366 recipients of IHBG funds. Each of the 366 IHBG recipients is required annually to submit an IHP and an APR for a total of 732 responses. Allowing for variations in the recipient’s program to provide and maintain low-income housing, recipient preparation of an IHP/APR takes an average of 62 hours. This median average in burden hours assumes that the completion of the Word version is estimated at 69 hours, the Excel version at 67 hours, and the EPIC version at 52 hours. HUD typically receives an average of 300 Formula Correction forms and assumes it takes a recipient an average burden of half an hour to complete the form. HUD typically receives 15 Formula Correction forms and assumes it takes a recipient an average burden of 150 hours to complete the form. In addition, if the recipient is accumulating funds in a reserve account, the recipient must have a depository agreement with its financial institution with provisions regarding disbursement of funding (HUD-52736-A). If a recipient has received approval to invest IHBG funds and seeks to have the funds managed by a broker/dealer, there must be a depository agreement signed by both the IHBG recipient and the broker dealer (HUD-52736-B). These agreements are to be kept on file for HUD review.

The table below provides estimates on the number of respondents, frequency of submissions, total responses, and the estimated annual burden.

Estimated Number of Respondents, Responses, and Annual Burden Hours

Type of Submission	Number of Respondents	Frequency of Submissions	Total Responses	Estimate Average Time (Hrs)	Estimate Annual Burden (Hrs)
IHP/APR (HUD-52737)	366	2	732	62	45,628
Formula Correction (HUD-4117)	300	1	300	.5	150
Formula Challenge (HUD-4119)	15	1	15	150	2,250
Depository Agreement (reserve accounts) (HUD 52736-A)	366	1	366	.25	91.5
Depository Agreement (broker/dealer) (HUD-52736-B)	366	1	366	.25	91.5
Total	366		1,779		48,211

The table below shows the estimated cost burden to respondents and is based on an average annual salary of $37,000.

Estimated Annualized Cost to Respondents

Type of Submission	Number of Hours	Cost per Hour	Total Cost
IHP/APR (HUD-52737)	45,628	$18	$821,304
Formula Correction (HUD-4117)	150	$18	$2,700
Formula Challenge (HUD-4119)	2,250	$18	$40,500
Depository Agreement (reserve account) (HUD-52736-A)	91.5	$18	$1,647
Depository Agreement (broker/dealer) (HUD-52736-B	91.5	$18	$1,647
Total	48,211	$18	$867,798

13. Provide an estimate of the total annual cost burden to respondents or record keepers 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 are no additional costs other than what is reported above.

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.

There are no additional costs to the Federal Government for this information collection. ONAP staff and contractors have been reviewing the forms in this information collection since the inception of the IHBG program. Further, ONAP staff and contractors do not review depository agreements annually, but require recipients to use a standard form and keep it on file. The table below summarizes the annualized cost for reviewing the forms in this information collection.

Type of Submission	Number of Respondents	Frequency of Submissions	Estimated Hours	Total Annual Burden Hours	Hourly Base Rate	Total Annual Cost
IHP/APR (HUD-52737)	366	2	20	14,640	$37.54	$549,585
Formula Correction (HUD-4117)	300	1	15	4,500	$37.50	$168,750
Formula Challenge (HUD-4119)	15	1	15	225	$50.00	$11,250
Total	366			19,365		$729,585

15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the OMB Form 83-I.

In the currently approved IHBG PRA, ROCIS showed an incorrect number of responses. ROCIS showed 366 responses when that is the number of respondents. The correct baseline for the number of responses should be 1,062 for the currently approved PRA. In the proposed IHBG PRA, HUD estimates 1,047 responses. This decrease is due to correcting the number of IHP/APR responses and Formula Correction form responses. ROCIS also showed an incorrect amount of annual time burden of an additional 6,410 hours for the proposed PRA. That number should have been a decrease of 6,410 hours. The updated reduction in proposed burden represents a decrease of 6.550 hours. The reduction in burden hours and costs occurred for three reasons. (1) A table in the budget section of the IHP/APR was eliminated because the collection of this information served no valid purpose. (2) The automated capabilities of the Excel and EPIC versions of the IHP/APR reduce burden hours and costs. (3) The completion of activities funded by the American Recovery and Reinvestment Act no longer requires recipients to submit HUD-52735-AS; therefore, this form has been deleted from the calculation of burden hours and costs.

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.

Section 407 of NAHASDA requires the Secretary to prepare an annual report to Congress; the information collected in the APR will be used to prepare that report. The Secretary is required to include a description of the progress made in accomplishing the objectives of NAHASDA and to summarize the use of funds during the preceding 12-month period.

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 number and expiration date of the information collection will be displayed on the forms.

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

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

B. Collections of Information Employing Statistical Methods

The information will not be published for statistical purposes.

OMB 83-I 10/95