0938ss21_FINAL_Rev

_{SUPPORTING STATEMENT FOR} INFORMATION COLLECTION

REQUEST NUMBER 0938.21 (2030-0020)

1. Identification of the Information Collection

1(a). Title of the Information Collection. “GENERAL ADMINISTRATIVE REQUIREMENTS FOR ASSISTANCE PROGRAMS (Renewal)”

OMB # 2030-0020, EPA ICR # 0938.21

1(b). Short Characterization/Abstract. This is a request for a renewal of an existing Information Collection Request (ICR). This ICR authorizes the collection of information under EPA’s General Regulation for Assistance Programs that establishes the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements). For awards made prior to December 26, 2014, 40 CFR Part 30, “Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations,” establishes the management requirements for institutions of higher education, hospitals, and other non-profit organizations, as well as procurement requirements for non-governmental recipients. For awards made prior to December 26, 2014, 40 CFR Part 31, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments,” includes the management requirements for States, local governments, and Indian Tribal governments. These regulations include only those provisions mandated by statute, required by Office of Management and Budget (OMB) Circulars, or added by EPA to ensure sound and effective financial assistance management. For awards made on or after December 26, 2014, 2 CFR 200 and EPA’s implementation of 2 CFR 200 at 2 CFR 1500 “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards” establishes the management requirements for all entity types. 40 CFR Part 35 outlines policies and procedures for assistance agreements to State, interstate, and local agencies and Indian Tribes and Intertribal Consortia for pollution abatement and control programs (listed in Subparts A and B).

In addition, under Executive Orders 11625, 12138, and 12432, EPA is required to promote and report on programs to assist minority and women-owned enterprises. Under P.L. 101-507 and P.L. 102-389, EPA is required to set aside funds for socially and disadvantaged individuals/firms under the Small Business Act, 15 U.S.C. 537(a) (5) and (6). This ICR combines all of these requirements under OMB Control Number 2030-0020. EPA award officials will use the information required by these regulations to make assistance agreement awards, to make assistance payments, and to verify that the recipient is using Federal funds appropriately to comply with Federal requirements.

This request renews the “General Administrative Requirements for Assistance Programs” ICR by consolidating and updating the information contained in the following ICRs previously approved by OMB:

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.11 (base ICR) - requested approval for collection of information under EPA’s assistance programs.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.12 (amendment ICR) - requested approval of EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.13 (amendment ICR) - adjusted burden hours under the ICR.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.14 (amendment ICR) - requested approval of nonsubstantive modifications to existing EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.15 (amendment ICR) - requested approval of nonsubstantive modifications to existing EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.16 (amendment ICR) – eliminated NCER Form 3212, “Itemized Budget for EPA STAR Grant Applications” and requested approval of EPA Form 6600-06, “Certification Regarding Lobbying.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.17 (amendment ICR) – increased burden estimates by incorporating the following program areas under which grants were funded for the American Recovery and Reinvestment Act (ARRA) (previously approved under Emergency ICR Number 2351.01):

• Diesel Emissions Reduction Act

• Superfund Cooperative Agreement

• Leaking Underground Storage Tank Enforcement and Cleanup Program

• Other assistance programs involving ARRA funds, including the Wastewater Treatment Construction Program, Water Quality Management Planning (Sections 205(j)(1) & 604(b)), and Clean Water Tribal Set-Aside Program

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.18 (amendment ICR) – removed burden associated with common forms and other obsolete requirements; added burden for Continuing Environmental Program (CEP) grant work plans, EPA Form 190-F-05-001, EPA Form 190-F-04-001, EPA Form 5700-53, EPA Form 5700-52A, SF 428 and SF 429; and adjusted other burden hours under the ICR.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.19 (amendment ICR) – Added to ICR 0938.18 three attachments forms for SF 428: Annual Report, the SF428-A; Final (Award Closeout) Report, SF-428-B; and a Disposition Request/Report, SF-428-C. The addition of these forms did not affect the burden.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.20 (amendment ICR) – Updated the ICR Supporting Statement for ICR 0938.18 and some forms due to the implementation of the Uniform Administrative Requirements, Cost Principles and Audit Requirements (Uniform Grants Guidance or UGG).  The changes did not affect the burden.

2. Need For and Use of the Collection

2(a). Need/Authority for the Collection. This ICR is necessary because of the information collection and reporting requirements included in EPA regulations at 40 CFR Parts 30, 31 and 35, and 2 CFR Parts 200 and 1500. For some existing grants awarded prior to December 26, 2014, 40 CFR Parts 30 and 31 implement OMB Circulars A-21, A-87, A-102, A-110, A-122, and A-133. For assistance agreements awarded on or after December 26, 2014, 2 CFR Part 1500 implements OMB regulations in 2 CFR Part 200. These regulations set forth pre-award, post-award, and after-the-grant requirements. This information is needed by EPA project officers, grant specialists, and finance officials to manage/oversee recipient programmatic and financial performance under all EPA assistance agreements.

Without the data compiled by using the forms, it would be impossible for EPA to manage any of its Federal assistance programs. Rational, fair grant awards would be extremely difficult to make, and financial and technical managerial information would not be available for assessing the status of grant efforts. Decreasing the frequency of data collection would have similar negative impacts.

2(b). Practical Utility/Users of the Data. The pre-award information is used by EPA to qualify and select assistance agreement applicants for funding. The post-award information is used to ensure that recipients are complying with statutory and regulatory requirements and to monitor recipient performance. The after-the-grant information is used to meet reporting and recordkeeping requirements and to close out awards. The information is necessary to ensure minimum fiscal control and accountability for EPA funds and to deter waste, fraud, and abuse.

3. Non Duplication, Consultations, and Other Collection Criteria

3(a). Non Duplication. There is no other source for this information.

3(b). Public Notice Required Prior to ICR Submission to OMB. A notice was published on page 82 FR 9738 of the February 8, 2017 Federal Register, announcing that EPA was beginning to prepare this ICR. No comments were received in response to the notice.

3(c). Consultations. We have received continuous feedback from applicants and recipients about this information collection.  Administering EPA assistance agreements requires constant recipient contact, such as written correspondence, telephone calls, and in-person meetings.  The EPA Office of Grants and Debarment (OGD) is both sensitive and responsive to recipients regarding burden, duplication, availability of data, clarity of instructions, and other concerns that are raised. OGD improves EPA assistance agreement forms and collection methods in an effort to address recipient concerns and streamline their activities.  Frequent applicant and recipient feedback and informal consultations are a significant component of the evaluation of EPA assistance agreement forms, and these contacts have been particularly useful in developing burden estimates. 

The purpose of this ICR is to request clearance for EPA assistance agreement forms that are used by respondents on a regular basis and made publicly available in several different locations (e.g., various websites) in both electronic and hardcopy format.  To evaluate the accuracy of its burden estimates, EPA consulted with the following assistance agreement recipient organizations:

 

John D. Chase

Colorado Department of Public Health and Environment

(303) 692-2023

 

Genita Alexander

Florida Department of Environmental Protection

(850) 245-8021

 

Megan Browning

West Virginia Department of Environmental Protection

(304) 926-0499 x 1281

 

Based on input received from the organizations above, it was determined that the burden associated with EPA assistance agreement forms, reporting and record keeping requirements had not changed since the issuance of the last ICR.

3(d). Effects of Less Frequent Collection. The effect of less frequent collection is that EPA would be unable to comply with OMB requirements for assistance agreements.

3(e). General Guidelines. In 1996, the regulations of Part 30 were revised to reflect “plain English.” Since then, EPA has continued to use plain English. As a result, EPA’s assistance agreement regulations and other documents are easier to understand by all organizations, large and small. The information collection is consistent with 5 CFR 1320.5(d)(2).

3(f). Confidentiality. No pledge of confidentiality is given for applicant responses.

3(g). Sensitive Questions. No sensitive information is collected under this ICR.

4. The Respondents and the Information Requested

4(a). Respondents/SIC Codes. The primary recipients of EPA assistance agreements are State and local governments, Indian Tribes, educational institutions, and not-for-profit institutions. The information requested is used to make awards, pay recipients, and collect information on how Federal funds are being spent.

Standard Industrial Classification Codes for respondents include 8211, 8221, 8399, and 919. The corresponding North American Industry Classification System (NAICS) Codes for respondents include 61111, 61131, 813212, 813219, 813311, 813312, 813319 and 92119.

4(b)(i). Information Requested - Data Items, Including Record Keeping Requirements.

The following identifies the application forms and non-form reporting requirements contained in this regulation. A detailed justification for each reporting requirement immediately follows. Burden estimates are summarized in Exhibit A.

EPA Forms, Reporting and Record Keeping Requirements

(1) Record Keeping - 40 CFR Sections 30.50, 30.52, and 31.42 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.301, 200.302, and 200.327 through 200.329 (for awards made on or after December 26, 2014) require recipients to establish an official record file for each assistance award to track how the recipient uses the project funds, to account for property purchased under the award or used as part of any in-kind contributions, to maintain time records, and to document compliance with applicable statutes and regulations (40 CFR Part 7). We estimate that this requirement imposes 5 burden hours on the recipient and 1 burden hour on EPA.

(2) Programmatic Advanced Monitoring - 40 CFR Sections 30.50, 30.52, and 31.42 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.327 through 200.329 (for awards made on or after December 26, 2014) require EPA project officers to perform reviews that pertain to programmatic components of assistance agreements. This type of evaluation focuses on reviewing information that can help assess recipients’ activities and progress toward meeting the goals and objectives outlined in the assistance agreements. Programmatic reviews also ensure that the work to be performed under the agreement is on schedule, within budget, and consistent with the agreements’ relevant programmatic regulation and/or programmatic terms and conditions. During the reviews, EPA project officers may request that recipients provide required information that is missing or incomplete. For those who complete these reviews, we estimate 1 burden hour on the recipient and 1 burden hour on EPA.

The extent of the information gathered and reviewed through this type of instrument will vary according to the size and scope of each agreement. Complex agreements that involve large financial grants and entail extensive staffing and complex tasks will require a greater degree of review and evaluation. Regardless of the size or complexity of the assistance agreement, the review instrument creates a framework that allows EPA to ensure the sound and effective management of assistance agreements.

(3) Submit Interim and Final Progress Reports - 40 CFR Sections 30.51 and 31.40 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.301, 200.302, and 200.328 (for awards made on or after December 26, 2014) require recipients to submit interim and final progress reports. EPA uses the interim progress reports to determine progress in relation to the approved schedule and project milestones during the project. The final progress report summarizes all of the work on the project and the extent to which the recipient has met the project’s objectives. We estimate that this requirement imposes a total of 6.5 burden hours on the recipient and 4 burden hours on EPA.

(4) CEP Work Plans - 40 CFR Sections 35.104 and 35.105 and 2 CFR 200 requires States and territories to submit work plans for CEP grants. Work plans identify environmental goals and objectives and output and outcome measures that are needed for management purposes. We estimate that this requirement imposes a total of 4 burden hours on the recipient and 4 burden hours on EPA.

(5) EPA Form 190-F-04-001, “EPA Payment Request,” is used to request payment from EPA for assistance agreements. We estimate that this form imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(6) EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form,” is completed by fellowship recipients to enable the Treasury Department to transmit payment data, by electronic means, to a financial institution. We estimate that this form imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(7) EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance,” is used to collect information that enables EPA to determine whether applicants are developing projects, programs, and activities on a non-discriminatory basis. We estimate that this form imposes 0.5 burden hours on the applicant and 0 burden hours on EPA.

(8) EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements,” is completed by recipients of Federal grants, cooperative agreements, or other Federal financial assistance which involve procurement of supplies, equipment, construction or services to accomplish Federal assistance programs. We estimate that this form imposes 1 burden hour on the recipient and 1 burden hour on EPA.

(9) EPA Form 5700-53, “Lobbying and Litigation Certification for Grants and Cooperative Agreements,” is completed at project completion to certify that funds have not been used to engage in the lobbying of the Federal Government or in litigation against the United States. We estimate that this form imposes 5 minutes of burden on the recipient and 5 minutes of burden on EPA.

(10) EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-54-2, “Key Contacts Form for Multiple Principal Investigators.” These forms are used to collect contact information for individuals responsible for various aspects of the proposed work, including authorized representative, payee, administrative contact, and investigators. A recipient must complete either form as applicable. We estimate that this form imposes 0.5 burden hours on the applicant and 0 burden hours on EPA.

(11) EPA Form 5770-2, “Fellowship Application,” is the basic application form for individuals seeking fellowships and requires information on the applicant’s educational and work experience background. We estimate that this form imposes 3 burden hours on the applicant and 3 burden hours on EPA.

(12) EPA Form 5770-3, “Fellowship Facilities and Commitment Statement,” requires information about the institution that will sponsor the fellowship applicant, the sponsor’s summarized plans for the applicant’s training, and the institution’s commitment to provide that training. We estimate that this form imposes 1 burden hour on the applicant and 1 burden hour on EPA.

(13) EPA Form 5770-5, “Agency Fellowship Certification,” is used by applicants who are current or prospective employees of a regional, State, or local environmental pollution control or regulatory agency. The form asks the agency director or designee for the kind of help (financial, leave of absence, etc.) the agency will be providing the applicant if the applicant receives an EPA fellowship. We estimate that this form imposes 0.5 burden hours on the applicant and 0.5 burden hours on EPA.

(14) EPA Form 5770-7, “EPA Fellowship Activation Notice,” is used by EPA to inform EPA’s Regional Services Staff to begin payment on the fellowship award. We estimate that this form imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(15) EPA Form 5770-8, “Fellowship Agreement,” contains the terms of the fellowship agreement and is used by the applicant to formally accept an EPA fellowship. We estimate that this form imposes 1 burden hour on the recipient and 1 burden hour on EPA.

(16) EPA Form 5770-9, “Completion of Studies Notice,” is used to officially terminate the fellowship. The form requires the recipient to provide EPA with two reprints of any publication work done under the fellowship, when applicable, and asks for constructive criticism from the recipient or his sponsor on EPA’s fellowship program. We estimate that this form imposes 1 burden hour on the recipient and 1 burden hour on EPA.

(17) EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire,” requests information about an organization’s administrative and financial policies, procedures, accounting and management of EPA assistance agreements. EPA uses the information to determine if recipients are in compliance with government-wide and EPA-specific rules, regulations and guidelines promulgated in the various OMB Circulars, Code of Federal Regulations, and Agency directives. Additionally, it is reviewed to determine if recipients have good business practices, such as consistently applied policies and procedures that safeguard the management and use of Federal funds. The form provides the Agency with information needed to conduct and complete its statistical analyses and evaluation of recipients. The information is collected on a statistically determined and random basis spread over the various types of organizations receiving funds from EPA. We estimate that this form imposes 30 burden hours on the recipient and 40 burden hours on EPA.

(18) EPA Form 6600-06, “Certification Regarding Lobbying,” is completed by grant applicants and contains certifications about the use of Federal appropriated funds in connection with lobbying, as specified. The form is used by EPA to confirm that no funds have been used for lobbying activities and, if applicable, to direct the recipient to complete Standard Form-LLL, Disclosure Form to Report Lobbying.” We estimate that this form imposes 0.25 burden hours on the recipient and 0.03 burden hours on EPA.

(19) EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments.” The “Lobbying Cost Certificate for Indirect Costs” portion is completed by non-profit grant recipients and contains the certification required by 2 CFR Parts 200 and 1500. The form is used by EPA to ensure compliance with the requirements and standards on lobbying costs in 2 CFR Parts 200 and 1500. The “Certificate of Indirect Costs for State and Local Governments” portion is completed by state, local, and tribal grant recipients and contains the certification required by 2 CFR Parts 200 and 1500. The form is used by EPA to ensure compliance with the requirements and standards on lobbying costs in 2 CFR Parts 200 and 1500. We estimate that this form imposes 0.25 burden hours on the recipient and 10 minutes of burden on EPA.

(20) EPA Form 6600-09, “EPA Administrative Capability Questionnaire,” is completed by non‑profit organizations seeking EPA grant awards of more than $200,000 and under certain special conditions (e.g., high‑risk recipients and to other applicants below these thresholds in special circumstances). Based on the information provided, EPA assesses the adequacy of an applicant’s administrative and financial management systems (i.e., administrative capability) and determines whether to award the grant. Applicants that provide information that demonstrates that they are administratively and financially capable are “certified” for the next four years. The questionnaire is necessary because it assists organizations to identify potential system weaknesses and compliance problems and correct them before grant award. We estimate that the form imposes 4 burden hours on the applicant and 3 burden hours on EPA.

(21) NCER Form 5, “Current and Pending Support,” is used by EPA’s National Center for Environmental Research to determine whether the principal investigator has available capability to handle the additional workload proposed by EPA under the grant. We estimate that this form imposes 0.5 burden hours on the applicant and 0.25 burden hours on EPA.

The reporting and record requirements burden estimates of 40 CFR Sections 30.25 through 31.36(h) and 2 CFR Sections (below) are not listed in Exhibit A due to low frequency of applicability and /or minimal response burden to applicants and recipients of EPA grants.

(1) Property Purchase Approval - 40 CFR Sections 30.25 and 31.32 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.308 and 1500.8 (for awards made on or after December 26, 2014) require recipients to obtain the award official’s approval before purchasing property or equipment with a unit acquisition cost of $5,000 or more.

We estimate that this requirement applies to about 20% of the non-construction assistance recipients, and that this requirement imposes 3 burden hours on those recipients and 2 burden hours on EPA.

(2) Property Management Standards - 40 CFR Sections 30.30-37 and 31.32 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.310 through 200.316 (for awards made on or after December 26, 2014) require recipients to comply with specific property management standards. The recipient is required to keep accurate records and carry out a physical inventory of property and reconcile the results, at least every two years. We estimate that this requirement imposes 3 burden hours on the recipient and 2 burden hours on EPA.

(3) Invention Reports - 40 CFR Section 30.36 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.315 and 200.343 (for awards made on or after December 26, 2014) requires recipients to submit invention reports after completion of each project.

(4) Deviation Request - 40 CFR Sections 30.4 and 31.6 (for awards made prior to December 26, 2014) and 2 CFR Section 1500.3 (for awards made on or after December 26, 2014) contain the requirements recipients must follow to request a deviation from an EPA regulation. We estimate that a deviation imposes 8 burden hours on the recipient and 8 burden hours on EPA.

(5) Disputes - 40 CFR Sections 30.63 and 40 CFR 31 Subpart F (for awards made prior to December 26, 2014) and 2 CFR 1500 Subpart E (for awards made on or after December 26, 2014) contain the procedures the recipient must follow to appeal an assistance agreement dispute between the recipient and the award official. We estimate that this requirement imposes 16 burden hours on the recipient and 16 burden hours on EPA. Less than 1% of EPA assistance agreements result in disputes.

(6) Procurement Requirements - 40 CFR Sections 30.40-48 and 31.36 (for awards made prior to December 26, 2014) and 2 CFR 200.317 through 200.326 (for awards made on or after December 26, 2014) contain the procurement requirements recipients must follow. We estimate that this requirement imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(7) Intergovernmental Reviews - 40 CFR Section 31.11 (for awards made prior to December 26, 2014) and 2 CFR 200.203 (for awards made on or after December 26, 2014) requires recipients to follow 40 CFR Part 29, which implements Executive Order 12372, “Intergovernmental Review of Federal Programs,” revokes OMB Circular A-95, and establishes new procedures for intergovernmental reviews. OMB has determined that the new requirements are not subject to the reporting burden clearance process.

(8) Bonding and Reporting Requirements - 40 CFR Section 31.36(h) (for awards made prior to December 26, 2014) and 2 CFR 200.325 (for awards made on or after December 26, 2014) contains the bonding and reporting requirements recipients must follow. We estimate that this requirement imposes 0.5 burden hours on the recipient and 1 burden hour on EPA.

Standard/Common Form Requirements (burden is not included in this ICR)

(1) SF 270, “Request for Advance or Reimbursement.” This is the standard form prescribed for recipients to use to request advances or reimbursement on all non-construction programs when the advance payment or reimbursement methods are used. We estimate that this form imposes 1 burden hour on the recipient and 1.5 burden hours on EPA.

(2) SF 271, “Outlay Report and Request for Reimbursement for Construction Programs.” This is the standard form prescribed by OMB Circular A-102 for recipients of a construction grant to request reimbursements. We estimate that this form imposes 1 burden hour on recipients and 0.5 burden hours on EPA.

(3) SF 3881, “ACH Vendor/Miscellaneous Payment Enrollment Form,” is completed by grant recipients to enable the U.S. Treasury Department to transmit payment data, by electronic means, to a financial institution. We estimate that this form imposes 0.25 burden hours on the recipient and 1 burden hour on EPA.

(4) SF 424, “Application for Federal Assistance,” is used by States, local governments, and Federally recognized Indian Tribal governments to apply for Federal financial assistance. SF-424 requires basic information about the applicant (name, address, telephone number, type of applicant, etc.), including a list of sources of proposed funding and a description of the proposed project. Supplemental information is provided in SF-424A, “Budget Information ‑ Non‑Construction Programs,” SF-424B, “Assurances ‑ Non‑Construction Programs,” SF-424C, “Budget Information ‑ Construction Programs,” and/or SF-424D, “Assurances ‑ Construction Programs,” as applicable. We estimate that this form imposes 4 burden hours on the recipient and 5 burden hours on EPA.

(5) SF 425, “Federal Financial Report,” is used by applicants to submit reports on their assistance agreement’s financial progress. We estimate that this form imposes 1.5 burden hours on the recipient and 1.5 burden hours on EPA.

(6) SF 425A, “Federal Financial Report Attachment,” is used by applicants for reporting on cash management activity for multiple assistance agreements. We estimate that this form imposes 0.5 burden hour on the recipient and 0.5 burden hours on EPA.

(7) SF 428, “Tangible Personal Property,” is used by recipients to report on tangible personal property (equipment and supplies) when required by a Federal financial assistance award. We estimate that this form imposes 2.75 burden hours on the recipient and 2.75 burden hours on EPA.

(8) SF 429, “Real Property Status Report,” is used by recipients of Federal financial assistance to report real property status or to request agency instructions on real property that was/will be provided as Government Furnished Property (GFP) or acquired (i.e. purchased or constructed) in whole or in part under a Federal financial assistance award. Supplemental information is provided in SF-429A, “General Reporting,” SF-429B, “Request to Acquire, Improve or Furnish,” and SF-429C, “Disposition or Encumbrance Request,” as applicable. We estimate that this form imposes 4 burden hours on the recipient and 4 burden hours on EPA.

(9) The SF LLL, “Disclosure of Lobbying Activities,” is used by applicants to disclose lobbying activities that have been secured to influence the outcome of a Federal action (e.g., contract, grant, cooperative agreement, etc.). We estimate that this form imposes 10 minutes of burden on the recipient and 0 burden hours on EPA.

4(b)(ii). Information Requested – Respondent Activities.

Grants.gov, originally called the E‑Grants Initiative, was a mandate of the President’s Fiscal Year 2002 Management Agenda, which directed agencies to “…allow applicants for Federal Grants to apply for and ultimately manage grant funds online through a common Web site, simplifying grants management and eliminating redundancies.”

Grants.gov implements the requirement in the Federal Financial Assistance Management Improvement Act, Public Law 106‑107, to develop a simple, unified source to electronically find, apply, and manage grant opportunities. Grants.gov is the central Federal electronic portal created in response to the Act.

Grants.gov Apply allows an applicant to download a proposal/application package from Grants.gov and complete the package offline based on agency instructions. The proposal/application package of forms generally includes a standard set of core data elements based on the updated version of the SF‑424. After an applicant completes the required proposal/application package of forms, they can be submitted electronically to Grants.gov, which transmits the proposal/application to the funding agency.

The Office of Grants and Debarment has constructed an electronic repository for Pre-Award activities within the Agency’s Integrated Grants Management System (IGMS) which receives, as the funding agency, the proposal/applications data and stores them for program retrieval and review.  As proposals/applications are selected for funding, the data will be migrated and processed through other downstream activities within IGMS for eventual award.

Effective February 17, 2015, EPA requires the use of Grants.gov as the EPA standard for the submission of initial proposals/applications for competitive and non-competitive assistance agreement awards.

5. The Information Collected – Agency Activities, Collection Methodology, and Information Management

5(a). Agency Activities. These data collection forms are reviewed periodically to identify and eliminate duplication in reporting requirements. Similar information is not available elsewhere.

These reports are reviewed in accordance with the requirements of 40 CFR Parts 30, 31 and 35 and 2 CFR Parts 200 and 1500. The Agency also conducts periodic on-site reviews to ensure recipient compliance with applicable requirements.

5(b). Collection Methodology and Management. Most of the information will be collected using standardized reports and appropriate recordkeeping. This information is entered into IGMS, the Agency’s database for tracking the status of assistance agreement actions.

5(c). Small Entity Flexibility. EPA believes the reporting requirements discussed in this ICR do not place an unreasonable burden on small entities; the estimated burdens cannot be further reduced for small entities. EPA requires the information requested to make award decisions, properly manage assistance agreements, maintain records, and monitor performance. This requested information may, in some cases, be dependent on the type of entity (e.g., state agency, non-profit organization, individual, etc.) but is not dependent on an entity’s relative size. EPA takes active steps to minimize the burden on small entities in the form of guidance materials and electronic forms. In most cases, the requirements do not impose a large burden on small entities because the information required is simple and straightforward.

5(d). Collection Schedule. Specific schedules for the collection of the data forms are outlined in grant solicitation notices for pre-award application forms and in the assistance agreement terms and conditions for post-award forms.

6. Estimating the Burden and Cost of the Collection

6(a). Estimating Respondent Burden. An estimation of the burden hours per requirement is included in Exhibit A. The number of respondents by application type are presented below.

Type of Information		Number of Respondents
Competed Grants	Unsuccessful Applications	2,364
	Awards	654
Not Competed Grant Awards		1,274
Fellowship Applications		1,200
TOTAL		5,492

6(b)(i). Estimating Respondent Costs – Estimating Labor Costs.

EPA estimates that 80% of burden hours for respondents will be used by the applicant and the remaining 20% will be used by secretarial/clerical staff. Estimated wage rates for the applicant and secretarial/clerical staff are:

• Applicant Wage Rate:¹ $47.38 x 1.43 = $67.75.

• Secretarial/Clerical Wage Rate:² $18.09 x 1.43 = $25.87.

6(b)(ii). Estimating Respondent Costs – Estimating Capital and Operations and Maintenance Costs. Start-up costs for EPA grant applications and associated forms are minimal and are part of customary and usual recipient business expenses. There are no capital costs related to EPA grant applications and related reporting requirements.

6(b)(iii). Estimating Respondent Costs – Capital/Start-up Operating and Maintenance Costs. There are no capital costs related to EPA grant applications and related reporting requirements. There are no O&M costs required.

6(b)(iv). Estimating Respondent Costs – Annualizing Capital Costs. Not applicable.

6(c). Estimating Agency Burden and Cost. As summarized in Exhibit A, the total annual burden hours for EPA is estimated to be 58,531. 58,531 hours divided by 5,492 respondents = 11 hours per respondent for EPA.

Thus: 5,492 respondents x 11 hours x $50.82³ = $3,070,138 (EPA labor costs).

6(d). Estimating the Respondent Universe and Total Burden and Costs

The total annual burden hours for recipients is estimated to be 90,124. 90,124 hours divided by 5,492 respondents = 16 hours per respondent.

EPA estimates that 80% of these 16 hours will be used by the applicant (13 hours at a rate of $67.75) and the remaining 20% by secretarial/clerical staff (3 hours at a rate of $25.87). The weighted average hourly rate for applicants is $59.90.

Thus: 5,492 respondents x 16 hours x $59.90 = $5,263,533 (applicant labor costs).



6(e). Bottom Line Burden Hours and Cost Tables.

	Burden Hours	Cost
Respondents	90,124	$5,263,533
EPA	58,531	$3,070,138

6(f). Reasons for Change in Burden. The overall respondent burden has decreased from the previous ICR by 64,882 hours (from 155,006 hours to 90,124 hours). This change occurred for several reasons. First, EPA carefully reviewed the set of grant and fellowship forms covered in this ICR. EPA removed burden associated with two forms that have been converted to common forms. These program changes are outlined in the table below.

Program Changes	Total Respondent Hours
Common Form Burden Removed from ICR
SF-428 "Tangible Personal Property"	-8,231
SF-429 "Real Property Status Report"	-120
Subtotal: Program Changes	-8,351

Then, EPA reviewed the burden assumptions in the ICR to ensure that they reflect the Agency’s current experiences under its grant programs.  Based on this review, EPA made significant adjustments to the estimated total number of respondents by application type as outlined in the table below.  EPA did not make any adjustments to the burden hour estimates for any of the forms or requirements included in the ICR.  A summary of the estimated number of annual responses and burden hours per requirement is included in Exhibit A.

Type of Information		Number of Respondents	Change from 2012 ICR
Competed Grants	Unsuccessful Applications	2,364	-1,394
	Awards	654	-705
Not Competed Grant Awards		1,274	-360
Fellowship Applications		1,200	-375
Total		5,492	-2,834

The results of the adjustment changes due to the decrease in respondents are outlined in the following table. Additional details about the revised estimates are included in Exhibit A.

Adjustment Changes	Total Respondent Hours	Change from 2012 ICR
Keep records	9,640	-5,325
Programmatic Advanced Monitoring	269	-107
Submit Interim and Final Progress Reports	50,128	-27,690
CEP Grant Work Plans	1,568	-2,016
EPA Form 190-F-04-001, "US EPA Payment Request"	11,568	-6,390
EPA Form 190-F-05-001, "Fellowship Stipend Payment Enrollment Form	30	-20
EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”	2,146	-1,230
EPA Form 5700-52A, "MBE/WBE Utilization Under Federal Grants and Cooperative Agreements"	2,874	-6,126
EPA Form 5700-53," Lobbying and Litigation Certificate"	161	-89
EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-54-2, “Key Contacts Form for Multiple Principal Investigators”	2,146	-1,229
EPA Form 5770-2, “Fellowship Application”	3,600	-1,125
EPA Form 5770-3, “Fellowship Facilities and Commitment Statement”	1,200	-375
EPA Form 5770-5, “Agency Fellowship Certification”	600	-187
EPA Form 5770-7, “EPA Fellowship Activation Notice”	30	-45
EPA Form 5770-8, “Fellowship Agreement”	60	-90
EPA Form 5770-9, “Completion of Studies Notice”	60	-90
EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire”	2,490	-3,510
EPA Form 6600-06, “Certification Regarding Lobbying”	1,073	-615
EPA Form 6600-08, "Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments”	74	-33
EPA Form 6600-09, “EPA Administrative Capability Questionnaire”	132	-68
NCER Form 5, “Current and Pending Support”	275	-171
Subtotal: Adjustment Changes		-56,531

The net effect of these program changes and adjustments is a decrease of 64,882 hours from the previous ICR.

6(g). Burden Statement: The annual public reporting and recordkeeping burden for this collection of information is estimated to average about 5 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OARM-2016-0762, which is available for public viewing at the Office of Environmental Information Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Office of Environmental Information Docket is (202) 566-1752. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OARM-2016-0762 and OMB Control Number 2030-0020 in any correspondence.

EXHIBIT A

ANNUAL ESTIMATE OF EPA ASSISTANCE AGREEMENT AWARDS

Type of Information		Number of Respondents
Competed Grants	Unsuccessful Applications	2,364
	Awards	654
Not Competed Grant Awards		1,274
Fellowship Applications		1,200
TOTAL		5,492

The above estimates were used to determine the number of actions per year for each of the following reporting requirements.

BURDEN HOURS PER REPORTING REQUIREMENT

NOTES: Column D = A x B x C

Column F = A x B x E

Burden estimates for analyzing, processing, and maintaining EPA grant forms were derived from EPA employees directly responsible for day-to-day grant operations. Employee estimates were obtained shortly after forms were approved for use and have been modified to reflect our grant processing streamlining efforts.

Information Collection Requirement	A	B	C	D	E	F
	Actions per Year	Submissions per Agreement	Burden Hours per Action	Total Burden Hours for Recipients	Burden Hours for EPA	Total Burden Hours for EPA
EPA Forms, Reporting and Record Keeping Requirements
Record Keeping - 40 CFR Sections 30.50, 30.52, and 31.42 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.301, 200.302, and 200.327 through 200.329 (for awards made on or after December 26, 2014)	1,928	1	5	9,640	1	1,928
Completion of Project Officer Protocol/Programmatic Advanced Monitoring - 40 CFR Sections 30.50, 30.52, and 31.42 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.327 through 200.329 (for awards made on or after December 26, 2014)	269	1	1	269	1	269
Submit Interim and Final Progress Reports - 40 CFR Sections 30.51 and 31.40 (for awards made prior to December 26, 2014) and 2 CFR Sections 200.301, 200.302, and 200.328 (for awards made on or after December 26, 2014)	1,928	4	6.5	50,128	4	30,848
CEP Grant Work Plans - 40 CFR 35.104 and 35.105 (for awards made prior to December 26, 2014) and 40 CFR Sections 35.104 and 35.105 and 2 CFR 200.200 (for awards made on or after December 26, 2014)	392	1	4	1,568	4	1,568
EPA Form 190-F-04-001, “US EPA Payment Request”	1,928	12	0.5	11,568	0.5	11,568
EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form”	60	1	0.5	30	0.5	30
EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”	4,292	1	0.5	2,146	0	0
EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements”	2,874	1	1	2,874	1	2,874
EPA Form 5700-53, “Lobbying and Litigation Certificate”	1,928	1	0.0833	161	0.0833	161
EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-54-2, “Key Contacts Form for Multiple Principal Investigators”	4,292	1	0.5	2,146	0	0
EPA Form 5770-2, “Fellowship Application”	1,200	1	3	3,600	3	3,600
EPA Form 5770-3, “Fellowship Facilities and Commitment Statement”	1,200	1	1	1,200	1	1,200
EPA Form 5770-5, “Agency Fellowship Certification”	1,200	1	0.5	600	0.5	600
EPA Form 5770-7, “EPA Fellowship Activation Notice”	60	1	0.5	30	0.5	30
EPA Form 5770-8, “Fellowship Agreement”	60	1	1	60	1	60
EPA Form 5770-9, “Completion of Studies Notice”	60	1	1	60	1	60
EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire”	83	1	30	2,490	40	3,320
EPA Form 6600-06, “Certification Regarding Lobbying”	4,292	1	0.25	1,073	0.03	129
EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments”	296	1	0.25	74	0.17	50
EPA Form 6600-09, “EPA Administrative Capability Questionnaire”	33	1	4	132	3	99
NCER Form 5, “Current and Pending Support”	550	1	0.5	275	0.25	138
TOTAL	28,925			90,124		58,531

EXHIBIT B

Forms Covered Under this ICR

• EPA Form 190-F-04-001, “EPA Payment Request”

• EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form”

• EPA Form 4700‑4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”

• EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements”

• EPA Form 5700-53, “Lobbying and Litigation Certification for Grants and Cooperative Agreements”

• EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-54-2, “Key Contacts Form for Multiple Principal Investigators”

• EPA Form 5770‑2, “Fellowship Application”

• EPA Form 5770‑3, “Fellowship Facilities and Commitment Statement”

• EPA Form 5770‑5, “Agency Fellowship Certification”

• EPA Form 5770‑7, “EPA Fellowship Activation Notice”

• EPA Form 5770‑8, “Fellowship Agreement”

• EPA Form 5770‑9, “Completion of Studies Notice”

• EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire”

• EPA Form 6600-06, “Certification Regarding Lobbying”

• EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/ Certificate of Indirect Costs for State and Local Governments”

• EPA Form 6600-09, “EPA Administrative Capability Questionnaire”

• NCER Form 5, “Current and Pending Support”

EXHIBIT C

ENVIRONMENTAL PROTECTION AGENCY

FINANCIAL ASSISTANCE PROGRAMS—CATALOG OF

FEDERAL DOMESTIC ASSISTANCE (CFDA) NUMBER AND TITLE

Office of Administration and Resources Management (OARM)

66.508 Senior Environmental Employment Program

66.518 State Senior Environmental Employment Program

Office of Air Radiation (OAR)

66.001 Air Pollution Control Program Support

66.032 State Indoor Radon Grants

66.033 Ozone Transport Commission

66.034 Surveys, Studies, Research, Investigations, Demonstrations and Special Purpose Activities Relating to the Clean Air Act

66.037 Internships, Training and Workshops for the Office of Air and Radiation

66.038 Training, Investigations, and Special Purpose Activities of Federally-Recognized Indian Tribes Consistent With the Clean Air Act (CAA), Tribal Sovereignty and the Protection and Management of Air Quality

66.039 National Clean Diesel Emissions Reduction Program

66.040 State Clean Diesel Grant Program

66.041 Climate Showcase Communities Grant Program

66.042 Temporally Integrated Monitoring of Ecosystems (TIME) and Long-Term Monitoring (LTM) Program

Office of Chemical Safety and Pollution Prevention (OCSPP)

66.612 Survey, Studies, Investigations, Training Demonstrations and Educational Outreach Related to Environmental Information and the Release of Toxic Chemicals

66.707 TSCA Title IV State Lead Grants Certification of Lead‑Based Paint Professionals

66.708 Pollution Prevention Grant Program

66.714 Regional Agricultural IPM Grants

66.716 Research, Development, Monitoring, Public Education, Training, Demonstrations, and Studies

66.717 Source Reduction Assistance

Office of the Chief Financial Officer (OCFO)

66.202 Congressionally Mandated Projects

66.204 Multipurpose Grants to States and Tribes

Office of Enforcement and Compliance Assurance (OECA)

66.305 Compliance Assistance Support for Services to the Regulated Community and Other Assistance Providers

66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program

66.309 Surveys, Studies, Investigations, Training and Special Purpose Activities Relating to Environmental Justice

66.310 Capacity Building Grants and Cooperative Agreements for Compliance Assurance and Enforcement Activities in Indian Country and Other Tribal Areas

66.313 International Compliance and Enforcement Projects

66.604 Environmental Justice Small Grants Program

66.700 Consolidated Pesticide Enforcement Cooperative Agreements

66.701 Toxic Substances Compliance Monitoring Grants

Office of Environmental Information (OEI)

66.608 Environmental Information Exchange Network Grant Program and Related Assistance

Office of International and Tribal Affairs (OITA)

66.473 Direct Implementation Tribal Cooperative Agreements

66.926 Indian Environmental General Assistance Program (GAP)

66.931 International Financial Assistance Projects Sponsored by the Office of International and Tribal Affairs

66.954 Tribal EcoAmbassadors Grant Program

Office of Research and Development (ORD)

66.509 Science to Achieve Results (STAR) Research Program

66.510 Surveys, Studies, Investigations and Special Purpose Grants within the Office of Research and Development

66.511 Office of Research and Development Consolidated Research/Training/Fellowships

66.513 Greater Research Opportunities (GRO) Fellowships For Undergraduate Environmental Study

66.514 Science to Achieve Results (STAR) Fellowship Program

66.516 P3 Award: National Student Design Competition for Sustainability

66.517 Regional Applied Research Efforts (RARE)

Office of Land and Emergency Management (OLEM)

66.801 Hazardous Waste Management State Program Support

66.802 Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative Agreements

66.804 Underground Storage Tank Prevention, Detection and Compliance Program

66.805 Leaking Underground Storage Tank Trust Fund Corrective Action Program

66.806 Superfund Technical Assistance Grants (TAG) for Community Groups at National Priority List (NPL) Sites

66.808 Solid Waste Management Assistance Grants

66.809 Superfund State and Indian Tribe Core Program Cooperative Agreements

66.812 Hazardous Waste Management Grant Program for Tribes

66.813 Alternative or Innovative Treatment Technology Research, Demonstration, Training and Hazardous Substance Research Grants

66.814 Brownfields Training, Research and Technical Assistance Grants and Cooperative Agreements

66.815 Environmental Workforce Development and Job Training Cooperative Agreements

66.816 Headquarter and Regional Underground Storage Tanks Program

66.817 State and Tribal Response Program Grants

66.818 Brownfields Assessment and Cleanup Cooperative Agreements

66.819 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Leaking Underground Storage Tank Trust Fund Corrective Action Program

Office of Administration (OA)

66.605 Performance Partnership Grants

66.609 Protection of Children from Environmental Health Risks

66.610 Surveys, Studies, Investigations and Special Purpose Grants within the Office of the Administrator

66.611 Environmental Policy and Innovation Grants

66.950 National Environmental Education Training Program

66.951 Environmental Education Grants

Office of Water (OW)

66.203 Environmental Finance Center Grants

66.418 Construction Grants for Wastewater Treatment Works

66.419 Water Pollution Control State, Interstate, and Tribal Program Support

66.424 Surveys, Studies, Investigations, Demonstrations, and Training Grants - Section 1442 of the Safe Drinking Water Act

66.432 State Public Water System Supervision

66.433 State Underground Water Source Protection

66.436 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative Agreements - Section 104(b)(3) of the Clean Water Act

66.437 Long Island Sound Program

66.439 Targeted Watersheds Grants

66.440 Urban Waters Small Grants

66.441 Healthy Watersheds Consortium Grant Program

66.454 Water Quality Management Planning

66.456 National Estuary Program

66.458 Capitalization Grants for Clean Water State Revolving Funds

66.460 Nonpoint Source Implementation Grants

66.461 Regional Wetland Program Development Grants

66.462 National Wetland Program Development Grants and Five-Star Restoration Training Grant

66.466 Chesapeake Bay Program

66.468 Capitalization Grants for Drinking Water State Revolving Funds

66.469 Great Lakes Program

66.472 Beach Monitoring and Notification Program Implementation Grants

66.473 Direct Implementation Tribal Cooperative Agreements

66.474 Water Protection Grants to the States

66.475 Gulf of Mexico Program

66.481 Lake Champlain Basin Program

66.482 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Capitalization Grants For Clean Water State Revolving Funds

66.483 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Capitalization Grants for Drinking Water State Revolving Funds

Region 1

66.110 Healthy Communities Grant Program

66.129 Southeast New England Program

Region 4

66.128 Southeastern Multi-Media and Geographic Priority Projects

66.130 Gulf Coast Ecosystem Restoration Council Comprehensive Plan Component

Region 6

66.124 Coastal Wetlands Planning Protection and Restoration Act

66.125 Lake Pontchartrain Basin Restoration Program (PRP)

Region 9

66.126 The San Francisco Bay Water Quality Improvement Fund

66.600 Environmental Protection Consolidated Grants for the Insular Areas - Program Support

Region 10

66.120 Puget Sound Watershed Management Assistance

66.121 Puget Sound Protection and Restoration: Tribal Implementation Assistance Program

66.123 Puget Sound Action Agenda: Technical Investigations and Implementation Assistance Program

1 $47.38 represents the average wage rate of several occupations expected to apply for grants or fellowships. This information is derived from Bureau of Labor Statistics; Occupational Employment and Wages, May 2015. This figure was derived from the median hourly wage for Bureau of Labor Statistics “Occupational Employment and Wages: Management Occupations” available at http://www.bls.gov/oes/current/oes110000.htm (accessed 3/24/2017). 1.43 represents a 43% rate for benefits.

2 $18.09 represents the average hourly wage rate of two administrative/clerical positions. This information is derived from Bureau of Labor Statistics; Occupational Employment and Wages, May 2015. 1.43 represents a 43% rate for benefits. This figure was derived from the median hourly wage for Bureau of Labor Statistics’ “Occupational Employment and Wages: Information and Record Clerks” available at http://www.bls.gov/oes/current/oes434199.htm ($18.26) and “Occupational Employment and Wages: Bookkeeping, Accounting, and Auditing Clerks” available at http://www.bls.gov/oes/current/oes433031.htm ($17.91) (accessed 3/24/2017).

3 Office of Personnel Management; 2017 General Schedule (GS) Base (Hourly Rate) for GS 11, Step 9 ($31.76). Available at: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/GS_h.pdf. This was fully burdened (x 60%), yielding a wage rate of $50.82.

15