Supporting Statement for Paperwork Reduction Act Submissions
(HUD-91070-OHF, HUD-91071-OHF, HUD-91073-OHF, HUD-91111-OHF, HUD-91725-OHF, HUD-92013-OHF, HUD-92023-OHF, HUD-92070-OHF, HUD-92080-OHF, HUD-92117-OHF, HUD-92205-OHF, HUD-92223-OHF, HUD-92266-OHF, HUD-92322-OHF, HUD-92330-OHF, HUD-92330A-OHF, HUD-92403-OHF, HUD-92403A-OHF, HUD-92415-OHF, HUD-92422-OHF, HUD-92434-OHF, HUD-92441-OHF, HUD-92442-OHF, HUD-92448-OHF, HUD-92452A-OHF, HUD-92452-OHF, HUD-92455-OHF, HUD-92456-OHF, HUD-92464-OHF, HUD-92466-OHF, HUD-92476-OHF, HUD-92476A-OHF, HUD-92476B-OHF, HUD-92479-OHF, HUD-92554-OHF, HUD-92576-OHF, HUD-93305-OHF, HUD-94000-OHF, HUD-94001-OHF, HUD-94128-OHF)
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.
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The collection of information requested is required specifically for the application and administration of the Department of Housing and Urban Development, Federal Housing Administration (FHA) Section 242 Hospital Mortgage Insurance Program pursuant to 24 CFR 242, 241, 223(f), and 223(a)(7). The Department is authorized to collect information that may be requested in these forms by virtue of The National Housing Act, 12 USC 1701 et seq. and the regulations at 24 CFR 5.212 and 24 CFR 200.6; and the Housing and Community Development Act of 1987, 42 USC 3543(a).
The collection is a comprehensive set of HUD documents that are critically needed for processing applications and loan endorsements for FHA mortgage insurance under the Section 242 Hospital Mortgage Insurance Program, for ongoing asset management of such facilities, and other information related to these facilities for loan modifications, construction projects, and physical and environmental reviews. This information is requested and is used by the Office of Healthcare Facilities (OHF) and Office of Architecture and Engineering (OAE) within FHA’s Office of Healthcare Programs (OHP). |
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.
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The purpose for which the information is being collected by HUD is to review Section 242 applications to determine the eligibility of applicant hospitals for FHA mortgage insurance, underwrite insured hospital loans, ensure that the collateral securing each loan is adequate, capture administrative data, process initial/final endorsement, and manage FHA’s hospital portfolio. Additional information related to loan modifications, construction projects, and physical and environmental reviews is collected if applicable.
The information being collected consists of various HUD forms that program participants complete with project specifications, technical descriptions, details, and/or signatures that are utilized by HUD during various stages of the application, underwriting, commitment, closing, and asset management processes involved with the administration of FHA’s Section 242 mortgage insurance program.
The information is used by HUD staff for internal review of applications to determine if projects qualify for Section 242 hospital mortgage insurance and to manage and monitor the application, commitment, initial/final endorsement, asset management, and administration processes needed to support hospital mortgage insurance projects insured by FHA. Agreements and legal documents are used by HUD staff, lenders, borrowers, construction managers, and depository institutions, when applicable, to process initial/final endorsement of loans. Information reported for ongoing asset management of FHA-insured facilities will be used by HUD staff to monitor and manage risk within the FHA portfolio and ensure ongoing compliance with regulations. Information is also be used by HUD staff to determine whether the Program meets its stated goals and management objectives.
The information is collected from lenders/mortgage bankers, borrowers/hospital management officials, attorneys, general contractors/construction managers, architects/engineers, agents and others involved in hospital projects, which may, at times include local government entities and other third parties, as well as others involved in hospital projects seeking FHA mortgage insurance.
Additional detail regarding the individual forms included in the collection are as follows:
Two new forms are being added to this collection that are listed in the table above: HUD-92266-OHF (Application for Transfer of Physical Assets) and HUD-92476B-OHF (Escrow Agreement for the Release of Collateral). The HUD-92266-OHF is being added for occasional situations involving the sale/purchase of an FHA-insured facility. The form allows HUD staff to review requests to transfer physical assets from an insured facility to a new purchaser that will continue to hold the FHA-insured loan. The HUD-92476B-OHF is being added to provide an escrow agreement template for infrequent instances when a borrower sells and requests to release HUD-insured collateral. Both documents are based on existing versions used by the Office of Housing in other mortgage insurance programs but modified to appropriately reflect Section 242 program needs.
HUD-9250-OHF (Funds Authorizations) will be removed from the collection. The document was added to Collection 2502-0602 in a prior submission and was based upon a similar form used for OHP’s residential care facility program. The form has proven to be unnecessary for the Section 242 hospital program and will be removed.
Thirty-five of the forty documents within the collection are being renewed with no operational content changes, except for updated burden hour estimates and additional language added to the burden statements to ensure that requirements under 5 CFR 1320.8(b)(3) are met. Additional language (specifically, the phrase “under penalty of perjury”) was also added to clarify fraud warnings and certification for forms with certifications.
Revisions are proposed for the HUD-92466-OHF (Regulatory Agreement), HUD-92422-OHF (Financial and Statistical Data for HUD Reporting), and HUD-94000-OHF (Security Instrument) to include edits that were made to include edits that were made to clarify current policies and definitions, reflect updated general accepted accounting standards, or to address minor inconsistencies across documents.
A summary of the specific changes made to the revised documents is provided below.
Summary of Changes to Documents:
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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.
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The collection of information is accessible via the internet, and forms are in Microsoft Word or PDF-fillable forms, thus allowing electronic submissions, in addition to hard copy paper submissions. Information is submitted electronically via digital storage drive or email attachment, or hard copies are submitted via mail or delivery service. Electronic submissions are submitted to the OHF Underwriting Division Director via email (paul.a.giaudrone@hud.gov). Hard copies or digital storage drives are mailed or delivered to HUD Headquarters at 451 7th Street SW, Room 6264, Washington, DC 20410.
To facilitate the reduction of burden hours, HUD is evaluating the possibilities for developing system-based technology to collect data. The collection of information does not currently involve the use of automation in such a system; however, HUD and the Office of Housing are undergoing a transformation of the IT infrastructure which will dictate the type of automated systems that will be developed. This process is very detailed and involves the evaluation of each data point received during a loan application process; how that data flows from the intake process through OHF’s underwriting process and then on to a longer-term asset management system for ongoing use in monitoring each project. Having these new workflows work in connection with the existing HUD systems requires development, review, testing, and understanding of how the internal and external submissions are feasible within firewall standards used by both HUD and the lending industry. This entire process is something OHF is interested in and is currently studying and working with HUD IT personnel to develop; however there are significant financial constraints that are also associated with such a large automation process, and this type of overall automation of program and its application review and monitoring process will take a significant amount of time and resources.
Further, it is imperative that the automatic system is developed adequately to address concerns for confidentiality and data security. Until the IT transformation has been able to establish such security and a platform that will house these new capabilities, it is difficult to establish a viable electronic intake process that will be sustained.
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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.
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This information is not collected elsewhere. A review of OHF information collections confirms that no other information collection provides this particular information. |
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.
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This collection of information will not have a significant impact on small business or other small entities. OHF healthcare project borrowers/stakeholders are rarely small businesses, and the average loan size for a hospital is very significant. Even small, rural critical access hospitals are not considered small businesses. |
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.
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If the information were not collected, then HUD would have no record of completion to provide to the satisfaction of all parties of the contract and responsible local government officials. |
7. Explain any special circumstances that would cause an information collection to be conducted in a manner: (PLEASE ANSWER EACH BULLET SEPARATELY)
* requiring respondents to report information to the agency more often than quarterly;
HUD-92422-OHF (Financial and Statistical Data for HUD Reporting) may be used to report information to HUD on a monthly basis in accordance with Program Obligations, until final endorsement has occurred, or at HUD’s request. Other than this form, there are no requirements to report the information requested in this collection more often than quarterly.
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
There are no requirements to prepare written responses to this collection of information in fewer than 30 days after receipt.
* requiring respondents to submit more than an original and two copies of any document;
There are no requirements for submitting more than an original and two copies of any document included in this collection.
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
Per HUD’s document retention policy, HUD documents are required to be maintained during the life of the insured loan plus 7 years after the closeout of the insured loan.
* in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
This collection is not connected with a statistical survey.
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
This collection does not require 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
This collection does not include 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.
* requiring respondents to submit proprietary trade secrets, 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.
This collection does not require respondents to submit proprietary trade secrets, 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. |
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8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
In accordance with 5 CFR 1320.8(d), a 60-day Federal Register Notice inviting public comments was published on May 24, 2019, Volume 84, No. 101, Pages 24167-24169.
HUD received one comment during the 60-day comment period that closed on July 23, 2019. The comment addressed an issue with the link to the posted documents online not working correctly. HUD corrected the issue and responded to this comment directly. A 30-day Federal Register Notice inviting public comments was published on August 20, 2019, Volume 84, Pages 43154-43156. No comments were received. |
To prepare this current information collection revision, OHF consulted with a representative from a healthcare financing industry stakeholder coalition (Committee on Healthcare Financing), an attorney (Krooth & Altman), and a lender (Gavin & Lavigne), to obtain their views on information collection activity documented in this collection. OHF regularly communicates with the respondents during the course of a year. OHF has considered the comments received and has made adjustments to the burden estimates to more accurately reflect anticipated activity during a calendar year.
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9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
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HUD does not provide payments or gifts to respondents in exchange for a benefit sought. |
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
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Mortgage insurance files and financial documentation generally fall under the confidentiality provisions of the Privacy Act and Freedom of Information Act. The Housing and Community Development Act of 1987, 42 U.S.C. 3543, requires persons applying for a federally insured or guaranteed loan to furnish his/her Social Security Number (SSN) or Employer Identification Number (EIN). The inclusion of SSN/EIN is considered a confidential matter. A Privacy Act notice is printed on the appropriate forms. HUD assures confidentiality to respondents on other information collected if it would result in competitive harm in accord with the Freedom of Information Act (FOIA) provisions or if it could impact on the ability of the Department’s mission to provide housing units under the various Sections of the Housing Legislation. |
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.
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The forms do not include questions of a sensitive nature.
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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 for approval 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.
* 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. |
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Estimated Annualized Burden Hours and Costs
Respondents (Primary Type of Respondent) |
Information Collection |
Form Name |
Number of Respon- dents |
Frequ. of Resp. |
Resp. per Annum |
Avg. Burden Hour Per Response |
Annual Burden Hours |
Avg. Hourly Cost Per Response |
Annual Cost |
Lenders, Borrowers, Attorneys (Business or other for-profit) |
HUD-91070-OHF |
Consolidated Certifications Borrower |
15 |
1 |
15 |
4 |
60 |
$103.53 |
$6,211.80 |
Lenders, Borrowers, Attorneys (Business or other for-profit) |
HUD-91071-OHF |
Escrow Agreement for Off-site Facilities |
3 |
2 |
6 |
2 |
12 |
$103.53 |
$1,242.36 |
Construction Managers (Business or other for-profit) |
HUD-91073-OHF |
HUD Survey Instructions and Surveyor’s Report |
15 |
1 |
15 |
8 |
120 |
$70.90 |
$8,508.00 |
Construction
Managers, Borrowers |
HUD-91111-OHF |
Survey Instructions and Borrower's Certification |
15 |
1 |
15 |
1 |
15 |
$104.25 |
$1,563.75 |
Attorneys (Business or other for-profit) |
HUD-91725-OHF |
Opinion by Counsel to the Borrower |
15 |
1 |
15 |
8 |
120 |
$99.60 |
$11,952.00 |
Lenders, Borrowers, Attorneys, Construction Contractor, Architect & Engineer (Business or other for-profit) |
HUD-92013-OHF |
Application for Hospital Project Mortgage Insurance |
15 |
1 |
15 |
4564 |
68460 |
$96.84 |
$6,629,666.40 |
Lenders (Business or other for-profit) |
HUD-92023-OHF |
Request for Final Endorsement of Credit Instrument - Hospitals/Section 242 |
15 |
1 |
15 |
2 |
30 |
$73.39 |
$2,201.70 |
Lenders, Borrowers,
Agents |
HUD-92070-OHF |
Lease Addendum |
10 |
1 |
10 |
1 |
10 |
$91.60 |
$916.00 |
Lenders (Business or other for-profit) |
HUD-92080-OHF |
Change of Mortgage Record |
10 |
1 |
10 |
1 |
10 |
$73.39 |
$733.90 |
Borrowers (Not-for-profit institutions) |
HUD-92117-OHF |
Borrower's Certification- Full or Partial Completion of Project |
5 |
5 |
25 |
1 |
25 |
$137.61 |
$3,440.25 |
Borrowers, Construction Managers (Not-for-profit institutions) |
HUD-92205-OHF |
Borrower's Pre-Closing Certificate of Actual Cost (Section 242/223f) |
5 |
1 |
5 |
4 |
20 |
$72.15 |
$1,443.00 |
Lenders, Borrowers, Attorneys (Business or other for-profit) |
HUD-92223-OHF |
Surplus Cash Note |
5 |
1 |
5 |
1 |
5 |
$103.53 |
$517.65 |
Lenders, Borrowers (Business or other for-profit) |
HUD-92266-OHF |
Application for Transfer of Physical Assets |
2 |
1 |
2 |
92 |
184 |
$105.50 |
$19,412.00 |
Lenders |
HUD-92322-OHF |
Intercreditor Agreement |
8 |
1 |
8 |
4 |
32 |
$73.39 |
$2,348.48 |
Construction Managers (Business or other for-profit) |
HUD-92330A-OHF |
Contractor's Certificate of Actual Cost - Hospitals/Section 242 |
15 |
1 |
15 |
2 |
30 |
$70.90 |
$2,127.00 |
Borrowers, Construction Managers (Not-for-profit institutions) |
HUD-92330-OHF |
Borrower's Certificate of Actual Cost - Hospitals/Section 242 |
15 |
1 |
15 |
2 |
30 |
$104.25 |
$3,127.50 |
Borrowers,
Architects/Engineers |
HUD-92403A-OHF |
Borrower's And Architect's Certificate of Payment (01/1995) |
15 |
1 |
15 |
1 |
15 |
$120.14 |
$1,802.10 |
Lenders, Borrowers (Business or other for-profit) |
HUD-92403-OHF |
Application for Insurance of Advance of Mortgage Proceeds |
7 |
12 |
84 |
1 |
84 |
$105.50 |
$8,862.00 |
Borrowers, Construction Managers (Not-for-profit institutions) |
HUD-92415-OHF |
Request For Permission To Commence Construction Prior To Initial Endorsement For Mortgage Insurance - Hospitals/Section 242 |
5 |
1 |
5 |
1 |
5 |
$104.25 |
$521.25 |
Borrowers, Lenders (Not-for-profit institutions) |
HUD-92422-OHF |
Financial And Statistical Data For HUD Reporting |
90 |
6 |
540 |
16 |
8640 |
$105.50 |
$911,520.00 |
Lenders |
HUD-92434-OHF |
Lender's Certificate |
15 |
1 |
15 |
8 |
120 |
$73.39 |
$8,806.80 |
Lenders, Borrowers,
Attorneys |
HUD-92441-OHF |
Building Loan Agreement |
10 |
1 |
10 |
10 |
100 |
$103.53 |
$10,353.00 |
Borrowers, Construction
Managers, Attorneys |
HUD-92442-OHF |
Construction Contract |
10 |
1 |
10 |
10 |
100 |
$102.70 |
$10,270.00 |
Construction Managers,
Architects |
HUD-92448-OHF |
Contractor's Requisition Project Mortgages |
10 |
1 |
10 |
4 |
40 |
$86.79 |
$3,471.60 |
Construction Managers,
Lenders, Attorneys |
HUD-92452A-OHF |
Payment Bond |
10 |
1 |
10 |
4 |
40 |
$81.30 |
$3,252.00 |
Construction Managers,
Lenders, Attorneys |
HUD-92452-OHF |
Performance Bond |
10 |
1 |
10 |
4 |
40 |
$81.30 |
$3,252.00 |
Lenders, Borrowers, Construction Managers (Business or other for-profit) |
HUD-92455-OHF |
Request for Endorsement of Credit Instrument & Certificate of Lender, Borrower & General Contractor |
15 |
1 |
15 |
8 |
120 |
$93.97 |
$11,276.40 |
Lenders, Borrowers (Business or other for-profit) |
HUD-92456-OHF |
Escrow Agreement for Incomplete Construction |
3 |
2 |
6 |
2 |
12 |
$105.50 |
$1,266.00 |
Borrowers |
HUD-92464-OHF |
Request for Approval of Advance of Escrow Funds - Hospitals/Section 242 |
5 |
5 |
25 |
2 |
50 |
$137.61 |
$6,880.50 |
Lenders, Borrowers,
Attorneys |
HUD-92466-OHF |
Regulatory Agreement - Borrower |
15 |
1 |
15 |
24 |
360 |
$105.50 |
$37,980.00 |
Lenders, Borrowers,
Attorneys |
HUD-92476-OHF |
Escrow Agreement for Deferred Work |
2 |
2 |
4 |
4 |
16 |
$105.50 |
$1,688.00 |
Lenders, Borrowers,
Attorneys |
HUD-92476A-OHF |
Escrow Agreement for Limited Rehabilitation |
4 |
2 |
8 |
4 |
32 |
$105.50 |
$3,376.00 |
Lenders, Borrowers,
Attorneys |
HUD-92476B-OHF |
Escrow Agreement for Proceeds from Partial Release of Collateral |
2 |
1 |
2 |
2 |
4 |
$105.50 |
$422.00 |
Lenders, Borrowers,
Attorneys |
HUD-92479-OHF |
Off-Site Bond - Dual Obligee |
5 |
2 |
10 |
2 |
20 |
$105.50 |
$2,110.00 |
Lenders, Borrowers, Construction Managers, Attorneys (Business or other for-profit) |
HUD-92554-OHF |
Supplementary Conditions of the Contract for Construction |
15 |
1 |
15 |
3 |
45 |
$93.97 |
$4,228.65 |
Borrowers, Agents (Not-for-profit institutions) |
HUD-92576-OHF |
Certificate for Need for Health Facility and Assurance of Enforcement of State Standards |
12 |
1 |
12 |
2 |
24 |
$100.70 |
$2,416.80 |
Lenders, Borrowers,
Construction Managers, Attorneys |
HUD-93305-OHF |
Agreement and Certification |
15 |
1 |
15 |
4 |
60 |
$93.97 |
$5,638.20 |
Lenders, Borrowers,
Attorneys |
HUD-94000-OHF |
Security Instrument/ Mortgage/Deed of Trust |
15 |
1 |
15 |
12 |
180 |
$103.53 |
$18,635.40 |
Lenders, Borrowers,
Attorneys |
HUD-94001-OHF |
Healthcare Facility Note |
15 |
1 |
15 |
4 |
60 |
$103.53 |
$6,211.80 |
Lenders (Business or other for-profit) |
HUD-94128-OHF |
Environmental Assessment and Compliance Findings |
12 |
1 |
12 |
8 |
96 |
$73.39 |
$7,045.44 |
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485 |
2.2 |
1,069 |
74 |
79,426 |
$97.79 |
$7,766,697.73 |
According to the U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm) the wage rate category for the following occupations that were used to estimate average rates for the respondents and a 1.46 multiplier was used to reflect a fully-loaded wage rate:
Respondent Type |
BLS Occupational Title |
Mean Hourly Wage Rate |
Fully Loaded Hourly Wage Rate |
Lenders |
Financial Analysts and Advisors |
$50.27 |
$73.39 |
Borrowers |
Chief Executives |
$94.25 |
$137.61 |
Attorneys |
Lawyers |
$68.22 |
$99.60 |
Construction Managers |
Construction Managers |
$48.56 |
$70.90 |
Architects/Engineers |
Architectural & Engineering Managers |
$70.33 |
$102.68 |
Agents |
Agents and Business Managers |
$43.69 |
$63.79 |
The average hourly cost per response was calculated by averaging the hourly wage rates of the respondent types associated with each form.
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).
* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and 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 collections 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.
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There is no additional costs to respondents or recordkeepers resulting from the collection of information. Any efforts to retain documents would occur as part of customary and usual business practices and would pose no additional cost burden for respondents or recordkeepers. |
14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table. |
Estimated Annual Cost to the Federal Government
* Note: The “Salary Rate” includes a 1.46 multiplier to reflect a fully-loaded wage rate.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
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This request is for a renewal of an existing collection approved by OMB that expires on August 31, 2019. The changes and adjustments reported in Items 13 and 14 are principally the result of revised estimates for the Estimated Annualized Burden Hours and Costs and revised estimates for the Annual Cost to the Federal Government. Average burden hour estimates were reviewed and updated when appropriate, to better reflect estimates for the hours required to complete the forms and to follow guidance for application (including the Pre-Application and Application Guides), construction, environmental, and other procedures presented in Handbook 4615.1 for the Section 242 Mortgage Insurance Program. The bulk of the hours estimated for application activities (including pre-application) of program stakeholders participating in the Section 242 Mortgage Insurance Program (including lenders, borrowers, attorneys, construction contractors, architects, and engineers) are estimated under the average hours for the HUD-92013-OHF, Application for Hospital Project Mortgage Insurance. Additional language was added to every burden statement in the collection to ensure that requirements under 5 CFR 1320.8(b)(3) are met. Revised average burden hour estimates result in an addition of 6,198.75 hours to the total Annual Burden Hours for the collection. The new and removed forms will add a net addition of 180.5 hours [184 hrs (HUD-92266-OHF, added) + 4 hrs (HUD-92476B-OHF, added) – 7.5 hrs (HUD-9250-OHF, removed)] for a total addition of 6,379.25 hours to the estimated Annual Burden Hours for this collection. The net change from the last submission of Total Annual Burden Hours is an increase of 6,379.25 hours for this collection. Updated wage rates were used based upon the mean labor rates published on the U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm) and the 2018 General Schedule Base Pay Table (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/GS.pdf). The wage rate calculations also now include a 1.46 multiplier to reflect a fully-loaded wage rate. The overall Annual Cost estimate increase is due to the updated burden hour estimates and revised and updated wage rates used to calculate the estimated annual costs. The net change from the last submission of overall Annual Cost estimate is an increase of $2,235,279. The change reflects the addition of two new forms (HUD-92266-OHF Application for Transfer of Physical Assets and HUD-92476B-OHF Escrow Agreement for the Release of Collateral) to accommodate specific and occasional situations involving the sale of FHA-insured collateral and transfer of physical assets, as well as the removal of HUD-9250-OHF (Funds Authorizations) from the collection, which has proven to be unnecessary for the Section 242 hospital program. Thirty-five of the forty documents within the collection are being renewed with no substantive content changes aside from the burden hour statement and fraud warning clarifications. Revisions are proposed for the HUD-92466-OHF (Regulatory Agreement), HUD-92422-OHF (Financial and Statistical Data for HUD Reporting), and HUD-94000-OHF (Security Instrument) to include edits that were made to include edits that were made to clarify current policies and definitions, reflect updated general accepted accounting standards, or to address minor inconsistencies across documents. Note: HUD-92415-OHF is an existing form that was included in the last OMB submission. It was discovered to be missing off the approved 2016 NOA. This was a data-entry error on the NOA. |
16. For collections 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.
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HUD does not intend to employ the use of statistics or the publication thereof for this information collection. |
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.
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HUD will display the expiration date for OMB approval of this information collection. |
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
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HUD does not request an exception to the certification of this information collections.
B. Collections of Information Employing Statistical Methods.
There is no statistical methodology involved in this collection.
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| File Type | application/msword |
| Author | h18889 |
| Last Modified By | SYSTEM |
| File Modified | 2019-08-28 |
| File Created | 2019-08-28 |