2577-0229 Supporting Statement with 8-27-2020

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		2. OMB Control Number: a. 2577-0229	b.   None      
3. Type of information collection: (check one) New Collection 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 6. Requested expiration date: a. Three years from approval date b. Other (specify)      

7. Title:

Resident Opportunities and Self Sufficiency (ROSS) program

8. Agency form number(s): (if applicable)

HUD-52752, HUD-52753, HUD-52755, HUD-52768, SF-424, HUD-2880, HUD 2991, HUD 2993, HUD-2994A, SF-LLL

9. Keywords:

Housing, public housing, ROSS, supportive services, self-sufficiency, independent living, grant funding, grants.

10. Abstract:

Application for the ROSS Service Coordinator grant program for Public Housing; Eligible applicants are PHAs, Tribes/TDHEs, Non-Profits and Resident Associations. Information collected will be used to evaluate applications and award grants.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.   Individuals or households e.   Farms b.   Business or other for-profit f.   Federal Government c. X 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 benefils c.   Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 350 b. Total annual responses 350 Percentage of these responses collected electronically 100% c. Total annual hours requested 1075.5 d. Current OMB inventory 1907 e. Difference (+,-) -831.5 f. Explanation of difference: 1. Program change: 0 2. Adjustment: -831.5		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs 0 b. Total annual costs (O&M) 0 c. Total annualized cost requested 0 d. Current OMB inventory 0 e. Difference 0 f. Explanation of difference: 1. Program change:       2. Adjustment:      
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. P Application for benefits e.   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 c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennually 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: Tremayne Youmans Phone: 202-402-6621

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, 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 Robert Mulderig, Deputy Assistant Secretary, Office of Public Housing Investments

Date:

Supporting Statement for Paperwork Reduction Act Submissions

1. Justification

1. Section 538 of the Public Housing Reform Act (Pub. L. 105-276, 112 Stat. 2461, approved October 21, 1998) added a new section 34 to the U.S. Housing Act of 1937 which provides a mandate to link supportive services to help public housing residents achieve economic self-sufficiency. The Resident Opportunities and Self-Sufficiency (ROSS) Program responds to this requirement by providing funding to Public Housing Authorities, Tribes/Tribally Designated Housing Entities, resident organizations, and qualified nonprofit organizations to provide supportive services or service coordination to public housing residents.

All applicants to the ROSS program must: have in place a firmly committed match contribution equivalent to 25 percent of the total grant amount requested; provide the sources of their match; indicate their expected outputs and outcomes; provide salary comparability information; and indicate the number of units they will serve.. The ROSS forms help the Department capture this information and evaluate applicants so that HUD can determine if applicants will meet these and other programmatic requirements.

2. The forms will collect information such as the number of Service Coordinators needed, the number of units to be served, the budget for each Service Coordinator, salary comparability information, the total match contribution, and the projected services and outcomes for each grantee. These forms are necessary in order to evaluate applicants’ capacity and eligibility for funding.

3. All applicants, unless granted a waiver, must submit grant applications electronically to HUD via the www.grants.gov web site. This does not necessarily reduce the reporting burden as the information required for submission is the same as that required when paper applications were submitted. Since the forms are electronic, this may also allow for responses to be prepopulated from one form to the other where applicable which may be less burdensome when applicants are completing forms.

3. There is no duplication of information. HUD standard forms used in conjunction with the application process do not ask questions that are specific enough for the program area to evaluate applicants' eligibility, applicants' full capacity, organizational composition, viablility of their proposal, and experience of relevant staff. For this reason, forms specific to the ROSS program have been developed. Without the information gathered in these forms, the Department would not be able to fully evaluate applicants’ capacity to run an effective program and administer federal funds.

5. The information being collected has no significant impact on small businesses or other small entities. All eligible applicants will submit the same forms, certifications, and assurances.     

6. ROSS-specific forms (HUD-52752, HUD-52753, HUD-52755, HUD-52768) are collected on a one-time basis. Less frequent collection is not possible as applicants apply for funding only once a year. This information must be collected to allow HUD to determine qualification for grant funding. Not collecting this information would make it impossible to assess which organizations should receive funding and the funding amount. These forms allow HUD to get a complete picture of each applicant and are a vital tool the Department uses to ensure that funding is awarded as fairly as possible.

Program-Specific Forms	Required For:
HUD-52752 (Cert. with Indian Hsng. Plan)	Tribes/TDHEs for ROSS
HUD-52753 (Cert. Resid. Board Election)	Resident Associations and Non-Profits supported by RAs for ROSS
HUD-52755 (Sample Contract Admin. Partnership Agreement)	All Resident Associations and Troubled PHAs for ROSS
HUD-52768 – ROSS SC Application Form	All ROSS SC Applicants

6. Explain any special circumstance that would cause an information to be collected in a manner:

There are no special circumstances that require the collection to be conducted in a manner which is inconsistent with the guidelines in 5 CFR 1320. The information is collected once a year during the application period and therefore, no other special circumstances exist requiring the collection to be conducted on a more frequent basis.

• Requiring respondents to report to the agency more than quarterly: None. These forms are only used once a year.

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days of receipt of it: None. These forms are only used once a year and applicants are given at least 45 days to respond.

• Requiring respondents to submit more than one original and two copies of any document: Only one copy of documents is required.

• Requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years: Not applicable.

• In connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of the study: Not applicable.

• Requiring the use of statistical data classification that has not been reviewed and approved by OMB: Not applicable.

• 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 Not applicable

• Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate it has instituted procedures to protect the information’s confidentiality to the extent permitted by law. Not applicable.

8. HUD published a Notice of Proposed Information Collection for public comments in the Federal Register, Volume 84; No. 247, page 70986 on December 26, 2019. The public had until February 24, 2020, to submit comments on the proposed information collection. No public comments were received.

9. No payment or gift will be provided to respondents.

1. No assurance of confidentiality is provided. The HUD Reform Act includes specific requirements for the government to make all information regarding applications for HUD assistance available for public inspection, after awardees have been determined and awards made.

The Privacy Act of 1974 (Pub. L. No. 93-579, 88 Stat. 1896, 5 U.S.C. 552a) protects respondents who meet the information reporting requirements.) 

11. The forms do not ask questions of a sensitive nature. This includes the Applicant/Recipient Disclosure/ Update Report (HUD 2880).

12. We estimate the information collection requirements of the ROSS NOFA will have the following reporting burden (please see chart below):

Information Collection	Number of Respondents	Frequency of Response	Total Annual Responses	Burden Hours/ Minutes per Response	Total Annual Burden Hours	Hourly Cost	Total Annual Cost
HUD-52752 (Cert. with Indian Hsng. Plan)	50	1	50	.17	8.5	$0	$0
HUD-52753 (Cert. Resid. Board Election)	100	1	100	.17	17	$0	$0
HUD-52755 (Sample Contract Admin. Partnership Agreement)	100	1	100	0	0	$0	$0
HUD-52768 (ROSS SC Application Form)	350	1	350	3	1050	$0	$0
SF-424 (OMB No: 4040-0004)	350	1	350	0	0	$0	$0
HUD-2880- Applicant Disclosure/ Update Report (OMB No: 2510-0011)	350	1	350	0	0	$0	$0
HUD-2991 – Certification of Consistency with Consolidated Plan (OMB No. 2506-0214)	325	1	325	0	0	$0	$0
HUD-2993 – Acknowledgement of Application Receipt (OMB No: 2577-0259) – Optional Form	5	1	5	0	0	$0	$0
HUD-2994A - You are Our Client (OMB No: 2535-0116) – Optional Form	350	1	350	0	0	$0	$0
SF-LLL-Disclosure of Lobbying Activities (OMB No: 0348-0046)	40	1	40	0	0	$0	$0
Grant Agreement*	150	1	150	N/A	0	$0	$0
Annual Report (InForm Tool) (2501-0034)	150	1	150	2	0	$0	$0
Subtotal (Program Reporting/Recordkeeping)	150	1	150	0	0	$0	$0
Total	350	1	350	Varies	1,075.5	$0	$0

The burden hours were estimated by HUD staff who completed a package of forms. For the ROSS SC program, the burden would be approximately 3.07 hours per application for a total of 1,074.5 hours.

*The Grant Agreement is completed by HUD staff, signed by the recipient of the grant, and returned to HUD electronically. This form is a certification and HUD ascribes no burden to its use.

13. There will be no additional costs to the respondents. Application preparation and submission are part of the regular operation of Housing Authorities, Tribes, nonprofits, and resident organizations.

14. There will be no additional costs to the Federal Government. HUD grant staff receives, processes, reviews and recommends approval/denial of applications for grant funding routinely.

15. This collection package is a revision of a previously approved collection. The Logic Model form is no longer required as part of the application process and burden hours have been reduced from a total of 1,907 to a total of 1,075.5 burden hours.

16. Only the grants awarded and their amounts will be published in the Federal Register as required by the 1989 Reform Act.

17. The OMB approval will be displayed in the grant announcement.

18. There are no exceptions to the certification statement identified in item 19 of the SF 83-i.

2. Collection of Information Employing Statistical Methods

This information will not be collected using statistical methods.

OMB 83-I 10/95