Final Supporting Statement

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION

State Assistance Management System (SAMS) Domestic

Results Monitoring Module &

NEA/AC Online Performance Reporting System (ACPRS)

OMB Number 1405- 0183, Form DS-4127

A. JUSTIFICATION

1. Why is this collection necessary and what are the legal statutes that allow this?

The President of the United States has the authority, under 22 U.S.C. § 2395(b) (Section 635(b) of the Foreign Assistance Act of 1961), to give grants to individuals, governments, businesses, and other organizations in furtherance of the Foreign Assistance Act. Executive Order 12163 delegates this authority to the Secretary of State.

The Department of State provides funding to U.S. and foreign organizations in the form of grants and cooperative agreements to support U.S. foreign policy goals. Recipient organizations are primarily non-governmental organizations (NGOs), institutions of higher education, international organizations, and other federal agencies. In a few instances, commercial firms are also grant recipients.

As a normal course of business and in compliance with Office of Management and Budget (OMB) Guidelines contained in 2 C.F.R. § 200, recipient organizations are required to provide, and the U.S. State Department required to collect, periodic program and financial performance reports. The responsibility of the State Department to track and monitor the programmatic and financial performance necessitates a database that can facilitate this in a consistent and standardized manner.

2. What business purpose is the information gathered going to be used for?

The responsibility of the Department to track and monitor the programmatic and financial performance necessitates a database that can help facilitate this in a consistent and standardized manner. The SAMS Domestic Results Monitoring Module and NEA/AC Performance Reporting System (ACPRS) enables enhanced monitoring and evaluation of grants through standardized collection and storage of relevant award elements, such as quarterly progress reports, workplans, results monitoring plans, grant agreements, and other business information related to Department of State implementers. The SAMS Domestic Results Monitoring Module and ACPRS streamlines communication with implementers and allows for rapid identification of information gaps for specific projects.

Representatives of each grantee organization enter their required performance report information on a quarterly basis through a password protected website. Using a standard quarterly reporting template, grantees report against the established objectives and performance indicators of the projects. The major workplan activities are automatically listed in the report and enable grantee organizations to easily notify the State Department of progress, delays and requested changes to the workplan.

Each grantee organization can also submit relevant supporting documentation as attachments, including the OMB-required SF-425 financial status report.

ACPRS is currently in the process of being phased out and awards are being transitioned into the SAMS Domestic system. While some information is still being collected in ACPRS, no awards created in 2019 are being monitored and evaluated through this system.

3. Is this collection able to be completed electronically (e.g. through a website or application)?

This collection of information is completely electronic, but a paper version of the information collection is available for organizations that are unable to submit their reports online. Nonetheless, quarterly reports that are submitted outside of the system are uploaded to the system in order to ensure quarterly reports are accessible to all relevant State Department officials in Washington, D.C. and overseas. At this time, 95% of U.S.-based grantees are using the electronic submission method.

4. Does this collection duplicate any other collection of information?

The information in SAMS Domestic and ACPRS is not duplicative of information maintained elsewhere or otherwise available. While hardcopy versions of all quarterly reports are saved in the official grant files, there is not an existing system of electronic record keeping for these reports. In addition, the standardized format and cumulative results reporting features make SAMS Domestic unique.

5. Describe any impacts on small business.

This collection does not have a significant impact on small businesses.

6. What are the consequences if this collection is not done?

OMB regulations require that grantees provide regular progress reports during the period of performance (See Item 1). The use of the SAMS Domestic Results Monitoring Module serves to streamline the process for grantees and to improve monitoring and evaluation capabilities of the U.S. Department of State. Bureaus’ ability to effectively assess the performance of individual projects and a broader portfolio of programs necessitates standardized reporting in an electronic format.

7. Are there any special collection circumstances?

No such circumstances exist.

8. Document publication (or intent to publish) a request for public comments in the Federal Register

The Department published Notice on April 7, 2020 (85 FR 19566), and received six public comments during the 60-day comment period. These comments were unrelated to the SAMS Results Performance Monitoring (RPM) or NEA/AC Online Performance Reporting System (ACPRS) functionality.

9. Are payments or gifts given to the respondents?

No payment or gift is provided to respondents.

10. Describe assurances of privacy/confidentiality

There are no assurances of confidentiality given to respondents.

11. Are any questions of a sensitive nature asked?

No questions of a sensitive nature are asked.

12. Describe the hour time burden and the hour cost burden on the respondent needed to complete this collection

It is estimated that writing a quarterly report, whether through the SAMS Domestic/ACPRS system or not, takes each implementer an average of 20 hours per report. (This ranges anywhere from 4 to 40 hours, depending on the size of the project; larger projects require more extensive information gathering and analysis. Also, some organizations have multiple rounds of editing and review, while others do not.) NEA/AC estimates that an average of 240 grantees per year will report quarterly through SAMS domestic. The average annual burden for reporting via SAMS Domestic is 19,200 hours (20 hours per report x 4 reports per year x 240 grantees).¹

The total hour cost burden for this collection is $773,760 ($40.30 x 19,200). The hour cost was calculated using the Bureau of Labor Statistics (www.bls.gov) wage rate for an Information and Record Clerk.² The mean hourly wage rate for this occupation in all industries is $20.15. To account for overhead costs such as rent, utilities, and office equipment the mean hourly wage was multiplied by 2. which is the Employment Cost Index for total compensation for December 2019.³ Therefore the actual wage rate is 20.15 X 2= $40.30.

13. Describe the monetary burden to respondents (out of pocket costs) needed to complete this collection.

The collection imposes no additional capital costs or operation and maintenance costs on respondents.

14. Describe the cost incurred by the Federal Government to complete this collection.

The estimated cost burden to the federal government for ACPRS is $ 32,912 (rounded) per year. This cost was calculated based off the contract with Pillar Systems Corporation in which the Federal government pays for the maintenance and support for ACPRS.⁴

15. Explain any changes/adjustments to this collection since the previous submission

There are no changes since the last submission.

16. Specify if the data gathered by this collection will be published.

Information collected from these progress reports is not intended for publication, though bureaus may highlight results from specific projects in published reports in the future. If results of a specific project are published, the grantee organization will be consulted to confirm the results.

Quarterly report information is used by the State Department to monitor and evaluate the performance of its programs. The information is used to evaluate current projects, assess future programming needs and maximize the effective use of resources. While primarily for internal use, information from these quarterly reports may be shared in part or whole with non-State Department stakeholders such as the U.S. Congress.

17. If applicable, explain the reason(s) for seeking approval to not display the OMB expiration date.

The OMB approval information and expiration date for this collection will be displayed.

18. Explain any exceptions to the OMB certification statement below.

No exceptions are being requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

1 Source: 2017 OMB Number 1405- 0183, Form DS-4127 Supporting Statement For
Paperwork Reduction Act Submission

2 Source: Occupational Employment and Wages, May 2018 43-4199 Information and Record Clerks, All Other, https://www.bls.gov/oes/2018/may/oes434199.htm#st

3 Source: Table 4. Compensation (not seasonally adjusted): Employment Cost Index for total compensation, for civilian workers, by occupational group and industry, https://www.bls.gov/news.release/eci.t04.htm

4 Source: Amounts provided by Contracting Officer Representative Rhonda Brathwaite