2024_ss_0013_final

SUPPORTING STATEMENT
National Historical Publications and Records Commission (NHPRC) Grant Program
NA Form 17001, NHPRC Budget Form and Instructions and
NA Form 17001a, NHPRC Grant Offer Acknowledgement
OMB Control No. 3095-0013
1. Circumstances making the collection of information necessary. The National Historical
Publications and Records Commission's grant program provides funding to nonprofit
organizations and institutions, state and local government agencies, and Federally
acknowledged or state-recognized Native American tribes or groups, for projects relating to
records that further an understanding and appreciation of American history. We issue grants
for preparing and publishing historical documentary editions, archival preservation and
planning projects, projects increasing accessibility of historical records, and projects
improving the ability of institutions and individuals to care for and make historical records
available for use, including educational programs.
To fulfill its broad mandate, the Commission must ensure the most effective use of the very
limited funds available for grants to preserve the nation's documentary heritage. (Our
competitive grants appropriation for fiscal year 2024 was $10 million.) This requires a
careful analysis of the proposed costs of each grant project in relation to the project's stated
goals and objectives, and in relation to other proposals for similar work.
We need the information from applicants requested in the grant budget form (NA Form
17001) and related documents to determine that applicants are eligible for consideration and
to determine whether we should award a grant. These regulations are contained in 44 U.S.C.
Chapter 25 and amendments, which authorize the Commission's grant program, and 36 CFR
Part 1206, which contains the information collection requirement.
In addition, we need the information recipients provide in NA Form 17001a. After the
Archivist of the United States, as chair of the Commission, recommends a grant for approval,
the prospective grantee must acknowledge the offer of the grant and agree to meet the
requirements of applicable Federal regulations. In addition, they must verify the existence of
an indirect cost agreement with a cognizant Federal agency if they are claiming indirect costs
in the project’s budget. This is done on NA Form 17001a.
2. Purpose and use of the information. In deciding whether to award a grant, we need
information from the applicant to determine if the applicant and its proposed project are
eligible and whether the proposed project is methodologically sound and suitable for support.
Much of this information comes in narrative sections of the grant that applicants learn about
in postings on NHPRC’s announcements on grants.gov. We review the information, along
with expert reviewers, and Commission members, in making decisions to award the grants.
We have found that Standard Form 424A, Budget Information - Non-Construction Programs,
does not provide the level of detail necessary for this purpose, and therefore we use NA Form
17001, NHPRC Budget Form and Instructions, as part of our grant application process.
There are many reasons why it is important for grant applicants to the National Historical
Publications and Records Commission to use NA Form 17001 for their project budgets rather
than the standard Federal budget form, 424A. The chief reason is that we evaluate individual
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line items in the project budgets, rather than object class categories as a whole, during the
decision-making process, in terms of assessing whether they are essential to accomplish the
work of the project. Our appropriation level does not permit us to provide full funding to
many of the projects that we support, while in a few cases the amount of funding offered may
be slightly increased over what is outlined in the proposal budget to ensure the grantee can
accomplish project goals. In making these decisions, rather than simply reducing or
increasing funding a certain percentage or arbitrary amount from the total requested, we
examine individual items requested in relation to the total project work, as well as other
funding available to the grantee. We believe this results in a more cost-effective use of tax
dollars than simply awarding full funding or arbitrarily altered funding, and leads to greater
accountability on the part of the Commission and its grantees, as well as serving as a check
on fraud, waste, and abuse.
3. Use of information technology and burden reduction. Our grant opportunities and grant
application packages are posted to grants.gov and on our web site at www.archives/nhprc.
4. Efforts to identify duplication and use of similar information. This information does not
duplicate similar information.
5. Impact on small businesses or other small entities. We have attempted to minimize the
burden on all respondents, including small entities. In addition, this collection does not have
a significant impact on small businesses.
6. Consequences of collecting the information less frequently. The information cannot be
collected less frequently because the applicants initiate the collection and they determine
whether and how often they request grant funding. We also cannot collect it less frequently
because we must review the individual application for each request. We also do not request
that they modify their budget submissions unless the requestee changes the amount they are
requesting, or if a change in the amount we award from their initial request necessitates it.
7. Special circumstances relating to the guidelines of 5 CFR 1320.5. This information
collection complies with 5 CFR 1320.5. All applicants apply through grants.gov.
8. Comments in response to the Federal Register notice and efforts to consult outside
agency. No formal consultations have taken place with regard to the information collection
itself. However, we regularly consult with state historical records advisory boards, expert
reviewers, and Commission members on the grant application and award processes, forms,
requirements, etc., and make efforts to streamline the process as much as possible in
response. We also published a notice of this information collection in the Federal Register on
May 13, 2024 (89 FR 41476) requesting public comments. We received no comments. In
addition, we also sometimes receive informal comments from applicants and grantees that we
use in future revisions of the information collection.
9. Explanation of any payment or gift to respondents. This information collection involves
no payments or gifts to respondents.
10. Assurance of confidentiality provided to respondents. We do not assure respondents of
confidentiality for information they provide under this collection.
11. Justification for sensitive questions. We do not ask any questions of a sensitive nature.
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12. Estimates of hour burden including annualized hourly costs. We estimate the annual
hour burden on individual respondents to be between 10-17 hours. If they submit an
application, it is about ten hours; if they are a recipient, they may be among the 1/3 of
recipients who need to revise their budget documents, adding about five hours, and they will
also need to complete the offer acknowledgement form, adding another two hours. The total
annual estimate for all respondents would be between 1,440-1,765. The numbers are broken
out in the following table:
Type of
Respondent and
activity

Average
number of
respondents
per year

Applicants:
Gather info and
prepare budget
form, NA Form
17001
Recipients (1/3):
Revise budget
Recipients (all):
Complete and
submit Grant
Offer
Acknowledgment,
NA Form 17001a

Responses
per
respondent
per year

Hours
per
response

Annual hour
burden (all
respondents)

10

1,440

144

25

1

100

5

125

2

200

Est. cost
per hour

Annual
hour cost
per
applicant

$360
$36
(average
for
project
director
and staff)

$180

$72

13. Estimate of other total annual cost burden to respondents or recordkeepers. We do not
require applicants to develop or maintain any operating systems solely for the NHPRC grant;
therefore, there is no additional cost burden.
14. Annualized cost to the Federal Government. We estimate the annual costs to the
Government of handling the information as:
Type of
Government cost
1Review
application budgets
and summarize for
Commission
reports (two per
year)
Review revised
budgets

Cost per hour

Hours per
application
2

$45-$70
(GS-12 and
GS-13
grades)

Number of
applications

Annual cost
$14,800
(based on
averaging the
salary range)

144

Review offer
acknowledgements
3

1

$8,280

.15

1,240

15. Explanation for program changes or adjustments. There is a modest increase in the
annualized cost to the federal government due to recent salary increases for GS-12 and GS13 employees.
16. Plans for tabulation and publication and project time schedule. We do not use the
information we collect for statistical studies or publications.
17. Reason(s) display of OMB expiration date is inappropriate. We display OMB’s approval
expiration date on the form.
18. Exceptions to certification for Paperwork Reduction Act submissions. We are not
requesting any exceptions to the certification statement identified in Item 19 of OMB Form
83-I.

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