Supporting Statement for Paperwork Reduction Act Submissions
2577-0161
Public Housing, Contracting with Resident-Owned Businesses
A. Justification
1. Why is this 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/authorizing the collection of information.
PHAs that enter contracts with resident-owned businesses prior to December 26, 2014, must comply with the requirements/procedures set forth in, 24 CFR §85.36(h), 24 CFR §85.36(i). Contracts with resident-owned businesses entered after December 26, 2014, must comply with 24 CFR part 963; 2 CFR §200.325, 2 CFR §200.326 and other such contract terms that may be applicable to the procurement under the Department’s regulations.
2. How is the information collected and how is the information to be used?
Within the scope of this information collection, PHAs must collect the following information to determine if the entity is an eligible resident-owned business:
Certified copies of any State, county, or municipal licenses that may be required of the business to engage in the type of business activity for which it was formed. Where applicable, the PHA must obtain a certified copy of its corporate charter or other organizational document that verifies that the business was properly formed in accordance with State law;
Certification that shows the business is owned by residents, disclosure documents that indicate all owners of the business and each owner’s percentage of the business along with sufficient evidence sufficient that demonstrates to the satisfaction of the PHA that the business could perform successfully under the terms and conditions of the proposed contract;
Certification as to the number of contracts awarded, and the dollar amount of each contract award received, under the alternative procurement process; and
Contract award documents, proof of bonding documents, independent cost estimates and comparable price analyses.
3. Describe whether, and to what extent, the collection of information is automated (item 13b1 of OMB form 83-i). If it’s not automated, explain why not. Also describe any other efforts to reduce the burden.
This collection of information does not currently involve use of automated, electronic or other technological collection techniques.
4. Is this information collected elsewhere? If so, why cannot any similar information already available be used or modified.
There is no similar information collected elsewhere. As such, there is no duplication.
5. Does the collection of information impact small businesses or other small entities (item 5 of OMB form 83-i)? Describe any method used to minimize burden.
This information does not impact small businesses. As such, there is no method to minimize the burden.
6. Describe the consequences 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.
If the information is not collected, both the Department and the PHAs will not be in compliance with the regulatory requirements regarding collection of documents specific to contracts entered into with resident-owned businesses.
7. Explain any special circumstances that would cause information to be collected in a manner:
requiring respondents to report information to the agency more than quarterly;
Not Applicable
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Not Applicable
requiring respondents to submit more than an original and two copies of any document;
Not Applicable
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 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.
Not Applicable
8. Identify the date and page number of the Federal Register notice (and provide a copy) soliciting comments on the information. Summarize public comments and describe actions taken by the agency in response to these comments. Describe all the efforts to consult with people outside the agency to obtain them.
HUD published a Notice of Proposed Information Collection for public comments in the Federal Register, Volume [89]; Page [76500] on 09/13/24. The public was given until 11/18/24, to submit comments on the proposed information collection. HUD received no comments on this proposed collection.
9. Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.
No payment or gift will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.
There is no personal, propriety or otherwise sensitive information being collected. PHAs are required to obtain documentation to verify eligibility of the resident-owned business and collect other information related to the contract award itself under the Department’s procurement requirement.
11. Justify any questions of a sensitive nature, such as sexual, religious beliefs, and other matters that are commonly considered private.
This item is not applicable.
12. Estimate public burden: number of respondents, frequency of response, annual hour burden. Read the complete instructions on the form 83i. Explain how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices. Provide a table to describe the elements of the burden. Break out each form used.
Although the Department has an inventory of 3,763 PHAs, the Department estimates that only 2 percent of PHAs contract with resident-owned businesses. The number is thought to be low because there are 1) likely to be very few eligible resident-owned businesses or 2) eligible resident-owned businesses may not have the requisite experience to meet requirements for available PHA procurements. The number of PHAs is less than the previous request due to several PHAs choosing to leave the program. but the Department anticipates there may have been more business or contracting opportunities particularly during the pandemic. The calculation for burden hours is as follows:
Information Collection |
Number of Respondents |
*Average Number of Reponses per Respondent |
Total Annual Responses |
Burden Hours/Minutes per Response |
Total Hours |
Hourly Cost |
Total Annual Cost
|
OMB Control No. 2577-0161 |
75* |
1 |
75 |
24 |
1, 800 |
$30.95 |
$55,710 |
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|
|
|
|
|
|
|
Totals |
75 |
Total Responses: 75 |
Total Hours: 1800 |
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*The Department estimates that out of a total of 3,763 PHAs only 2 percent or 75 PHAs contract with
resident-owned businesses. The calculation is as follows:
75 PHAs x 24 hours = 1,800 hours x $30.95 p/hr. = $55,710.00
**Average PHA salary = $64,5901 per year; $30.95 per hour2
A PHA is required to undertake the following activities under the alternative method of procurement:
Prepare the contract package (8 hours)
Prepare the advertisement (4 hours);
Review the bid documents and award the contract (8 hours);
Conduct follow-up activities as necessary prior to the start date of the work (4 hours)
The allocation of 24 hours per response is based upon the procurement activities reflected above.
13. Estimate of the annual cost to respondents or recordkeepers (do not include the cost of hour burden shown in Items 12 and 14). Read the complete instructions on the form 83i.
Notwithstanding the requirements set forth in the procurement regulations, PHAs already collect and maintain this information. As such, there is no annual cost burden on respondents or record-keepers resulting from this collection of information.
14. Estimate annualized costs to the Federal government.
There is no additional cost to HUD for collection of this information.
15. Explain any program changes or adjustments reported in items 13 and 14 of the OMB Form 83i.
Not Applicable
16. If the information is published, outline plans for tabulation and publication.
The information collected by PHAs will not be published or made available to the public.
17. Explain any request not to display the expiration date.
Not Applicable
18. Explain each exception to the certification statement identified in item 19.
Not Applicable
B. Collections of Information Employing Statistical Methods
2 Computed Hourly Rates of Pay Using the 2,087-Hour Divisor
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OMB-83-I 10/95
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Paperwork Reduction Act Submission |
| Author | WAYNE EDDINS |
| File Modified | 0000-00-00 |
| File Created | 2024-12-24 |