Supporting Statement A. Justification: IMLS Native American Library Services Enhancement Grants Program Notice of Funding Opportunity, OMB Control Number 3137-0110
Necessity of the Information Collection
The Institute of Museum and Library Services (IMLS) requests renewal of the clearance for the IMLS Native American Library Services Enhancement Grants Notice of Funding Opportunity under the Paperwork Reduction Act. The information collection in this package consists of one Notice of Funding Opportunity (NOFO) with instructions necessary to apply for IMLS support as part of the agency’s grant programs.
Background:
Application Notices of Funding Opportunities: IMLS uses an iterative review process for each set of NOFOs in every fiscal year. The process is defined in IMLS’s Grants Administration Manual, and it is designed to ensure that key stakeholders and agency officials review and authorize proposed Notices. For each round of NOFO production for clearance, text common to all IMLS grant program applications is reviewed and adjusted as necessary to provide consistent information and language across all program documents. IMLS complies with the Plain Writing Act of 2010 to provide “clear government communication that the public can understand and use.” IMLS is committed to writing new documents in plain language, using the Federal Plain Language Guidelines.
Purposes and Uses of the Data
The information collected through the NOFO will be used by IMLS staff to validate applicant eligibility, identify and assign peer reviewers, manage the grant competition, award discretionary grants, and to administer and monitor awards. It will also be used by the agency for strategic planning, performance analysis, and to provide information to the Administration and to Congress. Data elements subject to FOIA also provide information about grant applications and programs to individuals outside the agency, and they may be used by applicants to validate their project ideas or application strategies, to follow trends in their fields, and to identify effective practice that can be widely adapted to improve the quality of museum and library services in the United States. IMLS intends to make final performance reports available via its website and so informs awardees.
Use of Information Technology
IMLS is committed to the use of improved information technology to maximize the efficiency and effectiveness of its programs, while reducing burden on potential applicants. All information collected through this NOFO will be submitted through Grants.gov. The data provided by applicants will be automatically ingested into eGMS, the agency’s electronic grants management system, through a system-to-system interface, thus saving many hours of data entry time.
All submitted proposals and associated correspondence and documents will be stored in eGMS as the permanent record of the application, including associated peer reviews.
Efforts to Identify Duplication
All IMLS grant application NOFOs and publications are annually reviewed through an internal clearance process, which requires review by several different offices within the agency, including the program offices, the Office of General Counsel, and the Office of Grants Policy and Management. This annual review process protects against duplication. This NOFO does not duplicate any other collection being conducted by IMLS, nor are we aware of any other information collections that support the administration of a similar program of this scope and intent.
Method Used to Minimize Burden on Small Businesses
Participation is entirely voluntary. No small businesses are impacted, but some applicants for IMLS funding are from small nonprofit organizations. Every effort has been made to streamline processes and instructions and to simplify the application and reporting processes. The agency’s internal clearance process ensures that no undue burden is placed on any applicant for IMLS funding.
Consequences of Less Frequent Data Collection
This collection of information is essential to IMLS in meeting its statutory mission to award federal financial assistance and to facilitate the delivery of significant results consistent with the IMLS federal authorizing legislation (20 U.S.C. § 9101 et seq. in particular, § 9161 (Services for Native Americans) and its obligations to identify needs and trends in museum, library, and information service.
Special Circumstances
The proposed data collection activities are consistent with the guidelines set forth in 5 CFR 1320.6 (Controlling Paperwork Burden on the Public-General Information Collection Guidelines). There are no special circumstances that require deviation from these guidelines.
Consultations Outside the Agency
The 60-day Federal Register Notice for this Notice of Funding Opportunity was published in the Federal Register (88 FR 57134-57135) on August 22, 2023. The agency received no public comments under this Notice. A 30-day notice requesting comment was published in the Federal Register 88 FR 76260-76261, November 06, 2023.
IMLS routinely uses several different mechanisms to consult with persons outside the agency about its grant-making. Contact information for program officers is widely distributed and easily accessible from the IMLS website, and awardees and potential applicants are encouraged to communicate frequently with these experts. In addition, program officers convene nationwide conference calls and webinars to answer questions and take input. IMLS program staff also travel to national, regional, and local meetings of potential applicants to discuss program requirements. Over the last three years, IMLS has hosted a series of Nation-to-Nation Listening Sessions with tribal representatives to seek recommendations for how best to meet the needs of Indigenous communities through its grant-making.
Finally, IMLS consistently notes and evaluates suggestions for revising its NOFOs and reporting forms received from applicants responding to the invitation for comments found in the burden statement contained in each information collection. Efforts are continually made to shorten and simplify application instructions and forms in response to suggestions made by respondents.
Payments or Gifts to Respondents
No payments or gifts are provided to any of the respondents.
Assurance of Confidentiality
No assurance of confidentiality is provided. Grant files are subject to FOIA request and are handled on a case-by-case basis. IMLS intends to make final grant reports available via its website and so informs awardees.
Justification for Sensitive Questions
There are no questions of a sensitive nature.
Estimate of Hour Burden to Respondents
The estimated number of respondents to this Notice of Funding Opportunity is 35. This number has been estimated on the number of applications in previous years and on informal assessments of interest in the program. The estimated number of total burden hours is 1,400, calculated at 40 respondents spending 35 hours each per application to review instructions, search existing data sources, gather and maintain the data needed, and complete and review the narrative components of the application.
Estimate of Cost Burden to Respondents
The estimated cost to applicants is $40,992, representing 1,400 hours at an average cost per hour of $29.28, based on the Bureau of Labor Statistics average mean hourly wage of Archivists, Curators, and Museum Technicians.
The two cost components for total capital/start-up and operation/maintenance/purchase of services are not applicable.
Estimate of Costs to Federal Government
The annualized cost to IMLS is estimated at $1,744. The agency expects to receive 40 applications. Reflecting the auto-ingestion of application data from Grants.gov via a system-to-system interface, approximately 1 hour at a mean hourly wage of $43.59 will spent by IMLS staff reviewing and processing each response.
Explanation of Change in Burden
There is no change in burden over previous years.
Statistical Usage
Not applicable.
Request to Not Display Expiration Date
We are not requesting an exemption from the requirements to display the expiration date for OMB approval. All data collection materials and documentation will include the OMB approval number and expiration date.
Exception to Certification Statement
No exceptions to the certification statement apply to this program.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Generic Clearance Request 97 [doc] |
| Author | sdaisey |
| File Modified | 0000-00-00 |
| File Created | 2024-11-30 |