Instructions

INSTRUCTIONS FOR COMPLETING LIHEAP LEVERAGING REPORT FORMS

The Low Income Home Energy Assistance Act of 1981 (title XXVI of Public Law 97-35, as amended) authorizes a leveraging incentive program, beginning in fiscal year 1992. Under this leveraging incentive program, the Department of Health and Human Services (HHS) allocates supplementary Low Income Home Energy Assistance Program (LIHEAP) funds to LIHEAP grantees that have acquired non-Federal leveraged home energy resources for low income households.

In order to receive leveraging incentive funds under the LIHEAP leveraging incentive program, a LIHEAP grantee must submit to HHS a completed LIHEAP Leveraging Report (Form No. ACF-119). The completed leveraging report forms provide the information HHS needs to meet its statutory obligations in administering the leveraging incentive program. The LIHEAP Leveraging Report consists of the following two parts:

o Resource/Benefit Description Pages (Form No. ACF-119, Part 1)--This two-page form is to be completed for each separate leveraged resource that the grantee proposes to count for the base period. The financial information in item 1 on this form is to be added together for all resources/ benefits and the totals are to be shown on the Summary Page (Part 2 of the Leveraging Report).

o Summary Page (Form No. ACF-119, Part 2)--This one-page form is to show the grand totals for all leveraged resources that the grantee proposes to count for the base period, calculated by adding together the financial information provided in item 1 of the Resource/Benefit Description Pages (Part 1 of the Leveraging Report) for all resources/benefits. It is to show the gross value of these leveraged resources/benefits, any offsetting costs incurred by the grantee to leverage the resources, any offsetting costs imposed on low income households to receive the benefits, and the net value of the leveraged resources/benefits.

In addition, grantees may wish to use the Sample Leveraging Summary Worksheet to calculate the grand totals to be entered on the Summary Page. This sample worksheet is not part of the reporting requirement for the Leveraging Report, however.

Grantees must use HHS' version of the Summary Page. However, if they choose, grantees may submit the information required by the Resource/Benefit Description Pages on their own version of this form, as long as the wording from HHS' printed version of the form is duplicated, and the information is provided in the same order. The Leveraging Report forms are available on our LIHEAP web site at www.acf.hhs.gov/programs/ocs/liheap.

Leveraging Incentive Program Requirements and Guidelines

Requirements and guidelines for countable leveraged resources are set forth in section 2607A of the LIHEAP statute, and in the HHS block grant regulations at 45 CFR (Code of Federal Regulations) 96.87 and the accompanying regulatory preamble language. Requirements and guidelines for leveraging reports are contained in the above documents, in these instructions, and on the LIHEAP leveraging report forms.

Leveraging activities carried out in FY 1995 and earlier years were subject to the requirements of 45 CFR 96.87 as included in the interim final rule published in the Federal Register on January 16, 1992 (57 FR 1960). Leveraging activities carried out in FY 1996 and later years are subject to the requirements of 45 CFR 96.87 as included in the final rule published in the Federal Register on May 1, 1995 (60 FR 21322).

HHS may require submission of additional documentation and/or clarification as it determines necessary to verify information in a grantee's leveraging report, to determine whether a leveraged resource is countable, and/or to determine the net valuation of a resource. In such cases, HHS will set a date by which it must receive information sufficient to document countability and/or valuation.

General Instructions

Submit the original of both parts of the LIHEAP Leveraging Report to HHS. No additional copies need to be submitted. The grantee should keep a copy of the completed Leveraging Report for its files. When filling out the leveraging report forms, type or print legibly in ink.

Provide a response for all items on the forms. If an item is not applicable, enter "not applicable" or "N/A." Enter "-0-" as appropriate. Indicate any numbers that are estimates.

Instructions for Resource/Benefit Description Pages

Complete a Resource/Benefit Description Pages form for each separate leveraged resource/benefit that the grantee proposes to count for the base period. If more space is needed to complete an item, use an additional sheet clearly marked to indicate the resource it applies to, and clearly indicate on the Resource/Benefit Description Pages where the response is continued.

The term "base period" means the Federal fiscal year for which a grantee's leveraging activities are reported to HHS; the grantee's leveraging activities during the base period or base year are the basis for the distribution of leveraging incentive funds during the succeeding fiscal year (the "award period" or award year). The base period is the fiscal year during which the reported resources/ benefits were provided to low income households. For example, leveraging activities occurring during the base period of October 1, 1997, to September 30, 1998--fiscal year 1998--were the basis for making leveraging incentive fund awards during fiscal year 1999, which began on October l, 1998, and ended on September 30, 1999.

There is sometimes a distinction or difference between a resource as it was acquired/obtained, and the benefits that the resource provided to low income households. Resources acquired in the form of cash can be used to provide benefits in the form of certain cash payments, tangible items or goods, and/or services. However, when resources are acquired in the form of discounts, waivers, and/or in-kind contributions, the benefits are essentially the same as the resources. (See the instructions for items 2, 4, and 5 below.)

Grantees have some discretion with regard to counting certain resources and benefits as (or under) one resource or as separate resources. For example, a State might choose to count State funds distributed through the LIHEAP program, and oil overcharge funds distributed through the LIHEAP program, as separate resources. On the other hand, a State might choose to count State funds distributed through the State's LIHEAP program for both heating assistance and energy crisis assistance as one resource. Grantees should count resources/benefits as more than one resource if there is a reasonable possibility that counting them as only one resource will be confusing. If the response to item 13 on this form is different for these resources/benefits, then they must be submitted as separate resources. For example, State funds that were distributed through the State's LIHEAP program and that meet criterion (ii) under item 13 cannot be counted as the same resource as State funds that were not distributed through the LIHEAP program and that meet criterion (iii) under item 13.

Specific instructions follow for each item on this form.

At the top of the first page, enter the grantee's name. Also indicate the base period for which the information is provided, giving the month, day, and year of the beginning and end of the base period. Example: "10/1/99 - 9/30/00" (October 1, 1999, through September 30, 2000).

1. Resource #: Give each separate resource/benefit a number. Number the resources/benefits consecutively, beginning with #1, then #2, etc.

For items 1B, 1C, 1D, and 1E, enter the figure as a whole number rounded to the nearest whole dollar or rounded to the nearest multiple of 10 or 100, or enter "-0-," as appropriate. Example: instead of $100,748.44, enter $100,748, $100,750, or $100,700.

1A. Resource/benefit name: Give each resource/benefit a name by which it can be identified. Each separate resource/benefit is to have a different name. Examples: "State funds used for LIHEAP heating assistance"; "fuel oil price discounts from ABC Company"; "volunteer weatherization services in DEF City."

1B. Gross value of benefits: Enter the total gross value, in dollars, of countable benefits provided by this resource to low income households during this base period. This is the overall value of the countable benefits provided by the resource--before any costs to the grantee to leverage the resource and before any costs to recipient households to receive these benefits are deducted (offset). Determine the value of these benefits in accordance with 45 CFR 96.87(g)(1), (2), (3), and (4) in the HHS block grant regulations. (Item 12 on this form is to explain how this number was calculated.)

1C. Grantee's funds used to leverage resource: Enter the amount of the grantee's own State, tribal, or territorial funds that were used to leverage this resource. This includes grantee funds used to identify, develop, and/or demonstrate this resource. Determine this amount in accordance with 45 CFR 96.87(g)(5). Include only grantee funds whose use resulted in leveraged resources/benefits that have been provided to low income households. Do not include funds from the grantee's regular, Federal LIHEAP allotment under this item.

1D. Costs to recipients: Enter the amount of any costs and charges imposed on and paid by the low income households that received these benefits, in order to participate and/or receive these benefits. Determine this amount in accordance with 45 CFR 96.87(g)(5). (If there were any costs/charges to recipients, explain in item 12 on this form how this number was calculated.) Example: charges paid by low income households in order to receive leveraged fuel or have their homes weatherized by volunteer workers. Do not include costs/charges to households whose benefits are not counted. Do not include nonspecific costs imposed on low income (or other) households, such as costs resulting from an increase in an energy vendor's rates made to support or cover reduced rates for households in special programs.

1E. Net value of countable benefits: To calculate item E, subtract both item C and item D from item B. To do so, subtract item C from item B, and then subtract item D from the number that results from the first calculation: B - C - D = E. Another way to get the same result is to subtract the sum/total of items C and D from item B: B - (C + D) = E.

2. Type of resource: Indicate whether the resource was acquired/obtained in the form of cash, a discount or waiver, or an in-kind contribution--check one or two, as appropriate. Usually, only one of the three types of resource should be checked. However, for example, if leveraged cash was used to buy countable resources/benefits at a discounted price or cost, both "cash" and "discount/waiver" should be checked. Consult 45 CFR 96.87(e) for examples of each type of resource. "Cash" can be in the form of actual cash dollars, checks, electronic payments, etc.

If more than one type of resource is checked, state the gross value of the countable benefits provided by each type. This provides a breakdown of the number in item 1B. Be sure that the sum of these numbers equals the number in item 1B.

3. Source of resource: Name the source of the resource. The source of home energy discounts and waivers is the company or vendor providing the discount or waiver. Examples: "State funds"; "donations by GHI Natural Gas Company's customers and general public"; "JKL Fuel Oil Company."

4. Description of resource: Clearly and succinctly describe this leveraged resource. "Leveraged resource" refers to the resource as it was acquired by the grantee or other agency or entity, in the form of cash, discounts, waivers, or in-kind contributions. Examples: "cash--State funds"; "cash--GHI fuel fund"; "home energy discounts" (low income households paid reduced prices for home energy); "cash and home energy discounts" (a cash resource was used to purchase home energy at a reduced price; the home energy was then provided to low income households); "in-kind contribution--donated weatherization materials." Consult 45 CFR 96.87(b), (d), (e), and (f) for requirements for and examples of countable leveraged resources.

5. Description of benefit(s): Clearly and succinctly describe the benefits that were provided to low income households by this resource during this base period. Benefits are provided in such forms as cash payments for home energy assistance (such as heating assistance), tangible items (such as fuel used for home energy, or weatherization materials), discounts, waivers, and services (such as installation of weatherization materials). Consult 45 CFR 96.87(b), (d), (e), and (f) for requirements for and examples of countable leveraged benefits.

For resources that were acquired in the form of cash, the benefits provided to low income households will be in the form of cash (such as payments for heating assistance), tangible items purchased with the cash (such as wood used for heating, or weatherization materials), or services paid for with the cash (such as installation of weatherization materials). In other words, cash resources sometimes provide cash benefits to recipients, and cash resources sometimes provide non-cash benefits.

For resources acquired in the form of discounts, waivers, and in-kind contributions, the benefits essentially are the same as the resources. In such cases, if the description of this resource under item 4 on this form gives sufficient detail about the benefits provided to low income households by the resource, the grantee might choose to enter "See item 4" under item 5 on this form. Or, the grantee might need to enter additional specific information under item 5 in order to clarify the benefits provided.

Examples: "payments (cash benefits) for heating and energy crisis assistance" (from cash added to the grantee's LIHEAP program); "payments (cash benefits) toward recipients' natural gas bills" (from cash in a fuel fund); "purchase and installation of weatherization materials--specifically, weatherstripping and attic insulation"; "reduced prices for fuel oil for low income customers of JKL Company"; "wood purchased at discounted price and distributed at no cost to low income households"; "wood purchased at regular market price and distributed at no cost to low income households."

6. Geographical area: Name the geographical area in which these benefits were provided to low income households: name the city or cities, the county or counties, and/or the region of the State in which the benefits were provided, or indicate that benefits were provided statewide, as appropriate. Reservation-based tribes may choose to name the reservation and to specify any adjacent area in which the benefits were provided. Examples: "MNO and PQR counties"; "STU Reservation and adjacent area within 10 miles of reservation."

7. Month(s) and year(s): State the month(s) and year(s) when the benefits were provided to low income households during this base period.

8. Number of households: Include only households that received these benefits and that met the standards for LIHEAP income eligibility and/or LIHEAP categorical eligibility as set by section 2605(b)(2) of the Low Income Home Energy Assistance Act of 1981. Benefits that met all statutory and regulatory requirements and were provided to households that met these Federal eligibility standards may be counted even if the grantee's LIHEAP program had lower eligibility standards.

9. Eligibility standard(s): Check the appropriate space(s) to indicate the eligibility standards or requirements for the counted low income households to whom these benefits were provided. If "Other" is checked, specify the standards or requirements. Counted low income households must meet the standards for LIHEAP income eligibility and/or LIHEAP categorical eligibility as set by section 2605(b)(2) of the LIHEAP statute. Example under "Other": "Counted households had income at or below 125% of the poverty level."

10. Administering agency: Name the agency or agencies that administered the resource and provided the benefits to low income households. Examples: "Tribe's LIHEAP program"; "GHI Natural Gas Company and Salvation Army."

11. Data sources: List the sources of the data used to determine the value of this resource and its benefits (item 1B on this form). Also list the sources of the data used to determine any costs to the grantee to leverage this resource (item 1C on this form) and any costs to recipient low income households to receive these benefits (item 1D on this form). Example: "records of VWX Company and State." Grantees are responsible for verifying the accuracy and assuring the ready availability of these data. Per 45 CFR 96.87(h)(3), HHS may require submission of additional documentation and/or clarification as it determines necessary to verify information in a grantee's leveraging report, to determine whether a leveraged resource is countable, and/or to determine the net valuation of a resource.

12. How value was quantified/calculated: Explain clearly and succinctly how the value of the resource/benefits was quantified and how the gross (total) value of the benefits was calculated. Also explain how the value was quantified of any costs/charges to low income households whose benefits are counted, to participate/receive these benefits. In addition, if a discount is involved, state both the reduced rate/price that was actually paid for the resource/benefits, and the fair market value of the resource/benefits. Give sufficient information for HHS to reconstruct the major steps taken in the calculations. Unit costs (for example, fuel oil prices per gallon) should not be rounded. Examples:

• For increased heating assistance benefits--"Benefits of 425 households were increased by $42 each (425 x $42 = $17,850), and benefits of 98 households were increased by $35 each (98 x $35 = $3,430); $17,850 + $3,430 = $21,280 = gross value of countable benefits."

• For fuel oil purchased at a discount with leveraged cash, and distributed at no cost to low income households--"925 gallons of oil; fair market value = $1.18 per gallon. 925 x $1.18 = $1,092 = gross value of countable benefits. Amount actually paid was $971 (925 gallons x $1.05 per gallon). Cash resource = $971. Discount = $121 ($1,092 - $971 = $121)."

• For discount on electricity prices paid by low income households--"Electric company documented amount these households would have paid at regular rate ($75,843) and reduced amount the households actually paid ($68,711). Difference between these figures is amount of discount: $75,843 - $68,711 = $7,132."

13. Criteria met by resource/benefit: In order to qualify under the leveraging incentive program, leveraged resource/benefits must meet at least one of the three criteria in 45 CFR 96.87(d)(2). The first criterion concerns the role of the grantee's LIHEAP program in developing and/or acquiring leveraged resources from energy vendors. The second and third criteria concern the role of the grantee's LIHEAP program in distributing leveraged resources/benefits to low income households. Under the second criterion, benefits are distributed through--as a part of--the grantee's LIHEAP program. Under the third criterion, benefits are distributed as described in the grantee's LIHEAP plan and are integrated and coordinated with the grantee's LIHEAP program, but are not a part of the grantee's LIHEAP program. Check one or two of the three criteria, as appropriate. Criterion (ii) and criterion (iii) cannot both be checked, because they are mutually exclusive: a single, separate leveraged resource/benefit cannot be distributed both within (criterion (ii)), and outside of (criterion (iii)), the grantee's LIHEAP program.

These three criteria are summarized on the Resource/Benefit Description Pages. They are stated in full below:

(i) The grantee's LIHEAP program had an active, substantive role in developing and/or acquiring the resource/benefits from home energy vendor(s) through negotiation, regulation, and/or competitive bid. The actions or efforts of one or more staff of the grantee's LIHEAP program--at the central and/or local level--and/or one or more staff of LIHEAP program subrecipient(s) acting in that capacity, were substantial and significant in obtaining the resource/benefits from the vendor(s).

(ii) The grantee appropriated or mandated the resource/benefits for distribution to low income households through (that is, within and as a part of) its LIHEAP program. The resource/benefits are provided through the grantee's LIHEAP program to low income households eligible under the grantee's LIHEAP standards, in accordance with the LIHEAP statute and regulations and consistent with the grantee's LIHEAP plan and program policies that were in effect during the base period, as if they were provided from the grantee's Federal LIHEAP allotment.

(iii) The grantee appropriated or mandated the resource/benefits for distribution to low income households as described in its LIHEAP plan (referred to in section 2605(c)(1)(A) of Public Law 97-35)(42 U.S.C. 8624 (c)(1)(A)). The resource/benefits are provided to low income households as a supplement and/or alternative to the grantee's LIHEAP program, outside (that is, not through, within, or as a part of) the LIHEAP program. The resource/ benefits are integrated and coordinated with the grantee's LIHEAP program. Before the end of the base period, the plan identifies and describes the resource/benefits, their source(s), and their integration/ coordination with the LIHEAP program. The Department will determine resources/benefits to be integrated and coordinated with the LIHEAP program if they meet at least one of the following eight conditions. If a resource meets at least one of conditions A through F when the grantee's LIHEAP program is operating (and meets all other applicable requirements), the resource also is countable when the LIHEAP program is not operating.

(A) For all households served by the resource, the assistance provided by the resource depends on and is determined by the assistance provided to these households by the grantee’s LIHEAP program in the base period. The resource supplements LIHEAP assistance that was not sufficient to meet households’ home energy needs, and the type and amount of assistance provided by the resource is directly affected by the LIHEAP assistance received by the households.

(B) Receipt of LIHEAP assistance in the base period is necessary to receive assistance from the resource. The resource serves only households that received LIHEAP assistance in the base period.

(C) Ineligibility for the grantee’s LIHEAP program, or denial of LIHEAP assistance in the base period because of unavailability of LIHEAP funds, is necessary to receive assistance from the resource.

(D) For discounts and waivers: eligibility for and/or receipt of assistance under the grantee’s LIHEAP program in the base period, and/or eligibility under the Federal standards set by section 2605(b)(2) of Public Law 97-35 (42 U.S.C. 8624(b)(2)), is necessary to receive the discount or waiver.

(E) During the period when the grantee’s LIHEAP program is operating, staff of the grantee’s LIHEAP program and/or staff assigned to the LIHEAP program by a local LIHEAP administering agency or agencies, and staff assigned to the resource communicate orally and/or in writing about how to meet the home energy needs of specific, individual households. For the duration of the LIHEAP program, this communication takes place before assistance is provided to each household to be served by the resource, unless the applicant for assistance from the resource presents documentation of LIHEAP eligibility and/or the amount of LIHEAP assistance received or to be received.

(F) A written agreement between the grantee’s LIHEAP program or local LIHEAP administering agency, and the agency administering the resource, specifies the following about the resource: eligibility criteria; benefit levels; period of operation; how the LIHEAP program and the resource are integrated/ coordinated; and relationship between LIHEAP eligibility and/or benefit levels, and eligibility and/or benefit levels for the resource. The agreement provides for annual or more frequent reports to be provided to the LIHEAP program by the agency administering the resource.

(G) The resource accepts referrals from the grantee’s LIHEAP program, and as long as the resource has benefits available, it provides assistance to all households that are referred by the LIHEAP program and that meet the resource’s eligibility requirements. Under this condition, only the benefits provided to households referred by the LIHEAP program are countable.

(H) Before the grantee’s LIHEAP heating, cooling, crisis, and/or weatherization assistance component(s) open and/or after the grantee’s LIHEAP heating, cooling, crisis, and/or weatherization assistance component(s) close for the season or for the fiscal year, or before the entire LIHEAP program opens and/or after the entire LIHEAP program closes for the season or for the fiscal year, the resource is made available specifically to fill the gap caused by the absence of the LIHEAP component(s) or program. The resource is not available while the LIHEAP component(s) or program is operating.

14. If criterion (i) is checked in item 13 and the resource has a gross value of $5,000 or more, explain the role the grantee's LIHEAP program played in developing and/or acquiring the resource/benefits from home energy vendor(s), demonstrating that the involvement of the LIHEAP program was active, substantive, and significant. If criterion (i) is not checked in item 13, or if criterion (i) is checked and the gross value of the resource is under $5,000, enter "not applicable" or "N/A" here.

15. If criterion (iii) is checked in item 13, check the "condition(s)" under criterion (iii)--one or more of conditions A through H--that the resource/benefits meet that demonstrate that they were integrated and coordinated with the grantee's LIHEAP program. In order to be counted under criterion (iii), the resource/benefits must meet at least one of these eight conditions.

If criterion (iii) is checked in item 13 and the resource has a gross value of $5,000 or more, explain how the resource/benefits were integrated and coordinated with the grantee's LIHEAP program. If criterion (iii) is not checked in item 13, or if criterion (iii) is checked and the gross value of the resource is under $5,000, enter "not applicable" or "N/A" here.

Instructions for Summary Page

At the top of the page, enter the grantee's name, the address to which HHS should send any correspondence relating to this Leveraging Report, and the name and telephone number (including area code) of a knowledgeable person HHS may contact about the report. HHS will send LIHEAP leveraging incentive fund grant awards to the same address to which it sends each grantee's regular LIHEAP grant awards, unless a grantee specifies that a different address should be used for its leveraging incentive fund award.

Indicate the base period for which the information is provided, giving the month, day, and year of the beginning and end of the base period.

Under item A in the table on the Summary Page, indicate the total number of leveraged resources that the grantee proposes to count for this base period. To calculate the numbers to enter under items B, C, D, and E in this table, add the figures for items B, C, D, and E that are contained in item 1 of each of the Resource/Benefit Description Pages (Part 1 of the Leveraging Report). Then enter these grand totals in the appropriate spaces on the Summary Page. Enter the amounts in items B through G as whole dollars, or enter "-0-," as appropriate. Be sure that the numbers entered on the Summary Page calculate correctly within this table--that, in this table, B minus C minus D equals E.

Under item F, include all funds from the grantee's Federal LIHEAP allotment that were obligated during this base period specifically to identify, develop, and demonstrate leveraging programs--whether or not there were or are any resulting leveraged benefits. Include funds from regular and supplemental LIHEAP appropriations, with the exception of leveraging incentive funds provided under section 2602(d) of the LIHEAP statute. Determine this amount in accordance with 45 CFR 96.87(c) and (g)(5). Exclude the grantee's own funds used to leverage resources under this item.

To calculate item G, subtract item F from item E: E - F = G.

At the bottom of the page, obtain the signature of the grantee's chief executive officer or designee, and indicate the signer's title and the date of signature. If the Summary Page is signed by a designee, rather than by the chief executive officer, and HHS does not already have on file documentation of the delegation, then such documentation must be included as part of the Leveraging Report.

Sample Leveraging Summary Worksheet

Grantees whose leveraging reports include two or more leveraged resources will need to add the numbers they have entered in items B, C, D, and E under item 1 of the Resource/Benefit Description Pages (Part 1 of the Leveraging Report) for all of the resources, in order to calculate the grand totals to enter under the corresponding items B, C, D, and E of the Summary Page (Part 2 of the Leveraging Report). Grantees may find it helpful to use the Sample Leveraging Summary Worksheet when calculating these totals. This will help to assure that the grantee neither omits nor double-counts any resources, and that the totals are calculated correctly. The sample worksheet is not part of the reporting requirement for the Leveraging Report, however, and grantees will not be penalized if they do not submit it to HHS.

If a grantee chooses to use the Sample Leveraging Summary Worksheet, it would use the same resource numbers in this worksheet as it used in the Resource/Benefit Description Pages. It would list each resource/benefit sequentially until all are included on the worksheet, and it would enter the information from item 1 of the Resource/Benefit Description Pages in the appropriate columns on the worksheet. The worksheet provides space for information on ten leveraged resources. The number of worksheet pages needed would vary according to the number of leveraged resources that the grantee proposes to count for the base period. The grantee would add the columns for items B, C, D, and E on each worksheet page to provide subtotals for that page, taking care to ensure that the totals are correct when the numbers are calculated both vertically and horizontally. The grantee then would add the subtotals to provide the grand totals to be entered on the Summary Page.

Grantees may wish to prepare such a summary worksheet on their own computer spread sheets. Such a worksheet, of course, could contain more than ten resources/benefits per page.

Paperwork Reduction Act of 1995 Information

This information collection is conducted in accordance with the Low Income Home Energy Assistance Act of 1981 (title XXVI of Public Law 97-35, as amended) and 45 CFR 96.87. This collection provides the information that a LIHEAP grantee must submit as part of a LIHEAP leveraging incentive fund application if it wishes to receive a leveraging incentive grant award. Public reporting burden for this collection of information is estimated to average 38 hours per response, including the time for reviewing instructions, gathering and maintaining the data needed, and preparing the leveraging incentive grant application.

This information is not considered confidential; therefore, no additional safeguards are considered necessary beyond those customarily applied to routine government information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

Minor updates 8/99