Supporting Statement for Uniform Administrative Requirements for Grantors and Cooperative Agreements to State, Local, and Tribal Governments
A. Justification
Circumstances Making the Collection of Information Necessary
This is a request for a renewal of an existing Information Collection Request (ICR) due to expire July 31, 2009. This ICR authorizes the collection of information under the Department of Health and Human Services’ regulation at 40 CFR Part 92, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments.” This regulation, which implements OMB Circular A-102, includes the management requirements for States, local governments, and Indian Tribal governments. This regulation includes only those provisions mandated by statute or OMB Circulars. On March 12, 1987, the President signed a memorandum directing all affected Executive Departments and agencies to simultaneously issue a common rule that adopts Governmentwide terms and conditions for grants to State and local governments. The common rule sets forth the pre-award, post-award, and after-the-grant requirements. The information requirements have been in OMB Circular A-102 since 1971 and consequently subject to continuing comment by grantees. The legal authority for this information collection is 5 U.S.C 301.
Purpose and Use of Information Collection
The information is necessary because of the information collection and reporting requirements included in HHS regulation 45 CFR Part 92. This regulation implements OMB Circular A-102, and sets forth the pre-award, post-award, and after-the-grant requirements. This information is needed by HHS staff in order to manage the award and administration of assistance awards to State, local and Indian tribal governments.
The information is used to evaluate and select applications for grants, to monitor progress of grantees, to verify compliance with grant conditions, and to closeout accounts.
Use of Improved Information Technology and Burden Reduction
There is no improved technology that would reduce burden. In consideration of Federalism, reporting and recordkeeping is kept to a minimum, especially for State grantees.
States are required to follow the same financial, property and procurement rules and procedures as they would when spending their own State funds. Local and other governmental recipients are required to follow minimum, uniform, generic management standards.
Efforts to Identify Duplication and Use of Similar Information
There is no other source for this information.
Impact on Small Businesses or Other Small Entities
The information requirements do not pertain to small business or other small entities.
Consequences of Collecting the Information Less Frequent Collection
Less frequent collection of this information would make it impossible to account for the uses to which Federal appropriations are put. HHS staff would not be able to oversee the programmatic and financial performance of its assistance awards without this information.
The uniform administrative requirements require respondents to maintain records as required by statute or OMB circulars. The regulation also requires performance and financial reporting on an annual, quarterly or semi-annual basis, as directed by the HHS awarding office. The regulation also requires other financial reports to be used, when necessary, to monitor cash advanced to grantees and to obtain disbursement or outlay information for each grant from grantees. The regulation requires HHS grant recipients to use standard forms prescribed by OMB. Reporting frequency is determined by HHS agencies consistent with their program needs, while placing the minimum burden on grant recipients.
These reporting requirements have been prescribed by OMB through the rulemaking process. HHS cannot reduce the burden, unless directed by OMB, and subsequent rulemaking.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances in this collection. The request fully complies with the regulation
Comments in Response to the Federal Register Notice/Outside Consultation
A 60-day Federal Register Notice was published in the Federal Register on June 29, 2009, vol. 74, No.123; p. 31035. There were no public comments. See Attached 60-day FRN.
All of the basic information requirements under these regulations have already been subject to considerable comment by recipients through OMB’s revisions to OMB Circular A-102 Most of the recipient burden involves completing Federal Standard forms such as the SF-269, SF 272, SF 424, etc. HHS participates in the Grants Policy Committee and its various workgroups that are currently engaged in Government-wide grants streamlining efforts. This activity includes reviewing current administrative requirements and engaging the public through Federal Register notices and public meetings.
Explanation of any Payment/Gift to Respondents
No payments will be made for this collection.
Assurance of Confidentiality Provided to Respondents
No confidentiality is provided; however this collection does not consist of identifiable information.
Justification for Sensitive Questions
No sensitive information is collected.
Estimates of Annualized Burden Burden Hours (Total Hours & Wages)
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 70 hours per grantees
12A. Estimated Annualized Burden Hours
Type of Respondent
|
Number of Respondents |
Number of Responses per Respondent |
Average Burden hours per Response |
Total Burden Hours |
State, local and Tribal Governments |
4,000 |
1 |
70 |
280,000 |
12B. Cost Estimate:
Type of Respondent
|
Total Burden Hours
|
Hourly Wage Rate
|
Total Respondent Costs
|
State, local and Tribal Governments |
280,000 |
$18/ hr |
$5.04M |
Estimates of other Total Annual Cost Burden to Respondents or Recordkeepers/Capital Costs
The collection does not result in additional costs to grantees because the information would be maintained by State and local governments as a result of their own operations. Furthermore, HHS pays grantees the indirect costs resulting from grants.
Annualized Cost to Federal Government
Estimated Federal costs: 4000 grantees x 25 hrs. x $24/hr. = $2.4 million.
Explanation for Program Changes or Adjustments
There is no program change.
Plans for Tabulation and Publication and Project Time Schedule
No publication of results will be made.
Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable.
Exceptions to Certification for Paperwork Reduction Act Submissions
Not applicable.
| File Type | application/msword |
| File Title | How to Write and Submit |
| Author | CMS |
| Last Modified By | DHHS |
| File Modified | 2009-09-09 |
| File Created | 2009-09-09 |