Tribe Supporting Statement

Supporting Statement for Paperwork Reduction Act Submissions

Tribal Housing and Urban Development Veteran Administration Supportive Housing Program

OMB No: 2577-NEW

A. Justification

1. Explain the circumstances that make the collection of 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 or authorizing the collection of information.

The Tribal HUD-VA Supportive Housing (Tribal HUD-VASH) Program provides rental assistance and supportive services to Native American veterans who are homeless or at risk of homelessness in Indian country. Housing assistance under this program is made available by grants to Tribes and Tribally Designated Housing Entities (TDHEs) that are eligible to receive Indian Housing Block Grant (IHBG) funding under the Native American Housing Assistance and Self-Determination Act of 1996 (25 U.S.C. 4101 et seq.) (NAHASDA). Grants and renewal funds are awarded based on the number of rental units (Tenant-Based and Project-Based Rental Assistance) approved by HUD. Grants include an additional amount for administrative costs and eligible homeless veterans receive case management services through the Department of Veterans Affairs.

Attached are the relevant excerpts from the Consolidated and Further Continuing Appropriations Act, 2015 (Pub. L. 113-235, Title II), the Consolidated Appropriations Act, 2017 (P.L. 115-31), the Consolidated Appropriations Act, 2018, P.L. 115-141, the Consolidated Appropriations Act, 2019, P. L. 116-6, the Consolidated Appropriations Act, 2020, P.L. 116-94, the Consolidated Appropriations Act, 2021, P. L. 116-260, the Consolidated Appropriations Act, 2022, P.L. 117-103, and the Consolidated Appropriations Act, 2023 P. L. 117-328.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Tribal HUD-VASH Family Report form will record and gather information from Tribal HUD-VASH grantees on household demographic, personal, and rental information as required for the Tribal HUD-VASH program. The tribes/TDHEs record information about families assisted in their program, including lease start and end date, rental assistance type, property size, number of bedrooms, and rental assistance payments.

Application and Renewal of the Grant Information required for the Program:

The application materials are listed below.

1. Cover Letter: The tribe/TDHE must submit a one-page cover letter on the organization’s letterhead identifying the point of contact and their contact information, and an authorized representative signature.

2. Tribal Resolution (if applicable): Grantees must have a currently applicable Tribal resolution authorizing participation in the Tribal HUD-VASH program. For renewal applications, the cover letter can certify that the existing resolution is still in effect. New applications must submit the resolution with their application letter.

3. Program Update and Overview: The grantee must report how it has utilized its current funding to administer the demonstration program, including the grantee’s progress towards meeting the program’s goals, current and projected program enrollment, challenges faced, measures taken to address issues, conducting interim/annual reexaminations, and the grantee’s community involvement strategies.

4. Renewal Funding Information: A completed Renewal Funding Table as provided by HUD-ONAP.

5. Tribal HUD-VASH application and reporting materials as issued in the Federal Register Notice, “Implementation of the Tribal HUD-VA Supportive Housing Program” (FR 6091-N-01) or future notices.

6. Renewal Application Program Update and Overview: Grantees have the opportunity to submit a renewal application annually. The application reviews information reported by the Tribes or THDE’s that outlines their progress in housing Native American veterans who are homeless or at risk of homelessness. This application must include how they have utilized their current funding to administer the program. They also must identify their current and projected program enrollment, any challenges they have incurred and how they have addressed those obstacles. The Tribe or TDHE must also engage their community through their selected strategies to hear any comments or concerns regarding the renewal process.

7. Renewal funding criteria established in PIH Notice 2018-10, “Procedural Guidance for Tribal HUD-VA Supportive Housing Renewal Grant Applications.”: A completed Tribal HUD-VASH Family Report. The Excel spreadsheet collects information about lease dates, type of assistance, rent amount, source of funds, and veteran status.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden (item 13b1 of OMB form 83-i).

HUD is developing the Housing Information Portal (HIP) to replace the Inventory Management System/PIH Information Center (PIC/IMS) to collect information for the Tribal HUD-VASH Family Report online.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

There is no duplication of the subject information. 

5. Does the collection of information impact small businesses or other small entities (item 5 of OMB form 83-i)? Describe any methods used to minimize burden.

Very few small entities are impacted.

6. Describe the consequence 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.

Information is collected to meet requirements of the law and used to award funds to end homelessness among veteran Native Americans.

1. Explain any special circumstances that would cause an 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 secret, 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. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

• Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.

• Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.

HUD published a Notice of Proposed Information Collection for public comments in the Federal Register, Volume 88; Number 201; Page 72096 on October 19, 2023. No public comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.

No payments or gifts to respondents are provided.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

Personal identifiable information is covered under the Privacy Act of 1974 (U.S.C. 552a). 

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. Not Applicable

12. Provide estimates of the hour burden of the collection of information. The statement should: * Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Read the complete instructions on the form 83i.

The equivalent wage rate in Tribal governments and TDHEs is a GS 9 = $23.49

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
Tribal HUD VASH Family Report	35	25	875	90 minutes	1312.50	$23.49	$30,839.63
Tribal HUD VASH Application/Renewal Materials	35	1	35	480 minutes	280	23.49	6,577.20
Totals	70		910		1592.50		37,416.83

*Average Number of Responses per Respondent = Total Annual Responses / Number of Respondents

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.

There is no start-up or equipment costs.

14. Estimate annualized costs to the Federal government.

The estimated annualized cost to the Federal Government is based on the hourly rate of $51.15, of the 2023 General Pay Scale for a GS 12 Step 5, which represents the staff of HUD’s Office of Native American Programs (ONAP) Field and Headquarters staff. ONAP estimates that staff annually spend 284 hours on these documents. 284 hours per year X $51.15 = $14,526.60.

There is no additional cost to the Government related to reviewing these documents.

15. Explain any program changes or adjustments reported in items 13 and 14 of the OMB Form 83i.

This is a new collection.

16. If the information will be published, outline plans for tabulation and publication.

Not applicable

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

HUD is not seeking approval to avoid displaying the OMB expiration date.

18. Explain each exception to the certification statement identified in item 19.

Not Applicable, since statistical methods are not used.

B. Collections of Information Employing Statistical Methods