We have approved
the paperwork associated with the mandatory meals program for an
additional year, but are concerned at the Department's failure to
ensure that it is authorized to collect this information, which HUD
says is "essential for the effective operation" of the program. In
our previous review in 1989, we expressed concern at the
Department's collection of this information without OMB approval,
and the Department responded that this violation of the Paperwork
Reduction Act was an "oversight." Yet, the Department allowed OMB
approval to expire again on 1/31/90, and did not even subm a
request for OMB review until 6/12/90. We presume that once again
the Department has imposed these requirements without OMB approval.
I should be clear that the Department is not authorized to operate
its programs in violation of the law. If the Department believes
that information is essential, then it shall take the steps
necessary to keep the program operating in compliance with legal
requirements. We note this is only the latest in a string of
expired information collection requirements that have been
submitted for OMB review. When OMB approval expires, the Department
shall immediately cease collectin the information, and shall notify
the affected public. We ask that th Department respond to these
concerns within 30 days.
Inventory as of this Action
Requested
Previously Approved
10/31/1991
10/31/1991
400
0
0
2,000
0
0
0
0
0
FOOD PROGRAMS FOR THE ELDERLY, HOUSING
FOR THE ELDERLY, RENTAL HOUSIN HOUSING PROJECT OWNERS MAY REQUIRE
TENANTS PROGRAM AS A CONDITION OF OCCUPANCY IN PROJECTS EQUIPPED
WITH CENTRAL KITCHEN AND DINING FACILITIES.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.