omb477justif6-11-07rev.

omb477justif6-11-07rev..doc

A Reporting System for P.L. 102-477 Demonstration Project

OMB: 1076-0135

Document [doc]
Download: doc | pdf

Supporting Statement for Paperwork Reduction Act Submissions

A Reporting System for Pub. L. 102-477 Demonstration Project

OMB Control Number 1076-0135


Terms of Clearance: None.


General Instructions


A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 of the OMB Form 83-I is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.


Specific Instructions


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.


Public Law 102-477 authorizes tribal governments to integrate federally funded employment, training and related services programs into a single, coordinated, comprehensive delivery plan. The goal of the legislation is to reduce unemployment, improve services, and reduce administrative costs. The programs under the responsibility of the Secretary of the Interior, Secretary of Labor, and Secretary of Health and Human Services are all included within this authorization. The Bureau of Indian Affairs, (BIA) is legislatively required to serve as lead agency. A copy of the relevant statute is attached.


Section 11 of this Act, “Federal Responsibilities,” and sub-parts (a)(1) and (2) require the Secretary of the Interior to make available a single universal report format which shall be used by a tribal government to report on integrated activities undertaken within their project. It also requires that the Secretary make available a single universal report format related to the projected expenditures for the individual project which shall be used by the tribal government to report on all project expenditures.


These universal single page, one-sided report forms and the narrative with a total of six pages, (due annually) replaces 166 pages of instructions and applications representing three (3) different agencies and eleven (11) differently funded but related programs. Most of these eleven different program reports were completed quarterly. This 95% reduction in the number of reports and the reduced size of the required reports is consistent with the Paperwork Reduction Act and consistent with the National Performance Review.



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. [Be specific. If this collection is a form or a questionnaire, every question needs to be justified.]


(a.) The statistical report will be used to demonstrate how well a tribal plan was executed in comparison to its proposed goals. This one page, single sided, universal report form satisfies the very basic statutory requirements for the three participating federal agencies. It will help the funding agencies determine the quality of the employment, training, child care and related services provided to individual participants in the program. It will help determine the level of program activity in which the tribes are engaged. In accordance with standard regulations governing the administration of grants, the Common Rule, certain sanctions will be imposed on grantees if they do not report thoroughly and timely.


These reports are subdivided into three components. The statistical report identifies the number of participants enrolled in the program, the number that successfully completed the program, those that were not successful, the characteristics and barriers to employment faced by participants and the types of activities and services the participant received while enrolled. This information helps to determine the success of current employment and training programs.


(b) The financial status report is used to track cash flow, compare program activity with expenditures, compare general expenditures with approved intent and budget and to avoid over expenditures and identify savings. The form is a slightly modified SF-269A (short form). An addendum is added to the standard form to seek assurances required by the Job Training Partnership Act, as amended. This report will identify the tribes applying for grants, the period of operation, and total resources committed to the plan. The form includes a “previously reported” column, a “current expenditures” (this period) column and a “cumulative” column. This report is acceptable to all the participating federal agencies.


(c) The Narrative Report allows tribes to go beyond numbers and report goals and objectives against accomplishments and describe problems or unmet needs toward addressing employment and training issues.


We have deleted the requirement for grantees to report on child care during non-traditional hours, (e.g., nights, weekends and work related child care that is for 24 hours or more). The Administration for Children and Families, Child Care Bureau does not collect this data for other grantees and have determined that at this time, the extra information is not needed.


We have also clarified that grantees should report the type of child care provided (e.g., center-based care, group home care, family home care and care in the child’s own home) by the number of children receiving care. Previously, some respondents were reporting this data by number of families and other respondents were reporting this data by number of children resulting in inconsistent data elements.


The forms were developed by all three participating Federal agencies and directly in collaborative efforts with tribes. The agencies use all of the above data collected to ensure statutory compliance, report to the Congress, the Office of Management and Budget, and to report to the respective agency administration. These reports may include a discussion of the use of funds, activities engaged in by tribes and the extent to which tribes are successful. The goal of the program is to find unsubsidized employment for Indians either through direct referrals or assisted through training, education and other supportive services such as child care.



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 [and specifically how this collection meets GPEA requirements.].


During December 2001, Indian Affairs (IA) was forced to disconnect from the internet by a court order issued by the judge in the Cobell litigation. Hence, IA cannot implement GPEA until reconnection to the internet is completed.


The reports were designed to provide tribes the opportunity to collect, maintain and report the data using technological collection techniques. Some tribes have automated the data to such an extent that they are able to meet their own day-to-day needs, (i.e., identify candidates for employment meeting specific qualifications while meeting with prospective employers), as well as complete the annual reports. The use of technology at the tribal level depends upon the extent to which each tribe has developed an integrated intake and reporting system.


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.


While three different federal agencies representing eleven different programs do collect the information, comprising an estimated 166 pages of reports and instructions annually, we have consolidated that into one set of forms including seven (7) pages annually through this reporting mechanism. Terms used in the reports have been standardized among the three federal agencies. Duplication has been eliminated.


5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.


Tribal entities worked with the federal agencies to develop a streamlined plan that met everyone’s needs and avoided duplication as cited in paragraph 3 of number 1 and reiterated in number 4.


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.


Grant funds are dependent upon filing the necessary reports. If the reports are not completed annually by the grantee, additional payments to the grantee will not be made. Once reports are submitted, payments will resume.


7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* requiring respondents to report information to the agency more often than quarterly;

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* requiring respondents to submit more than an original and two copies of any document;

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* 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

* requiring respondents to submit proprietary trade secrets, 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. Regulatory compliance indicates annual reports are sufficient; tribes control the content of the information and normally do not deal in sensitive information when compiling this report. Any copies needed by other agencies are made by the Bureau.


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 in response to the PRA statement associated with the collection over the past three years] 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 on the data elements to be recorded, disclosed, or reported.


The following Federal partners to this initiative were consulted on the review of these forms:


Ms. Ann Bowker, Native Employment Works Program Specialist,

Department of Health and Human Services, Administration of Children and Families

370 L’ Enfant Promonade, Aerospace Bldg.

Washington, DC 20447

(202) 401-5308


Mr. Ray Apodaca and Mr. Ray Shelbourne

Temporary Assistance to Needy Families

Department of Health and Human Services, Administration for Children and Families

370 L’Enfant Promenade, Aerospace Bldg.

Washington, D.C. 20447


Ms. Evangeline Campbell, ICWA Specialist

DOI/OTS, Division of Human Services

1849 C. Street, NW, MS-4513-MIB

Washington, DC 20240

(202) 513-7623


Ms. Dawn Anderson

Department of Labor

Division of Indian and Native American Programs,

Washington, D.C.


Mr. Chris Redman

Office of Indian Education

Department of the Interior

Washington, D.C.


We have also met with and consulted with Pub. L. 102-477 Tribal Work Group during the past 12 months. The revised forms were on the agenda each time. The group consists of:


  1. Aleutian Pribilof Island Association

Mr. Ken Selby

201 E. 3rd Avenue

Anchorage, Alaska 99501

Telephone: (907) 276-2700 Fax: 907-279-4351


  1. Association of Village Council Presidents

Mr. John Owens

P.O. Box 219

Bethel, Alaska 99559

Telephone: (907) 543-7321 Fax: (907) 543-3569

1-800-478-3921 extension-7300


  1. Bristol Bay Native Association

Mr. Mark Hiratsuka

P.O. Box 310

Dillingham, Alaska 99576

Telephone Number (907) 842-2262 Fax: (907) 842-5932


  1. Chugachmiut

Mr. Tim Anderson

4201 Tudor Center Drive, Suite 210

Anchorage, Alaska 99508

Telephone: (907) 562-4155 Fax: (907)- 563-2891


  1. Citizen Potawatomi Tribe

Ms. Carol Levi (Margaret Zientek)

1901 S. Gordon Cooper Drive

Shawnee, Oklahoma 74801

Telephone: (405) 275-5269 Fax: (405) 878-4668

E-mail: [email protected]


  1. Cherokee Nation of Oklahoma

Mr. Chad Smith, Principle Chief

Ms. Penny Norseworthy

P. O. Box 948

Tahlequah, Oklahoma 74465

Telephone: (918) 456-0671 x2375 Fax: (918) 458-7666


  1. Cheyenne River Sioux Tribe

Mr. Harold Frazier, Chairman

P. O. Box 837

Eagle Butte, South Dakota 57625

Contact: Kathleen Lafferty

Telephone: (605) 964- 6415 Fax: (605) 964-6416


  1. Chickasaw Nation

Mr. Bill Anoatubby, Governor

Ms. Angie Gilliam, Program Manager

P. O. Box 1548/ 520 E. Arlington

Ada, Oklahoma 74821-1548

Telephone: (580) 436-2603 x7512, Fax: (580) 436-7257

[email protected]


  1. Confederated Tribes of the Colville Reservation

Ms. Sheilah Cleveland

State Hwy 155 & Cache Creek Road

Nespelem, Washington 99155

Telephone: (509) 634-8841/2730/2729 Fax: (509) 634-2734


  1. Cook Inlet Tribal Council

Ms. Carrie McMillan

2700 Gambell Street, Suite 442

Anchorage, Alaska 99503

Telephone: (907) 793-3419 Fax: (907) 793-3422


  1. Copper River Native Association

Mile 104 Richardson Highway, P. O. Box H

Copper Center, Alaska 99573

Contact: Susan Voyles

Telephone: (907) 822-8841, Fax (907) 822-8801


  1. Eastern Shoshone Tribes

Mr. John Wadda

P.O. Box 538/ 647 Blue Sky Hwy.

Fort Washakie, Wyoming 82514

Telephone: (307) 332-8052, Fax: (307)332-8055


  1. Fort Belknap Community Council

Mr. Ben Speakthunder, President

Ms. Tesha Hawley, (406) 353-8382

Mr. Ken Shawl, Finance

RR 1, Box 66,

Harlem, Montana 59526

Telephone: (406) 353-2205 Ext. 427 or 1-800 859-2794 Ext. 382


  1. Confederated Tribes of the

Grand Ronde Community

Ms. Kathryn Harrison, Chairperson

9615 Grand Ronde Rd

Grand Ronde, OR 97347

Contact: David Fullerton

Telephone: (503) 879-2036 Fax: (503) 879-5127


  1. Ho Chunk Nation

Mr. Kenneth LeMieux

P.O. Box 667, W. 9814 Airport Rd.

Black River Falls, Wisconsin 54615

Telephone: (715) 284-5877 Ext. 1137, Fax: (715)-284-1520


  1. Kawerak, Inc.

Ms. Dawn Salesky

Contact: Jerry Trainor, Vice President

P.O. Box 948

Nome, Alaska 99762

Telephone: (907) 443-4351 Fax: (907) 443-4452


  1. Knik Tribal Council

Mr. Michael Tucker

477 Contact: Christina Flowers

P.O. Box 871565

Wasilla, Alaska 99687

Telephone: (907) 373-7991 Fax: (907) 373-2161


  1. Kodiak Area Native Association

Ms. Margie Bezona

3449 Rezanof Drive, East

Kodiak, Alaska 99615

Telephone: (907) 486-9816 Fax: (907) 486-9898


  1. Pueblo of Laguna Tribe of Indians

Mr. Roland E. Johnson, Governor

P.O. Box 207

I-40 West, Exit 114, Bldg. 1125

Laguna, NM 87026

Telephone: (505) 552-6008 x 17/ 7242

Marilyn Johnson, (505)-552-6008 x 11, Fax :(505) 552-6398

E-mail: [email protected]


  1. Menominee Indian Tribe of Wisconsin

Lisa Waukau, Chairwoman

P.O. Box 910, Tribal Office Loop Rd., Hwy 47-55

Keshena, WI 54135

Contact: Ann Marie Johnson, 477 Coordinator

Telephone: (715) 799-4419, Fax 715-799-4525


  1. Metlakatla

Ms. Mae Williams and Frankie Nelson

P.O. Box 8

Metlakatla, Alaska 99926

Telephone: (907) 886-5872, Fax: (907) 886-4469


  1. Miami Tribe of Oklahoma

Mr. Floyd E. Leonard, Chief

477 Contact: Ms. Barbra Mullin

P. O. Box 1326

Miami, Oklahoma 74355

Telephone: (918) 542-1445, Fax: (918) 542-7260


  1. Mille Lacs Band of Chippewa Indians

477 Contact: Don Novak

43408 Oodena Drive

HRC-67, Box 194

Onamia, Minnesota 56539

Telephone: (320) 532-4181, Fax: (320) 532-3785

  1. Nez Perce Tribe

Samuel N. Penny, Chairman

Contact: Ronald T. Halfmoon or Kay Kidder

Main Street & Beaver Grade

P.O. Box 365

Lapwai, ID 83540

Telephone: (208) 843-7363 x 2320, (208) 843-7365: Fax: (208) 843-7365


  1. Orutsaramuit Native Council (ONC)

Ms. Bing Santamore

P.O. Box 927, 835 Richcrest Dr.

Bethel, Alaska 99559

Telephone: (907) 543-2608 Fax: (907) 543-2639

[email protected]


  1. Osage Nation

Mr. Ted Moore

1333 Grandview

Pawhuska, OK 74056

Telephone: 1-800-390-6724, (918) 287-4525 or 5302 (Ted), Fax: (918) 287-5567


  1. Pawnee Nation of Oklahoma

Robert L. Chapman, President

Pawnee Business Council

P. O. Box 470

Pawnee, Oklahoma 74058

Debra Echohawk, Director of Education

Telephone: (918)-762-2541, Fax: (918)-762-6446


  1. Port Gamble

Ms. Marilyn Olson

31912 Little Boston Road, NE

Kingston, WA 98346

Telephone: (360) 297-2646/9636 Fax: (360) 297-7097


  1. Red Lake Band of Chippewa Indians

Mr. Darrell Seki, Tribal administrator

Contact: Mr. Ronald Turney

P.O. Box 550

Red Lake, Minnesota 56671

Telephone: (218) 679-3341/3350 Fax: (218) 679-3367


  1. Reno-Sparks Indian Colony Tribal Council

Mr. Arlan D. Melendez, Tribal Chairman

1900 Prosperity Street

Reno. NV 89502

Contact: Mr. Michael Hill, Education Director

Telephone: (775) 329-6114, Fax: (775) 785-9161


  1. Rosebud Sioux Tribe

Mr. William Kindle, Chairman

P.O. Box 430: Tribe

Legion 1 Ave., Red Log Bldg.

Rosebud, South Dakota 57570

Contact: Laurie Bordeaux

Telephone: (605) 747-2393, Fax: (605) 747-5177


  1. Confederated Salish and Kootenai Tribes

of the Flathead Nation

Ms. Anna Whiting-Sorrell or Teresa Wall-McDonald

P.O. Box 278

Pablo, Montana 59855

Telephone: (406) 675-2700 Ext. 1026 or 1049 Fax: (406) 675-2806


  1. Seneca Nation of New York

Ms. Debbie Cooper

1530 Route 438

Irving, New York 14081

Telephone: (716) 532-1033 Fax: (716) 532-6178


  1. Shonaq’ Tribe of Alaska

Mr. Robert L. Polasky

312 W. Marine Way

Kodiak, Alaska 99615

Contact: Arlene ?

Telephone: (907) 486-4449, Fax: (907) 486-3361

Plan Dates: July 1, 2004 to June 30 2007

  1. Shoshone-Bannock Tribe

Ms. Ida Hidalgo

P.O. Box 306, Pima Dr.

Fort Hall, Idaho 83203

Telephone: (208) 478-3737, Fax: (208) 478- 3852


  1. Shoshone-Paiute Tribes of Duck Valley

Mr. Marvin Cota, Chairman

P.O. Box 219

Owyhee, Nevada 89832-0219

Contact: Carol Jones

Telephone: (775) 757-3211 x 224, Fax: (775) 757-2219


  1. Confederated Tribes of the Siletz Indians

Mr. Bob Jensen / contact: Nancy McCrary

P.O. Box 549

Siletz, Oregon 97380

Telephone: 1-800-922-1399 Fax: (541) 444-2307

  1. Sisseton-Wahpeton Sioux Tribe

Mr. Richard Keeble

Lake Traverse Reservation

P.O. Box 509, Veteran Memorial Dr.

Agency Village, South Dakota 57262

Telephone: (605) 698-3911, Fax: (605) 698-7907


  1. Spirit Lake Sioux Tribe

Ms. Jolene Crosswhite

Community Center, Main Street

Fort Totten, North Dakota 58335

Telephone: (701) 766-1200 Fax: (701) 766-1236


  1. Spokane Tribe of Indians

Gregory Abrahamson, Tribal Chairman

Luanne Ferguson, Employment and Training

6195 Ford/Wellpinit Rd.

P. O. Box 100

Wellpinit, Washington 99040

Telephone: (509) 533-1360, Fax: (509) 533-0899


Stockbridge-Munsee Community

477 Contact: Ms. Misty Cook

P.O. Box 70

N8476 MohHeConNuck Rd.

Bowler, Wisconsin 54416

Telephone: (715) 793-4060, Fax: 715-793-4083


  1. Tanana Chiefs Conference, Inc

Ms. Deborah McCarter or Mr. Don Shircel

122 First Ave., Suite 600

Fairbanks, Alaska 99701

Telephone: (907) 452-8251 Ext. 3229 Fax: (907) 459-3883


  1. Three Affiliated Tribes

Mr. Leo Cummings

P.O. Box 220, 304 Main St.

New Town, North Dakota 58763

Telephone: (701) 627-2520 Fax: (701) 627-4496


  1. Tulalip Tribes of Washington

Stanley G. Jones, Chairman

Ed Parris or Charlene James, TANF

6700 Totem Beach Road

Tulalip, Washington 98271

Telephone: (360) 651-4381, Fax: (360) 651-3920

  1. Central Council of Tlingit & Haida Indians

Ms. Sharon Olsen

320 West Willoughby, Suite 300

Juneau, Alaska 99801

Telephone: (907) 463-7134, Fax: (907) 463-7312


  1. White Earth Reservation Tribe

Mr. Robert C. Goodwin

P.0. Box 70

2531 310th Avenue

Naytahwaush, Minnesota 56566

Telephone: (218) 935-5554, ext.3213 Fax: (218) 935-2593


  1. Winnebago Tribe of Nebraska

Mr. Matt Cleveland

Accounting: Cheryl Painter: (402)-878-3140

P.O. Box 723 or P.O. Box 687

St. Augustine Mission Hill Dr.

Hwy. 77 North

Winnebago, Nebraska 68071

Telephone: (402) 878-2379 Fax: (402) 878-2228

  1. Yakutat Tlingt Tribe

Mr. Bert Adams, Sr., Council President

P.O. Box 418

Yakutat, AK 99689

Contact: Ms. Shelly Bremner

Telephone: (907) 784-3401, Fax: (907) 784-3595


  1. Pueblo of Zuni

Mr. Arlen Quetawki, Sr., Governor

P.O. Box 339

Zuni, NM 87327

Contact: Joan Shocky

Telephone: (505) 782-7186, Fax: (505) 782-7223


The Federal Register notice requesting comments on the reporting requirements for Public Law 102-477 grantees was published on October 18, 2006 (71 FR 61505). No comments were received; The Bureau of Indian Affairs meets with the grantees once each quarter. We have discussed these specific reporting requirements and the forms presented here are a product of those discussions. There are minor modifications to reflect legislation creating new Federal employment and training programs, including the Welfare to Work and Temporary Assistance to Needy Families programs. We met with the federal and tribal stakeholders on April 11, 2006 to discuss Government wide common performance measures for all employment and training programs which standardizes measures that the White House has implemented for FY 2004.


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


No payments or gifts are made to respondents.


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


Not applicable; the annual report deals with totals and summaries, not with individual applicants.


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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.


Questions of a sensitive nature are not collected and, therefore, not applicable to this collection.


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. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.


The collection of data necessary to complete the forms is completed by administrators of the grant to determine eligibility and to report to tribal councils. No additional data collection is required to complete the P.L. 102-477 forms. These reports will be retained for the life of the grant.


The reporting requirements currently used will affect approximately fifty-one grantees. We estimate that fewer hours are needed to complete the forms than previously estimated in previous years This estimate is based upon three years of experience implementing the P.L. 102-477 program and working directly with respondents on the completion of forms. Many of the grantees state that their reporting requirement to their respective tribal councils is more stringent than the reports required by this program, is reported more frequently and the data is already collected. This allows easier completion of the forms for respondents.


The “Financial Status Report” requires an estimated two (2) hours to complete. Estimating the salary costs at $35/hour, this report costs $35 X 2 X 51 equals an annual sum of $3,570.00.


The “P.L. 102-477 Demonstration Project Statistical Report,” requires approximately sixteen (16) hours to complete. The estimated salary cost is $35/hour for each grantee, times sixteen (16) hours per grantee or $560. All 51 grantees cost will be $28,560 to complete the statistical form.


We estimate it requires 40 hours to complete the program narrative for each grantee or $35.00 per hour X 40 hours = $1,400 each grantee. There are 51 grantees X $1,400 equals $71,400. The total cost for the Statistical Report and the Narrative totals $99,960.


Not all 51 grantees include TANF funds in their Pub. L. 102-477 grants. We estimate 30 grantees will participate in TANF resulting in 2 hours per grantee to complete the forms at $35.00 per hour or $70.00 per grantee times 30 grants equal $2,100 for all grantees. The following table explains the burden.



Form Information

Number of Respondents

Hourly Burden

Total Annual Burden Hours

Total Annual Cost: HrX$35

O&M annual cost: $5X51

Total Federal Cost: HrX$40

Financial Report


51


2


102


$3570.



160 hours

Statistical Report & Narrative



51



56



2856



$99,960.



$255.

TANF

30

2

60

$2,100.00


Totals



3018

$105,630

$255.

$6400.00



13. Provide an estimate of the total annual [non-hour] cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

* The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information [including filing fees paid]. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.


There are no additional costs to grantees reported in #12 above; any automation has probably been done by grantees for use in managing the tribal government and would have occurred regardless of this report. An estimated $5.00 per grantee for the cost of paper and file maintenance, times 51 grantees equals $255.00 for all.



14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.


Approximately 160 hours annually is spent on the collection, verification of forms, summarizing data, printing and distribution of data to other federal agencies and to bureau management for policy decisions. This estimated does not include cost to the Department of Labor Department of Health and Human Services which receives copies of the data.


The estimated annual cost is based on $40/hour X 160 hours per year or $6,400. per year. This estimate is based on five (5) years of experience implementing the program.



15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.


There are an additional 2 new tribes that were added since 2003 from 49 tribal grantees to 51 tribal grantees. We are reporting 6762 hours to reinstate and an adjustment downwards of 3744 hours based on improved estimates.


16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.


The Bureau of Indian Affairs does not intend to publish the annual reports; we will distribute the summary to each of the other two Federal agencies involved in the project.



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.


We will display the OMB Control number and expiration date on the forms.



18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

The requirements for certification for the Paperwork Reduction Act submissions are fully met with no exceptions requested.



P.L. 102-477 Page 16

File Typeapplication/msword
File TitleSupporting Statement for Paperwork Reduction Act Submissions
AuthorRuth Bajema
Last Modified ByIndian Affairs User
File Modified2007-07-03
File Created2007-07-03

© 2024 OMB.report | Privacy Policy