6-27-07 rev FNL PROCESS justification

A. Justification: Extension of the Generic Clearance for Grant Programs for the Institute of Museum and Library Services, OMB Control Number 3137-0029

1. The Institute of Museum and Library Services (IMLS) requests generic clearance for all of the agency’s information collection requests (excluding surveys, evaluations, and data calls used for policy-making purposes) for its grant program processes under the Paperwork Reduction Act. The information collections in this package include all of the guidelines and instructions necessary to (1) apply for IMLS support, (2) identify grant reviewers, and (3) complete post-award reports for the agency’s grant programs. In a separate complementary clearance submission and justification submitted at the same time, IMLS is requesting a three-year generic clearance for all forms used in its grant programs, including application materials and post-award reports.

Background: On 11/21/2003, IMLS requested Office of Management and Budget (OMB) generic clearance for information collections associated with the majority of IMLS applications and grant administration materials. OMB approved this request, without modification, on 01/14/04. On 11/29/2006, IMLS requested, and OMB approved, an extension of this generic clearance until 4/30/2007, to enable the agency to consolidate all of its forms under one clearance and take steps to ensure consistency of language across its grant program guidelines and materials. IMLS now requests OMB clearance of the information collections the Institute requires to carry out its grant programs.

In this general clearance request IMLS brings together its application processes, guidelines, and forms in a single package. The general clearance now in effect includes the following grant programs’ application guidelines, forms, and the processes associated with them:

Program	OMB Clearance No.	Expiration date
Conservation Project Support	3137-0029	04/30/2007
Museums for America	3137-0029	04/30/2007
Native American Library Services	3137-0029	04/30/2007
Native Hawaiian Library Services	3137-0029	04/30/2007

IMLS requests that this current general clearance be extended for three years. In addition, IMLS asks that the application guidelines and forms for the programs listed below be consolidated into the 3137-0029 general clearance. These programs were added subsequent to the general clearance 3137-0029 (FY 2003), with the exception of the National Leadership Grants, which received additional clearance in 2005 for new information being collected.

Program	OMB Clearance No.	Expiration date
Laura Bush 21st-Century Librarian Program	3137-0049	04/30/2008
Native American/Native Hawaiian Museum Services	3137-0057	01/31/2008
21st Century Museum Professionals Program	3137-0060	11/30/2008
National Leadership Grants for Libraries and Museums	3137-0060	11/30/2008
Partnership for a Nation of Learners	3137-0060	11/30/2008
Museum Grants for African American History and Culture	3137-0065	06/30/2009

As new grant initiatives are established within the period of the renewed clearance, IMLS expects to use the submitted application guideline content and application forms, and the current, ongoing, internal review process for programs and guidelines. The agency continually makes minor adjustments to programs and priorities to address emerging needs and other changes in the environment . For example, the form for Specifications for Projects that Develop Digital Products is adjusted to reflect the changing technologies in this fast-developing field. These adjustments may impact the guidelines. The agency needs the discretion to make such changes within the scope of its general clearance. None of them is expected to change the burden.

Application guidelines: IMLS uses an iterative review process for each set of guidelines in every fiscal year. The process is defined in IMLS’ Grants Administration Manual and it is designed to ensure that key stakeholders and agency officials review and authorize proposed guidelines. In FY 2007, text common to all of IMLS grant program applications was rewritten to provide consistent information and language across all of these program documents.

2. The information collected by IMLS is used by the agency to carry out its grant programs. The information is used by IMLS staff to validate applicant eligibility, identify and assign peer reviewers, manage grant competitions, award discretionary and formula-based grants, and administer and monitor its grants. It is also used by the agency for strategic planning, performance analysis, and to provide information to the Administration and to Congress. Data elements subject to FOIA also provide information about IMLS’ grant applications and programs to individuals outside the agency, and may be used by applicants to validate their project ideas or application strategies, to follow trends in their fields, and to identify effective practice that can be widely adapted to improve the quality of museum and library services in the United States.

3. During the agency’s FY 2007 discretionary grant cycle, applicants could submit applications online for all of the Institute’s programs through Grants.Gov. The use of Grants.Gov was required in three of the agency’s programs, and optional in all others. Beginning in FY 2008, IMLS will require all discretionary applicants to apply for Federal financial assistance through Grants.Gov. In the Institute’s Grants to State Library Administrative Agencies Program, the Five-Year Plan, annual State Program Report and annual Financial Status report are all submitted on-line.

4. In FY 2007, IMLS posted application packages for all of its discretionary grant programs on Grants.Gov. Anticipating the use of Grants.Gov and cognizant of the need to extend OMB clearance for them, all of the forms used by IMLS for applications, post-award reporting, and the Grants to State Library Administrative Agencies program were reviewed, consolidated, and validated through an iterative process involving staff and managers. Particular attention was paid to standard government-wide forms and forms cleared by other agencies that are available for use on Grants.Gov. For its discretionary programs, IMLS uses the SF 424S and Grants.Gov forms for Abstracts and Attachments. The agency has kept to a minimum the use of non-standard forms, and is providing fifteen forms to OMB: five forms used in discretionary grant applications, five forms used in post-award reporting, two forms specific to Grants to States, and three forms for other applications. See question 8 for additional detail.. The State Grants Program annual reporting process has been updated and made electronic to increase consistency and efficiency. All IMLS grant application guidelines and publications are annually reviewed through an internal clearance process, which requires review by several different offices within the agency, including the program offices, the Office of General Counsel, and the Grants Office. This annual review protects against duplication.

5. No small businesses are impacted, but some applicants for IMLS funding are small non-profit organizations. Every effort has been made to streamline processes and instructions and to simplify the application and reporting processes. The agency’s internal clearance process ensures that no undue burden is placed on any applicant for IMLS funding.

6. These collections of information are essential to IMLS in meeting its statutory mission to award Federal financial assistance under the Museum and Library Act (20 U.S.C. Section 9101 et seq.), and its obligation to identify needs and trends in library and museum service. The information collections included in this package vary in frequency. Many are one time per application, others are annual or semiannual; one is every five years.

7. None of the listed conditions apply.

8. The 60-day notice for this collection was published in the Federal Register Vol. 71, no. 213 (November 3, 2006), page 64746. No public comments were received. A second 30-day notice requesting comment for this generic clearance was published in the Federal Register: Vol. 72, no. 79 (Wed., April 25, 2007) page 20566.

IMLS uses several different mechanisms to consult with persons outside the agency.

Contact information for program officers is widely distributed and easily accessible

from the IMLS Web site and grantees and potential applicants are encouraged to

communicate frequently with these experts. In addition program officers convene

nationwide conference calls to answer questions and take input. IMLS program staff also

travel to national, regional and local meetings of potential applicants to discuss program

requirements. Finally, Agency staff consults informally with its communities throughout

the year, including regular meetings with the Chiefs of State Library Administrative

Agencies, semiannual information meetings hosted for represents of key professional

associations, and IMLS convenings for other purposes.

During the grant application review process outside experts are asked to review

applications and discuss the agency’s forms, instructions and process. These experts are

consulted by IMLS staff regarding the clarity and value of the guidelines and informally

comment on the burden of response required by applicants.

IMLS notes and evaluates suggestions for revising guidelines and reporting forms

received from applicants responding to the invitation for comments found in the burden

statement contained in each information collection. Efforts are continually made to

shorten and simplify application instructions and forms in response to suggestions made

by respondents.

9. No payments or gifts are provided to any of the respondents.

10. All IMLS guidelines and application instructions contain a notice furnished in compliance with the Privacy Act.

11. No information on sexual behavior, religious beliefs, or other personal matters is solicited.

12. The number of respondents is 1,594, the number of applicants for IMLS grants in FY 2006, the most recent year for which data is available. The number of annual burden hours is 39,261.02, based on estimates of the average number of hours an applicant will need to review instructions, search existing data sources, gather and maintain the data needed, and complete and review the narrative components of the application. Burden hours per application range from 2 hours to 40 hours, depending on the complexity of an applicant’s grant project.

Note: burden hours for completing forms associated with applications are accounted for in the ICR for generic clearance for applications and reporting forms.

Fifty-six respondents and 5,040 burden hours represent the Five-Year Plan for Grants to State Library Administrative Agencies, required by law from each SLAA at five year intervals and due in this clearance period.

13. The estimated cost to applicants is $928,130.52. The cost per hour is based on $23.64, the Bureau of Labor Statistics mean hourly wage of a museum or library professional. The estimated burden hour cost per application ranges from $47.28 for the simplest application to $945.60 for a complex, large-scale project. IMLS grants range in size from $5,000 to $1,000,000; burden correlates well with grant size.

The total estimated cost to State Library Administrative Agencies for the Five-Year Plan is $119,145.60, which is incurred once every five years. The estimated cost to each SLAA is $2,134. Grants to the 50 States and the District of Columbia range from $821,234 to $16,557,920; burden is positively correlated with grant size.

Note: the cost for completion of forms associated with applications is accounted for in the ICR for generic clearance for applications and reporting forms.

The two cost components for total capitol/start-up and operation/maintenance/purchase of services are not applicable.

14. Not applicable.

15. The IMLS burden may change slightly from year to year as new needs are identified and priorities shift in response to appropriations and to changes in the museum and library environments. Programs may be added, enlarged, reduced or discontinued. Such changes are reflected in the difference between the burden estimated in the 2003 generic clearance request and the request submitted here. In that period IMLS added five programs, including the Laura Bush 21^st-C Librarian Grants, which have grown from $10,000,000 to $21,000,000 per year. If all of the current clearances combined in this submission are added together, the total estimated burden in this period is 46,867 hours and $845,650. Applications in this period exceeded expectations, allowing IMLS to reach more institutions and communities with federal funding.

The burden estimates submitted here for forms and applications total 58,802 hours and $1,366,443. The difference of $520,793 from combined earlier clearance requests reflects growth in programs and applications, feedback from respondents raising the estimated time to complete complex requests for funding, and increased emphasis on accountability from OMB. A small portion of the increase is due to a recalculated average hourly wage for IMLS respondents, from $18.00 to 23.64.

16. Not applicable.

17. Not applicable.

18. Not applicable. The expiration date will be displayed.

19. Not applicable.