Icr 2577-fup

Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.

1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of Public and Indian Housing, Office of Housing Programs, Office of Housing Voucher Management and Operation Division		2. OMB Control Number: a. 2577-xxx	b.   None      
3. Type of information collection: (check one) New Collection Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)      

7. Title:

Family Unification Program (FUP)

8. Agency form number(s): (if applicable)

HUD-52515, HUD-50058, HUD-96011, SF-424, SF-LLL, HUD-2993, HUD 2994-A and HUD 27061

9. Keywords:

Housing, public housing, rent subsidies, family unification, public child welfare agency

10. Abstract:

Public Housing Agencies (PHA) application for funding of new Housing Choice Vouchers to promote family unification. The Family Unification Program (FUP) is a program under which vouchers are provided to families for whom the lack of adequate housing is a primary factor in the imminent placement of the family's child, or children, in out-of-home care; or the delay in the discharge of the child, or children, to the family from out-of-home care. Youths at least 18 years old and not more than 21 years old (have not reached 22nd birthday) who left foster care at age 16 or older and who do not have adequate housing are also eligible to receive housing assistance under the FUP. A FUP voucher issued to such a youth may only be used to provide housing assistance for the youth for a maximum of 18 months.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.   Individuals or households e.   Farms b.   Business or other for-profit f.   Federal Government c.   Not-for-profit institutions g. P State, Local or Tribal Government		12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a.   Voluntary b. P Required to obtain or retain benefits c.   Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 200 b. Total annual responses 200 Percentage of these responses collected electronically 92% c. Total annual hours requested 5,357 Current OMB inventory 0 e. Difference (+,- 5,357 f. Explanation of difference: 1. Program change: 5,357 2. Adjustment:		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs 0 b. Total annual costs (O&M) 0 c. Total annualized cost requested 0 d. Current OMB inventory 0 e. Difference 0 f. Explanation of difference: 1. Program change:       2. Adjustment:      
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. X Application for benefits e. P Program planning or management b. Program evaluation f.   Research c.   General purpose statistics g.   Regulatory or compliance d.   Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe)      
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Stephanie Y. McQueen Phone: 202-708-3936

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. Burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

9. It uses effective and efficient statistical survey methodology; and

10. It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     

Signature of Program Official: X Danielle Bastarache, Director, Housing Voucher Management and Operations Division     

Date:

Supporting Statement for Paperwork Reduction Act Submissions

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 Family Unification Program (FUP) is authorized by section 8(x) of the United States Housing Act of 1937 {42 U.S.C. 1437(X)}. Title II of Division K of the Consolidated Appropriations Act, 2008 (P.L. 110-161, December 26, 2008), provided $20 million for incremental voucher assistance through the FUP. The FUP will provide housing choice vouchers to eligible PHAs to assist families for whom the lack of adequate housing is a primary factor in the imminent placement of the family's child, or children, in out-of-home care; or the delay in the discharge of the child, or children, to the family from out-of-home care. Youths at least 18 years old and not more than 21 years old (have not reached 22nd birthday) who left foster care at age 16 or older and who do not have adequate housing are also eligible to receive housing assistance under the FUP. A FUP voucher issued to such a youth may only be used to provide housing assistance for the youth for a maximum of 18 months.

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

HUD will use the information to evaluate applications and determine eligibility for funding. To be eligible for funding in response to the FUP NOFA, the applicant must meet the program threshold requirements and receive at least 50 points of the maximum 100 total points that could be achieved.

Threshold Criteria 1 requires the PHA to demonstrate the need for an equal or greater number of HCVs than it is requesting under this NOFA. The PHA must assess and document the unmet housing need for its geographic jurisdiction.

Threshold Criteria 2 requires that the PHA describe the effect it has taken beyond those required by federal law or regulation to provide area wide housing opportunity.

Threshold Criteria 3, the PHA must provide a Memorandum of Understanding (MOU) between the PHAs and the Public Child Welfare Agency (PCWA) to identify the actions each agency will take to identify to assist FUP eligible families and youths.

Threshold Criteria 4, requires the PHA to obtain and submit the PCWA’s narrative statement of need for FUP in the area to be served.

Letter of Intent and Narrative which will also serve as a cover letter. The PHA must state in its cover letter the number of vouchers it is requesting and the minimum number of vouchers it will accept if selected under a lottery system. The cover letter must also include a statement by the PHA certifying that the PHA has consulted with the agency or agencies in the State responsible for the administration of welfare reform to provide for the successful implementation of the State's welfare reform for families and youths receiving rental assistance under the FUP. The application must also include an explanation of how the applicant meets the requirements for Threshold Criterion 1 through 4.

Evaluation Certifications. The PHA and the PCWA, in separate certifications, must state that the PHA and PCWA agree to cooperate with HUD and provide requested data to the HUD office or HUD-approved contractor delegated the responsibility for the program evaluation. No specific language for this certification is prescribed by HUD.

Form HUD-2993. All PHAs must complete and submit this Acknowledgement of Application Receipt.

Form HUD-2994-A. You Are Our Client! Grant Applicant Survey, Optional.

Form HUD-96011. Third Party Documentation Facsimile Transmittal (“Facsimile Transmittal Form” on Grants.gov). Used as the cover page to transmit third party documents and other information designed for each specific application for tracking purposes

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.

As part of the ongoing implementation of the Electronic Government (E-Government) component of the President's Management Agenda, all application packages for funding under the Housing Choice Voucher Family Unification Program are submitted to HUD electronically by PHAs.

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.

Information collected used to determine eligibility for the FUP program. PIH is not aware of any duplication efforts to collect this data, therefore it is believed there is no duplication of effort.

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.

The information being collected has no significant impact on small businesses or other small entities.

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.

Federal program requirements, policy activities and statutory mandates would not be met if the collection is not conducted, or is conducted less frequently. The information is a one-time collection by the PHA and submitted to HUD for review in accordance with statutory requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner: 1) requiring respondents to report information to the agency more often than quarterly; 2) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; 3) requiring respondents to submit more than an original and two copies of any document; 4) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; 5) 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; 6) requiring the use of a statistical data classification that has not been reviewed and approved by OMB; 7) 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 8) 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.

There are no special circumstances that would cause information collection to be conducted inappropriately.

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 on 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 may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), HUD published a Notice of proposed Information Collection in the Federal Register announcing the agency’s intention to request an OMB review of data collection activities related to the FUP program. The Notice was published on September 23, 2008. A copy of this Notice is included with this Information Collection request.

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

No payments or gifts are provided to the respondents.

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

No assurance of confidentiality is provided. Information collected from applicants (PHAs) will be solely used to determine eligibility of funding.

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.

No sensitive questions are being asked.

12. Provide estimates of the hour burden of the collection of information. The statement should: 1) 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, 2) 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, and 3) 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 13.

Estimated Annual Reporting and Recordkeeping Burden

Description of Information Collection	Number of Respondents	Responses per Year	Total Annual Responses	Hrs per Response	Total Burden Hours
SF424 (0348-0043) Application for Federal Assistance	200	1	200	0.75	150
SF LLL (0348-0046) Lobbying Form	10	1	10	0.17	1.7
HUD-96011 (2535-0118) 3rd Party Documentation Facsimile Transmittal	200	1	200	.1	20
HUD -2993 Acknowledgement of Application	200	1	200	0	0
HUD 2994-A You Are Our Client Survey	200	1	200	0	0
Threshold Criteria 1	200	1	200	1.25	250
Threshold Criteria 2	200	1	200	1.25	250
Threshold Criteria 3	200	1	200	1.25	250
Threshold Criteria 4	200	1	200	1.25	250
Narrative Statement/Cover letter	200	1	200	1.00	200
Evaluation Certification	200	1	200	0.60	120
Subtotal (Application)	200	1	200	7.32	1491.7
HUD – 27061 (2535-0113) Racial and Ethnic Data Reporting Form	70	1	70	1.15	80.5
Family Report HUD-50058 (2577-0083)	70	41	2870	.5	1435
Program and Accounting Recordkeeping	200	1	200	10	2000
Funding Application HUD-52515 (2577-0169)	200	1	200	.75	150
Affirmatively Furthering Fair Housing Statement (addendum)	200	1	200	1.00	200
Subtotal (Reporting/Recordkeeping)
Total					5,357.2

The estimate of the total annual cost burden to respondents/recordkeepers resulting from the collection of this information is: 5,357.2 burden hours x $18/hour = $96,069.60

13. Provide an estimate for the total annual 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. 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 collections 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 the respondents.

14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Estimated annualized cost to the Federal Government for this collection:

No. of Hrs. Per Annual Cost Cost to

Responses Response Hrs Per Hr. Fed/yr

Reporting 200 1 200 $22.00 $4,400

Funding Application 200 4 800 $22.00 $17,600

Total Cost $22,000

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

This is a new collection.

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 information collection results will not be published; the funded grant awards will be published as required by the HUD Reform Act.

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.

The expiration date and the OMB approval number will be displayed in the Notice of Funding Availability and on all related forms.

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

There are no exceptions to the certification statement identified in item 19.

B. Collections of Information Employing Statistical Methods

This collection of information does not employ statistical methods.

OMB 83-I 10/95