83-i VMS PRA -FINAL04-05-11 ljedit (2) (3)
83-i VMS PRA -FINAL04-05-11 ljedit (2) (3).docx
Housing Choice Voucher Program
OMB: 2577-0169
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 Public Housing and Voucher Programs |
2. OMB Control Number: a. 2577-0169
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b. None
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
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)
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7. Title: Title:
Housing Choice Voucher Program
8. Agency form number(s): HUD-52515, HUD-52667, HUD-52580, HUD-52580-A, HUD-52681, HUD-52681-B, HUD-52672, HUD-, HUD-52517, HUD-52646, HUD-52665, HUD-52641, HUD-52641-A, HUD 52642, HUD 52642-A, HUD 52649, HUD 52531A and B, HUD 52530A, HUD 52530B, HUD 52530C, HUD 52578B, HUD 52663.
9. Keywords:
Housing Choice Vouchers (HCV), Rent subsidies, Low-income housing, Homeownership, HCV Transfers; Project-Based Vouchers
10. Abstract:
Public Housing Authorities (PHA) apply for funding to assist very low-income families to lease or purchase housing. PHAs maintain records on participant eligibility, unit acceptability, lease and/or housing assistance payments, and budget and payment documentation. In some cases, PHAs voluntarily divest their voucher programs to a receiving PHA. PHAs may also project-base a portion of their vouchers or use their vouchers under the Homeownership Option.
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 |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 492,450 b. Total annual responses 3,037,954 Percentage of these responses collected electronically 0.3% c. Total annual hours requested 1,238,448 d. Current OMB inventory 1,223,748 e. Difference (+,-) +14,700 f. Explanation of difference: 1. Program change: +14,700 2. Adjustment:
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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 b. Total annual costs (O&M) c. Total annualized cost requested d. Current OMB inventory e. Difference f. Explanation of difference: 1. Program change: 2. Adjustment: |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. Application for benefits e. X Program planning or management b. X Program evaluation f. Research c. General purpose statistics g. P 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. Biennually 8. Other (describe)
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Phyllis Smelkinson Phone: 202-402-4138
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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:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
Burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
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);
It uses effective and efficient statistical survey methodology; and
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 Milan M. Ozdinec, Deputy Assistant Secretary, Office of Public Housing and Voucher Programs, PIH, HUD |
Date: |
Supporting Statement for Paperwork Reduction Act Submissions
A. Justification:
Why is this information necessary?
The housing choice voucher (HCV) program is the federal government's major program for assisting very low-income families, the elderly, and the disabled to afford decent, safe, and sanitary housing in the private market. Since housing assistance is provided on behalf of the family or individual, participants are able to find their own housing, including single-family homes, townhouses and apartments.
Under the HCV program, the Department enters into an Annual Contributions Contract (ACC) with PHAs to assist very low-income families to lease or purchase safe, decent, and affordable housing. PHAs are required to maintain complete and accurate program and accounting records in accordance with HUD requirements; in a manner that permits a speedy and effective audit. PHAs must maintain records on eligibility (e.g., verification of income, disability status and citizenship); records of subsidized units (e.g., unit inspection reports, rent reasonableness documentation, tenant leases and housing assistance payments (HAP) contracts); and accounts and other records supporting PHA budget and financial statements for the program (e.g. HAP registers which document payments to landlords).
Section 8 of the United States Housing Act of 1937 (42 U.S.C. 1437 f) permits the Secretary of HUD to make annual contributions to public housing agencies (PHAs) to provide voucher-based rental assistance. The Secretary is required to embody the provisions for such annual contributions in a contract guaranteeing payment. Applicable regulations are 24 CFR 982 for Section 8 Tenant Based Assistance: Housing Choice Voucher Program.
How is this information to be used?
Financial Form HUD-52681-B is entered by the PHA into the Voucher Management System (VMS). None of the other data under this submission is automated. The information collected from PHAs will used to ensure statutory, regulatory and contractual compliance.
Use of information. The requested information requirements (how, by whom and for what purpose the information is to be used) for the voucher program consists of the following:
Information Collections Required of PHAs
Funding Application, Form HUD-52515, Regulatory References 982.54, 982.103, and 982.158. HUD collects information from the PHA on Form HUD-52515, which is the HCV program funding application that specifies the number of units requested, as well as the PHA's objectives and plans for administering the HCV program. The application is reviewed by HUD and ranked according to the PHA's administrative capability, the need for housing assistance, and other factors specified in the Notice of Funding Availability. PHAs are required to prepare an Administrative Plan that states local PHA policy on matters for which the PHA has discretion to establish local policies. The PHA must discuss in these plans how it will operate the HCV program, e.g., organization of the waiting list, opening and closing of the waiting list, selection of families from the waiting list, terms of the voucher and occupancy policies. Standard forms were added to the funding application process. Purpose: Application for benefits.
Allowances for Tenant Furnished Utilities and Other Services, Form HUD-52667, Regulatory References 982.158 and 982.517. The PHA must establish a utility allowance schedule for all utilities and other services. The utility allowance is used in determining the family's monthly HAP and rental or homeownership share. The allowance is provided for those utilities paid by the family. The utility allowance schedule is determined based on the typical cost of utilities and services paid by energy-conservative households that occupy housing of a similar size and type in the same locality. The PHA must submit its initial utility allowance schedule and supporting documentation to HUD in order for HUD to ensure that the costs are reasonable. Thereafter, the updated form is not sent to HUD unless requested. Purpose: Program planning or management; Regulatory compliance. This purpose will remain applicable to remaining forms and documents.
Inspection Form, HUD-52580, Regulatory References 982.158, 982.401, 982.405 and 982.631. Form HUD-52580 (form HUD-52580-A is the same form as 52580 with the addition of detailed instructions on the form) is the inspection form used by the PHA to determine if a unit meets the housing quality standards (HQS) of the HCV program. The goal of the HCV program is to provide decent, safe and sanitary housing to very low-income families. In keeping with that goal, the primary objective of the HQS is to protect the family receiving assistance under the program by guaranteeing a basic level of assisted housing. The units must pass inspection before HAP may be paid to owners and must be re-inspected at least once a year when an assisted family continues occupancy. Annual re-inspections are not required under the homeownership option. The inspection reports are not submitted to HUD.
Financial Forms, HUD- 52672, 52681, 52681-B, Regulatory References 982.157 and 982.158. PHAs that administer the HCV program are required to maintain financial reports in accordance with accepted accounting standards in order to permit timely and effective audits. The HUD-52672 and 52681 financial records identify the amount of annual contributions that are received and disbursed by the PHA and are used by PHAs that administer the five-year Mainstream Program. The required financial statements are similar to those prepared by any responsible business or organization at the end of the fiscal year. The automated form HUD-52681-B is entered by the PHA into the Voucher Management System (VMS) on a monthly basis during each calendar year to track HAP and administrative fee expenses as well as portability families, fraud recovery, Family Self-Sufficiency escrow accounts, etc. The inclusion of the four new fields of Net Restricted Assets (NRA), Unrestricted Net Assets (UNA), Cash/Investments, and the number of vouchers issued but not under active housing assistance payment (HAP) contract will further allow the PHAs and the Department to realize a more complete picture of the PHAs’ resources and program activities, promote financial accountability, and improve the PHAs’ ability to provide assistance to as many households as possible while maximizing budgets. In addition, the aforementioned fields will be crucial to the identification of actual or incipient financial problems that will ultimately effect funding for program participants. Through submission of these reports, HUD is able to ensure that PHAs do not over or under utilize their baseline unit months or annual budget authority thereby affecting the number of qualified families that can participate in the HCV programs. HCV funding is provided to PHAs each calendar year on a formula basis in accordance with recent Congressional Appropriations Acts.
Voucher, Form HUD-52646, Regulatory References 982.158, 982.302 and 982.629. The voucher is the document that authorizes the family to look for an eligible unit and specifies the appropriate unit size necessary to meet the family's needs. The voucher also sets forth the family's obligations under the HCV program. This form is not sent to HUD.
HAP Contracts and Tenancy Addenda, Forms HUD-52641, 52641A, 52642 and 52642A -Regulatory References, 982.158, 982.305, 982.308, 982.309, 982.451, 982.454, 982.620. The HAP contract is a written agreement between the PHA and the owner of a unit or manufactured home space occupied by a voucher participant. The HAP contract must be executed before the PHA can make payment on behalf of an eligible family. The HAP contract consists of three parts: Part A (Contract Information); Part B (Body of the Contract); and Part C (Tenancy Addendum). Separate tenancy addenda forms are provided to the landlord for attachment to the tenant’s lease. The PHA must be provided a copy of any revisions to the lease agreed to by the owner and the tenant. This information is not submitted to HUD. Below is an explanation of each contract form.
Requisition for Partial Payment of Annual Contributions, Section 8 Housing Assistance Payments ProgramPublic reporting burden for this collection of information is estimated to average 1.5 hours per response, including the ime for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. This agency may not conduct or sponsor, and you are not required to respond to, a collection of information unless that collecton displays a valid OMB control number. Authority for this collection of information is the Housing and Community Development Act of 1987. Housing Agencies (HAs) required to maintain financial reports in accordance with accepted accounting standards too permit timely and effective audits. The financial records identify the amount of annual contributions that are received and disbursed by HAs. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality.
HAP Contract for Section 8 Tenant-Based Assistance Housing Choice Voucher Program, Form HUD-52641 -- This contract form is used for all program, participants except manufactured homeowners leasing the manufactured home space. This form is not sent to HUD.
Tenancy Addendum, Form HUD-52641-A-- This form must be attached to a copy of the lease that is provided to the tenant by the landlord. If there is any conflict between the tenancy addendum and any other provisions of the lease, the language of the tenancy addendum shall control. This form is not sent to HUD.
HAP Contract for Manufactured Home Space Rental, Form HUD-52642-- This contract form is used for manufactured homeowners who lease the manufactured home space. This form is not sent to HUD.
Tenancy Addendum, Form HUD-52642-A-- This form is to be attached to a copy of the lease provided to the tenant by the landlord, for manufactured home space rental. If there is any conflict between the tenancy addendum and any other provisions of the lease, the language of the tenancy addendum shall control. This form is not sent to HUD.
Information Collected by PHAs from Program Participants / Tenant-Based Owners
Request for Tenancy Approval, Form HUD-52517, Regulatory References 982.158 and 982.302. The Request for Tenancy Approval is completed and submitted by the family to the PHA when the family finds a unit that is suitable for its needs. The PHA reviews the request to determine if the owner is eligible to participate in the program, if the unit is eligible, and if the lease complies with the program and statutory requirements governing prohibited and required lease provisions. This form is not sent to HUD.
Statement of Homeowner Obligations Housing Choice Homeownership Voucher Program, Form HUD-52649, Regulatory Reference 982.625 and 982.633. The PHA and family participating in the homeownership voucher program must execute a “statement of homeowner obligations” before HAP begin. This statement describes the types of information to be provided by the family during the process for determining a family’s eligibility for participation in the program, and the program requirements a family must comply with as a condition of participation. The statement indicates the homeowner’s acknowledgment of obligations to provide various types of information to the PHA for the purpose of determining general eligibility for participation in the program, income eligibility, or compliance with stated program requirements.
Information Requirement from PHA to PHA
Family Portability Information, Form HUD-52665, Regulatory Reference 982.158 and 982.355. This form standardizes the portability information submitted to the receiving PHA by the initial PHA. In addition, this form is used for monthly portability billing by the receiving PHA. After the payment amount is established, the form does not need to be resubmitted until the annual recertification or if the payment amount changes between annual recertifications. This information is not provided to HUD.
Information Requirement from PHA to Owner
PHA Preparation of Information about the Tenant for the Owner, Regulatory Reference 982.307. When the PHA is approving a new unit selected by the family, the PHA must advise the owner that the PHA has not screened the family and provide the name and address of previous landlords if such information is readily available. This information is not provided to HUD.
Information Requirement for Voucher Transfers
PHA Notification Letters. Regulatory Reference 982.151. HUD uses the notification letters to initiate the transfer process. Families and owners use their notification letters to be aware of changes in policies (such as occupancy and subsidy standards that may affect the family’s tenancy under a different PHA).
Information Requirement for Homeownership Voucher Contract of Sale
Required Contract of Sale Provisions, Housing Choice Homeownership Voucher Program, Regulatory Reference 982.631(c)(2). Before commencement of monthly homeownership assistance, a member or members of the family must enter into a contract of sale with the seller of the unit to be acquired by the family. The family must give the PHA a copy of the contract of sale. The contract of sale must specify the price and other terms of sale by the seller to the purchaser; provide that the purchaser will arrange for a pre-purchase inspection of the dwelling unit by an independent inspector selected by the purchaser; provide that the purchaser is not obligated to purchase the unit unless the inspection is satisfactory to the purchaser; provide that he purchaser is not obligated to pay for any necessary repairs; and contain a certification from the seller that the seller has not been debarred, suspended, or subject to a limited denial of participation under part 24 of this title.
Information Requirements for Additional Renewal Funding (subject annually to Congressional Appropriations Acts)
Plans from Disaster PHAs. Regulatory reference 982.102. PHAs that were eligible for assistance under Section 901 in Public Law 109-148 or are located in the same counties as those eligible for Section 901 and operate voucher programs, but do not operate public housing programs, and any other PHA that otherwise qualifies under this category must demonstrate they have experienced a loss of rental housing stock as a result of the 2005 hurricanes to receive additional renewal funding. To receive funding, the PHA must submit a plan, to be approved by the Secretary, demonstrating that the PHA can effectively use the funding under this provision within 12 months of HUD approval of the plan.
Plans from PHAs in Receivership or in Breach of an ACC by June 1. 2007. Regulatory reference 982.102
These PHAs that would receive less funding under the method provided in Public Law 110-5 (re-benchmarking) than they would receive under the special provisions of the Supplemental 2007 (Public Law 110-28) must submit a plan, to be approved by the Secretary, demonstrating that the PHA can effectively use the funding under this methodology within 12 months of HUD approval of the plan.
Application/Certification and Evidence of Unforseen Circumstances for Set-Aside Funding. Regulatory reference 982.102. The revised Continuing Resolution 2007 provided $100 million to be set aside for renewal funding for PHAs that experienced an increase in costs due to unforeseen circumstances.
Application/Certification and Evidence of Decrease in Funding due to Re-benchmarking for Set-Aside Funding. Regulatory reference 982.102. The revised Continuing Resolution 2007 provided that part of the $100 million will be set aside for renewal funding for PHAs that would experience a decrease in funding due to re-benchmarking.
Information Requirements for Project-Based Voucher (PBV) Program
Public Notice of PHA Request for PBV Proposals. Regulatory reference 983.51(c). If the PHA must select proposals competitively through public notice. The public notice procedures may include publication of the notice in a local newspaper of general circulation and other means for broad circulation.
PHA Notice of Owner Selection. Regulatory reference 983.51(d). The PHAmust give prompt written notice to the party that submitted a selected proposal and must also give prompt public notice of such selection.
Agreement to Enter into a Housing Assistance Payments Contract. Form HUD-52531A&B. Regulatory reference 983.152. For PBV units that will be newly constructed or substantially rehabilitated, the PHA must enter into an Agreement prior to development or rehabilitation activities begin.
PBV HAP Contract for New Construction or Substantial Rehabilitation. Form HUD-52530A. Regulatory reference 983.202. The PHA must enter into a HAP contract with the owner in order for housing assistance to be paid to the owner for occupied units.
PBV HAP Contract for Existing Units. Form HUD-52530B. Regulatory reference 983.202. The PHA must enter into a HAP contract with the owner in order for housing assistance to be paid to the owner for occupied units.
Tenancy Addendum. Form HUD-52530C. Regulatory reference 983.256((b)(3). The lease under the PBV program must include a HUD-required tenancy addendum with all provisions required by HUD.
Statement of Family Responsibilities. Form HUD-52578B . Regulatory reference 983.1, 982.551. Each family participating in the PBV program must sign this form which includes family obligation.
3. Describe whether, and to what extent, the collection of information is automated?
Financial Form HUD-52681-B is the only portion of this PRA that is automated and all submissions are entered monthly into the Voucher Management System (VMS). Any enhancements to the current VMS are focused on within the following parameters: 1) streamlining the administering of the system and the customer inputs on the part of the Department, 2) improving the user friendliness of the system by making slight modifications to the input screens and strategically positioning related inputs in close proximity for expedited error identification and missing inputs, and 3) creating a visible collaboration of multiple systems that automatically reveals financial data pertaining to specific PHAs to assist them with their analytical processes to promote financial health. These changes are to the system while in its current state, meaning that we are simply focusing on what can be done to improve the system ‘as-is’ and not making any long term plans or designing any major overhauls.
PIH is in the beginning phase of the Business Process Reengineering (BPR) effort as part of the approved transformational initiatives that is in line with the Department of Housing and Urban Development (HUD) Secretary’s high priority goals and HUD’s mission.
BPR will be a reengineering of the voucher management business models and processes across the Rental Housing Assistance Line of Business (RHA-LOB), including PIH, MFH, and CPD program offices, with an intent to create a uniform funding mechanism governed by one set of rules and regulations, expanding the supply of affordable rental homes. The outcome of the BPR project will be a cross-functional solution designed to enhance the Voucher Management operations across the RHA Programs.
The Housing Choice Voucher Program (HCVP) of PIH provides a broad representation of the processes, procedures and systems used to manage the voucher business within the RHA-LOB and therefore HCVP has been selected as the demonstration project for the initial phase of this investment. While the BPR is a multi-year, multi-phased project, the focus is on delivering functionality in six month intervals starting in April 2011.
4. Duplication of information. There is no duplication of the subject information.
Does the collection of information impact small businesses or other small entities?
No small entities are impacted.
6. Describe the consequences to federal program or policy activities if the collection is not conducted or is conducted less frequently. The burden associated with Parts 982 and 983 is the minimum needed for program monitoring and implementation and incorporates program applications for funding, program financial reporting, and contractual and other documents necessary to program administration and implementation. The information cannot be collected less frequently because it is either (1) information necessary to ensure housing is adequate and occupancy is by eligible families (2) information necessary to comply with contractual arrangements or (3) information necessary to ensure compliance with a statutory mandate. In regard to voluntary transfers, notification letters to the field office, families and owners are only required once.
7. Explain any special circumstances. PHAs will submit data in the VMS for each month, but will submit the data after the end of each month. Validation will occur online as the PHA prepares its submission. Items that fail specified edit checks will be immediately identified and the PHA will review and either correct or confirm the data.
8. Identify date and page number of the Federal Register notice soliciting comments on the information.
A notice of proposed information collection for the Public Housing Annual Contributions contract was published in the Federal Register, Volume 75, Page Number 55596, on September 13, 2010. No public comments received.
9. Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts to respondents are provided.
10. Describe any assurance of confidentiality provided to respondents. The information provided is not of a confidential nature.
11. Justify questions of a sensitive nature, such as sexual, religious beliefs and other matters that are commonly considered private. The information collected does not contain questions of a sensitive nature.
12. Annual Reporting Burden
The previous reported burden hours for Financial Form HUD 52681-B (VMS) were based on 1.5 hours per response; based on industry and staff review, the burden hours is revised to 2 hours per response.
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Estimated annual cost. 1,238,448 hours times average hourly costs of $20 = $24,768,960. *2,450 PHAs + 245,000 families + 245,000 owners
** Note 1: that since the divesting PHA is only required to notify the field office of the transfer, there are no burden hours recorded for that action. It would also skew the cost per respondent if added to the burden hours recorded for the receiving PHA. It is estimated that the preparation of the notification letter to the field office should take no more than one hour to prepare. It is further estimated that notification letters to owners and families should take no more than 15 minutes each as PHAs can use the mail merge feature when preparing these letters. **Note 2: PHAs are required to locally maintain and update their financial statements (income statement and balance sheet) and voucher counts on a regular basis. The requested information for the four additional fields should be readily available and require only that the PHA simply transfer the information from their available statements to VMS; An increase of .5 additional burden hours are recorded for this action. The accompanying Notice explains in detail the location and calculations of each field on the financial states along with how to calculate the number of vouchers available vice vouchers issued.
13. Additional cost to respondents. No additional costs to respondents other than as reported in Item 12.
14. Annualized cost to the Federal Government
Estimated annualized cost is $30 per hour, based on the 2010 General Pay Scale for a GS-11 Step 1, which represents the HUD field staff performing reviews of PHA requests. $30 per hour for an estimated 1,000 hours per year equals $30,000. There is no significant increase in the cost to the government.
Federal Government Costs Requirement Annual Cost Total Burden Hours per hour Cost Funding Application 1,500 $30.00 $45,000 Tenant-Furnished Utilities 1,500 $30.00 $ 45,000 Financial Forms 12,250 $30.00 $367,500 Totals 15,250 $457,500
There is no additional cost to the government for the transfer of voucher programs or contracts of sale under the homeownership option.
15. Reason for program changes. This revision reflects the addition of four new reporting fields in the VMS. The four additional fields in VMS will allow the Department a more complete picture of the PHAs’ resources and program activities, promote financial accountability, and identify and correct any financial shortfalls that may threaten program participation.
16. Plans for publication of information collected. Not applicable; information will not be published for statistical use.
18. Exceptions to certification. There are no exceptions to the certification statement identified in item 19.
B. Collection of Information Employing Statistical Methods:
Section B is not applicable since statistical methods are not used.
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Financial
Form (HUD-52681
OMB 83-I 10/95
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Paperwork Reduction Act Submission |
| Author | WAYNE EDDINS |
| File Modified | 0000-00-00 |
| File Created | 2021-02-02 |
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