Narrative of Changes

Changes to Collection OMB No. 1660-0047

The following questions have been updated since the last OMB Approval:

FEMA Form Numbers Changed from: FEMA Forms 90-129 and 90-136

To: FEMA Form Numbers 010-0-8 and 010-0-7 Note: Same forms with new form numbers using FEMA’s new numbering system.

8 b. 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. Please note change in 8 b and c.

The Emergency Support Functions Leadership Group (ESFLG) comprised of other Federal agencies meets quarterly throughout the year to discuss the resources necessary and available to meet the needs of states during times of disasters. Discussions regarding the mission assignment function are routinely occurring during these meetings.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The Mission Assignment Manager Monthly conference call provides an open forum among Regional Mission Assignment Managers and program offices.  This forum provides ample opportunities for feedback on internal items such as the Mission Assignment Standard Operating Procedures and the overall mission assignment process.

12. Provide estimates of the hour burden of the collection of information. The statement should:



 a. 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 desired. 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.

FEMA has estimated that approximately 10 States will complete the FEMA Form 010-0-7 (Action Request Form). Each form is estimated to take 20 minutes to complete. The total annual burden is estimated to be 10 x 640 = 6,400 x 20 minutes per response = 2,133 burden hours.

FEMA has estimated that approximately 10 States will complete the FEMA Form 010-0-7 (Mission Assignment). Each form is estimated to take 3 minutes to complete. The total annual burden is estimated to be 10 x 320 = 3,200 x 3 minutes per response = 160 burden hours.

Training – It is estimated that 10 Financial Managers will attend 2 training sessions a year, and that each session will last for 8 hours. The annual hour burden for training will be 10 x 2 x 8 hours = 160 burden hours.

 b. 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.

c. 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.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
State, local or Tribal Government	FEMA Form 010-0-7 / Action Request Form	10	640	6,400	20 minutes	2,133	$56.69	$120,919.77
State, local or Tribal Government	FEMA Form 010-0-8 / Mission Assignment	10	320	3,200	3 minutes	160	$56.69	$9,070.40
State, local or Tribal Government	Training / No Form	10	2	20	8 hours	160	$56.69	$9,070.40
Total		10		9,620		2,453		$139,060.57

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.4 multiplier to reflect a fully-loaded wage rate.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for State Financial Managers is estimated to be ($40.09 x 1.4 =) $56.59 per hour including the wage rate multiplier, therefore, the estimated burden hour cost to respondents State Financial Managers is estimated to $139,060.57 annually.

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

There are no operation and maintenance, or capital and start-up costs associated with this the collection of information.

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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Note change to cost to the Federal Government below.



Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]	N/A
Staff Salaries [ Four GS 12 step 1 employees spending approximately 5 % of time annually processing information for this data collection] $74,872 x 5% x 1.4 x 5 employees = $14,974	$14,974
Facilities [cost for renting, overhead, ect. for data collection activity]	N/A
Computer Hardware and Software [cost of equipment annual lifecycle]	N/A
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	N/A
Travel 3 persons traveling 3 times a year = $1,500 x 3 = $4,500	$4,500
Printing [number of data collection instruments annually]	N/A
Postage [annual number of data collection instruments x postage]	N/A
Other [Training conducted in regions on the mission assignment process] 3 GS 12 Step 1 employees spending 2% of their time conducting the training: $74,872 x 2% x 1.4 x 3 employees = $6,289	$6,289
Total	$25,763

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal government action. These changes that result from new estimates or actions not controllable by the Federal government are recorded as adjustments. See descriptions below each chart for changes.

 A "Program increase" is an additional burden resulting from an federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
Action Request Form / FEMA Form 010-0-7				196	2,133	+1,937
FEMA Form 010-0-8 / Mission Assignment				653	160	-493
Training / No Form				896	160	-736
Total(s)				1,745	2,453	+708

Explain:

FEMA Form 010-0-7 has an adjustment increase in the number of annual hours burden due to the increased in estimate of the number of Action Request Forms received during disaster annually. This increase has resulted from State’s filing more requests to issues that arise from a disaster. The prior hour burden was 196 hours, and the new hour burden is 2,133 for an increase of 1,937 hours.

FEMA Form 010-0-8 has an adjustment decrease due to the better estimation of the number of Action Request Forms that actually result in an approval for a Mission Assignment during a disaster. The prior annual hour burden was 653 hours; the requested annual hour burden is 160 hours resulting in a decrease of 493 hours.

The training has also had an adjustment decrease due to the better estimation of the number of States affected by disaster declarations in a year. The new estimate is 160 hours and the previous estimate was 896 hours, a decrease of 736 hours.

There has been no change to the information being collected.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
FEMA Form 010-0-7 / Action Request Form				$22,979	$120,919.77	+$97,940.77
FEMA Form 010-0-8 / Mission Assignment				$6,897	$9,070.40	+$2,173.40
Training / No Form				$31,530.55	$9,070.40	-$22,460.15
Total(s)				$61,406.55	$139,060.57	+$77,654.02

Explain:

For FEMA Form 010-0-7, there is an adjustment increase in the annual cost burden due to the application of the 1.4 multiplier to the wage rate and due to the increase in the number of responses. The current approved cost is $22,979; the requested cost is $120,919.77 resulting in an increase of $97,940.77.

For FEMA Form 010-0-8, there is an adjustment increase in the annual cost burden due to the application of the 1.4 multiplier to the wage rate and a decrease due to the reduction in the number of responses. The current approved cost is $6,897; the requested cost is $9,070.40 resulting in an increase of $2,173.40.

The training, there is an adjustment decrease in the annual cost burden due to the lower estimate of the number of state respondents participating in the training even after taking into account the application of the 1.4 multiplier. The current approved cost is $31,530.55; the requested cost is $9,070.40 resulting in a decrease of $22,460.15.