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SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) TITLE OF THE INFORMATION COLLECTION

Contractor Cumulative Claim and Reconciliation (Renewal), EPA Form 1900-10. Information Collection Request (ICR) 0246.11, OMB Control No. 2030-0016.

(b) SHORT CHARACTERIZATION/ABSTRACT

The Federal Acquisition Regulation (FAR) 4.804-5 states that the office administering a contract is responsible for initiating administrative close out following physical completion of the contract. Funds status review is a mandatory part of contract closeout. It includes settlement of interim or disallowed costs and settlement of indirect cost rates.

Under a cost reimbursement type contract, when the contract is completed, the contractor submits EPA Form 1900-10 which summarizes all cost incurred in performance of the contract and sets forth the final indirect rates. This form is reviewed by the contracting office to determine the final costs reimbursable to the contractor. A copy of the form is attached to this request.

2. NEED FOR AND USE OF THE COLLECTION

(a) NEED/AUTHORITY FOR THE COLLECTION

FAR 52.216-7 states that the Government will pay only the costs determined to be allowable by the contracting officer in accordance with FAR 31.2. Furthermore, FAR 52.216-7 states that indirect cost rates shall be established for each fiscal year at the close of a contractor’s fiscal year. EPA Form 1900-10 summarizes this information for the entire contract period and provides a basis for cost review by contracting, finance, and audit personnel. As stated previously, FAR 4.804-5 mandates that the office administering the contract shall ensure that the costs and indirect cost rates are settled.

(b) PRACTICAL UTILITY/USERS OF THE DATA

Information collected on the 1900-10 will be used by the contracting, financial, and audit personnel to determine the final amount of costs reimbursable to the contractor. EPA personnel and auditors from the Defense Contract Audit Agency (DCAA), if requested, will review the information in order to determine the final contract costs prior to final payment under the contract.

3. NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

1. NON DUPLICATION

Information collected is contract-specific. Cumulative contract cost information, as requested, is not available from any other source.

2. PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

The Federal Register document required under 5 CFR 1320.8(d), soliciting comments on this collection of information was published on 12/28/2011 (76 FR 81490).

3. CONSULTATIONS

Nine vendors who had cost type contracts with EPA which expired within the past five years were contacted to discuss collection activities.

4. EFFECTS OF LESS FREQUENT COLLECTION

The information is collected only once at contract closeout. This information is required by the Federal Acquisition Regulation to be collected at that time.

5. GENERAL GUIDELINES

This information collection meets all OMB guidelines with the exception of two: (1) small entities have to follow the same collection procedures as other respondents and (2) Confidential Business Information (CBI) is requested. Item one is addressed in paragraph 4(c). CBI is protected from release to the public by 40 CFR Part 2.

6. CONFIDENTIALITY

Information collected under this request, particularly cost and pricing data, is treated as CBI. This information is protected from public release in accordance with the Agency's confidentially regulation, 40 C.F.R. Part 2.201 et seq.

7. SENSITIVE QUESTIONS

Information collected under this request is treated as CBI and is protected from public release in accordance with the Agency's confidentially regulation, 40 C.F.R. Part 2.201 et seq.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

(a) RESPONDENTS/NORTH AMERICAN INDUSTRY CLASSIFICATION (NAICS) CODES

All contractors who have completed an EPA cost reimbursement type contract will be required to submit EPA Form 1900-10. These contractors represent a wide range of industries which include, but are not limited to: 541511, Custom Computer Programming, 5416 Management and Consulting Services, 6215 Medical Laboratories, and 541380, Testing Laboratories.

(b) INFORMATION REQUESTED

(i) DATA ITEMS

Data requested in EPA Form 1900-10 (attached) has not changed since the last OMB review. This information includes major cost elements such as direct labor, direct material and supplies, equipment, travel, subcontract costs, consultant fees, indirect costs and fixed fees. Indirect costs are broken down showing base year and rate for each cost center for each year of contract performance.

Please note that EPA has omitted the expiration date from form 1900-10. As stipulated in 5 CFR 1320.8(b)(1), the collection of information should display a currently valid OMB Control Number and, if appropriate, an expiration date. Due to the fact that this form has been in use for a number of years without change, and since the collection activity and use of the form continue to be required, it is not appropriate to include the expiration date on the form.

(ii) RESPONDENT ACTIVITIES

In order to complete the EPA Form 1900-10, respondents must total all cost incurred under the contract, including costs for direct labor, all equipment, materials and supplies, travel, subcontracts, consulting fees, indirect costs, and fees. During contract performance, this information is included on the contractor’s monthly invoice for reimbursement. To calculate total contract costs, the contractor adds the cost from each invoice submitted under the contract. If costs were claimed on an invoice that was disallowed, the contractor would subtract the disallowed amount from the total.

Negotiated indirect cost rates are applied to the base costs in order to determine the indirect costs for each cost center. This information is also contained in the contractor’s invoices, and in correspondence concerning allowable costs and negotiated agreements on indirect rates. None of the information collected under this ICR must be created or researched. Rather, the data is compiled from various existing sources and summarized for this information collection. After the data is compiled, it must be reviewed for accuracy against existing records. It is customary business practice for a contractor to maintain the type of financial performance information required to complete EPA Form 1900-10.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

(a) AGENCY ACTIVITIES

Once EPA Form 1900-10 is reviewed by the Agency, the data is reconciled with Agency records, and audited. If the information collected is correct, final contract payment is made.

(b) COLLECTION METHODOLOGY AND MANAGEMENT

Information submitted is checked against Agency records such as invoices, correspondence, and negotiated agreements. Respondents have the option of reporting in their own computerized format provided all the required data is present. Completed forms, after review, become part of the contract files and will not be disclosed outside the Government.

(c) SMALL ENTITY FLEXIBILITY

Data requested is required by the Federal Acquisition Regulation. It is not possible to develop separate or simplified requirements for small businesses or other small entities because the information required is necessary to complete the closing out of a contract, an alternate collection of information for small businesses is not appropriate.

(d) COLLECTION SCHEDULE

Data is collected once at contract completion. Generally, this is after a five year period of performance.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

(a) ESTIMATING RESPONDENT BURDEN

Vendors indicated that the information required in completion of this form is financial information that is routinely kept for company records.

(b) ESTIMATING RESPONDENT COSTS

(i) Estimating Labor Costs

The annual labor cost to respondents is estimated at $9,001.80 based on the following calculations. Contractors may claim the cost of completing this form under the appropriate contract.

ACTIVITY TIME TO COMPLETE RATE COST

1. Gather information 180.0 minutes $113.96 $341.88

2. Compile data 27.5 minutes $113.96 $ 52.23

3. Review data 27.5 minutes $113.96 $ 52.23

4. Enter data onto form 5.0 minutes $45.10 $ 3.75

Total 240 minutes $450.09

Step 1 thru 3 of the collection activity is performed by an administrative manager. Administrative support personnel are responsible for completing step 4.

The cost associated with this effort was estimated using a loaded hourly rate based upon the Occupational Employment Statistics: Occupational Employment and Wages, May 2010; published by the U.S. Department of Labor, Bureau of Labor Statistics. This data represents the most current survey data available. The median hourly wage for each labor group was used in the computations.

Since the labor rates from the Occupational Employment and Wages are from 2010, an escalation factor of 3% (based on the Consumer Price Index published by the U.S. Department of Labor, Bureau of Labor Statistics) was applied for each year to determine an average wage for 2011. The escalated hourly labor rate is multiplied by an estimated loading factor of 2.95 (*see below) to reflect industries’ overhead, fringe benefits, and general and administrative costs.

The following are the loaded labor rates used in the calculations in the table above:

Administrative Service Manager (11-3011):

2010 = $37.45

2011 = ($37.45 x 1.03) = $38.63 x 2.95 = $113.96

Administrative Support (43-6014):

2010 = $14.82

2011 = ($14.82 x 1.03) = $15.29 x 2.95 = $45.10

* 2.95 is a factor recommended by EPA cost analyst as representative of labor related burdens experienced by EPA contractors.

The cost for each labor category was determined by first dividing the hourly labor rate by 60 minutes to obtain the per minute rate. Then the per minute rate is multiplied by the minutes to complete each activity, to obtain the cost.

EPA processes approximately 20 contract closeouts annually, using EPA Form 1900-10. As indicated above, each form takes 240 minutes, or about 4 hours to complete. The 20 annual actions, multiplied by the cost to process one action, $450.09, are used to determine the above annual cost burden to the respondents. The 20 annual actions, multiplied by 4 hours equates to an annual hourly burden of 80 hours. The amount of time required to complete each of the tasks involved is based on consultations with contractors, contractor consultation with their subcontractors and Agency experience. Also respondents have pointed out that the complexity of the contract to be closed out and the timeliness of consulted subcontractors increases the amount of time needed to gather the required information. Most firms keep all of their financial data required for completion of this form in a computer database.

(ii) Capital/Start-up Costs

Because it will not be necessary for respondents to acquire any capital goods to provide the requested information, EPA included no capital or start-up costs in the burden estimate.

(iii) Operating and Maintenance Costs

Operating and Maintenance Costs, which include such items as file storage,

photocopying, and postage, are minimal for this effort, and are estimated at $13.20 per action for a total annual burden of $264.00 (20 annual actions x $13.20).

(c) ESTIMATING AGENCY BURDEN & COST

Once the Agency receives the information, it is reviewed by the employee conducting contract close-out. Annual Agency burden is estimated at $523.60 calculated as follows:

ACTIVITY TIME REQUIRED RATE COST

1. Review data against 30 minutes $52.37 $26.18

Agency records

Generally, the individual closing out the contract is a GS-12 grade level. The wage rate was calculated by taking the GS-12 median hourly rate ($32.73) and multiplying it by a factor of 1.6 to account for benefits. The cost per action was determined by first dividing the hourly labor rate by 60 minutes to obtain the per minute rate. Then the per minute rate is multiplied by the minutes to complete the review of one action to obtain the cost. As described above, 20 annual actions were multiplied by the cost, $26.18, to review an action in order to calculate the Agency burden.

(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COSTS

(e) BOTTOM LINE BURDEN HOURS AND COST TABLES

(f) REASONS FOR CHANGE IN BURDEN

The increase in the burden from the previous approval is due to the inflation rate of approximately 10% since 2007. The total number of hours is unchanged.

(g) BURDEN STATEMENT

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 240 minutes per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OARM-2011-0997, which is available for public viewing at the Office of Environmental Information (OEI) Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the OEI Docket is (202) 566-1752. An electronic version of the public docket is available through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket . Use EDOCKET to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once in the system, select “search,” then key in the docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OARM-2011-0997 and OMB Control Number 2030-0016 in any correspondence.

EPA Form 1900-10 (Rev. 3-06)

Previous Edition is Obsolete

EPA United States Environmental Protection Agency Contractor's Cumulative Claim and Reconciliation					OMB No. 2030 - 0016
1. Contractor's Address (include zip code)					2. Contract No.
3. Total amounts claimed under this contract (less disallowances concurred by the contractor and disallowances not subject to appeal) and approved on Public Vouchers Nos. to (including completion vouchers).
Item					Amount
Direct Labor					$
Direct Material and Supplies					$
Equipment					$
Travel					$
Subcontract Costs					$
Other Direct Costs					$
Consultant Fees					$
Fixed Fee					$
Indirect Costs (Total From Section 4)					$
Total Amount Claimed					$
4. Reconciliation of Indirect Costs Claimed. Record the amount of indirect costs calculated, for each cost center, using negotiated final indirect cost rate(s). Use provisional rate(s) if final rates are not negotiated for any fiscal year period(s). Use the reverse side of this form, if necessary, to display all years and cost centers.
	Cost Center	Cost Center		Cost Center		Cost Center	Cost Center
FY­
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
Totals
No monies or other benefits may be paid unless this report is completed and filed as required in the EPA billing instructions.
I certify that the information provided on this form and attachments thereto are accurate and complete. I acknowledge that any knowingly false or misleading information may be punishable by fine and/or imprisonment under applicable law.
Name and Title (Print or Type)			Signature					Date

Paperwork Reduction Act Notice Public reporting burden for this collection of information is estimated to average 240 minutes per response, including the time for searching existing data sources, gathering and maintaining data, and completing and reviewing data. Send comments regarding this burden estimate or any other aspect of this collection of information (including suggestions for reducing this burden) to: (1) Manager, Policy and Oversight Service Center (mail code 3802R) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460; and Paperwork Reduction Project (OMB No. 2030-0016) Office of Information and Regulatory Affairs Office of Management and Budget Washington, DC 20503. Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, D.C. 200503.
	Cost Center	Cost Center	Cost Center	Cost Center	Cost Center
FY
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
FY­
Base
Rate
Indirect Costs
Totals
No monies or other benefits may be paid unless this report is completed and filed as required in the EPA billing instructions.

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