Final Supporting Statement 3150-0109 (2)

FINAL SUPPORTING STATEMENT FOR

BILLING INSTRUCTIONS FOR NRC COST TYPE CONTRACTS

(3150-0109)

EXTENSION

Description of the Information Collection

The U.S. Nuclear Regulatory Commission’s Office of Administration, Division of Contracts (DC), in administering its contracts, provides contractors with Billing Instructions to follow when preparing invoices to ensure billed costs are proper for payment (Enclosure). These instructions stipulate the level of detail in which supporting cost data must be submitted for the NRC review of costs billed. Included with the instructions, for contractor reference, is a sample format that can be used when preparing the voucher/invoice. The contractor may submit a voucher/invoice in alternate formats provided all requirements of the billing instructions are addressed.

1. Need for the Collection of Information

The cost information is needed for license fee recovery and to ensure costs incurred are allowable and allocable and that the amount requested is proper for payment.

2. Agency Use of Information

Vouchers/invoices and supporting documentation are reviewed by the National Business Center (NBC) of the Department of the Interior, DC, and the NRC Contracting Officer’s Representative (COR). Taken together, the review ensures costs are billed per the contract rates and the costs incurred are commensurate with work performed. The instructions provide contractors with a clear idea of the level of detail required to support their voucher/invoice submissions. Receipt of properly prepared vouchers/invoices expedites the review process and permits prompt payment.

3. Reduction of Burden Through Information Technology

There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. NRC issued a regulation on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e‑mail, special Web-based interface, or other means.

To reduce the burden on contractors, contractors were requested, effective May 1, 2008, to electronically submit all vouchers/invoices to the NBC. However, contractors still have the option of submitting a hardcopy voucher/invoice. Voucher/invoices are submitted electronically 100 percent of the time.

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4. Effort to Identify Duplication Use Similar Information

No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.

5. Effort to Reduce Small Business Burden

The collection represents the minimum information required for submission of a proper voucher/invoice and required supporting documentation required for review in order to ensure costs billed are proper for payment.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not

Conducted or is Conducted Less Frequently

Contractors are required to complete and submit vouchers/invoices and attachments once each month unless otherwise authorized by the Contracting Officer. The consequence of not collecting the data, or of less frequent collection, would be withholding of reimbursement to the contractor of costs incurred as the work progresses. The provisions of Federal Acquisition Regulation (FAR) Clause 52.216-7, require payment be made upon request, but (except for small business concerns) not more often than once every two weeks.

7. Circumstances Which Justify Variation From OMB Guidelines

To ensure prompt payment is made to the contractor, the contractor must electronically submit a proper voucher/invoice, including supporting documentation, which is reviewed and approved by NBC. If it is determined that the voucher/invoice was properly prepared, payment will be made 30 calendar days from receipt of the proper voucher/invoice. If it is determined that the voucher/invoice is not proper, payment will be made 30 calendar days from receipt of the proper invoice. This procedure ensures compliance with the requirements of the Prompt Payment Act, as amended. Additionally, consistent with the guidance in the Office of Management and Budget’s September 14, 2011 memorandum titled “Accelerating Payments to Small Businesses for Goods and Services,” small business payments are generally made within 15 days of receipt of a proper invoice/voucher.

The agency-designated billing office for submittal of the voucher/invoice is the NBC. The payment process begins once NBC electronically receives a proper invoice. NBC sends the voucher/invoice electronically to the COR and DC for review and approval. The COR reviews and approves the electronic copy, and then it is electronically sent to DC for final review and approval. After DC reviews and approves the voucher/invoice, it is electronically sent to NBC for final processing (payment).

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8. Consultation Outside the NRC

Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on April 4, 2012 (77 FR-20437). No comments were received.

9. Payment or Gift to Respondents

None

10. Confidentiality of Information

Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).

11. Justification for Sensitive Questions

Normally sensitive information considered private or personal is not required or requested. This information is only required when contracts containing sensitive material are processed. Proprietary data is protected under the Freedom of Information Act and 10 CFR Part 9.

12. Estimate of Burden and Burden Hour Cost

The burden estimates for this information collection are based on a projected 34 active contracts (i.e., 34 respondents). These 34 contracts are divided into the following type of contracts:

• 18 contracts have no task orders (TOs) associated with them, and are billed monthly (i.e., 12 bills annually).

• Three contracts have TOs which are for projects not related to license fees, and have a total of 16 TOs and an average of four billings annually per TO.

• 13 contracts have TOs for license fee recoverable projects with a total of 119 TOs and an average of four billings per TO.

• The 13 contracts listed above require an additional 239 hours for contractors to prepare the License Fee Recovery Cost Summary, which has a total of 119 TOs and is prepared an average of four times per year.

The total hourly reporting burden for this collection is 618 hours, which is described in the table below.

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ANNUAL REPORTING REQUIREMENTS

Contract/Task Order Type	Number of Contracts	Avg. # Invoices per TO	Annual Responses per Respondent	Total # Responses	Burden per Response (Hours)	Total Annual Burden Hours	Cost @ $274/Hr.
NRC Cost Type Contracts
No Task Order or License Fee Recovery Contract	18	NA	12	216	0.5	108	$29,592
Task Order – Not License Fee Related	3	5.3	4	64	0.5	32	$8,768
Task Order – License Fee Related	13	9.2	4	478	0.5	239	$65,486
License Fee Recovery Cost Contracts
Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders	13	9.2	4	478	0.5	239	$65,486
Total	34			1236		618	$169,332

The license fee recovery section of the billing instructions is included in cost type contracts that include fee recoverable work. The section on licensing fee costs generally applies to TO contracts for plant inspections, licensing actions or other site-specific activities.

13. Estimate of Other Additional Costs

The NRC has determined that the quantity of records to be maintained is roughly proportional to the recordkeeping burden and, therefore, can be used to calculate approximate records storage costs. Based on the number of pages maintained for a typical clearance, the records storage cost has been determined to be equal to 0.0004 times the recordkeeping burden cost. Because the recordkeeping burden is estimated to be 0 hours, the storage cost for this clearance is $0.00 (0 hours x 0.0004 x $274/hour).

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14. Estimated Annualized Cost to the Federal Government

These costs are fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171. Total cost to the agency is $273,178.

Estimated Annual Cost to the Federal Government

Contract/Task Order Type	Number of Contracts	Avg. # Invoices per TO		Annual Responses per Respondent	Total # Responses	Burden per Response (Hours)	Total Annual Burden Hours	Cost @ $274/Hr.
NRC Cost Type Contracts
No Task Order or License Fee Recovery Contract	18	NA		12	216	1.0	216	$59,184
Task Order – Not License Fee Related	3	5.3		4	64	1.0	64	$17,536
Task Order – License Fee Related	13	9.2		4	478	1.0	478	$130,972
License Fee Recovery Cost Contracts
Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders	13	9.2	4		478	0.5	239	$65,486
Total							997	$273,178

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15. Reasons for Changes in Burden or Cost

The number of responses decreased from 2,404 to 1,236 and the number of burden hours decreased by 584 (from 1,202 to 618 hours) due to a decrease in the number of cost type contracts projected within the next 3 years (from 64 to 34). The projected decrease is largely due to decreased use of this contract type. Specific changes are described below:

• Contracts which have no TOs or license fee recovery associated with them and provide for monthly billing are expected to decrease by 27 contracts (from 45 to 18).

• TOs associated with the three contracts not license fee recoverable are expected to decrease by 60 (from 76 total TOs to 16 total TOs.)

• TOs associated with the 13 contracts with recoverable license fees are expected to decrease by 76 (from 195 total TOs to 119 total TOs.)

Also, due to the decrease in the number of active cost type contracts (from 64 to 34), annual reporting costs decreased (from $286,076 to $168,714) and estimated annual cost to the Government decreased (from $479,332 to $273,178), notwithstanding an increase in the cost for professional effort from $238 to $274 per hour.

16. Publication for Statistical Use

Results will not be tabulated or published.

17. Reason for Not Displaying the Expiration Date

The OMB clearance expiration date is displayed.

18. Exceptions to the Certification Statement

Not Applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

The collection of information does not employ statistical methods.