2900-0661 justification

2900-0661 justification.docx

Forms for Grants to States for Construction and Acquisition of State Home Facilities

OMB: 2900-0661

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Forms for Grants to States for Construction & Acquisition of State Home Facilities

(Documents and Information Required for State Home Construction & Acquisition Grants)

VA Form(s) 10-0388

2900-0661


The cover includes a second page for State Home Construction Grant forms that lists each form, its purpose and how it is to be used.


A. JUSTIFICATION


1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.


38 U.S. Code Sections 8133(a) and 8135(a) authorize and appropriate expenditure of funds for State Home Domiciliary, Nursing Home, and Hospital Care. These portions of the USC require among other things that the State applicant provide the Department of Veterans Affairs (VA) with an application.


2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.


Only state governments will submit this information to complete an application for the State Home Construction Grant Program; private groups or citizens are not eligible. States may either obtain printed copies of the forms or electronically download the required package of forms. These forms are then completed and the applications submitted to the VA by mail with the original signatures. The signed forms provide state certification of compliance with VA grant requirements. VA will use this information, along with other documents submitted by the states, to determine the feasibility of the projects for VA participation, determine eligibility for a grant award and raking on the annual fiscal year priority list that is signed by the Secretary of the Department of Veterans Affairs.


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 described any consideration of using information technology to reduce burden.


These forms will be accessed and downloaded at the One-VA Forms Site (http://vaww4.va.gov/vaforms/), the Program Office Site (http://www.va.gov/geriatricsshg/) and http://www.grants.gov Standard Forms (SF 424, Application for Federal Assistance, SF 424C, Budget Information - Construction Programs, and SF 424D, Assurances Construction Programs) will be available through links at these sites. It is not cost effective to make these low use forms fillable on-line. Additionally, until we have the capability to utilize electronic signatures, signed forms must be mailed to the VA. These signed forms will provide State certification of compliance with VA grant requirements. VA will use this information, along with other documents submitted by the States to determine the feasibility of the project for VA participation and to rank the projects in establishing the annual fiscal year priority list. The priority list is the mechanism the VA uses to commit to State Home construction projects during the various fiscal years. This innovation has lessened the burden on the applicants and also on the Federal government and has improved consistency of the submissions.

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.


The information provided by the various States to the program requirements is unique for each application and there is no duplication.


5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


As these are submitted by State Governments, no small businesses or other small entities are impacted by this information collection.


6. Describe the consequences 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.


This information is collected only when a state government wishes to apply to for a State Home Construction Grant. If this information was collected less frequently, VA would be unable to perform its statutory obligation to administer the program.


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


There are no such special circumstances


8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’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 sponsor in responses to these comments. Specifically address comments received on cost and hour burden.


The notice of Proposed Information Collection Activity was published in the Federal Register on May 11, 2011, page 27385. We received no comments in response to this notice.


b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.


In discussing the reporting format, VA meets, at least quarterly, with stakeholders in the discussion and sharing of program information and the development of future data collection efforts. The VA Form package is available at (http://www4.va.gov/vaforms/) and (http://www.va.gov/geriatricsshg/).


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


No payment or gift is provided to respondents.


10. Describe any assurance of privacy, to the extent permitted by law, that is provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


Not Applicable. Information requested is not patient specific.


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; include 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.


There are no questions of a sensitive nature.


12. Estimate of the hour burden of the collection of information:


We project 50 new applications annually, submitted by various states. The application package requires approximately 24 hours to provide the requested information and complete all of the forms for an annual total of 1200 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.


This request covers 12 forms


10-0388-1: 6 hours

Documents and Information Required for State Home Construction and Acquisition Grants-Initial Application

10-0388-2: 1 hour

Certification of Compliance with Provisions of Davis-Bacon Act, (40 U.S.C. Sections 276a to 276a-7)

10-0388-3: 2 hours

State Home Construction Grant Program – Space Program Analysis – Nursing Home & Domiciliary

10-0388-4: 2 hours

State Home Construction Grant Program – Space Program Analysis – Adult Day Health Care

10-0388-5: 6 hours

Additional Documents and Information Required for State Home Construction and Acquisition Grants Application

10-0388-6: 1 hour

Certification of State Matching Funds to Qualify for Group 1 on the Priority List

10-0388-7: 1 hour

Certification Regarding Debarment, Suspension, and other Responsibility Matters – Primary

Covered Transactions

10-0388-8: 1 hour

Certification Regarding Drug-Free Workplace Requirements for Grantees Other Than Individuals

10-0388-9: 1 hour

Certification Regarding Lobbying

10-0388-10: 1 hour

Certification of Compliance with Federal Requirements-State Home Construction Grant

10-0388-12: 1 hour

Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion – Lower Tier Covered Transactions

10-0388-13: 1 hour

Documents and Information Required for State Home Construction and Acquisition Grants – Post Grant Requirements


c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. 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.


The cost to the respondents for completing these forms is $1,104 per application (24 burden hours x $46 per hour). We do not require any additional recordkeeping.


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).


a. There is no capital, start-up, operation or maintenance costs.

b. Cost estimates are not expected to vary widely. The only cost is that for the time of the respondent.


c. There are no anticipated capital start-up cost components or requests to provide information.


14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.


The cost to the Federal government is included in the overall management of the State Home Construction Grant Program; which has a dedicated staff for program operations.


15. Explain the reason for any burden hour changes since the last submission.

The previous forms incorrectly estimated burden hours and forms have been revised to be easier to use in order to reduce burden on the states. The number of applications has been reduced from 60 to 50; however the time to complete the package increased from 6, which was previously miscalculated, to 24 hours.


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.


We do not plan to publish this data.


17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


We do not seek approval to eliminate the expiration date from the forms.


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


There are no exceptions.


B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS


No statistical methods are used in this data collection.


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