HUDQC OMB Section A

OMB Clearance Package
Quality Control for Rental Assistance Subsidy
Determinations

Submitted by:
Office of Policy Development and Research
Department of Housing and Urban Development
Washington, DC 20410

Prepared by:
ICF Macro
530 Gaither Road
Rockville, MD 20850

Updated February 10, 2014
Original Submission October 18, 2013

Table of Contents
A.

JUSTIFICATION ..................................................................................................................1
1.

Circumstances that make the collection of information necessary ..................................... 1

2.

Use of information .............................................................................................................. 3

3.

Information technology....................................................................................................... 4

4.

Efforts to identify duplication ............................................................................................. 5

5.

Minimization of burden on small entities ........................................................................... 5

6.

Consequences of not collecting the information ................................................................. 6

7.

Special circumstances ......................................................................................................... 6

8a. Federal Register notice ....................................................................................................... 6
8b. Consultation with persons outside the agency .................................................................... 7
9.

Payments or gifts to respondents ........................................................................................ 7

10. Confidentiality .................................................................................................................... 7
11. Justification of questions..................................................................................................... 8
12. Hour Burden...................................................................................................................... 10
13. Cost burden ....................................................................................................................... 13
14. Annualized costs to Federal Government ......................................................................... 13
15. Program changes or adjustments ...................................................................................... 14
16. Plans for tabulation and publication ................................................................................. 14
17. Non-display of expiration date.......................................................................................... 15
18. Exception to certification statement.................................................................................. 15
B.

COLLECTIONS OF INFORMATION EMPLOYING
STATISTICAL METHODS ...............................................................................................16
1.

Respondent universe and sampling methods .................................................................... 16

2.

Procedures for collection of information .......................................................................... 18

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3.

Maximization of response rates ........................................................................................ 26

4.

Tests of procedures or methods ........................................................................................ 29

5.

Individuals consulted on statistical aspects of design ....................................................... 29

Appendix A

Federal Register Notice

Appendix B

Acceptable Practices Terms and Agreement for the FY 2013 Study

Appendix C

Project-Specific Information Cover Letters
Project-Specific Information Forms

Appendix D

Household Questionnaire Letter to Tenants
Household Questionnaire Data Collection Instrument

Appendix E

Project Staff Questionnaire Cover Letter
Project Staff Questionnaire

Appendix F

Third-party Verification Release Letter
Third-party Verification Forms

Appendix G

Analysis Plan

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A.

JUSTIFICATION

1.
Circumstances that make the collection of information necessary
Explain the circumstances that make the collection of information necessary. Identify legal or
administrative requirements that necessitate the collection of information.
Introduction
The U.S. Department of Housing and Urban Development (HUD) has been conducting
comparable Assisted Housing Quality Control (QC) error measurement studies since 2000. The
findings from the most recent study (for Federal FY 2012) indicate that subsidies for 28 percent
of households receiving assistance through the Public Housing and Section 8 programs contain
some type of error resulting in $246 million dollars in net annual erroneous payments. This is a
great improvement over the findings from the 2000 study according to which at least 56 percent
of the subsidies for households receiving housing assistance contained some type of error
resulting in more than $1 billion in net annual erroneous payments. HUD continues to need
information that will help sharpen its management efforts to correct the most serious of such
errors and meet the requirements of the Improper Payments Act of 2002 (IPIA) and the Improper
Payments Elimination and Recovery Act of 2010 (IPERA).
The quality control studies will provide HUD with updated estimates on the type, severity, and
cost of errors in the income certification and recertification, and rent calculation process. It will
also analyze changes in the type and severity of such errors since the previous studies. This
information, along with other HUD efforts, will provide HUD with mechanisms to improve
determinations of assisted-housing tenants’ income, rent, and subsidy amounts. HUD will use the
findings from this study to focus efforts on correcting the most serious errors and determine the
effectiveness of corrective measures.
Authorization to Collect Information
The collection of survey data by HUD is authorized under the Housing and Urban Development
Act of 1970 (12USC 1701z-1):
Sec. 501. The Secretary of Housing and Urban Development is authorized and
directed to undertake such programs of research, studies, testing, and
demonstration relating to the mission and programs of the Department as he
determines to be necessary and appropriate.
Sec. 512(g). The Secretary is authorized to request and receive such information
or data as he deems appropriate from private individuals and organizations, and
from public agencies. Any such information or data shall be used only for the
purposes for which it is supplied, and no publication shall be made by the
Secretary whereby the information or data furnished by any particular person or
establishment can be identified, except with the consent of such person or
establishment.
Sec. 210 of the Housing and Community Development Amendments of 1979 states—
The Secretary shall establish procedures which are appropriate and necessary to
assure that income data provided to public housing agencies and owners by
families applying for or receiving assistance under this section is complete and
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accurate. In establishing such procedures, the Secretary shall randomly, regularly,
and periodically select a sample of families to authorize the Secretary to obtain
information from these families for the purposes of income verification, or to
allow those families to provide such information themselves. Such information
may include, but is not limited to, data concerning unemployment compensation
and Federal income taxation and data relating to benefits made available under the
Social Security Act, the Food Stamp Act of 1977, or title 38, United States Code.
Any such information received pursuant to this subsection shall remain
confidential and shall be used only for the purpose of verifying incomes in order
to determine eligibility of families for benefits (and the amount of such benefits, if
any) under this section.
Title I, Section 1, Sec. 8(k) of the Housing Act of 1937 as amended [Public Law 93-383, 88 Stat.
633] (42 U.S.C. 1437) states—
The Secretary shall establish procedures which are appropriate and necessary to
assure that income data provided to public housing agencies and owners by
families applying for or receiving assistance under this section is complete and
accurate. In establishing such procedures, the Secretary shall randomly, regularly,
and periodically select a sample of families to authorize the Secretary to obtain
information on these families for the purposes of income verification, or to allow
those families to provide such information themselves. Such information may
include, but is not limited to, data concerning unemployment compensation and
Federal income taxation and data relating to benefits made under the Social
Security Act, the Food Stamp Act of 1977, or title 38, United States Code. Any
such information received pursuant to this subsection shall remain confidential
and shall be used only for the purpose of verifying incomes in order to determine
eligibility of families for benefits (and the amount of such benefits, if any) under
this section.
To further institutionalize Federal agency efforts to eliminate improper payments, the President
signed the Improper Payments Information Act (IPIA) of 2002 (Public Law 107-300) into law on
November 26, 2002. The central purpose of the IPIA is to enhance the accuracy and integrity of
Federal payments. To achieve this objective, the IPIA provides an initial framework for Federal
agencies to identify the causes of, and solutions to, improper payments. In turn, guidance issued
by the Office of Management and Budget (OMB) in May of 2003 (Memorandum 03-13) requires
agencies to: (i) review every Federal program, activity, and dollar to assess risk of significant
improper payments; (ii) develop a statistically valid estimate to measure the extent of improper
payments in risk susceptible Federal programs; (iii) initiate process and internal control
improvements to enhance the accuracy and integrity of payments; and (iv) report and assess
progress on an annual basis.
More recent OMB guidance, issued as Part III to OMB Circular A-123, Appendix C (M-10-13),
reinforces the need for Federal agencies to reduce improper payments and establish reporting
requirements. Most recently the President signed the Improper Payment Elimination and
Recovery Act (IPERA) of 2010 (Public Law 111-204) into law on July 22, 2010 which further
amended the IPIA by providing guidance to improve agency efforts to reduce and recover
improper payments.

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2.
Use of information
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.
HUD will use the information to identify the amount and source of error and to recommend
corrective measures that can be taken to reduce the amount of error in eligibility determinations
and rent calculations. HUD and its agents need information concerning the type and severity of
errors that are occurring in order to construct effective remedies. If those data are not collected,
no assessment as to the amount and type of errors can be made nor can corrective actions be
developed and implemented. Without such corrective action it is believed that a portion of HUD
findings subsidies will be misused. For example, the FY 2012 study (the most recent study with
published findings) found various net payment errors, detailed below.
All summary error estimates represent the summation of net case-level errors. That is, a
household is determined to have a net overpayment error, no error, or a net underpayment error.
Major findings were—
Rent underpayments of approximately $522.5 million annually (up from $469.5 million in
FY 2011). For tenants who paid less monthly rent than they should pay (16%), the average
monthly underpayment was $60. For purposes of generalization, total underpayment errors
spread across all households (including those with no error and overpayment error) produces a
program-wide average monthly underpayment error of $9 ($110 annually). Multiplying and
weighting the $110 by the approximately 4.7 million units represented by the study sample
results in an overall annual underpayment dollar error of approximately $522.5 million per year.
• Rent overpayments of approximately $276.3 million annually (up from $225.7 million in
FY 2011). For tenants who paid more monthly rent than they should pay (12%), the average
monthly overpayment was $39. When this error is spread across all households it produces an
average monthly overpayment of $5 ($60 annually). Multiplying and weighting the $60 by the
approximately 4.7 million assisted housing units represented by the study sample results in an
overall annual overpayment dollar error of approximately $276.3 million per year.
• Aggregate net rent error of $246.2 million annually. When combined, the average gross rent
error per case is $14 ($9 + $5). Over- and underpayment errors partly offset each other; the net
overall average monthly rent error is -$4 (-$9 + $5). HUD subsidies for Public Housing and
PHA-administered Section 8 programs equal the allowed expense level or payment standard
minus the tenant rent, which means that rent errors have a dollar-for-dollar correspondence with
subsidy payment errors, except in the Public Housing program in years in which it is not fully
funded (in which case, errors have slightly less than a dollar-for-dollar effect). The study found
that the net subsidy cost of the under- and overpayments was approximately $246.2 million per
year ($522.5 million–$276.3 million).

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Subsidy over- and underpayment dollars are summarized in Exhibit A2.1.
Exhibit A2.1
Subsidy Dollar Error
Subsidy
Overpayment

Subsidy
Underpayment

$60
(16% of cases)

$39
(12% of cases)

$9

$5

$522.5 million

$276.3 million

$393.6-$651.4 million

$206.5-$346.2 million

Type of Dollar Error
Average Monthly Per Tenant Error for Households with Errors
Average Monthly per Tenant Error Across all Households
1

Total Annual Program Errors

Total Annual Errors (95% Confidence Interval)

Exhibit A2.2 provides estimates of program administrator error by program type.
Exhibit A2.2
Estimates of Error in Program Administrator Income
and Rent Determinations (in $1,000’s)
Subsidy
Overpayments

Subsidy
Underpayments

Net Erroneous
Payments

Gross Erroneous
Payments

Public Housing

$118,049

$72,801

$45,248

$190,849

PHA-Administered Section 8

$272,915

$157,801

$115,113

$430,716

Total PHA-Administered

$390,964

$230,602

$160,362

$621,566

Owner-Administered

$131,523

$45,711

$85,811

$177,234

Total

$522,486

$276,313

$246,173

$798,800

95% Confidence Interval

±$128,911

±$69,843

±$144,793

±$148,415

Administration Type

3.
Information technology
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 describe any consideration of using
information technology to reduce burden.
Automation of tenant data collection. We will continue to use the computer-assisted data
collection technology developed for the 2000 study (data was collected for actions taken in 1999
and early 2000) and enhanced for the FY 2003 through FY 2012 studies to gather the majority
of the data from project files and tenants. Our field staff will use laptops with modules designed
specifically for selecting the tenant sample, abstracting tenant file data (including the HUD50058/59 Form), and interviewing the tenant. In addition, automated tracking and data
monitoring systems will ensure that the data and supporting paper documents are collected and
accurate. This approach offers the following advantages:


1

More objective data collection. QC field staff will apply a consistent set of procedures,
questions, and probes. Branching and skip patterns applied by the system will prevent field

Estimates should be viewed in conjunction with 95% confidence intervals. Based on the sample, estimates may
vary from year to year. Variations in estimates may not be statistically significant.
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staff from mistakenly skipping sections, omitting questions, or asking the wrong questions
during the tenant interview.


Onsite editing of abstraction and interview data. The computer-assisted data collection
process will apply logic, consistency checks, and computational checks on all information
provided.



Monitoring of field staff’s productivity and accuracy. Field data, uploaded daily, will be
monitored by ICF Macro’s field supervisors for accuracy to assure HUD of high-quality data
at a reasonable cost.

For each phase of data collection the table below provides the percent of responses that are
collected via an electronic means.
Exhibit A3.1
Percent of Electronic Responses by Data Collection Phase

Phase
I

Respondent Group
PHA/owner

II

Data Collection
Instrument

Estimated
Number of
Survey
Respondents

Percent of
Responses
Collected
Electronically

550

99%

Project-Specific
Information Form
Household File Abstraction

N/A

III

Tenant

Household Interview

IV

PHA/owner

Project Staff
Questionnaire

V

Third Parties (e.g.,
employers, financial
institutions, doctors’ offices)

Third-Party
Verification Forms

2,400

100%

550

99%

3,000

10%

4.
Efforts to identify duplication
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.
There is no duplication of the data to be collected in this study.
5.
Minimization of burden on small entities
If the collection of information impacts small businesses or other small entities, describe any
methods used to minimize burden.
Procedures for the data collection at the primary participating entities (i.e., PHAs/projects) have
been designed to minimize burden as much as possible. Since the data must be collected in a
consistent manner, no special procedures are possible for small entities. Due to the structure of
the smaller entities, it is likely that fewer staff members will have to be contacted at the smaller
entities since one staff member will likely have the responsibility for several management areas
(and therefore be able to answer questions about them) while in larger agencies several staff may
have to be contacted to obtain all the required information.
The only other small entities involved in this study might be a small business (e.g., employer,
pharmacy; doctor’s office) from which we need to collect third-party verification. A verification
request requires only a small amount of information so the burden on any one employer will be
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small. We do not anticipate that any one small business be likely to have more than one request
for third-party verification.
6.
Consequences of not collecting the information
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.
If this data collection did not occur, HUD would be in violation of the Improper Payments
Information Act (IPIA) of 2002 (Public Law 107-300). The central purpose of the IPIA is to
enhance the accuracy and integrity of Federal payments. To achieve this objective, the IPIA
provides an initial framework for Federal agencies to identify the causes of, and solutions to,
reducing improper payments. In turn, guidance issued by OMB in May of 2003 (Memorandum
03-13) requires agencies to: (i) review every Federal program, activity, and dollar to assess risk
of significant improper payments; (ii) develop a statistically valid estimate to measure the extent
of improper payments in risk susceptible Federal programs; (iii) initiate process and internal
control improvements to enhance the accuracy and integrity of payments; and (iv) report and
assess progress on an annual basis. More recent OMB guidance, issued as Part III to OMB
Circular A-123, Appendix C (M-10-13), reinforces the need for Federal agencies to reduce
improper payments and established reporting requirements. The Improper Payment Elimination
and Recovery Act (IPERA) of 2010 (Public Law 111-204) further amends the IPIA by providing
guidance to improve agency efforts to reduce and recover improper payments.
Congress requires an estimation of the rate of improper payments on an annual basis. Differences
in the rate of improper payments that may be the result of changes in the economy or other
factors would need to be identified by primary data collection.
7.
Special circumstances
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, grantin-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.
For two of the data collection instruments – the Project Specific Information Form, and the
Project Staff Questionnaire, we request written responses in fewer than 30 days from receipt.
While we could provide a longer response time, and some PHA/owners take longer to complete
the documents, we find respondents pay more attention to the request if the response time is
shorter rather than longer.
8a. Federal Register notice
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.

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In accordance with the Paperwork Reduction Act of 1995, HUD published a notice in the Federal
Register announcing the agency’s intention to request an OMB review of data collection
activities for the Quality Control for Rental Assistance Subsidy Determinations Study. The
notice was published on September 10, 2013, in Volume 78, Number 175, pages 55,281–55,282
and provided a 60-day period for public comments. A copy of this notice appears in Appendix A.
No public comments have been received to date.
8b. Consultation with persons outside the agency
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.
ICF Macro worked with the consultant listed below who is fully conversant with the HUD
programs included in the study and the policies and procedures of those programs.
Judy Payne
Independent Consultant
Former Executive Director of two housing agencies, and a not-for-profit housing and
development agency.
Phone Number: 208-866-4780
9.
Payments or gifts to respondents
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. Confidentiality
Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
All ICF Macro and data collection staff are required to sign a data confidentiality pledge
associated specifically with this study. A copy of this pledge is located in Appendix B.
During the data collection process, field interviewers ensure confidentiality to sampled tenants
by reading the following text from the tenant consent form:
Confidentiality. All information collected during this study will be kept confidential by the
individual field interviewers who conduct the interviews. The information is transferred to secure
computer systems at the study headquarters. The information will not be shared directly with
staff at your local housing project. However, information identifying you and your household
members, such as names, birth dates, and social security numbers may be provided to HUD
headquarters in Washington, DC. This information is matched with centralized national
databases such as Social Security files that contain information on the income received by
individuals throughout the U.S.

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11. Justification of questions
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.
Almost all questions in the tenant questionnaire concern household income and expenses and
certain characteristics of household members, all of which could be considered to be sensitive
topics. Because the purpose of the study is to measure error in rent and eligibility determinations,
and such determinations are based on household income, expenses, and certain characteristics
(e.g., tenant disability or elderly status, number of dependents), those questions are absolutely
necessary to conduct the rent calculations.
Before the in-person tenant interview, the field interviewer will read aloud the following consent
form.

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Department of Housing and Urban Development
Quality Control for Rental Assistance Subsidy Determinations Study
Household Interview Consent Form

Name of Tenant: _________________________________
Purpose. You have been selected to participate in a research study being conducted by the United States
Department of Housing and Urban Development (HUD). The purpose of this study is to learn more about
the types of errors that occur when determining tenant eligibility and monthly rent in HUD programs so
that improvements can be made. We will be interviewing 2,400 randomly selected households from all
over the United States and Puerto Rico.
Study Procedures. We have already contacted the staff at the local housing office. They provided your
name and allowed us to review the file they created when they determined the amount of rent you pay.
Today, I plan to interview you. The interview will take from 40 to 60 minutes. This interview will include
questions about who lives in your home with you, income received by your household, and any assets or
other expenses you may have. Your responses to the questions will be entered into a laptop computer and
transmitted to the study headquarters where the information will be processed.
Risks and Benefits. Participation in this study will not result in any direct benefit to you. The study
findings will be used to make HUD program changes that will lead to fewer errors when determining
eligibility for housing assistance and calculating the amount of tenant rent. You need to know that if you
do not provide complete and accurate information you may lose your housing assistance. It is possible
(but unlikely) that the PHA/project staff will investigate your situation after this study is completed. This
may result in an increase or decrease in your rent. Also, you may find that some of the questions are of a
personal nature and you may feel uncomfortable answering those questions.
Confidentiality. All information collected during this study will be kept confidential by the individual
field interviewers who conduct the interviews. The information is transferred to secure computer systems
at the study headquarters. The information will not be shared directly with staff at your local housing
project. However, information identifying you and your household members, such as names, birth dates,
and social security numbers may be provided to HUD headquarters in Washington, DC. This information
is matched with centralized national databases such as Social Security files that contain information on
the income received by individuals throughout the United States.
Participant Rights. Persons who receive housing assistance from HUD programs are required to
participate in this study. You agreed to do so when you signed the rental assistance forms. You need to
know that HUD may stop your housing assistance if you choose to not participate in this study or you do
not respond to the questions asked during the interview. If you have questions about this study, you can
talk with the study director using the toll-free number, 877-392-9776.
*******************************
Field Interviewer Certification. By signing this document, you are certifying that you read this
agreement to the respondent and he/she has

□

agreed

not agreed

to participate in the FY 2013 Quality Control for Rental Assistance Subsidy Determinations Study.
Field Interviewer Name: _____________________
Field Interviewer Signature: ____________________________

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Date:

______________

February 10, 2014

Affix C/P/C Label

□

12. Hour Burden
Estimate of the hour burden of the collection of information.
Five phases of data collection activities with three separate groups of respondents are associated
with this study. Phases I and IV entail collecting information from the PHA/owners who
represent the project staff that is responsible for administering the assisted-housing programs.
Approximately five hundred and fifty PHA/owners will be sampled. In earlier executions of this
study, phases I and IV were combined into one phase. With experience we concluded that the
data collection is simplified by splitting the one phase into two (i.e., two instruments: a projectspecific information form and a project staff questionnaire, administered at two separate times).
Phase II of the data collection has no respondent burden. This phase entails a tenant file
abstraction task that is done partially by the data collector on site at the PHA/owner site and
partially by ICF Macro staff at study headquarters. The PHA/owner is not asked to conduct any
recordkeeping or provide any information that is outside the realm of what would normally be
accomplished in administering the assisted housing programs under study.
The second respondent group is that of adult tenants who are members of the sampled
households. In phase III, 2,400 households will be interviewed.
The third respondent group consists of third-party entities from which we are obtaining
verification for tenant characteristics, income, assets and expenses. These entities typically
include employers, financial institutions, state social service agencies, medical providers,
pharmacies and educational institutions.
Phase I Data Collection
Project-Specific Information Form
The project-specific information form is completed via a web survey by the PHA/owner at the
outset of the study. This form, which has four versions based on housing program type, covers
the following topics: project location, project contact information, location of tenant files and
requests for specific values needed to calculate tenant rent (e.g., welfare rent, passbook rates,
gross rent). The version that is used for the voucher program also contains sections on rent
comparability and utility allowances. The survey link is e-mailed to sampled projects for their
completion and return. The estimated burden is 550 respondents x 30 minutes = total burden of
16,500 minutes or 275 hours. Copies of the Project-Specific Information Forms and
accompanying cover letters are located in Appendix C.
Phase II Data Collection
Tenant File Abstraction
Phase II of the data collection has no respondent burden as described above.
Phase III Data Collection
Household Interview
This interview will be conducted with one household member from each of the 2,400 sampled
households to obtain data concerning income, expenses, and household composition to be used

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in identifying rent error. The length of the interview will vary depending on the household’s
circumstances (e.g., an elderly household with income only from Social Security and no medical
expenses would be considerably shorter than an interview with a family in which several
members are employed and that has substantial assets or other unusual circumstances). The
estimated range is from 50 to 60 minutes, or an average of 55 minutes. It is not possible to
reduce this time since all reasonable income sources must be checked for each household. The
estimated burden is 2,400 respondents x 55 minutes = total burden of 132,000 minutes or 2,200
hours. A copy of a paper representation of the computer-assisted personal interview is located in
Appendix D as well as a copy of the letter sent to the tenants informing them of the need to be
interviewed.
Phase IV Data Collection
Project Staff Questionnaire
The Project Staff Questionnaire is administered via a web survey to PHA/owner staff during the
household data collection cycle. This document collects information on the number and types of
staff administering the assisted housing programs, staff training and communication of changes
in HUD policy, quality control procedures, local housing policy, how tenant interviews are
conducted, computer automation, and verification procedures. The estimated burden is 550
respondents x 45 minutes = total burden of 24,750 minutes or 413 hours. A copy of the Project
Staff Questionnaire and accompanying cover letter are located in Appendix E.
Phase V Data Collection
Third-Party Verification
Third-party verification forms are mailed to entities from which we are obtaining verification for
household composition, income, asset and expense items. Each verification form will be
accompanied by a release letter signed by the tenant that authorizes ICF Macro to collect the
information. There are 16 third-party verification forms and each is tailored for the type of
information requested. The 16 verification forms include:
1. Periodic Payments
2. Assets
3. Employment Income
4. Training Programs
5. Alimony
6. Child Support
7. TANF and Other Welfare
8. Medical and Disability Expenses
9. Child Care Expenses
10. Student Gifts and Contributions
11. Student Verification
12. Trust Funds
14. Life Insurance
13. Real Estate and Personal Property
15. Gifts and Contributions
16. Disability Status

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The estimated burden is 3,000 respondents x 10 minutes = total burden of 30,000 minutes or 500
hours A copy of the third-party verification forms and accompanying tenant release letter are
located in Appendix F.
The estimate of 3,000 third party verification requests is accurate given past years’ actual data
collection activities (e.g., for FY 2012 n=2,974; for FY 2011 n=3,136). Third-party verification
is not sought for every household member, but rather only for those income, asset and expense
sources that were not fully verified by housing project staff.
Table A12.1 summarizes the anticipated burden of each of the data collection components.
Table A12.1. Respondent Burden Estimate by Data Collection Phase

Phase

Respondent Group

I

PHA/owner

II

Data Collection
Instrument
Project-Specific
Information Form

Estimated
Number of
Survey
Respondents

Minutes per
Respondent

Respondent
Burden
Hours

550

30

275

Household File Abstraction

III

Tenant

Household Interview

IV

PHA/owner

V

Third Parties (e.g.,
employers, financial
institutions, doctors)

No burden
2,400

55

2,200

Project Staff Questionnaire

550

45

413

Third-Party Verification
Forms

3000

10

500

The estimated burden for this information collection is based on four data collection activities
with three respondent groups. The Bureau of Labor Statistics is the source for hourly wage rate
information (http://www/bls.gov/bls/blswage.htm). For PHA/owner staff median national rate
information is used for the Community and Social Service Specialist labor category. The tenant
wage rate information is based on the current Federal minimum wage of $7.25. For third-party
data collection median national rate information is used for the Payroll and Timekeeping Clerk
labor category. The total annualized costs for respondent burden is $38.820.45 as indicated in
Table A12.2.

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Table A12.2. Annualized Cost for Respondent Hour Burden
Phase

I

Type of
Respondent

PHA/owner

II

Data
Collection
Instrument

Estimated
Number of
Survey
Respondents

Number of
Responses
per
Respondent

Average
Burden
per
Response
(in hours)

Hourly
Wage
Rate

Total
Respondent
Cost

550

1

.50

$19.74

$5,428.50

ProjectSpecific
Information
Form

Household File Abstraction

III

Tenant

Household
Interview

IV

PHA/owner

Project Staff
Questionnaire

V

Third Parties
(e.g., employers,
financial
institutions,
doctors)

Third-Party
Verification
Forms

No Burden
2,400

1

.92

$7.25

$16,008.00

550

1

.75

$19.74

$8,142.75

3,000

1

.17

$18.12

$9,241.20

Total

$38,820.45

13. Cost burden
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).
The cost to respondents will be the time required to respond to the survey.
14. Annualized costs to Federal Government
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.
OMB Clearance is being sought for the FY 2013 data collection effort with the expectation that
annual studies will continue to be conducted. Each data collection (i.e., FY study) typically lasts
for approximately 12-months. The values provided in Table A14.1 are the expected costs to
execute the FY 2013 study and include: 1) updating of the instruments, correspondence and
administrative forms, 2) development of the sampling plan and project and tenant sample
selection, 3) review and documentation of existing HUD policy and the study operationalization
of that policy, 4) development of the management and analysis plans, 5) systems programming
of the data collection software and tracking systems, 6) study pretest, 7) field interviewer

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training, 8) data collection, 9) data cleaning and processing, 10) data tabulation and analyses, 11)
report writing, and 12) overall project management. These costs were estimated by calculating
the number of person-hours required to execute the study tasks and adding the associated other
direct costs.
Table A14.1 Cost by Study
Study

Study Timeframe

Cost

FY 2013

October 2013–September 2014

$5,253,393

15.

Program changes or adjustments

There are three adjustments to the HUDQC data collection from its previous submission in July
2010.
1. The third party verification data collection was added to this OMB submission, but in fact
it has always been a component of the HUDQC data collection process. It was omitted in
error from the previous OMB submission.
2. The project specific information (PSI) data collection increased its burden from 138
hours to 275 hours. This increase is due to HUD’s request that we collect additional
policy documents from the housing projects to gather information on local discretionary
policies that impact tenant rent calculation.
3. The household interview data collection increased its burden from 2,000 hours to 2,200
hours. This increase is due to the fact that tenants are now being asked to provide
supporting documents for income, asset and expense items during the interview.
16. Plans for tabulation and publication
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.
The primary purpose of the study is to determine the type, severity, and cost of errors associated
with income certification and rent calculations. This study will produce national estimates of
error in each program and be published in a final report. Thirteen study objectives have been
outlined, each having corresponding tabulations and analyses. The analysis plan and table shells
for each of the 13 study objectives are located in Appendix G.

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The schedule for data collection and reporting is shown in Table A16.1.
Table A16.1. Data Collection and Reporting Schedule
Activity

Time schedule

Project Sample Selection

October 2013

Phase I—Project-Specific Information Mailing

October 2013 – November 2013

Phase II—Tenant File Abstraction

December 2013 – April 2014

Phase III—Tenant Household Interview

December 2013 – April 2014

Phase IV—Project Staff Questionnaire

January 2014 – March 2014

Data Cleaning and Analysis

April 2014 - August 2014

Final Report

September 2014

17. Non-display of expiration date
If seeking approval to omit the expiration date for OMB approval of the information collection,
explain the reasons that display would be inappropriate.
Approval is not being sought.
18. Exception to certification statement
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.

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