Justification

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1.  Need for Information Collection

The Corporation for National and Community Service (CNCS) awards grants to states, institutions of higher education, non-profit organizations, Indian tribes, and U.S. Territories to operate AmeriCorps State, AmeriCorps National, AmeriCorps NCCC, AmeriCorps VISTA, Social Innovation Fund and Senior Corps programs. This information collection comprises the questions applicants answer to apply to be an AmeriCorps grantee.

A2.  Indicate how, by whom, and for what purpose the information is to be used.

Applicants respond to the questions included in these instructions in order to apply for funding in AmeriCorps competitions. The AmeriCorps competitions will use the information collection to select grantmaking entities that will identify, support and evaluate nonprofit organizations to implement and scale evidence-based solutions to community challenges.

 

 A3.  Minimize Burden: Use of Improved Technology to Reduce Burden

CNCS will be eliciting and accepting applicants’ response to these questions electronically via eGrants the CNCS’ secure online grants management system and by documents submitted via email. If applicants are unable to apply or report on-line, they can use the attached forms and instructions to submit their application.

A4.  Non-Duplication

There are no other sources of information by which CNCS can meet the purposes described in A2 (above).

 

A5.  Minimizing for economic burden for small businesses or other small entities.

This collection of information does not impact small businesses because they are not eligible to apply for grants. There is no economic burden to any other small entities beyond the cost of staff time to collect and report the data. This is minimized to the degree possible by only asking for the information absolutely necessary to assess an organization’s eligibility to apply and capacity to administer a Social Innovation Fund grant.

A6.  Consequences of the collection if not conducted, conducted less frequently, as well as any technical or legal obstacles to reducing burden.

 

The Corporation will be unable to request the necessary information to assess prospective AmeriCorps grantees.

A7.  Special circumstances that would cause information collection to be collected in a manner requiring respondents to report more often than quarterly; report in fewer than 30 days after receipt of the request; submit more than an original and two copies; retain records for more than three years; and other ways specified in the Instructions focused on statistical methods, confidentially, and proprietary trade secrets.

Generally, there will be no special circumstances that would require the collection of information in these ways. However, there may be instances driven by funding partners that may necessitate reporting in fewer than 30 days after receipt of the request.

A8.  Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice. Summarize comments received and actions taken in response to comments. Specifically address comments received on cost and hour burden.

The 60 day Notice soliciting comments was published on August 19, 2013 on page 50401. Six entities provided comments. Individual comments and the disposition of each are addressed below.

Two commenters asked that if CNCS releases multiple versions of the Application Instructions that they be dated. CNCS will date all versions of the Applications Instructions moving forward.

Three commenters asked that CNCS raise the applicant burden to 80 hours to account for both the initial application preparation as well as the reworking of the application based on State Commission review and feedback. CNCS will raise the applicant burden to 80 hours.

Two commenters asked if the fields “Total Private Match” and “Total Local, State, and Federal Government Match” will be populated by the “Total Match” amount captured in the budget. No, it will not be populated as “Total Match” captured in the budget is a combination of private and government match. CNCS is interested in breaking out the match into the two categories referenced.

Two commenters asked the purpose of requesting “Leveraged funds,” if there was a requirement to track those funds, and what repercussions would there be if an applicant raised above or below the expected amount of leverage funds. The collection of “Leveraged funds” enables CNCS to better understand the total cost of running an AmeriCorps program. For cost reimbursement applicants, there may be additional revenue needed beyond the CNCS share and the required match. For fixed amount applicants that have no match requirements, there is additional revenue that is needed beyond the CNCS share to run an AmeriCorps program. There is no requirement to track leveraged funds and thus there are no repercussions should the applicant raise more or less than the anticipated leverage amount.

One commenter asked for definitions for “episodic” and “ongoing” volunteers. CNCS has provided those definitions in the accompanying NOFO.

One commenter asked if the operating sites chart will be provided to State Commission as part of the consultative process. CNCS plans to incorporate the operating site data into the state profiles. At this time, it does not have plans to share this information with state commissions as part of the consultative process, largely due to egrants system limitations.

Comments submitted to this information collection that related to the 2013 NOFO are not detailed in this document. They will be addressed by CNCS in a different forum.

 

 A9.  Payment to Respondents

There are no payments or gifts to respondents

  

A10.  Assurance of Confidentiality and its basis in statute, regulation, or agency policy.

The information requested is collected pursuant to 42 U.S.C. §§ 12581 - 12585 of the National and Community Service Act of 1990 as amended. Purposes and Uses - The information requested is collected for the purposes of reviewing grant applications and granting funding requests. Routine Uses - Routine uses may include disclosure of the information to federal, state, or local agencies pursuant to lawfully authorized requests. In some programs, the information may also be provided to federal, state, and local law enforcement agencies to determine the existence of any prior criminal convictions. The information may also be provided to appropriate federal agencies and Department contractors that have a need to know the information for the purpose of assisting the Department’s efforts to respond to a suspected or confirmed breach of the security or confidentiality or information maintained in this system of records, and the information disclosed is relevant and unnecessary for the assistance. Executive Summaries of all compliant applications received and applications of successful applicants will be published on the CNCS website as part of ongoing efforts to increase transparency in grantmaking. This is described in more detail in the Notice of Federal Funding Opportunity. The information will not otherwise be disclosed to entities outside of the Social Innovation Fund and CNCS without prior written permission. Effects of Nondisclosure - The information requested is mandatory in order to receive benefits.

A11.  Sensitive Questions

 

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

These are the application instructions for the AmeriCorps competition.

We expect approximately 2,000 respondents to use these instructions to apply to become AmeriCorps grantees. The frequency of response will generally not be greater than annually however may sometimes be more than annually based on funding opportunities, and should not exceed 80 hours of effort per respondent. There is no estimated annual hour burden outside of the customary and usual business practices.

 

A13. Cost burden to the respondent

There is no cost to the respondent.

 

A14. Cost to Government

There are no additional costs to the Government.

A15. Reasons for program changes or adjustments in burden or cost.

Not applicable.

 

 A16.  Publication of results

Some results of this grant competition will be published on the CNCS website for the purpose of transparency in federal grantmaking. 

 

A17.  Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

Not applicable.

 

 A18.  Exceptions to the certification statement

There are no exceptions to the certification statement in the submitted ROCIS form.

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