Paperwork Reduction Act Submission
Please read the instructions before completing this form. For additional forms or assistance in completing this form, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.
1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of Community Planning and Development |
2. OMB Control Number: a. 2506-0085
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b. None
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)
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7. Title:
State Community Development Block Grant (CDBG) Program
8. Agency form number(s): (if applicable)
Form HUD-40108
9. Keywords:
Housing, Community Development, CDBG, States, Economic Development
10. Abstract:
States submit an annual report and keep records related to the Community Development Block Grant (CDBG) Program. These records include definitions of conditions, certifications of activities/plans, slum/blight activities, business assistance and community revitalization strategies and other items. States must distribute CDBG funds to units of local government in a timely manner and record keeping must document compliance with program requirements. States will submit a form to verify the timely distribution of State CDBG funds.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. Individuals or households e. Farms b. Business or other for-profit f. Federal Government c. Not-for-profit institutions g. P State, Local or Tribal Government |
12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. Voluntary b. P Required to obtain or retain benefits c. Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 50 b. Total annual responses 50 Percentage of these responses collected electronically 93% c. Total annual hours requested 112,180 d. Current OMB inventory 112,180 e. Difference (+,-) 0 f. Explanation of difference: 1. Program change: 0 2. Adjustment: 0 |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs $0.00 b. Total annual costs (O&M) $0.00 c. Total annualized cost requested $0.00 d. Total annual cost requested $0.00 e. Current OMB inventory $0.00 f. Explanation of difference: 1. Program change: 0.00 2. Adjustment: 0.00 |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. Application for benefits e. X Program planning or management b. X Program evaluation f. Research c. General purpose statistics g. P Regulatory or compliance d. X Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure b. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe)
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Eva Fontheim Phone:202-402-3461
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19. Certification for Paperwork Reduction Act Submissions
On behalf of this Federal Agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). Appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.
The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected (see note in item 19 of the instructions);
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
Signature of Program Official:
X
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Date: |
Signature of Senior Officer or Designee:
X Collette Pollard, Departmental Paperwork Reduction Act Officer Office of the Chief Information Officer |
Date: |
Supporting Statement for Paperwork Reduction Act Submissions
This submission is to request an extension of a currently approved information collection, for the reporting burden associated with information that State Community Development Block Grant (CDBG) grantees will report in the Integrated Disbursement and Information System (IDIS) for CDBG-assisted activities, recordkeeping requirements, and reporting requirements, which will enable HUD to track program progress.
1. Need for the Information Collection
This request identifies the estimated reporting burden associated with information that CDBG state grantees will report in IDIS for CDBG-assisted activities, recordkeeping requirements, and reporting requirements. Grantees are encouraged to update their accomplishments in IDIS on a quarterly basis. In addition, grantees are required to retain records necessary to document compliance with statutory and regulatory requirements, Executive Orders, applicable OMB Circulars, and determinations required to be made by grantees as a determination of eligibility. Grantees are required to prepare and submit their Consolidated Annual Performance and Evaluation Reports, which demonstrate the progress grantees make in carrying out CDBG-assisted activities listed in their consolidated plans. This report is due to HUD 90 days after the end of the grantee’s program year. The information required for any particular activity is generally based on the eligibility of the activity and which of the three national objectives (benefit low- and moderate-income persons; eliminate/prevent slums or blight; or meet an urgent need) the grantee has determined that the activity will address. HUD is required by statute to determine on an annual basis that states have distributed funds to their units of general local government in a timely manner.
The statutory and regulatory provisions that govern the record keeping and reporting requirements for the CDBG state program are:
24 CFR 570.490(a) requires the retention of records necessary to document compliance with statutory and regulatory requirements, Executive Orders, applicable OMB Circulars, and determinations required to be made by grantees as a condition of eligibility.
24 CFR 570.491 requires that each grantee shall submit performance and evaluation report in accordance with 24 CFR part 91, and 24 CFR 91.520 requires each grantee that has an approved consolidated plan to annually report, in a form prescribed by HUD, on the progress that it has made in carrying out its consolidated plan (which includes activities carried out under the CDBG entitlement program). The report is submitted to HUD within 90 days after the end of the grantee’s program year. State grantees are required by Section 104(e) of the Housing and Community Development Act of 1974, as amended (HCDA), to submit a performance report, which is necessary for the Secretary to perform an annual review of performance, as required by that section of the law, as well as provide information necessary for HUD to report on the results of the use of funds awarded under the CDBG program. Grantees are required to input accomplishment data at least annually to comply with this annual reporting requirement, but they are also strongly encouraged to update data on accomplishments in IDIS on a quarterly basis.
24 CFR 570.494 requires that each grantee must meet the requirement for the timely distribution of State CDBG funds to units of general local government under their jurisdiction. The grantee must obligate and announce all of its grant to units of general local government within 15 months of the state signing its grant agreement with HUD. Recaptured funds and program income received by the state must be expeditiously expended obligated and announced to units of general local government. HUD may collect information from states to determine timely distribution.
Section 104(e)(2) of HCDA requires HUD to perform an annual review to determine if the state grantee is distributing CDBG funds to it’s units of general local government in a timely manner.
2. How the information is or will be used:
This request identifies the estimated reporting burden associated with information that CDBG state grantees will report in IDIS for CDBG-assisted activities. The information required for any particular activity is generally based on the eligibility of the activity and which of the three national objectives (benefit low- and moderate-income persons; eliminate/prevent slums or blight; or meet an urgent need) the grantee has determined that the activity will address. Grantees provide information in IDIS that documents the outputs obtained from individual activities and the performance measurement data will enable HUD to report on the outcomes that result from the use of CDBG funds. The revision to collect information from grantees regarding the distribution of their grant will enable HUD to determine whether grantees are distributing CDBG funds in a timely manner.
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.
IDIS is an electronic system that grantees use to report information to HUD on their use of CDBG funds, and to prepare and submit requests for drawdowns of funds from their lines of credit. Ninety-three percent of the reporting is generated from IDIS, 7 percent from hard copy documents. Grantees can input information about their CDBG-assisted activities, including accomplishments, into IDIS on an on-going basis throughout their program year. The use of IDIS eliminates duplication of information and reduces inconsistent reporting. Grantees can generate reports from IDIS to more readily inform constituents of how CDBG funds are used, and HUD can easily access the information in IDIS for management and oversight purposes.
Describe efforts to identify duplication.
No duplication of effort is caused by this information collection request.
Impact on small businesses or other small entities.
No impact on small businesses or other small entities. CDBG state grantees provide assistance to units of general local government to carry out eligible activities. Those local governments are required to provide the grantee with the information the grantee needs to document the compliance of the activity with program requirements and to allow the grantee to report the use of funds in IDIS
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
If no records are collected on this aspect of the program, program performance/regulatory compliance will not be able to be determined. Title I precludes a less frequent information collection. More importantly, the information being collected is the minimum necessary to implement the statute and achieve its stated purposes and objective.
State grantees are required by Section 104(e) of the HCDA to submit a performance report, which is necessary for the Secretary to perform an annual review of performance required by that section of the law, as well as providing the information to Congress, upon request. Section 104(e)(2) requires that the Secretary review whether the states have distributed CDBG funds to units of general local government in a timely manner. Failure to make such determination may result in unnecessary delays in putting appropriated funds to use as intended by Congress.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner (eight items listed that would impose additional workload burden on recipients).
There are no special circumstances that would cause this information collection to be conducted in a manner that would impose one or more of the additional requirements identified under this item.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d).
HUD published a notice describing the Paperwork Reduction Act Submission in the Federal Register on
January 23, 2014; vol 79 page 3845, for 60 days.
9. Explain any decision to provide any payment or gift to respondents and the basis for the assurance in statute, regulation, or agency policy.
No payment or gifts are provided to any respondents for any information.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
24 CFR 570.490(c)(2) of the CDBG regulations states that grantees shall provide citizens with reasonable access to records regarding the past use of CDBG funds, consistent with applicable State and local laws regarding privacy and obligations of confidentiality.
11. Provide additional justification for any questions of a sensitive nature.
The information collection request does not include any sensitive questions.
12. Provide estimates of the hour burden of the collection of information.
TASK |
No. of Respondents |
Frequency of Response (Annual) |
Burden Hours per response |
Total U.S. Burden Hours |
Current Inventory: |
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PER (Performance & Evaluation Report/IDIS) |
50 |
1 |
237 |
11,850 |
Recordkeeping: States Localities |
50 3,500 |
on-going
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176 26.13 |
8,800 91,455 |
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Timely Distribution Form: States
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50 |
1 |
1.5 |
75 |
TOTAL |
50 plus |
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112,180 |
Description of estimation methodology:
Because of the differences between CDBG state grantees; their variations in population size and needs; the wide range of funding allocations; and the wide range of activities that may be assisted under the CDBG program, a determination was made to identify the average number of activities per year, per grantee, and use that as the basis for identifying recordkeeping and reporting burdens associated with this data collection.
13. Estimate for total annual cost burden to respondents (other than hours)
No other costs than stated in #12 above.
14. Estimates of annualized cost to the Federal Government.
(16 hours on average, to review each annual report plus 30 minutes to review each timeliness distribution form )
50 x 16.5 hours x $39.23**(per hour) = $32,365.
** GS 12, step 5 (2014 OPM tables)
15. Reasons for program changes or adjustments reported in items 13 or 14
No program changes or adjustments are being made.
16. The information collected is not for statistical use nor does its collection use statistical methods, however, the information is provided to Congress, upon request.
17. HUD is not seeking approval to not display the expiration date for OMB approval of the information collection.
18. There are no exceptions to the signed certification.
OMB 83-I 10/95
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Paperwork Reduction Act Submission |
| Author | Dennis L. Vearrier |
| File Modified | 0000-00-00 |
| File Created | 2021-01-28 |