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pdfDraft as of 1/20/15
Supporting Statement for Paperwork Reduction Act Submission:
Consumer Operated and Oriented Plans [CO-OP] Program Loans
A.
Justification
1. Circumstances Making the Collection of Information Necessary
On March 23, 2010, the President signed into law the Patient Protection and Affordable Care Act (P.L. 111148). On March 30, 2010, the Health Care and Education Reconciliation Act of 2010 was signed into law.
The two laws are collectively referred to as the Affordable Care Act. The Affordable Care Act includes a
wide variety of provisions designed to expand coverage, provide more health care choices, enhance the
quality of health care for all Americans, hold insurance companies more accountable, and lower health care
costs.
The Consumer Operated and Oriented Plan (CO-OP) program was established by Section 1322 of the
Affordable Care Act. Qualified non-profit health insurance issuers who received CO-OP loan funding must
offer at least one qualified health plan at the silver level of benefits and one at the gold level of benefits in
the individual market State Health Benefit Exchanges (Exchanges). At least two-thirds of policies or
contracts offered by a CO-OP must be offered in the individual or small group markets. Profits generated
by the nonprofit CO-OPs must be used to lower premiums, improve benefits, improve the quality of health
care delivered to their members, expand enrollment, or otherwise contribute to the stability of coverage
offered by the CO-OP. By increasing competition in the health insurance market and operating with a strong
consumer focus, the CO-OP program provide consumers more choices, greater plan accountability,
increased competition to lower prices, and better models of care, benefiting all consumers, not just CO-OP
members.
The CO-OP program provided non-profit entities with loans to fund start-up costs and State reserve
requirements, in the form of Start-up Loans and Solvency Loans. 1
Applicants had the option to apply for (1) joint Start-up and Solvency Loans; 2 or (2) only a Solvency Loan.
However, only joint Start-up and Solvency Loans were awarded. Start-up Loans assisted loan recipients
with the many start-up costs associated with establishing a new health insurance issuer. Solvency Loans
assist loan recipients with meeting the solvency requirements of States in which the applicant seeks to be
licensed to issue qualified health plans.
The Funding Opportunity Announcement (FOA) was released on July 28, 2011. It was amended on
December 9, 2011 to conform to the changes in the Final Rule for the CO-OP Program released on
December 8, 2011 (45 CFR Part 156). The first round of applications was due on October 17, 2011. In
total, there were six rounds of applications. Applications were reviewed through the fifth round. Between
the fifth and sixth round, funding for the CO-OP Program was reduced and the current funding available to
the program is through the American Tax Relief Act (ATRA). ATRA reduced the funding for the CO-OP
Program to 10 percent of the originally obligated funds under Section 1322(g) of the Affordable Care Act.
1
Although Section 1322 of the Affordable Care Act refers to Solvency Loans as “grants” to assist with meeting State solvency
requirements, they are loans because they must be repaid. Therefore, Solvency Loans are referred to as “loans” throughout this
document.
2
Hereafter this option will be referenced as “joint Start-up and Solvency Loans.” Although an applicant needed to submit only one
application in order to apply for a Start-up Loan and a Solvency Loan, and the loans were awarded at the same time, please note that
they are two separate loans with different terms and conditions.
1
Draft as of 1/20/15
ATRA does not allow CMS to award loans to new loan recipients but additional funds may be awarded to
existing loan recipients. Under ATRA, CMS completed two opportunities to existing CO-OPs for
additional loan funding.
2. Purpose and Use of Information Collection
The data collection in this package includes requirements outlined in 45 C.F.R. Part 156 Subpart F, the
FOA, and the Loan Agreement for:
• Loan applications;
• Reconsideration requests and appeals;
• Loan Agreement acceptance and execution;
• Milestone updates;
• Financial reports;
• Progress reports;
• Enhanced financial and progress reports;
• Requests for additional funding;
• Disbursement requests;
• Core Contracts;
• Updated Business Plans;
• Audits; and
• Recordkeeping.
The above information assists CMS in administering the program, tracking the progress of loan recipients,
ensuring that loans are being appropriately spent and that instances of fraud, waste and abuse are avoided,
and to determine if a loan recipient is deviating from business plan targets or is violating programmatic
compliance, including compliance with state and federal laws.
This funding opportunity requires that loan recipients meet certain periodic reporting requirements to assist
CMS in identifying that recipients are making appropriate progress towards achieving the goals specified in
their Loan Agreements. Start-up Loans and Solvency Loans are made available for drawdown incrementally
according to recipient progress; thus, recipients must report on their progress and funding needs in order to
be allowed to drawdown their loan funds.
3. Use of Improved Information Technology and Burden Reduction
Information collected in the package is submitted electronically with the exception of the Loan Agreement,
which must be signed by an officer of the applicant who has the ability to legally bind the applicant and
must be returned to CMS in hard copy. CMS staff analyzes the data in the same manner by which it was
submitted and communicates with applicants using e-mail or telephone.
4. Efforts to Identify Duplication and Use of Similar Information
Not applicable.
5. Impact on Small Businesses or Other Small Entities
No impact on small business.
2
Draft as of 1/20/15
6. Consequences of Collecting the Information Less Frequent Collection
Information collected in the package consists of both one-time data collection and regular programmatic
reporting to CMS. In order to ensure federal funds are being used correctly and efficiently, CMS must
receive regular program information to monitor the spending of federal dollars and be best positioned to
promptly address programmatic issues such as instances of fraud, waste and abuse. In addition, loan
recipients must report to CMS regularly in order to continue to be able to draw down their loan funding.
Other items addressed in this package, such as record retention requirements, are a one-time data collection.
7. Special Circumstances Relating to the Guidelines of 5 C.F.R. 1320.5
No special circumstances.
8. Comments in Response to the Federal Register Notice/Outside Consultation
A 30-day notice in the Federal Register will be published on April 17, 2015 to seek public comments in
response to the information collection request described below.
9. Explanation of any Payment/Gift to Respondents
Not applicable.
10. Assurance of Confidentiality Provided to Respondents
All information will be kept private to the extent allowed by application, laws, and regulations.
11. Justification for Sensitive Questions
CMS performed criminal background checks and credit checks on key personnel listed in applications in
order to ensure that key personnel were involved in any criminal proceedings, especially those related to
fraud or misuse of funds. Applicants were contacted via email to request the Social Security numbers of key
personnel. The email explained that the Social Security numbers will be used to perform background and/or
credit checks and require that that the applicant obtained the personnel’s consent before sending us their
Social Security numbers. All HIPAA privacy rules were followed in obtaining such information such as
requesting sensitive information be shared via encrypted email or by phone.
3
Draft as of 1/20/15
12. Estimates of Annualized Burden Hours (Total Hours & Wages)
1. Application – Start-up/Solvency Loans
Applicants were required to submit a complete loan application to CMS. The applications are the same
regardless of whether the applicant applied for joint Start-up and Solvency Loans or only a Solvency Loan. This
burden estimate includes the total estimated burden to complete and submit an application for joint Start-up and
Solvency Loans or only a Solvency Loan in connection with the FOA and 45 C.F.R. Part 156 Subpart F.
We estimate that it took each applicant nonprofit approximately 516 hours to read, complete, and submit an
application to CMS. In accordance with the FOA and 45 C.F.R. Part 156 Subpart F, a complete application for
Start-up/Solvency Loans will include: standard forms; a cover letter; an abstract; a project narrative; an
organizational chart, position descriptions, & resumes of key personnel; a description of the target market &
proposed products; a budget & budget narrative; a description of the proposed enrollment strategy & financial
projections; an operations plan; a governance & licensure plan; a feasibility study; proof of nonprofit status; an
eligibility affidavit & application certification; affidavit(s) of criminal &/or civil proceedings; and evidence of
support. We believe 9 people per nonprofit will be involved in completing the application: a senior-level
manager to oversee the application, two policy analysts, a lawyer, a budget analyst, an actuary, and three seniorlevel managers of supporting organizations, who will write letters of support for the applicant organization.
We received a total of 147 applications. The total estimated burden for all applicants is 75,852.
2. Application Reconsideration Requests and Termination Appeals
Pursuant to the FOA, an applicant may request reconsideration of a loan application determination. To request
reconsideration of its application, the applicant must submit its request in writing to CMS within 30 days of
receipt of the determination. An applicant may only request reconsideration of a specific application once; any
determination made by CMS as result of reconsideration is final and will not be subject to review or appeal.
Additionally, as outlined in the FOA, a loan recipient may appeal a decision by CMS to terminate its loan
agreement by submitting a written request for appeal with appropriate supporting documents within 30 days,
consistent with the terms of its loan agreement.
We estimate that it will take each applicant/loan recipient approximately 15 hours to write and submit a
reconsideration request/appeal request. We believe 3 people per applicant will be involved in requesting
reconsideration/appeal: a senior-level manager and two policy analysts. Of the 147 total applications received,
103 applications were reconsidered. The average annual burden for each applicant/loan recipient is 45 hours
and the total annual burden for all applicants/loan recipients is estimated at 1,545 hours.
3. Loan Agreement Acceptance
Pursuant to the FOA, once a loan application is approved, the applicant must agree to the terms stated in the
loan agreement in order to receive the loan. The loan agreement states the requirements that the applicant must
meet in order to participate in the CO-OP program, continue to receive funding, and be determined to be in
compliance with the CO-OP program. In order to indicate its acceptance, the applicant must sign and submit the
loan agreement to CMS. This is a one-time requirement.
Prior to accepting the loan agreement, the loan recipient may have the opportunity to negotiate the terms and
conditions with CMS.
We estimate that it will take each recipient approximately 16 hours to read, negotiate, sign, and submit the loan
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Draft as of 1/20/15
agreement to CMS. We believe 4 people per recipient will be involved in this task: a senior-level manager, two
policy analysts, and a budget analyst.
To date, 24 non-profits accepted Loan Agreements. The estimated total, one-time burden was 384 hours for all
loan recipients.
4. Standard Reporting Before Loan Repayment – Start-up/Solvency Loan(s) Recipients
Pursuant to the FOA, prior to full loan repayment a recipient of joint Start-up and Solvency Loans or only a
Solvency Loan will be required to submit to CMS: monthly milestone updates, monthly reporting, quarterly
financial reports, quarterly pro forma financial projections certified by an actuary (including monthly cash flow
projections through the calendar year following submission. For example, any report submitted in 2015 would
include monthly cash flow projections through December 2016), semi-annual progress reports, and ad-hoc
reports as deemed necessary by CMS. In addition, loan recipients will have the option of submitting a bi-annual
application to be deemed in compliance with standards for participation in the Affordable Insurance Exchanges.
We estimate that all recipients will choose to submit such applications.
With all reporting requirements averaged out on a monthly basis, we estimate that it will take each recipient an
average of approximately 26 hours per month to assemble and submit all required and optional reports. We
believe 4 people per recipient will be involved in completing each item: a senior-level manager, a
market/research analyst, a budget analyst, and an actuary. The average annual burden for each loan recipient is
312 hours and the total annual reporting burden for all loan recipients is estimated at 7,176 hours.
To date, 24 non-profit entities were awarded joint start-up and solvency loans. However, one loan recipient’s
Loan Agreement was terminated by the CMS on September 16, 2013. Therefore, any burden related to
reporting after the Loan Agreement Acceptance Burden (number 3 above) is based on 23 loan recipients.
5. Standard Reporting After Loan Repayment – Start-up/Solvency Loan Recipients
Pursuant to the FOA, during a 10-year period after full loan repayment, a recipient of joint Start-up and
Solvency Loans or only a Solvency Loan will be required to submit to CMS annual progress reports and ad-hoc
reports as deemed necessary by CMS. In addition, loan recipients will have the option of submitting a bi-annual
application to be deemed in compliance with federal standards for participation in the Marketplace. We
estimate that all recipients will choose to submit such applications.
We estimate that it will take each recipient an annual total of approximately 20 hours to assemble and submit all
required and optional reports. We believe 4 people per recipient will be involved in completing each item: a
senior-level manager, a market/research analyst, a budget analyst, and an actuary.
We estimate that up to 23 nonprofits will submit standard reports. We estimate an average annual total
reporting burden of 460 hours for all recipients.
6. Enhanced Reporting – Start-up/Solvency Loan Recipients
Pursuant to the FOA, CMS may place a loan recipient in an enhanced oversight plan if the loan recipient
underperforms or has difficulty in meeting program milestones and benchmarks, as identified in its Loan
Agreement. Under an enhanced oversight plan, CMS will conduct thorough and more frequent review of the
loan recipient’s operations and financial status. CMS may require the loan recipient to develop and implement
a corrective action plan and submit monthly updates.
We estimate that it will take each affected applicant approximately 3 hours per monthly response to comply
with required enhanced reporting. We believe 4 people per applicant will be involved in the task: a senior-level
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Draft as of 1/20/15
manager, market/research analyst, a budget analyst, and an actuary.
We estimate that up to 10 loan recipients will be required to submit enhanced reporting each year, and that each
case of enhanced reporting will last 2 months. We estimate an average annual total reporting burden of 60 hours
for all recipients estimated to be required to submit enhanced reporting.
7. Requests for Additional Funding
Pursuant to ATRA, CMS may award additional funding to existing loan recipients. For additional funding, the
loan recipient will have to submit an application which includes information addressing how this funding will
contribute to the viability and sustainability of the loan recipient’s organization.
We believe 4 people will be involved in the task: a senior level manager, a market/research analyst, a budget
analyst, and an actuary. In June 2014, we received 10 applications for additional funding. We estimate it takes
each applicant for additional funding 20 hours to complete the application and the total average annual burden
for all applicants was 200 hours. If funding allows for subsequent rounds of applications for additional funding,
we estimate we will receive 5 applications for each round. The total estimate annual burden for subsequent
rounds of additional funding is 100 hours.
8. Disbursement Requests
Pursuant to the Loan Agreement, the disbursement of start-up loan funding occurs when loan recipients reach
previously agreed upon milestones. Loan recipients must show proof that they have met milestones prior to
receiving the disbursement. Loan recipients must also include any core contracts that are tied to milestone
completion. We believe 3 individuals will be involved in the task: a senior level manager, a market/research
analyst and a budget analyst. We estimate that the annual burden for each loan recipient will be 4 hours and the
total average annual burden is 92 hours for all loan recipients.
Requests for disbursement of solvency funds are communicated to CMS directly by the loan recipient. We
believe 4 individuals will be involved in the task: a senior level manager, a policy analyst, a budget analyst and
an actuary. We estimate each request will take 7 hours and the annual burden for each loan recipient to be 28
hours. The total annual burden for all loan recipients is 644 hours.
9. Core Contracts
A loan recipient is required to submit any core contract that does not align with milestone completion to CMS
for prior approval. We believe this task will be done by a senior level manager and estimate it will take each
loan recipient 1 hour to complete this requirement. The total annual estimated burden for each loan recipient is
5 hours and the total average annual burden for all loan recipients is 115 hours.
10. Updated Business Plans
CMS may request updated business plans from loan recipients who may not be demonstrating a viable and
sustainable organization. We believe 4 people will be involved in this task: a senior level manager, a
market/research analyst, a budget analyst and an actuary. We believe that updated business plans will be
requested from at least 10 loan recipients annually. We estimate that each updated business plan will have an
estimated burden of 10 hours for each loan recipient and an estimated total annual burden of 100 hours for all
loan recipients. Please note that the burden for the updated business plan does not include any internal actions
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Draft as of 1/20/15
taken by each loan recipient to continually assess its business plan. The estimate only accounts for the time it
will take a loan recipient to produce an updated business plan responsive to CMS’s request.
11. Audits
Pursuant to the FOA, the loan recipient must agree that HHS or its designees have the right to audit, inspect,
and evaluate any books, contractors, records, documents, and other evidence of the loan recipient, and its
members, providers and suppliers, and contracted entities that pertain to the loan recipient’s compliance with
program requirements and the ability of the loan recipient to repay loan funds to CMS.
CMS audits may consist of comprehensive onsite performance reviews, less-intensive site visits, and desk
reviews. The timing of any audit is at the discretion of CMS.
We estimate that it will take each applicant approximately 120 hours to comply with an audit. We believe 5
people per applicant will be involved in the task: a senior-level manager, a market/research analyst, a budget
analyst, an actuary, and an office manager.
We estimate that up to 23 loan recipients will be audited each year. We estimate an average annual total
reporting burden of 2,760 hours for all audited recipients.
12. Recordkeeping
A loan recipient is required to meet the requirements for recordkeeping contained in the FOA. A loan recipient
is required to retain all records that they or their subcontractors create, collect or maintain while participating in
the program for at least ten years following termination.
We estimate that it will take each loan recipient an average of approximately 60 hours annually to appropriately
maintain their records. We believe that 2 people per applicant will be involved in the task: an office manager
and a laborer/mover.
We estimate that 23 loan recipients will be required to comply with recordkeeping requirements. We estimate
an average annual total burden of 1,380 hours.
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Draft as of 1/20/15
12A. Estimated Annualized Burden Hours
1. Application – Start-up/Solvency Loans
Form
Type of
Respondent
Complete and submit loan application
Non-profit
Total
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours per
Response
147
1
516
75,852
-
-
516
75,852
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
hours per
Response
103
1
15
1,545
-
-
15
1,545
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours per
Response
24
1
16
384
-
-
16
384
-
Total
Burden
Hours
2. Application Reconsideration Requests
Form
Type of
Respondent
Application Reconsideration Request
Non-profit
Total
-
Total
Burden
Hours
3. Loan Agreement Acceptance
Form
Type of
Respondent
Read, negotiate, and accept loan agreement
Non-profit
Total
-
Total
Burden
Hours
4. Standard Reporting Before Loan Repayment – Start-up/Solvency Loan(s) Recipients
Form
Reporting Requirements
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
Non-profit
23
16
26
9,568
-
-
-
26
9,568
Total
Average
Burden
Hours per
Response
Total
Burden
Hours
5. Standard Reporting After Loan Repayment – Start-up/Solvency Loan Recipients
Form
Annual Reporting Requirements
Total
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours
per
Response
23
1.5
20
690
-
-
20
690
nonprofit
-
8
Total
Burden
Hours
Draft as of 1/20/15
6. Enhanced Reporting (Before Loan Repayment) – Start-up/Solvency Loan Recipients
Form
Enhanced Reporting Requirements
Total
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours per
Response
nonprofit
10
2
3
60
-
-
-
3
60
Average
Burden
Hours
per
Response
Total
Burden
Hours
7. Request for Additional Funds
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
nonprofit
10
1
20
200
-
-
-
20
200
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours
per
Response
nonprofit
23
4
1
92
Solvency Loan Disbursement Request
-
23
4
7
644
Total
-
-
8
736
Form
Request for Additional Funds
Total
Total
Burden
Hours
8. Disbursement Requests
Form
Start-up Loan Disbursement Request
Total
Burden
Hours
9. Core Contracts
Form
Core Contracts Requirements
Total
Average
Burden
Hours
per
Response
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
nonprofit
23
5
1
115
-
-
-
1
115
9
Total
Burden
Hours
Draft as of 1/20/15
10. Updated Business Plans
Form
Updated Business Plan Requirements
Total
Average
Burden
Hours
per
Response
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
nonprofit
10
1
16
160
-
-
-
1
160
Type of
Respondent
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden
Hours
per
Response
nonprofit
23
1
120
2,760
-
-
-
120
2,760
Average
Burden
Hours per
Response
60
60
Total
Burden
Hours
1,380
1,380
Total
Burden
Hours
11. Audits
Form
Audit Requirements
Total
Total
Burden
Hours
12. Recordkeeping
Form
Annual Recordkeeping
Total
Type of Respondent
nonprofit (loan recipient)
-
Number of
Respondents
23
-
10
Number of
Responses
per
Respondent
1
-
Draft as of 1/20/15
12B. Cost Estimate for All Respondents
1. Application – Start-up/Solvency Loans
Type of Respondent
Number of
Responses
per
Respondent
Number of
Respondents
Average
Burden Hours
per Response
Burden Costs
All
Respondents
Wage per
Hour
Senior-level manager
147
1
89.50
$53
$697,294.50
Policy analyst with insurance expertise
147
1
85
$41
$512,295.00
Policy analyst with health policy expertise
147
1
86.5
$41
$521,335.50
Lawyer
147
1
27.5
$60
$242,550.00
Budget analyst
147
1
115.5
$29
$492,376.50
Actuary
147
1
113.5
$46
$767,487.00
-
-
516
-
$3,233,338.50
Number of
Respondents
Number of
Responses
per
Respondent
Average
Burden Hours
per Response
Wage per Hour
Burden
Costs All
Respondents
Senior-level manager
103
1
4
$53
$21,836.00
Policy analyst with insurance expertise
103
1
5
$41
$21,115.00
Policy analyst with health policy expertise
Total
103
1
6
$41
$25,338.00
-
-
15
-
$68,289.00
Total
2. Application Reconsideration Requests
Type of Respondent
3. Loan Agreement Acceptance
Type of Respondent
Senior-level manager
Number of
Responses
per
Respondent
Number of
Respondents
Average
Burden
Hours per
Response
Wage per
Hour
Burden Costs All
Respondents
1
4
$53
$5,088.00
Policy analyst with insurance expertise
24
24
1
4
$41
$3,936.00
Policy analyst with health policy expertise
24
1
4
$41
$3,936.00
Budget analyst
24
1
4
$29
$2,784.00
Lawyer
24
1
4
$60
$5,760.00
-
-
20
-
$21,504.00
Total
11
Draft as of 1/20/15
4. Standard Reporting Before Loan Repayment – Start-up/Solvency Loan(s) Recipients
Number of
Respondents
Number of
Responses per
Respondent
Senior-level manager
23
16
Market/Research analyst
23
Budget analyst
Actuary
Type of Respondent
Total
Average
Burden
Hours
Wage per
Hour
Burden Costs All
Respondents
5
$56
$103,040.00
12
8
$33
$72,864.00
23
12
6
$35
$57,960.00
23
16
7
$52
$133,952.00
-
-
45
-
$367,816.00
5. Standard Reporting After Loan Repayment – Start-up/Solvency Loan Recipient
Burden
Type of Respondent
Number of
Respondents
Number of
Responses per
Respondent
Average
Burden
Hours
Wage per
Hour
Costs All
Respondents
Senior-level manager
23
1.5
4
$56
$7,728.00
Market/Research analyst
23
5
$33
$5,629.50
Budget analyst
23
1.5
1.5
7
$35
$8,452.50
23
1.5
4
$46
$6,348.00
-
-
20
-
$28,158.00
Actuary
Total
6. Enhanced Reporting (Before Loan Repayment) – Start-up/Solvency Loan Recipients
Burden
Type of Respondent
Senior-level manager
Number of
Respondents
Number of
Responses per
Respondent
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
2
2
0.5
$56
$560.00
Market/Research analyst
10
10
1
$33
$660.00
Budget analyst
10
2
1
$35
$700.00
Actuary
10
2
0.5
$52
$520.00
-
-
3
-
$2,440.00
Total
7. Request for Additional Funding
Burden
Type of Respondent
Senior-level manager
Number of
Respondents
Number of
Responses per
Respondent
10
1
12
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
6
$56
$3,360.00
Draft as of 1/20/15
Market/Research analyst
10
1
3
$33
$990.00
Budget Analyst
10
1
3
$35
$1,050.00
Actuary
10
1
8
$52
$4,160.00
-
-
20
-
$9,560.00
Total
8a. Disbursement Requests (Start-up Loans)
Burden
Type of Respondent
Number of
Respondents
Senior-level manager
Number of
Responses per
Respondent
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
4
4
2
$56
$10,304.00
Market/Research analyst
23
23
1
$33
$3,036.00
Budget analyst
23
4
1
$35
$3,220.00
-
-
4
-
$16,560.00
Total
8b. Disbursement Requests (Solvency Loans)
Burden
Type of Respondent
Senior-level manager
Number of
Respondents
Number of
Responses per
Respondent
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
4
4
2
$56
$10,304.00
Market/Research analyst
23
23
1
$33
$3,036.00
Budget analyst
23
4
1
$35
$3,220.00
23
4
4
$52
$20,608.00
8
-
$37,168.00
Actuary
Total
-
-
9. Core Contracts
Burden
Type of Respondent
Senior-level manager
Total
Number of
Respondents
Number of
Responses per
Respondent
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
23
5
1
$56
$6,440.00
-
-
1
-
$6,440.00
Average
Burden
Wage
per Hour
10. Updated Business Plans
Type of Respondent
Number of
Respondents
Number of
Responses per
13
Burden
Draft as of 1/20/15
Respondent
Hours
Costs All
Respondents
Senior-level manager
1
1
3
$56
$1,680.00
Market/Research analyst
10
10
4
$33
$1,320.00
Budget Analyst
10
1
2
$35
$700.00
Lawyer
10
1
2
$64
$1,280.00
Actuary
10
1
5
$52
$2,600.00
-
-
16
-
$7,580.00
Total
11. Audits
Burden
Type of Respondent
Number of
Responses per
Respondent
Number of
Respondents
Average
Burden
Hours
Wage
per Hour
Costs All
Respondents
Senior-level manager
23
1
16
$56
$20,608.00
Market/Research analyst
23
1
32
$33
$24,288.00
Budget analyst
23
1
32
$35
$25,760.00
Actuary
23
1
16
$52
$19,136.00
Office Manager
23
1
24
$26
$14,352.00
-
-
120
-
$104,144.00
Total
12. Recordkeeping
Burden
Number of
Respondents
Number of
Responses per
Respondent
Average
Burden
Hours
Office Manager
23
1
50
$26
$29,900.00
Laborers and Freight, Stock & Material Movers
23
1
10
$12
$2,760
-
-
60
-
$32,660.00
Type of Respondent
Total
Wage
per
Hour
Costs All
Respondents
Salaries were taken from the Bureau of Labor Statistics website.
(http://www.bls.gov/oco/ocos007.htm)
13. Estimates of other Total Annual Cost Burden to Respondents or Record
Keepers/Capital Costs
There are no additional record keeping/capital costs.
14
Draft as of 1/20/15
14. Annualized Cost to Federal Government
The cost to the government for the review and awarding of loan applications prior to ATRA is listed below.
Type Federal Employee Support
Senior Leadership reviewers; annual
First level reviewers; annual
Contract
Total
Total
Burden Hours
160
480
-
Hourly
Wage Rate*
SES equivalent $75
GS13 equivalent $50
-
Total Federal
Government Costs
$12,000.00
$24,000.00
$325,706.00
$361,706.00
*Salaries based on Senior Executive Service and GS wage rate for Washington, D.C. area.
The annual cost to the government for reviewing reports and awarding additional funds to existing loan recipients is listed
below:
Type of Review
Number of
Reports per
year, per
loan
recipient
Number of
loan
recipients
Average
Burden
Hours
Total
Federal
Government
Costs
Wage per
Hour
Review of monthly reporting (mid-level)
12
23
.5
$29
$4,002.00
Review of quarterly reporting (mid-level)
4
23
4
$29
$10,672.00
Review of semi-annual reporting (mid-level)
Review of updated business plan reporting
(mid-level)
2
23
6
$29
$8,004.00
1
10
9
$29
$6,003.00
Review of monthly reporting (senior-level)
12
23
1
$48
$13,248.00
Review of quarterly reporting (senior-level)
4
23
1
$48
$4,416.00
Review of semi-annual reporting (senior-level)
Review of updated business plan reporting
(senior-level)
Review of requests for additional funding (midlevel)
Review of requests for additional funding
(senior level manager)
Review of requests for additional funding
(selection committee)
2
23
1
$48
$2,208.00
1
10
4
$48
$1,920.00
1
10
8
$29
$2,320.00
1
10
15
$7,200.00
1
10
35
$48
$75 (SES
Equivalent)
$26,250.00
Contract
-
-
-
-
$176,000.00
Total
-
-
-
-
$262,243.00
15. Explanation for Program Changes or Adjustments
CO-OPs are required to provide annual pro forma financial projections to CMS on March 1. At CMS’s
discretion, the pro forma financial projections may be requested on a semi-annual basis. The guidance for this
is included in the semi-annual reporting tool which is submitted to CMS on March 1 and August 15. Pro forma
financial projections aid CMS in determining whether a CO-OP is a financial risk. As the lender to the COOPs, CMS has a vested interest in a given CO-OP’s financial viability. As such, we are requiring an additional
reporting requirement to collect pro forma financial projections (including monthly cash flow projections for 18
months from the date of submission) on a quarterly basis. Furthermore, CMS is amending the monthly
15
Draft as of 1/20/15
reporting guidance to clarify current requirements and include additional data elements necessary for CMS to
conduct appropriate oversight over the CO-OP program. The additional quarterly reporting requirements will
increase the total burden from 89,172 hours annually to 93,220 hours annually. Please note that there is no
change in the burden for the additional data elements in the monthly reporting requirements as this information
is readily available to the CO-OPs on a monthly basis.
16. Plans for Tabulation and Publication and Project Time Schedule
Start-up/Solvency Loans, Standard Reporting: Information in this package prior to loan repayment will be
primarily collected monthly, quarterly and semi-annually, with potential ad hoc collections of specific
information related to business plans and optional bi-annual updates. Information in this package for the ten
years following loan repayment will be primarily collected annually, with optional bi-annual updates.
Start-up/Solvency Loans, Audits: Audits will be primarily performed annually and may include a site visit.
Loan recipients may also receive a second site visit annually. Record retention requirements will be a one-time
data collection.
17. Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable.
B. Collection of Information Employing Statistical Methods
Not applicable. The information collection does not employ statistical methods.
16
| File Type | application/pdf |
| File Title | Supporting Statement for Paperwork Reduction Act Submission: |
| Author | Johanna |
| File Modified | 2015-03-31 |
| File Created | 2015-03-31 |