Final SS Invoice Submissions by Contractors

FINAL SUPPORTING STATEMENT

FOR

INVOICE SUBMISSIONS BY CONTRACTORS FOR NRC CONTRACTS/ORDERS

(3150-0109)

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EXTENSION

Description of the Information Collection

The U.S. Nuclear Regulatory Commission’s (NRC) Office of Administration, Acquisition Management Division (AMD) provides contractors with an invoice template and instructions for how to properly prepare invoices so that they are complete and accurate.  AMD requires contractors to follow the instructions when submitting invoices to the NRC to ensure that billed costs are proper for payment.  Use of the invoice template is voluntary; contractors may submit a voucher/invoice in alternate format provided all requirements of the billing instructions are sufficiently addressed.  Invoices that are not prepared in accordance with the instructions may be rejected.

The invoices provide NRC with costs incurred during the performance and through the final payment of the contract/order, to ensure compliance with the terms and conditions of the contract.  The invoice provides a summary description of the services performed or products submitted for the invoice period and specifies the section or Contract Line Item Number (CLIN) or SubCLIN in the contract pertaining to the required deliverable(s).  These instructions and template stipulate the items and level of detail in which supporting cost data must be submitted to facilitate the NRC’s review of costs billed.

1. JUSTIFICATION

To support the submission of invoices and supporting documentation, the NRC supplies contractors billing instructions with templates to follow during their preparation.

1. Need for the Collection of Information

The cost information is needed for license fee recovery and to ensure costs incurred are allowable and allocable and that the amount requested is proper for payment.

2. Agency Use of Information

Vouchers/invoices and supporting documentation are reviewed by the NRC Payments, AMD and the NRC Contracting Officer’s Representative (COR). Taken together, the review ensures costs are billed per the contract rates and the costs incurred are commensurate with work performed. The instructions provide contractors with a clear idea of the level of detail required to support their voucher/invoice submissions. Receipt of properly prepared vouchers/invoices expedites the review process and permits prompt payment.

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3. Reduction of Burden Through Information Technology

There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. NRC issued a regulation on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e‑mail, special Web-based interface, or other means.

To reduce the burden on contractors, contractors were requested, effective May 1, 2008, to electronically submit all vouchers/invoices to the NRC. However, contractors still have the option of submitting a hardcopy voucher/invoice. Voucher/invoices are submitted electronically 100 percent of the time.

4. Effort to Identify Duplication Use Similar Information

No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.

5. Effort to Reduce Small Business Burden

The collection represents the minimum information required for submission of a proper voucher/invoice and required supporting documentation required for review in order to ensure costs billed are proper for payment.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not

Conducted or is Conducted Less Frequently

Contractors are required to complete and submit vouchers/invoices and attachments once each month unless otherwise authorized by the Contracting Officer. The consequence of not collecting the data, or of less frequent collection, would be withholding of reimbursement to the contractor of costs incurred as the work progresses. The provisions of Federal Acquisition Regulation (FAR) Clause 52.216-7, require payment be made upon request, but (except for small business concerns) not more often than once every two weeks.

7. Circumstances Which Justify Variation From OMB Guidelines

To ensure prompt payment is made to the contractor, the contractor must electronically submit a proper voucher/invoice, including supporting documentation, which is reviewed and approved by NRC. If it is determined that the voucher/invoice was properly prepared, payment will be made 30 calendar days from receipt of the proper

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September 14, 2011 memorandum titled “Accelerating Payments to Small Businesses for Goods and Services,” small business payments are generally made within 15 days of receipt of a proper invoice/voucher.

The agency-designated billing office for submittal of the voucher/invoice is the NRC. The payment process begins once NRC electronically receives a proper invoice. NRC sends the voucher/invoice electronically to the COR and AMD for review and approval. The COR reviews and approves the electronic copy, and then it is electronically sent to AMD for final review and approval. After AMD reviews and approves the voucher/invoice, it is electronically sent to NRC for final processing (payment).

8. Consultation Outside the NRC

Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on March 18, 2015 (80 FR 14172). The NRC contacted eight (8) contractors as part of the Public Consultation process via e-mail and no comments were received.

9. Payment or Gift to Respondents

None.

10. Confidentiality of Information

Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).

11. Justification for Sensitive Questions

Normally sensitive information considered private or personal is not required or requested. This information is only required when contracts containing sensitive material are processed. Proprietary data is protected under the Freedom of Information Act and 10 CFR Part 9.

12. Estimate of Burden and Burden Hour Cost

The burden estimates for this information collection are based on a projected 41 active contracts (i.e., 41 respondents). These 41 contracts are divided into the following type of contracts:

• 22 contracts have no task orders (TOs) associated with them, and are billed monthly (i.e., 12 bills annually).

• Three contracts have TOs which are for projects not related to license fees, and have a total of 15 TOs and an average of four billings annually per TO.

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• 16 contracts have TOs for license fee recoverable projects with a total of 120TOs and an average of four billings per TO.

• The 16 contracts listed above require an additional 294 hours for contractors to prepare the License Fee Recovery Cost Summary, which has a total of 120 TOs and is prepared an average of four times per year.

The total hourly reporting burden for this collection is 752 hours, which is described in the table below.

ANNUAL REPORTING REQUIREMENTS

Contract/Task Order Type	Number of Contracts	Avg. # Invoices per TO		Annual Responses per Respondent		Total # Responses	Burden per Response (Hours)	Total Annual Burden Hours	Cost @ $279/Hr.
NRC Cost Type Contracts
No Task Order or License Fee Recovery Contract	22	NA		12		264	0.5	132	$36,828
Task Order – Not License Fee Related	3	5.3		4		64	0.5	32	$8,928
Task Order – License Fee Related	16	9.2		4		589	0.5	294	$82,026
License Fee Recovery Cost Contrasts
Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders	16	9.2		4		589	0.5	294	$82,026
Total	41					1506		752	$209,808

The license fee recovery section of the billing instructions is included in cost type contracts that include fee recoverable work. The section on licensing fee costs generally applies to contracts for plant inspections, licensing actions or other site-specific activities.

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13. Estimate of Other Additional Costs

There are no additional costs.

14. Estimated Annualized Cost to the Federal Government

These costs are fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171. Total cost to the agency is $337,869.

Estimated Annual Cost to the Federal Government

Contract/Task Order Type	Number of Contracts	Avg. # Invoices per TO		Annual Responses per Respondent	Total # Responses	Burden per Response (Hours)	Total Annual Burden Hours	Cost @ $279/Hr.
NRC Cost Type Contracts
No Task Order or License Fee Recovery Contract	22	NA		12	264	1.0	264	$73,656
Task Order – Not License Fee Related	3	5.3		4	64	1.0	64	$17,856
Task Order – License Fee Related	16	9.2		4	589	1.0	589	$164,331
License Fee Recovery Cost Contracts
Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders	16	9.2	4		589	0.5	294	$82,026
Total							1211	$337,869

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15. Reasons for Changes in Burden or Cost

.

The number of responses increased from 1,236 to 1,506 and the number of burden hours increased by 134 (from 618 to 752 hours) due to an increased in the number of cost type contracts projected within the next 3 years (from 34 to 41). Specific changes are described below:

• Contracts which have no TOs or license fee recovery associated with them and provide for monthly billing are expected to increase by 4 contracts (from 18 to 22).

• Three contracts which have TOs associated with them have no license fee recoverable (no change).

• TOs associated with the 16 contracts with recoverable license fees are expected to increase by 1 (from 119 total TOs to 120 total TOs.)

Also, due to the increased in the number of active cost type contracts (from 34 to 41), annual reporting costs increased (from $169,332 to $209,808) and estimated annual cost to the Government increased (from $273,178 to $337,869), notwithstanding an increase in the cost for professional effort from $274 to $279 per hour.

16. Publication for Statistical Use

Results will not be tabulated or published.

17. Reason for Not Displaying the Expiration Date

The OMB clearance expiration date is displayed.

18. Exceptions to the Certification Statement

Not Applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

The collection of information does not employ statistical methods.