2502-New - Supporting Statement (Disaster Survey)

Supporting Statement for Paperwork Reduction Act Submissions

Survey to Assess Operational and Capacity Status of Housing Counseling Agencies

after a Disaster

OMB Control Number 2502-NEW

No Form

A. Justification

1. The Office of Housing Counseling is responsible for administration of the Department’s Housing Counseling Program, authorized by Section 106 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701w and 1701x). The Housing Counseling Program supports the delivery of a wide variety of housing counseling services to homebuyers, homeowners, low- to moderate–income renters and the homeless. The primary objectives of the program are to expand homeownership opportunities, preserve homeownership and improve access to affordable housing. The housing counselors provide guidance and advice to help families and individuals improve their housing conditions. After a disaster, these services expand to include assessing housing, financial, and other issues caused by the disaster, discussing the best resources for assistance, working with local resources that may provide with additional assistance, helping communicate with lenders, insurance companies and government agencies, and helping with necessary paperwork.

To participate in HUD’s Housing Counseling program, a housing counseling agency must be approved by HUD, or designated as a subgrantee or affiliate of a HUD-approved intermediary, multi-state organization, or a state housing finance agency. A participating agency shall deliver housing counseling services consistent with the agency's housing counseling work plan.

24CFR214.305 specifically requires agencies to notify HUD when any aspect of the agency's purpose or functions may impair its ability to comply with these regulations or the applicable grant agreement within 15 days. This notification is by email or letter. During a Performance Review, the Staff verifies that these notifications have occurred.

A wide spread disaster makes it critical that the Office of Housing Counseling receive information on the impact of the disaster on HUD-participating housing counseling agencies quickly and with consistent input. “Survey to Assess the Operational and Capacity Status of Housing Counseling Agencies after a Disaster” more accurately assesses the operating status and capacity of agencies of housing counseling agencies impacted by Presidentially Declared Disasters and/or FEMA Emergency Declaration to provide their approved counseling services This Assessment Survey provides the post-disaster information needed for the Office of Housing Counseling to determine the ability of the housing counseling agencies to perform their required functions in the disaster recovery period. The information collected will be used to identify and provide recovery support and assistance to the agencies and their clients. It also provides information that allows the Office of Housing Counseling develop alternates ways to provide the services to people impacted by a disaster.

2. HUD participating housing counseling agencies are non-profit and government organizations that provide housing services.

3. The “Survey to Assess the Operational and Capacity Status of Housing Counseling Agencies after a Disaster” would be conducted by a survey instrument such as SurveyMonkey and an EXCEL spreadsheet, with contacts made by email and phone. More advanced technology often could not be used as the communication systems of impacted agencies would be limited due to the likely destruction of communication infrastructure. The survey would be launched immediately after the Declaration. This collection requests information necessary to determine the extent of physical damage and curtailment of services to housing counseling agencies and curtailment of services provided to clients, if any, caused by a declared disaster. The information collected will be used to identify and provide recovery support and assistance to the agencies and their clients. It also provides information that allows the Office of Housing Counseling develop alternates ways to provide the services to people impacted by a disaster.

4. There is no duplication of other sources for this information. Each declared disaster is unique, and requires unique outreach and responses.

5. HUD makes every effort to minimize the burden of information collection to all organizations participating in the Housing Counseling Program. Only information critical to evaluating an organization’s compliance with program requirements is collected.

6. If there was not an assessment of the Operational and Capacity Status of Housing Counseling Agencies after a Disaster, HUD would not be able to provide the necessary support and assistance to housing counseling agencies and their clients to assist in the recovery efforts after a disaster.

7. There are no special circumstances that would require HUD to collect information in any manner described in question #7 of this form.

8. In accordance with 5 CFR 1320.8(d), this information collection soliciting public comments was announced in the Federal Register No comments were received. (Pending approval)

9. There are no payments or gifts to respondents with respect to this collection.
10. No assurance of confidentiality, statute, regulation, or agency policy is provided.
11. There are no questions of a sensitive nature included with this collection.
12. The estimated number of respondents, frequency of response, annual hour burden and estimated cost to the respondents are stated below
Information Collection	Number of Respondents	Frequency of Response	Responses Per Year	Average Burden Hours Per Response	Annual Burden Hours	Hourly Cost per Response	Total Annual Cost
Survey of Operational and Capacity Status	100	2	200	.5	100	$25	$2,500
TOTALS	100		200		100		$2.500

13. There is no additional cost to respondents or record keepers.

14. Estimate of annualized costs to the Federal government.
Information Collection	Number of Respondents	Frequency of Response	Responses Per Year	Burden Hours Per Response	Annual Burden Hours	Hourly Cost per Response	Total Annual Cost
Survey of Operational and Cap	100	2	200	1	200	$35.38	$7,076
TOTALS	100		200		200		$7,076

This cost is based on the hourly rate of a GS13-1.

15. This collection is a new collection.

16. There is no anticipated publication of the information gathered through this collection.

17. HUD is not requesting approval to avoid displaying the expiration date

18. There are no exceptions to the certification statement identified in item #19 Certification of the Paperwork Reduction Act” of the OMB 83-I.

B. Collections of Information Employing Statistical Methods

The collection of information does not employ statistical methods.

3