Privacy Threshold Analysis Form (PTA)

U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT

PRIVACY THRESHOLD ANALYSIS (PTA)
Moving to Work Amendment to the
Consolidated Annual Contributions Contract
Moving to Work Office
Public and Indian Housing
Instruction & Template
2577-New

December 11, 2018

PRIVACY THRESHOLD ANALYSIS (PTA)
SUMMARY INFORMATION
Project or
Program Name:

Moving to Work Amendment to the Consolidated Contributions Contract

Program:

Public and Indian Housing (Pifi)

CSAM Name (if
applicable):

N/A

CSAM Number
(if applicable):

N/A

Program

Project or
program
status:

Operational

January 1, 2019

Pilot launch
date:

N/A

N/A

Pilot end date:

N/A

Choose an item.

ATO
expiration date
(if applicable):

N/A

.

.

Type of Project or
Program:
Date first
developed:
Date of last PTA
update:
.

ATO Status (if
applicable)
.

PROJECT OR PROGRAM MANAGER
Name:

Christopher Golden

Office:

Moving to Work Office, PIH

Title:

Phone:

202-402-2413

Emad:

.

HoUSIflg Innovations

Specialist
Christopher.M.Golden @ hud.
gov

INFORMATION SYSTEM SECURITY OFFICER (ISSO) (IF APPLICABLE)
Name:

N/A

Phone:

N/A

Email:

N/A

4(a) Does the project, program, or system
retrieve information from the system about
a U.S. Citizen or lawfully

admitted

permanent resident allens by a personal

Please continue to next question.
Yes. If yes, please list all personal identifiers

No.

[1

used:

Identifier?
No. Please continue to next question.

4(b) Does the project, program, or system
have an existing System of Records Notice
(SORN) that has already been published In
the Federal Register that covers the
information collected?

Q Yes. If yes, provide the system name and
number, and the Federal Register
citation(s) for the most recent complete notice and
any subsequent notices
reflecting amendment to

4(c)llas the project, program, or system
undergone any significant changes since the

SORN?

No.

Security Numbers (SSN)?

Please continue to next question.

[]

Yes. If yes, please describe.

Q

Yes.

4(d) Does the project, program, or system
use Social

the system

No.

4(e) If yes, please provide the specific legal
authority and purpose for the collection of

Click here to enter text.

SSNs:

4(f) If yes, please describe the uses of the
SSNs within the project, program, or

Click here to enter text.

system:
4(g) If this project, program, or system is
an information technology/system, does ft

relate solely to infrastructure?

For example, is the system a Local Area Network
(ZAN) or Wide Area Network (WAN)?
4(h) If header or payload data3 Is stored in the

No. Please

continue to next question.

[J

Yes. If a log kept of communication traffic,
please answer this question.

communication

traffic log, please detail the data

elements stored.

N/A

5.

Does this project, program, or system
connect, receive, or share PU with any
other fflJD programs or systems?

No.

Header Information that is placed before the actual data. The header normally contains a small number of bytes of
control information, which is used to communicate important facts about the data that the message contains and how
it is to be interpreted and used. It serves as the communication and control link between protocol elements on different
devices.
Payload data: The actual data to be transmitted, often called the payload of the message (metaphorically borrowing a
term from the space industry!) Most messages contain some data of one form or another, but some actually contain
none: they are used only for control and communication purposes. for example, these may be used to set up or
terminate a logical connection before data is sent.

PRIVACY THRESHOLD ANALYSIS REViEW
(TO BE COMPLETED BY PROGRAM PLO)
Program Privacy Liaison Reviewer:

Arlette Mussington

Date submitted to Program Privacy
Office:

December 18, 2018

Date submitted to HUD Privacy Branch:

December 18, 2018

1i
-

Program Privacy Liaison Officer Recommendation:
Please include recommendation below, including what new privacy compliance documentation is needed.
None.

(TO BE COMPLETED BY THE HUB PRIVACY BRANCH)
HUB Privacy Branch Reviewer:

Cindy Etheridge

Date approved by HUD Privacy Branch:

Click here to enter a date.

.

This PTA will suffice, however; if there are any changes,
an update will be required.

.

PTA Expiration Date:

DESIGNATION
Privacy Sensitive System:
Category of System:
Determination:

No

If”no” PTA adjudication is complete.

Choose an item.
•

If “other” is selected, please describe: Click here to enter text.

XLI PTA sufficient at this time.
Q Privacy compliance cocwnentation determination in progress.
U New information sharing arrangement is required.
Q HUD Policy for Computer-Readable Extracts Containing Sensitive Pfl
applies.

Q Privacy Act Statement required.
LI Privacy Impact Assessment (PJA) required.
Q System of Records Notice (SORN) required.
U Paperwork Reduction Act (PEA) Clearance may be required. Contact
your program PEA Officer.

U A Records Schedule may be required. Contact your program Records
Officer.
IA•

Choose an item.
If covered by existing PtA, please list: Click here to enter text.

DOCUMENT ENDORSMENT

DATE REVIEWED:
PRIVACY REVIEWING OFFICIALS NAME:

By signing below, you attest that the content captured in this document is accurate and complete
and meet the requirements of applicable federal regulations and HUD internal policies.

i\&( f
Date
Marianne Nazzaro, Director
Moving to Work Office

Date
ohn Bravacos
Senior Agency Official for Privacy
Privacy Branch
OFFICE OF ADMINISTRATION

Supporting Statement for Paperwork Reduction Act Submissions
A. Justification
1.

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative
requirements that necessitate the collection. Attach a copy of the appropriate section of each statute aid regulation
mandating or authorizing the collection of information.
The Moving to Work (MT’,V) amendment to the Consolidated Annual Contributions Contract, signed by HUD and the
selected Public Housing Authority (PHA) is necessary to authorize 100 new PHA’s participation in the MTW
demonstration pursuant to the 2016 Appropriations Act. It will allow the PHA to operate under the MTW Operations
Notice and its respective selection notice, while retaining the authority of the ACC when not otherwise waived by the
notice, and to detail the termination and default actions of HUD should an agency fail in its implementation of the
demonstration.

2.

Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the
actual use the agency has made of the information received from the current collection.
This is an authorizing document to be used by HUD and the PHA to authorize 100 new PHA’s participation in the
MTW demonstration pursuant to the 2016 Appropriations Act.

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, e.g., permitting
electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe
any consideration of using information technology to reduce burden.
The amendment will be collected physically for storage with an electronic copy posted on HUD’s website.

4.

Describe efforts to identify duplication. Show specifically why any similar information already available cannot be
used or modified for use for the purposes described in Item 2 above.
The document is a legally binding amendment to the ACC and is necessary for an agency to participate in the MTW
demonstration.

5.

If the collection of information impacts small businesses or other small entities (Item 5 of 0MB form 83-I) describe
any methods used to minimize burden.
This collection will include 50 small PHAs but it has not burden hours.

6.

Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less
frequently, as well as any technical or legal obstacles to reducing burden.
If the amendment to the CACC is not signed, then a PHA can not participate in the MTW demonstration.

7.

Explain any special circumstances that would cause an information collection to be conducted in a manner:
• requiring respondents to report information to the agency more than quarterly;
Not Applicable
• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after
receipt of it;
Not Applicable
• requiring respondents to submit mote than an original and two copies of any document;
Not Applicable

0MB 83-I

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• provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying
gnd using appropriate wage rate categories. The cost of contracting out or paying outside parties for information
collection activities should not be included here. Instead this cost should be included in Item 13.
The MTW CACC amendment simply requires the signature of a selected PHA and will impose no burden.
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of
information (do not include the cost of any hour burden shown in Items 12 and 14).
• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized
over its expected useful life); and (b) a total operation and maintenance purchase of services component. The
estimates should take into account costs associated with generating, maintaining, and disclosing or providing the
information. Include descriptions of methods used to estimate major cost factors including system and technology
acquisition, expected useful life of capital equipment, the discount rate(s) and the time period over which costs will
be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as
purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage
facilities;
• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons
for the variance. The cost of purchasing or contracting out information collection services should be a part of this
cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents
(fewer than 10) utilize the 60-day pre-OMB submission public comment process and use existing economic or
regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
• generally, estimates should not include purchases of equipment or services, or portions thereof made: (1) prior to
October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information
collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of
customary and usual business or private practices.
Not applicable.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to
estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead,
printing, and support staff’), and any other expense that would not have been incurred without this collection of
information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
There will be no annual cost to the Federal government.

15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the 0MB Form 83-I.
Not applicable.
16. For collection of information whose results will be published, outline plans for tabulation and publication. Address
any complex analytical techniques that will be used. Provide the time schedule for the entire project, including
beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
The amendment to the CACC will be published on HUD’ s website as a matter of public record and requires no
analysis.
17. If seeking approval to not display the expiration date for 0MB approval of the information collection, explain the
reasons that display would be inappropriate.
The amendment to the CACC will not require additional submissions and will be binding for the duration of a PHA’s
participation in the MTW demonstration.
18. Explain each exception to the certification statement identified in item 19.
Not applicable.

0MB 83-a

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