2900-0559 Justification 051920

Supporting Statement for

State Cemetery Data, VA Form 40-0241 and

Cemetery Grant Documents, 40-0895 Series

1. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

The State Cemetery Data form, VA Form 40-0241, and the Cemetery Grant Document Forms, 40-0895 series, are required to provide data regarding the number of interments conducted at State Veterans cemeteries and support grant applications each year. This data is necessary for budget, oversight and compliance purposes associated with existing and establishment of new State and Tribal government veteran cemeteries. In addition, the Department of Veterans Affairs (VA’s) Veterans Cemetery Grants Program needs this data to answer questions which arise during the course of the year to respond to Congressional correspondence and to project and predict the need for burial space and the demand for state grants. Burial data tells us usage rates and helps in the prediction of when a cemetery needs to develop additional acreage (request a grant to expand) or if a cemetery is going to close. The amount of acreage used helps the Veterans Cemetery Grants Program and National Cemetery Administration (NCA) anticipates the closing and the requirement for additional cemeteries (either State or national). Lower burial rates may indicate problems such as ineffective outreach or poor maintenance that should be investigated. The data is used in conjunction with the data gained from the national cemeteries to consider where to place national or state cemeteries. 38 CFR, Part 39.3 states that “the Secretary and any authorized representative (in this case the Veterans Cemetery Grants Program) will have access to and the right to examine all records, books, papers or documents related to the grant.” Part 39.5 discusses follow-up procedures once a cemetery is established and states the need for audits, etc. See 38 CFR Extracts. The Cemetery Grant Document forms are used to document and evaluate state submissions in compliance with grant preapplications in 38 CFR, Part 39.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

The data gathered annually is used by the Veterans Cemetery Grants Program to conduct studies and award State and Tribal government Veteran cemetery grants. For example, the Program uses this data to demonstrate to the States (especially those without State Veterans’ cemeteries) not only the viability of the program, but to demonstrate that they have a need. The Service can demonstrate that State Veterans cemeteries are needed and a demand exists for the services provided. The Veterans Grants Service is a user of this data as is the Office of the Deputy Under Secretary for Field Programs and the Budget and Planning Service in the Office of the Deputy Under Secretary for Finance and Budget in NCA. States use this data as well as congressional offices, veteran’s organization and interested citizens.

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 agency utilizes electronic collection of most of the data requested on the forms. New State Veteran’s cemeteries, for example, are being connected during construction to the NCA’s Burial Operations Support System, an automated management information system. New pre-applications are required to be submitted through grants.gov. Existing cemeteries are being connected as feasible, but the connection requires new software, training, and in some cases, hardware and data transmission infrastructure. The State Cemetery Data form, with an explanation to fill it out, is relatively simple. It is designed to be simple for a person to fill-out and the user (Veterans Cemetery Grants Program) to extract data (see attached form). The State Cemetery Data form and the Cemetery Grant Document forms are available on the VA’s forms 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.

There is no duplication. The State Cemetery Data form and the Cemetery Grant Document Series are the only reports required from the State veterans cemeteries to determine current usage and support future grant applications.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The forms do not impact small businesses.

6. Describe the consequences 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 this data were not collected, the Veterans Cemetery Grants Program would be hampered in its ability to document cemetery usage and ensure compliance with grant award requirements, convince States and Tribal Governments to apply for grants and to accept the burden of operating and maintaining these cemeteries in perpetuity. It is in the interest of the Federal Government to encourage States and Tribal governments to share the burden of developing, operating and maintaining these cemeteries. Without the forms, the Service could not answer various congressional or State correspondence or internal inquiries within VA to support the usage at the cemeteries or the documentation to support future grant awards. The budget process would be hampered by our inability to provide objective data required of us to justify and explain the program. We could not compare the state grants program to other similar programs, which data is periodically asked for. Without the data, we could not anticipate the need for new or additional burial space.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.

We know of no special circumstances that make the collection of information inconsistent with 5 CFR 1320.6, or that would cause this information collection to be conducted in a manner that would be inconsistent with the restrictions listed in the 10/95 instructions for completing Paperwork Act Submissions.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The Department notice was published in the Federal Register Friday, March 6, 2020, Volume 85, No. 45, page 13238. VA received no public comments.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There is no payment or gift to respondents for completing the State Cemetery Data form or the Cemetery Grant Document forms.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statue, regulation, or agency policy.

There are no assurances of confidentiality in connection with these forms. The result of studies gained from the data is passed back to the States in a generic form. We do produce a “ranking” of the most active State veterans’ cemeteries, but do not produce a ratio expressing the relationship between operating costs and numbers of burials. Too many variables, including climate and local expectations, would tend to make such comparisons unproductive. Data is generally aggregated on a national or multi-state basis or the data is used to respond to a specific question that does not include such comparisons. Nonetheless, there is no assurance of confidentiality offered or implied.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The questionnaire contains no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

Estimated Burden Hours

VA Forms

Estimated

No. of Respondents

(x) times Estimated

No. of

Responses

(x) times Average

Minutes

Per Response

=
(Equals)

÷

by 60 =

Actual

Number of Burden Hours

State Cemetery Data, 40-0247

100

1

60

6,000

100

Certification of Compliance with Provisions of the Davis-Bacon Act 40-0895-2

15

1

15

225

3.75

State or Tribal Government Cemetery Grants Service Space Program Analysis – Buildings 40-0895-3

15

1

180

2,700

45

Certification of State or Tribal Government Matching Architectural and Engineering Funds to Qualify for Group 1 on the Priority List 40-0895-6

15

1

30

450

7.50

Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion – Primary Covered Transactions (State or Tribal Governments 40-0895-7

15

1

15

225

3.75

Certification Regarding Drug-Free Workplace Requirements for Grantees Other Than Individuals 40-0895-8

15

1

15

225

3.75

Certification Regarding Lobbying 40-0895-9

15

1

15

225

3.75

Certification of Compliance with Federal Requirements – State or Tribal Government Construction Grant 40-0895-10

15

1

15

225

3.75

Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion – Primary Covered Transactions (Contractor 40-0895-12

21

1

15

315

5.25

Certification Regarding Documents and Information Required for State or Tribal Cemetery Construction Grants – Post Grant Requirements 40-0895-13

15

1

120

1,800

30

Certification of Cemetery Maintained in Accordance with National Cemetery Administration Standards 40-0895-15

15

1

15

225

3.75

State or Tribal Government Cemetery Plan Preparation 39.32 and 39.83 40-0895-16

15

1

640

9,600

160

State or Tribal Government Cemetery Documentation of Grant Accomplishments (39.120) 40-0895-17

15

1

960

14,400

240

ACCUMULATIVE TOTAL

300

286

610.25

According to the May 2019 Bureau of Labor Statistics National Occupational Employment and Wage Estimates, the respondent population is composed All Occupations (Code 00-0000). The Mean Hourly Wage is $25.72, making the total cost to the respondents $15,695.63. (610.25 x $25.72 per hour).

Source: May 2019 National Occupational Employment and Wage Estimates
United States: https://www.bls.gov/oes/current/oes_nat.htm#00-0000

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

1. There is no capital, start up, operation or maintenance costs.

2. Cost estimates are not expected to vary widely. The only cost is respondent’s time.

3. There are no anticipated capital start-up cost components or request to provide information.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation 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.

The annual cost to the Federal Government for administering the State Cemetery Data form is estimated at $9,246.38 based on 286 responses annually. This amount is based on a processing time of one (1) hour per response in the Veterans Cemetery Grants Program, NCA, using a salary of a GS 9/5 ($32.33 per hour). If this form were not used, Federal costs would be much higher because staff would have to spend many hours on an ad hoc basis, interviewing state cemeteries and responding to questions as they arise rather than being able to review collected data to answer questions. The Cemetery Grant Document forms are essential in properly developing proposed projects and for the Federal Government to ensure compliance with 38 U.S.C. 501, 2408 and 38 CFR Part 39. Grants would not be awarded without the documentation.

Source: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2020/DCB_h.pdf

15. Explain the reason for any program changes or adjustments reported in Items 13 or 14 of OMB 83-I

The reason for the change/adjustments is due to the 2020 GS Payscale for GS9/5, which is now 32.33 per hour. There is also a change in the burden calculation. The prior clearance request miscalculated the burden in the ROCIS system. The number of minutes to complete each form was over-averaged at 35.14 hours per 286 respondents. The proper calculation has been made that created a reduction of 9,440 burden hours to equal the 610 time burden that was provided in this current and past justification.

16. For collections 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.

There are no plans to publish the results of this collection of information.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

This question does not apply to these forms as we are not seeking approval to not display an expiration date.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

There are no exceptions to the certification statement.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

No statistical methodology or estimation procedures are necessary to collect this information.