Office of Housing Counseling
– Agency Performance Review
Revision of a currently approved collection
No
Regular
02/23/2021
Requested
Previously Approved
36 Months From Approved
03/31/2021
353
455
353
4,323
0
0
HUD-approved agencies are non-profit
and government organizations that provide housing services. The
information collected allows HUD to monitor and provide oversight
for agencies approved to participate in the Housing Counseling
Program. Specifically, the information collected is used to ensure
that participating agencies comply with program policies and
regulations and to determine if agencies remain eligible to
maintain an approval status. Housing counseling aids tenants and
homeowners in improving their housing conditions and in meeting the
responsibilities of tenancy and homeownership.
US Code:
12
USC 1701x Name of Law: Housing and Urban Development Act of
1968
US Code: 12
USC 1701w Name of Law: Housing and Urban Development Act of
1968
This is a revision of a
currently approved collection, however, OHC requests renaming this
collection to “Office of Housing Counseling - Agency Performance
Review.” The removal of the word “biennial” from the title is
because the timing of an agency’s performance review is based on a
risk rating model. As such, the lower the risk, the longer the
HCA’s HUD approval is in effect. First, OHC revised the “Grant
Management” section to include questions required under 2 CFR Part
200, Subpart E and to eliminate redundancies, outdated references,
questions irrelevant to grant analysis, or where verification was
impractical. The revisions reduced the number of questions in the
“Grant Management” section by half—from twelve to six, while
simultaneously strengthening analysis of grant expenses and
ensuring proper and consistent application of uniform grant
procedures. Second, OHC revised form HUD-9910 “Maintaining Approval
Criteria” section in Part A to include a question that addresses
the agency’s ongoing regulatory duty to screen for ineligible
participants. The new question asks the reviewer to verify whether
the agency maintains policies to screen for ineligible
participants. Including this question resolves a key OIG
recommendation to clarify the documentation to be produced during a
performance review to demonstrate compliance with 24 CFR
214.103(c). For the present renewal, OHC has made a correction to
form HUD-9910. Line item #82 used to give the respondent the option
of replying Yes, No, or N/A. Underneath line item #82, however,
were items a-d where the respondent answered line item #82. Thus,
the Yes, No, and N/A boxes were “blacked out” specifically online
item #82, which is now line item #77 on the revised form HUD-9910.
This collection has rectified those inaccuracies by obtaining the
most current data and computing the tables accurately so they
comport with OMB’s Supporting Statement requirements. The previous
responses were 455, which has been decreased to 353 respondents.
The decrease of 102 responses is the result of two factors: first,
there has been a decrease in the total number of HCAs since the
last collection, and secondly, the most current data has been
utilized to complete the table. There has also been a significant
decrease in the burden hours per response. In the last collection,
4,323 burden hours were reported. The new collection reports 353
burden hours since the annual reporting hours per response has
changed from 9.5 hours to 1 hour for a respondent to complete and
return form HUD-9910. OHC believes that the misunderstanding of the
last preparer contributed to this difference. As previously
mentioned in Sections 3 and 8, plans are underway to further
streamline form HUD-9910 and fully automate it in a new HUD system
called HCAMS, HUD system P301, which has been in development for
several years. A new module has been created that will replace the
paper form HUD-9910 and enable HCAs to complete the form on-line,
thus further reducing the reporting burden. The module has just
completed the final testing phase. Once OMB 2502-0574 (this
collection) has been approved by OMB, then a new PRA collection
will be submitted for the agency performance review module which
will be the first module to be activated in the HCAMS system.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form HUD 9910 Office of Housing Counseling – Agency Performance Review
FR 2502-0574.pdf
Forms Revision Chart for OMB Collection 2502-0574.docx
Office of Housing Counseling – Agency Performance Review