Office of Housing Counseling – Agency Performance Review

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Form HUD 9910 Office of Housing Counseling – Agency Performance Review	Form and Instruction	New	Repair queued
Form HUD 9910 Office of Housing Counseling – Agency Performance Review	Form and Instruction	Modified	Repair queued
FR 2502-0574.pdf	Supplementary Document	Uploaded 2021-02-23	Repair queued
Forms Revision Chart for OMB Collection 2502-0574.docx	Supplementary Document	Uploaded 2021-01-12	Repair queued
Support Statement, OMB 2502-0574.docx	Supporting Statement A	Uploaded 2021-02-23	Repair queued
Published 60-Day FRN for OMB Collection 2502-0574, 12-17-2020.pdf	Supplementary Document	Uploaded 2021-01-12	Missing upstream
Signed PIA, HUD-9910 rev4 cw 10.16.20.pdf	Supplementary Document	Uploaded 2021-01-12	Repair queued
Housing-Counseling-Handbook.pdf	Supplementary Document	Uploaded 2021-01-12	Repair queued
12 U.S.C. 1701w and 1701x.pdf	Supplementary Document	Uploaded 2021-01-12	Repair queued
24 CFR Part 214.pdf	Supplementary Document	Uploaded 2021-01-12	Missing upstream

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
245309	Office of Housing Counseling – Agency Performance Review	Form and Instruction	New
184068	Office of Housing Counseling – Agency Performance Review	Form and Instruction	Modified

ICR Details

OMB Control No: 2502-0574	ICR Reference No: 202101-2502-002
Status: Received in OIRA	Previous ICR Reference No: 201705-2502-007
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: Office of Housing Counseling – Agency Performance Review
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 02/23/2021

table that charts list comparision

	Requested	Previously Approved
Expiration Date	36 Months From Approved	03/31/2021
Responses	353	455
Time Burden (Hours)	353	4,323
Cost Burden (Dollars)	0	0

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Abstract: 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.

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Authorizing Statute(s): 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
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 81945	12/17/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	86 FR 10993	02/23/2021
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

table that charts list of burden

IC Title	Form No.	Form Name
Office of Housing Counseling – Agency Performance Review	HUD 9910	Office of Housing Counseling – Agency Performance Review
Office of Housing Counseling – Agency Performance Review	HUD 9910	Office of Housing Counseling – Agency Performance Review

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ICR Summary of Burden

table that charts list of burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	353	455	0	-102	0	0
Annual Time Burden (Hours)	353	4,323	0	-3,970	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: 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.

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Annual Cost to Federal Government: $3,279,655

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 02/23/2021

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