1505-0266 Supporting Statement-ERA1 Interim Report and Requirements 2021-04-20

Department of the Treasury 

Information Collection Request – Supporting Statement 

 

Emergency Rental Assistance Program  

OMB No. 1505-0266

 

A.  Justification 

 

1.  Circumstances necessitating the collection of information 

 

Justification for Emergency Processing: 

 

On December 27, 2020, the President signed the Consolidated Appropriations Act, 2021 (the “Act”), Pub. L. No. 116-260. Division N, Title V, Section 501(a)(1) of the Act established the Emergency Rental Assistance (ERA) program and provides $25 billion for the U.S. Department of the Treasury (Treasury) to make payments to States (defined to include the District of Columbia), U.S. Territories (Puerto Rico, U.S. Virgin Islands, Guam, Northern Mariana Islands, and American Samoa), Indian tribes or tribally designated housing entities, as applicable, the Department of Hawaiian Homelands, and certain local governments with more than 200,000 residents (collectively the “eligible grantees”) to provide financial assistance and housing stability services to eligible households.

 

Section 501(g) requires Treasury to provide public reports on a quarterly basis regarding ERA grantees’ use of ERA award funds, including but not limited to, the number of eligible households that receive ERA assistance, and the type or types of assistance provided to each eligible household. To create these public reports and fulfil its obligation under Section 501(g), Treasury needs to collect the data outlined in the interim reports from ERA grantees.

Due to the need to expeditiously have ERA grantees prepare and submit quarterly interim reports in order for Treasury to meet its public reporting obligation under Section 501(g), Treasury requests emergency processing for the ERA interim report and the interim reporting guidance for ERA grantees.

 

Acceptance of Award Terms Form

An eligible grantee that elects to receive payment under the ERA program must complete and sign a form that will indicate its agreement to the award terms, including the requirement to comply with reporting requirements established by Treasury, in order for Treasury to comply with its reporting requirements under section 501(g), and its reallocation requirements under section 501(d). Treasury does not have rulemaking authority with respect to this program, so it must obtain the agreement of eligible grantees to require them to comply with these provisions.

Recipient Payment Information Form

In order to ensure proper payment by Treasury, each eligible grantee must supply basic identifying and bank routing information. This information should be readily available to officials completing the form.

ERA Redirected Funds Form

The ERA Redirected Funds Form will be used by local government grantees that no longer wish to implement an ERA program. The form will document the transfer of ERA funds and legal responsibilities therein from the local governments to their respective State government. The form must be signed by both the chief executive of the local government and an authorized official of the State government. The completed and signed form as well as a copy of the ACH or wire transfer must be submitted to Treasury as evidence of the transfer, cancellation of the local government’s ERA award, and modification of the State’s ERA award. We estimate a small percentage of local governments will choose to transfer the ERA funds therefore we expect to receive no more than 30 forms.

ERA Interim Report and Interim Reporting Guidance

 

Treasury developed the ERA interim report and the interim reporting guidance for ERA grantees to submit summary information on their utilization of ERA award funds to date to facilitate Treasury’s quarterly reporting obligations under Section 501(g) and to effectively monitor the ERA grantees’ compliance with the requirements of the ERA award. In addition to information required from ERA grantees pursuant to Section 501(g),¹ Treasury will also be collecting information on the ERA grantees’ use of funds for administrative expenses to ensure compliance with the limitations on administrative costs under the ERA program. The interim report will capture zip code level reporting to enable Treasury to track which low-income zip codes are receiving a proportional amount of assistance under the ERA program as compared to zip codes that are not low-income.

 

2. Use of the data 

 

The information reported will allow Treasury to fulfill its reporting requirements under Section 501(g) and obtain a better understanding of ERA program activity. 

 

3.  Use of information technology  

 

Treasury will manage the submission process with the use of existing and widely available technology such as a web portal and e-mail.

 

4.  Efforts to identify duplication    

 

The information collections are under new statutory mandates.  The information is not known to overlap with any other data collected under any other information collections at Treasury.  Furthermore, the information collection is tailored to leverage data that already exists and require only additional data that is necessary. 

 

5.  Impact on small entities 

 

This collection of information will minimally affect small entities.  However, Treasury will attempt to minimize burden on small entities to the greatest extent practicable.  

  

6.  Consequences of less frequent collection and obstacles to burden reduction 

 

Treasury will collect only the information required to make any payments to the eligible grantees.  The eligible grantees will submit a limited amount of information that should be readily available to the entity in the ordinary course of business.  If the eligible grantees are unable to provide their completed recipient payment information form and acceptance of award terms form, Treasury would not be able to make payment to those eligible grantees.  If ERA grantees fail to complete and submit their interim reports to Treasury, Treasury will not be able to meet its public reporting obligations under Section 501(g) and monitor ERA grantees’ compliance with the ERA program requirements.  

   

7.  Circumstances requiring special information collection 

 

There are no special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines. 

 

8.  Solicitation of comments on information collection and justification for expedited processing pursuant to 5 C.F.R. § 1320.13 

 

This ICR is being submitted under emergency clearance procedures in order to comply with statutory deadlines and expedite payments to eligible grantees.  As such, advance public notice and comment is not possible. 

 

9.  Provision of payments to respondents 

 

No payments or gifts are provided to respondents. 

 

10.  Assurance of confidentiality 

 

Information collected will be kept confidential to the extent appropriate and consistent with the Freedom of Information Act and other applicable laws. 

 

11.  Justification of sensitive questions 

 

No sensitive questions will be asked of eligible grantees.  

 

12.  Estimate of the hour burden of information collection

 

The Recipient Payment Information form, Acceptance of Award Terms form, ERA Interim Report, and ERA Redirected Funds Form and all associated Recordkeeping burden estimates are as follows: 

 

Reporting	# Respondents	# Responses Per Respondent	Total Responses	Hours per Response	Total Burden in Hours	Cost to Respondents  ($47.50 per hour*)
ERA Interim Report	438	1	438	4	1752	$83,220
Recipient Payment Information Form	1,150	1	1,150	0.25 (15 minutes)	288	$13,680
ERA Redirected Funds Form and Recordkeeping	30	1	30	1 hour	30	$1,425
Acceptance of Award Terms Form	1,150	1	1,150	0.25 (15 minutes)	288	$13,680
Total	2768		2768		2358	$112,005

* Bureau of Labor Statistics (BLS), U.S. Department of Labor, Occupational Outlook Handbook, Accountants and Auditors, on the Internet at https://www.bls.gov/ooh/business-and-financial/accountants-and-auditors.htm (visited December 30, 2020).  In 2019, the median pay for accounts and auditors was $34.40/hour.  To account for the fully-loaded employer cost of employee compensation, the median pay is increased by 38%, resulting in a fully-loaded wage rate of $47.50.  According to BLS’s Employer Cost for Employee Compensation from September 2020 at https://www.bls.gov/news.release/pdf/ecec.pdf (released on December 17, 2020), employers provided 38% of total employee compensation in the form of non-wage compensation (i.e., benefits such as paid leave, health insurance, etc.) for state and local government workers.

13.  Estimated total annual cost burden to respondents

 

There are no annualized capital/startup costs for the eligible recipients to provide the information in the form or certification.   

 

14.  Estimated cost to the federal government

 

As this is a new program being set up in response to emergency circumstances, Federal costs have not been estimated yet. 

 

15.  Reasons for change in burden 

There is an increase of 1,752 hours of burden due to the addition of the Quarterly Interim Report Form, due to agency discretion.

 

16.  Plans for tabulation, statistical analysis and publication 

 

Treasury plans to publish the data for disbursements.  

 

17. Display of the expiration date for OMB approval 

 

Treasury plans to display the expiration date for OMB approval of the information collection on all instruments. 

 

18.  Exceptions to submission requirements 

 

There are no exceptions to the submission requirements. 

 

 

Part B.  Describe the use of statistical methods such as sampling or imputation

 

This collection does not employ statistical methods. 

1 Section 501(g) reporting and research requirements are exempt pursuant to paragraph (5) of that section from Paperwork Reduction Act requirements.