Supporting Statement OMB 2502-0615 with OGC revisions, 7-26-2021

Supporting Statement for Paperwork Reduction Act Submissions

Survey to Assess Operational Status and Capacity of Housing Counseling Agencies

Due to a Disaster/National Emergency

OMB Control Number: 2502-0615

No Forms: (Disaster/National Emergency Survey)

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 and regulation mandating or authorizing the collection of information. Include a statement regarding the changes for this submission.

The Office of Housing Counseling (OHC) is responsible for administration of the Department’s Housing Counseling Program, authorized by section 4(g)(3) of the United States Department of Housing and Urban Development Act (42 U.S.C. 3533(g)(3) and section 106 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701x). The Housing Counseling Program supports the delivery of a wide variety of housing counseling services to homebuyers, homeowners, low- to moderate–income renters and the homeless. The primary objectives of the program are to expand homeownership opportunities, preserve homeownership and improve access to affordable housing. The housing counselors provide guidance and advice to help families and individuals improve their housing conditions. After a disaster or national emergency, these services may expand to include assessing housing, financial, and other issues caused by the disaster or national emergency, discussing the best resources for assistance, working with local resources that may provide with additional assistance, helping communicate with lenders, insurance companies and government agencies, and helping with necessary paperwork. There may also be changes to agency operations, such as doing business virtually.

To participate in HUD’s Housing Counseling Program, a housing counseling agency must be approved by HUD, or be designated as a subgrantee or affiliate of a HUD-approved of a counseling agency participating in the Housing Counseling Program as an intermediary, multi-state organization, or a state housing finance agency. All participating agencies must deliver housing counseling services consistent with the agency's housing counseling work plan.

While HUD has regulatory authority under 24 CFR 214.307(b) to require performance reviews that examine agency's level of success in delivering counseling services and regulatory authority under 24 CFR 214.317 to require reports from participating agencies, OHC is not mandating that participating agencies complete this survey.”

However, a disaster or national emergency could make it critical that OHC receive information on its impact on HUD-participating housing counseling agencies quickly and with consistent input. The “Survey to Assess the Operational Status and Capacity of Housing Counseling Agencies due to a Disaster/National Emergency (Disaster/National Emergency Survey)” allows more accurate assessment of the operating status and capacity of impacted housing counseling agencies to provide their approved counseling services.

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.

The purpose of the “Survey is to collect information from HUD Participating Housing Counseling Agencies on the impacts of a disaster or national emergency on their operations. The information collected by the survey will be used by OHC to determine the ability of housing counseling agencies to perform their required functions during a disaster/national emergency. Housing counseling agencies will be asked about their operational status and their capacity to provide approved services. Information collected will include the status of the agencies’ ability to communicate, operate remotely, and provide services to clients. The information collected will be used to identify the needs of the housing counseling agency and to inform OHC about the types of support that would be the most responsive to the needs of agencies and their clients.

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 Survey will be conducted by the electronic survey instrument SurveyMonkey, with contacts made by email and phone by OHC staff. Housing counseling agencies will access the survey at https://www.surveymonkey.com/r/HCAA DIASTER/. Upon Office of Management and Budget (OMB) emergency approval in November 2020, the survey was sent to 1250 housing counseling agencies to assess the impact of the COVID-19 pandemic on operations. The Survey will also be sent to housing counseling agencies after other disaster or national emergencies. Utilizing SurveyMonkey facilitates agencies reporting operational readiness and reduces paperwork by eliminating the need for agencies to complete and mail paper responses, as well as reduce postage costs.

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.

This is a revised collection. The information already available to OHC about the housing counseling agencies may no longer be accurate as a result of the impact of the disaster or national emergency. This revised collection is necessary to assess the operational capacity of each agency and to better support the agencies efforts to address the needs of the victims of the disaster or national emergency.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

HUD makes every effort to minimize the burden of information collection to all organizations participating in the Housing Counseling Program. Only information critical to evaluating an organization’s compliance with program requirements is collected.

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 there an assessment of the operational status of impacted housing counseling agencies is not made after a disaster/emergency, HUD would not be able to provide the necessary support and assistance to housing counseling agencies and their clients to assist in their operations. The frequency is dependent on the occurrence of a disaster, not a regular schedule

7. Explain any special circumstances that would cause an information collection to be conducted in a manner: (PLEASE ANSWER EACH BULLET SEPARATELY)

* requiring respondents to report information to the agency more often than quarterly.

This voluntary Survey is only deployed after a disaster/emergency, not on a regular schedule. The frequency is dependent on the occurrence of a disaster. The nature and scope of ae disaster or national emergency may require the survey to be deployed to impacted agencies more than one time. The operating status and ability of the agency to provide services may change over the course of the disaster and may require more frequent data collection. The Department may need more frequent updates to respond appropriately.

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

Not applicable. Agencies are not required to prepare a written response.

* requiring respondents to submit more than an original and two copies of any document.

Not applicable Agencies respond electronically through SurveyMonkey. No other documents are not needed.

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years.

Not applicable. Respondents are not required to retain 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.

Not applicable. There is no statistical survey.

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

Not applicable. There is no statistical survey or data classification that has not been reviewed and approved by OMB;

*that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use;

Not applicable. There is no additional pledge of confidentiality.

or

* requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

Not applicable. There is no such requirement.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency'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 agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), a 60-day Federal Register Notice soliciting public comments was announced in the Federal Register on May 10, 2021, Volume 86, Page 24880. No comments were received.

A 30-day Federal Register Notice inviting public comments was published on July 26, 2021, Volume 86, Page 40076. No comments were received.

OHC consulted with housing counseling agencies to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.  Such consultation takes place at least annually. To date, there has not need to revise the survey based on comments.

Consultation was made with representatives are listed below.

             Kelly Gill Gordon, Grant Programs and Initiatives Director

[email protected]

4224 Cox Road, Glen Allen, VA 23060

(804) 343-5534

Veronica Depotty

HUD Grant Manager & Housing Education Specialist

Homeownership Division

[email protected]
Michigan State Housing Development Authority
735 E. Michigan Avenue, Lansing MI 48912
(517) 335-0345   

Teresa Bardwell, Housing Counseling Program Manager,

[email protected]                             

RURAL COMMUNITY ASSISTANCE CORP.

3120 Freeboard Drive, Suite 201 – 2nd Floor West Sacramento, CA 95691

(720) 234-9565

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

There are no payments or gifts to respondents with respect to this collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Information requested is only for a housing counseling agency, not for individual clients. No PII is requested in the Disaster or National Emergency Survey since information is not collected on clients. HUD is committed to protecting the privacy of individuals’ information stored electronically or in paper form, in accordance with federal privacy laws, guidance, and best practices. The Privacy Statement is posted on the Survey.

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. This justification should include the reasons why the agency considers the questions necessary, the 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.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and 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.

	Estimated Annualized Burden Hours and Costs
Information Collection / Type of Respondent	Form Name / Form Number	Number of Respondents	Frequency of Response	Responses Per Year	Average Burden Hours Per Response	Annual Burden Hours	Hourly Cost per Response (Hourly Wage Rate)	Total Annual Respondent Cost
Not-for-profit institutions	Survey to Assess the Operational Status and Capacity of Housing Counseling Agencies due to a Disaster/National Emergency (Disaster/National Emergency Survey)	1,097	1	1,097	1	1,097	$86.36	$94,736.92
State, Local & Tribal Government	Survey to Assess the Operational Status and Capacity of Housing Counseling Agencies due to a Disaster/National Emergency (Disaster/National Emergency Survey)	517	1	517	1	517	$86.36	$44,648.12
TOTALS		1,614		1,614		1,614		$139, 385.04

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.46 multiplier to reflect a fully loaded wage rate.

According to the 2019 U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm) the wage rate category for 11-1021, General and Operation Managers is estimated to be $86.36 ($59.15 x 1.46) per hour, therefore, the estimated burden hour cost to respondents General and Operation Managers is estimated to be $139,385.04 annually.

13. Provide an estimate for 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).

* 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 and 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 collections 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.

There are no recordkeeping, capital, start-up or maintenance costs associated with this information collection.

14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [None	0
Staff Salaries* an estimated .05 FTE from OHC with total hours of 104 annually needed to analyze data for this data collection] Using (GS 13-10) hourly rate of $49.01 x 1.46 multiplier = $71.55 x 104 = a total cost of $7,441.20	$7,441.20
Facilities [cost for renting, overhead, etc. for data collection activity]	0
Computer Hardware and Software SurveyMonkey	$600
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	0
Travel	0
Printing [number of data collection instruments annually]	0
Postage [annual number of data collection instruments x postage]	0
Other	0
Total	$8,041.20

*Note: The “Salary Rate” includes a 1.46 multiplier to reflect a fully loaded wage rate.

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

There has been a slight increase in responses/burden hours of 14 to account for the State, Local or Tribal Governments. There have been no changes to the information being collected.

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.

The results of the information collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

HUD will display the expiration date for OMB approval of this information collection.

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

HUD does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved in this collection.

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