Supporting Statement - IHBG 83 i

Supporting Statement for Paperwork Reduction Act Submissions

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.

HUD’s Office of Native American Programs (ONAP) is responsible for managing the Indian Housing Block Grant (IHBG) Formula and Competitive programs, as described below.

IHBG Formula Program

The Native American Housing Assistance and Self-Determination Reauthorization Act of 1996 (25 U.S.C. 4101 et seq.) (NAHASDA) authorizes the IHBG Formula program that supports the development, management, and operation of affordable homeownership and rental housing; infrastructure development; and other forms of housing assistance intended for low-income persons. Federally recognized Native American tribes, Alaska Native villages, tribally designated housing entities, and a limited number of State-recognized tribes that were funded under the Indian Housing Program authorized by the U.S. Housing Act of 1937 are eligible to receive IHBG funds. Under the IHBG Formula Program, eligible recipients receive an equitable share of funds as appropriated by Congress.

IHBG Competitive Program

In Fiscal Year 2018, Congress enacted H.R. 1625- Consolidated Appropriations Act, 2018 (P.L. 115-141)

(Effective: 3/23/18) that appropriated $99,000,000 for competitive grants under NAHASDA. In Fiscal Year 2019, Congress renewed program funding for an additional $99,000,000 in awards. The Indian Housing Block Grant Competitive (IHBG Competitive) program gives priority to projects that spur housing construction and rehabilitation from eligible recipients while considering need and administrative capacity. Additionally, applicants could have applied for other eligible activities under Section 202 of NAHASDA.

Attached to this submission are copies of the FY 2018 Appropriations language for the IHBG Competitive program, FY 2018 IHBG Competitive NOFA, NAHASDA, and NAHASDA regulations at 24 CFR Part 1000. The regulations and requirements governing the formula-driven IHBG program apply to the IHBG Competitive program.

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.

ONAP will use the information collected to monitor grantee performance throughout the grant term and report annually to Congress.

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 (item 13b1 of OMB form 83-i).

ONAP makes full utilization of automated information collection.

IHBG Formula recipients may submit the Indian Housing Plan/Annual Performance Report (IHP/APR) (HUD-52737) either as a fillable PDF or using HUD’s online EPIC system. Both versions of the same form provide advanced automated functionality such as numerous drop-down menus, and fields that perform auto population and calculation.

IHBG Competitive grantees submit their grant applications electronically through Grants.gov and report on program progress and expenditures using the IHBG Competitive APR that is a fillable PDF with all the automated functionality described in the fillable PDF above. The IHBG Competitive APR is submitted to HUD electronically either by fax or as an email attachment.

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 are no other sources of information that are being submitted to HUD that duplicate the information identified in this collection.

5. Does the collection of information impact small businesses or other small entities (item 5 of OMB form 83-i)? Describe any methods used to minimize burden.

HUD has minimized the burden on small grantees by allowing grantees to determine the scale and complexity of their housing programs. HUD staff is available to provide one-on-one assistance to small grantees if needed.

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.

The IHBG Formula and Competitive programs are authorized by Congress and the information collected is required for ONAP’s annual reports to Congress.

7. Explain any special circumstances that would cause an information to be collected in a manner:

• requiring respondents to report information to the agency more than quarterly;

Recipients are required to submit Federal Financial Reports (SF-425s) quarterly and within 90 days of project completion.

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

Not Applicable

• requiring respondents to submit more than an original and two copies of any document;

Not Applicable

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

Not Applicable

• in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of the study;

Not Applicable

• requiring the use of statistical data classification that has not been reviewed and approved by OMB;

Not Applicable

• 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; or

Not Applicable

• requiring respondents to submit proprietary trade secret, 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

8. Identify the date and page number of the Federal Register notice (and provide a copy) soliciting comments on the information. Summarize public comments and describe actions taken by the agency in response to these comments. Describe all efforts to consult with persons outside the agency to obtain them.

HUD published a Notice of Proposed Information Collection for Public Comments in the Federal Register, Volume 86; No. 14; Page 6910 on January 25, 2021. The public was given until March 25, 2021 to submit comments on the proposed information collection. HUD received no comments on this proposed collection.

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

There are no provisions to provide any payments or gifts to respondents, other than remuneration of contractors or recipients.

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

The information collection is public information; therefore, there is no assurance of confidentiality.

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.

There are no questions of a sensitive nature included in the information to be collected.

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. Read the complete instructions on the form 83i.

The table below provides estimates on the number of respondents, frequency of submissions, total responses, and the estimated annual burden and costs. The estimated levels of effort are based on recent discussions with ONAP staff and their interactions with tribes and tribally designated housing entities. The estimated hourly rate represents a mid-level staff position in a mid-sized tribal government at an average annual salary of $75,000 for FY 2020.



Information Collection	Form Name	Number of Respondents	Number of Responses per Respondent	Total Annual Responses	Burden Hour/Minutes per Response	Total Annual Burden	Hourly Cost	Total Annual Cost
HUD-52737	IHBG Formula IHP/APR	792	2	1584.00	62.00	98,208.00	$ 36	$ 3,535,488.00
HUD-4117	Formula Response Form	792	1	792.00	2.00	1,584.00	$ 36	$ 57,024.00
HUD-4119	Formula Challenge Form	15	1	15.00	150.00	2,250.00	$ 36	$ 81,000.00
HUD-52736-A	Depository Agreement (Banker)	394	1	394.00	0.25	98.50	$ 36	$ 3,546.00
HUD-52736-B	Depository Agreement (Broker)	394	1	394.00	0.25	98.50	$ 36	$ 3,546.00
HUD-53246	IHBG Cost Summary	54	1	54.00	2.00	108.00	$ 36	$ 3,888.00
HUD-53247	IHBG Implementation Schedule	54	1	54.00	2.00	108.00	$ 36	$ 3,888.00
HUD-XXXX	IHBG Competitive APR	54	1	54.00	32.00	1,728.00	$ 36	$ 62,208.00



Totals

792

Total Responses: 3341

Total Hours: 104,183

Number of Responses per Respondent = Total Annual Responses / Number of Respondents

13. Estimate of the annual cost to respondents or recordkeepers (do not include the cost of hour burden shown in Items 12 and 14). Read the complete instructions on the form 83i.

See table above.

14. Estimate annualized costs to the Federal government.

The estimated levels of effort are based on recent discussions with ONAP staff and their interactions with tribes and tribally designated housing entities. The estimated hours rate of $25/hour represents the mean in the FY 2019 GS-11, Step 1 schedule for an Area ONAP and the $46/hour represents the mean in the FY 2019 GS-13 Step 1 schedule for HQ ONAP.



Information Collection	Form Name	Number of Respondents	Number of Responses per Respondent	Total Annual Responses	Federal Annual Burden Hours	Total Annual Burden	Hourly Cost	Total Annual Cost
HUD-52737	IHBG Formula IHP/APR	792	2	1584.00	20	31,680	$ 25	$792,000.00
HUD-4117	Formula Response Form	792	1	792.00	15	11,880	$ 46	$546,480.00
HUD-4119	Formula Challenge Form	15	1	15.00	15	225	$ 46	$10,350.00
HUD-52736-A	Depository Agreement (Banker)	394	1	394.00	2	788	$ 25	$19,700.00
HUD-52736-B	Depository Agreement (Broker)	394	1	394.00	2	788	$ 25	$19,700.00
HUD-53246	IHBG Cost Summary	54	1	54.00	3	162	$ 26	$4,212.00
HUD-53247	IHBG Implementation Schedule	54	1	54.00	4	216	$ 27	$5,832.00
HUD-XXXX	IHBG Competitive APR	54	1	54.00	20	1,080	$ 25	$27,000.00

Totals 46,819 $1,425,274.00

15. Explain any program changes or adjustments reported in items 13 and 14 of the OMB Form 83i.

This is a revision of a currently approved collection.

HUD-XXXX (IHBG Competitive Annual Performance Report)

On February 14, 2019, OMB issued a Notice of Action approving an APR for the IHBG Competitive program. That APR was based on the APR used for the IHBG formula program as the IHBG Competitive NOFA’s reporting requirements had not been finalized prior to submission of the IHBG Competitive PRA Package. This information collection pertains to the IHBG Competitive APR that is based on reporting requirements contained in the NOFA.

HUD-4117 (Formula Response Form)

The number of respondents submitting a HUD-4117 increased from 300 to 792. This is due to the new requirement that all 792 IHBG recipients certify tribal enrollment annually. Previously, the form had been used by an estimated 300 recipients only when a challenge was made to the formula allocation.

The decrease in burden hours is due to the elimination of several IHBG Competitive application forms.

16. If the information will be published, outline plans for tabulation and publication.

Section 407 of NAHASDA requires HUD to prepare an annual report to Congress and the information gathered in this collection will be used to prepare that report. HUD is required to include a description of the progress made in accomplishing the objectives of the IHBG Formula and Competitive programs and to summarize the use of funds during the preceding 12-month period and at the end of the period of performance.

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.

The OMB control number and expiration date of the information collection will be displayed on the form.

18. Explain each exception to the certification statement identified in item 19.

There are no exceptions to the certification identified in item 19.

B. Collections of Information Employing Statistical Methods

The information will not be published for statistical purposes.

OMB 83-I 10/95