3245-Comm v3PRA_Supporting Statement_Community Navigators 5-13-2021

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.

The American Rescue Plan Act of 2021 (Pub. L. 117-2 §5004) authorizes SBA to establish a Community Navigator Pilot Program. Under this authority, SBA will make grants to private nonprofit organizations, resource partners, States, Tribes and units of local government to ensure the delivery of free community navigator services to current or prospective owners of small businesses in order to improve access to Covid related assistance programs and resources.

Navigators will provide outreach, education and technical assistance to small businesses. They will focus on Covid recovery and utilization of SBA programs in communities that are under-engaging with SBA resources.

The SBA must collect information to fulfill information and reporting requirements in alignment with OMB M-21-20 to ensure that programs are achieving results for effective stewardship of these funds. President Biden has required that ARP programs design, track, and report on new programs to ensure trust and equity from the American public. This data collection also helps ensure that it meets Executive Order 13985 to ensure program equity.

Purpose and Use of the Information Collected

Indicate how, by whom, how frequently, 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.

This information collection consists of two parts. One is the application information to be submitted by the non-profit or State/local government organizations seeking a Community Navigator grant. The second part consists of the reporting and recordkeeping requirements that successful Community Navigator applicants (“grantees”) must comply with to carry out the terms of the grant award.

Application:

Applicants for this program will submit a written proposal consisting of:

A cover letter with identifying information and DUNS
A technical proposal with project description and overview, staffing, description of proposed service area, partner organizations and outline of SMART goals;
Budget proposal and narrative; and
Attachments and exhibits such as partner organization commitment letters and state and local government support letters

The agency will use this information to evaluate each applicant and select awardees. Applicants will only be applying once for this program.

Program and Financial Reports and Recordkeeping:

Successful Community Navigator grantees will be expected to provide quarterly performance and financial reports to SBA utilizing the designated electronic systems.

For quarterly performance reporting, grantees will electronically transmit the data collected from clients on SBA Form 3516 along with a narrative providing an update on how the grantee is meeting its pre-defined SMART goals (as documented in the Notice of Award). Appendix B provides the output metrics and evaluations that will be used and are outlined in the Notice of Funding Opportunity. Detailed guidance will also be provided to successful awardees in the Notice of Award.

Financial reports will be submitted electronically to the SBA using the SF-425 Federal Financial Report (FFR) and any supporting documentation. Additionally, at the end of each fiscal year, grantees will submit all the information listed above plus report all unliquidated obligations (if any) on SF Form 425.

Grantees will be required to submit these quarterly narrative performance and financial reports electronically to SBA within thirty (30) days of the completion of each three (3) month period.

This information is pertinent to SBA’s analysis of each grantees’ program activity and will assist SBA in evaluating the impact of each grantee and whether they are achieving desired program results and whether they are appropriately utilizing grant funds in support of this program. The information will also be used to support SBA’s performance plans, evaluations and other submissions made to the Office of Management and Budget, the White House and the Congress in alignment with the Government Performance and Results Modernization Act, OMB Circular A-11, Circular A-136, OMB M-21-20, and any other reporting requirements.

Use of Information Technology and Burden Reduction

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. Insert any applicable electronic web address.

The SBA is committed to promoting the use of technology to lessen the burden of data collection. Applicants will submit their grant applications through Grants.gov. The Agency allows and encourages grantees to collect information from small business clients (recipients of their technical assistance) via electronic means. Additionally, the SBA is building an electronic system that will enable grantees to transmit their quarterly and annual data to SBA. The use of electronic systems to apply and report will greatly lessen the burden on respondents and SBA, ultimately allowing for more efficient services to clients.

4. Efforts to Identify Duplication and Use of Similar Information

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.

The information we propose to collect is unique to the Community Navigator program and is not collected through other programs at SBA or elsewhere. Each report provides new data on activities that happened during the reporting period; that data cannot be substituted for any other period.

Impacts on Small Businesses or Other Small Entities

If the collection of information impacts small business or other small entities, describe any methods used to minimize burden.

To implement and support the Community Navigator program, SBA may collect information from two different sets of small entities. Small entities such as local government or Tribes may apply for the Community Navigator grant itself. Once the grantees are selected and begin providing technical assistance, information will be collected from the small businesses that receive technical assistance from the Community Navigator grantees. SBA is utilizing Grants.gov platform to collect applications from entities applying for the Community Navigator grant.

The grantees will be encouraged collect information of SBA Form 3516 from the small businesses receiving technical assistance electronically and SBA will provide API and other support to enable grantees to leverage electronic data collection with SBA’s designated system. This will reduce the burden on both grantees and small businesses. The SBA is requiring information from small businesses that is necessary to provide the business assistance the small business seeks and is necessary for SBA to report to the President and Congress.

The grantees will be asked to transmit the client information and results obtained by the small business as a result of technical assistance provided (e.g., small business successfully receives SBA loan after loan packaging assistance provided by grantee) to SBA quarterly through an online portal being created for this purpose.

Neither of the data collections outlined above is expected to have a significant impact on any small entities or small businesses. Use of technology by the grantees will be encouraged in an effort to further minimize time and effort to collect the data represented on SBA Form 3516.

Consequences of Collecting the Information Less Frequently

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 data collected is critical to SBA’s ability to meet regular reporting requirements and performance management functions. As an American Recovery Plan program, SBA will need to provide regular reports to the White House and Congress. This is a $100 million grant program so it is also critical that SBA collects this information for proper management and oversight of the program. Without the data collection, SBA will be unable to effectively manage the program and ensure equity, a core tenet of the program. If the information is collected less frequently, SBA would not be able to intervene in a timely manner when performance issues arise or if the intended results of the program are not being achieved.

Special Circumstances Relating to the Guideline of 5 CFR 1320.5

Explain any special circumstances that would cause an information collection to be conducted in a manner:

requiring respondents to report information to the agency more often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax 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;
requiring the use of a statistical 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; or
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.

SBA Form 3516 requests some confidential and proprietary information (e.g., race, gender, gross revenues/sales) as a means to ensure equitable access to and support from the Community Navigator grantees. However only the client, the grantee and SBA will be privy to the individualized confidential and proprietary information, protecting the integrity of the data. SBA has instituted procedures to protect confidentiality to the extent permitted by law and only aggregate and summary data will be provided in public reports.

Comments in Response to the Federal Register Notice and Efforts to Consult

Outside the Agency. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, 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. 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 form, and on the data elements to be recorded, disclosed, or reported.

As part of its request for emergency processing of this information collection SBA is also requesting waiver of the required public comment notice. If the request is granted, SBA will publish the notice in the Federal Register before the emergency approval period ends.

Explanation of Any Payment or Gift to the Respondents

Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

No payments or gifts will be made to respondents.

Assurance of Confidentiality Provided to Respondents

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

Any personal information collected will be protected to the extent permitted by law, including the Privacy Act of 1974 and the Freedom of Information Act. In addition, to the extent permitted under FOIA, confidential business information (CBI) will only be disclosed to contractor or Agency personnel assigned to work on these programs. The data will be stored at the SBA in systems which adhere to all Federal Government data protection requirements. The form also notifies respondents that information will be kept confidential.

Justification for Sensitive Questions

Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

To conform to Executive Order 13985, respondents will be asked for the following information which may be considered sensitive: gender, veteran status, ethnicity, race, sexual orientation, and disability status to ensure program equity. Race and ethnicity questions were written in compliance with the OMB Standards for the Classification of Federal Data on Race and Ethnicity. Collection of this information is voluntary. The form contains statement that describes how the information they provide will be used and handled.

The information collected is in response to compliance with various reporting requirements, including those to the White House and Congress. Additionally, it is essential to the mission of the agency and to monitoring business performance. SBA has instituted procedures to protect confidentiality to the extent permitted by law and only aggregate and summary data will be provided in public reports.

Additionally, SBA is asking for business EINs from clients receiving technical assistance. The EIN is the unique business identifier already used by SBA’s loan and financial assistance programs. In order to verify financial assistance received by the client, we need to use the same unique identifier. Without the EIN, SBA will not be able to verify whether the client receiving the technical assistance also received SBA financial assistance. While the EIN is not deemed sensitive, businesses who use their Social Security Number (SSN) instead of an EIN will be asked to provide SSN. The ability for SBA to collect SSNs information for this specific purpose vests with EO 9397.

Estimates of Hour Burden, Including Annualized Hourly Costs

Provide estimates of the hour burden of the collection of information. Indicate the affected public, number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

The SBA estimates the total annual burden to be 10,400 hours for grant applicants (application plus quarterly reporting for one year) and 150,000 hours for SBA Form 3516 (client and technical assistance provider together). The total annualized hour and costs burdens are set out below in Exhibit 1. The burden is based on the current burden experienced by respondents for similar SBA programs.

Application: Because Community Navigators is a new program, it is difficult to determine how many entities will apply. Given the appropriation for this program is $100 million, SBA can award a maximum of 100 awards (at the lowest award level which is tied to the smaller entities) - $100 million divided by $1 million. Given the limited funding, we estimate receiving 200 applications and making approximately 50 awards. We will update the burden for this information collection as necessary during the standard processing phase as, at that point, we will know how many entities actually applied and can provide better data. The burden calculation below is based on an average Federal grant proposal/application taking 50 hours with grant writers on average receiving $33¹ per hour. Additionally, we estimate the quarterly reports will take approximately two hours each quarter.

SBA Form 3516: will collect data on the clients served by the Navigators. This form will be completed by both the client and the grantee working with the client. The client will only complete the form one time while the grantee will document the client’s needs with each visit. Not all clients will utilize the technical assistance more than once. The cost burden of SBA Form 3516 is based on an estimated median annual income of $66,500 for small business owners, which equates to an hourly rate (2000 work hours per annum) of $33² and an estimated median annual income for counselors of $50,000 which equates to an hourly rate of $25.

Exhibit 1. Information Collection Burden Estimates Per Year

	Anticipated Number of Respondents	Number of Responses	Frequency of collection	Average minutes spent	Total Burden (hours)	Total Cost Burden
Grantee Application & Reporting
Proposal creation (Application)	200	200	One time	50 hours	10,000	$330,000
Grantee Quarterly Reports to SBA	50	50	4x/year	120	400	$13,000
Grantee Total	250				10,400	$343,000

SBA Form 3516
First Visit - Client	300,000	300,000	One time	10	50,000	$1,650,000
First Visit – TA Provider	50	300,000	One time	10	50,000	$1,250,000
Follow-up Visits – TA Provider	50	150,000	2x/year	10	50,000	$1,250,000
Form 3516 Total	300,050	450,000			150,000	$4,150,000

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the costs of any hour burden shown in items 12 and 14)

There is no other annual cost burden to respondents or record keepers.

14. Annualized Costs to Federal Government

Provide estimates of annualized cost to the federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

Since Community Navigators is a new program, SBA will leverage contractor support to build and maintain the information technology system SBA will use to collect performance report information from grantee. The estimated cost of the information technology contract for the first year is $4.5 million and second year is $3 million.

Additionally, during the first year of the program, SBA will leverage a combination of new staff hires and contract support to fill key program roles such as grants management specialists and program and financial analysts. SBA intends to transition to utilizing all SBA employees during the second year. The first-year estimate of human resource support including SBA staff and contract support is approximately $2.5 million and $1.8 million in second year.

15. Explanation for Program Changes or Adjustments

Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

This is a new data collection for the newly created Community Navigators Pilot Program.

16. Plans for Tabulation and Publication and Project Time Schedule

For collections of information whose results are planned to 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.

Information collected from SBA Form 3516 will only be published in summary form as a means of providing SBA management officials, Congress and the President with reports on program activity and participant outcomes. SBA expects to produce annual reports to the White House and Congress on the impact of the Community Navigator program leveraging aggregate data to illustrate program objectives and outcomes have been met.

Information regarding the grantees (name and amount of award) will be published on USASpending.gov.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

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

SBA plans to display the OMB expiration date.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

Explain each exception to the certification statement identified in item 19, “Certification Requirement for Paperwork Reduction Act” of OMB Form 83-I. If Agency is not requesting an exception, the standard statement should be used.

SBA is not requesting any exceptions to the certification.

B. Collection of Information Employing Statistical Methods. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used.

Not Applicable, as statistical methods will not be used.

1See Grant writer salary: https://www.erieri.com/salary/job/grant-writer/united-states#:~:text=The%20average%20pay%20for%20a,is%20between%20%2449%2C703%20and%20%2485%2C517

2 See http://www.payscale.com/research/US/Job=Small_Business_Owner_%2F_Operator/Salary.

File Type	application/vnd.openxmlformats-officedocument.wordprocessingml.document
Author	Kelsye Turner
File Modified	0000-00-00
File Created	2021-05-14

3245-Comm v3PRA_Supporting Statement_Community Navigators 5-13-2021