Supporting Statement 4040-0013 Lobbying ICs v1.1

Supporting Statement

Data Collection Form for

Disclosure of Lobbying Activities (SF-LLL) form and

Certification Regarding Lobbying form
4040-0013

The Disclosure of Lobbying Activities (SF-LLL) is part of an OMB-approved collection (4040-0013). The Certification Regarding Lobbying form is a supplementary form used to collect additional lobbying data from grant applicants. The information collections will be utilized by 26 Federal agencies and additional grant-making entities. We are requesting that the Certification Regarding Lobbying form be added to 4040-0013, an extension of 4040-0013 with a 3-year clearance and classification as Common Forms.

A. Justification

1. Need and Legal Basis

The Office of Federal Financial Management (OFFM) leads efforts at government-wide grants management to assure that Federal grants to non‑Federal entities are managed properly and spent in accordance with laws and regulations. Working cooperatively with Federal grant‑making agencies and non‑Federal entities, OFFM establishes policies and guidelines through OMB's Uniform Administrative Requirements. OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards establish the reporting requirements fulfilled by this form. Grants.gov serves as a repository for Federal grant-related forms on behalf of OMB OFFM. The form is used by non-Federal entities to apply for federal financial assistance.

2. Information Users

The form is used by non-Federal entities to apply for grants, and by Federal grants management staff to evaluate applicants for Federal financial assistance.

3. Improved Information Technology

Federal awarding agencies have the option of allowing recipients to use electronic submission of alternate forms. Although agencies can allow recipients to submit electronically, or via other forms, they are only approved to collect the information approved under this information collection.

4. Duplication of Similar Information

There is no other source for the information reported on this form.

5. Small Businesses

The information requirements do not pertain to small business or other small entities.

6. Less Frequent Collection

No less frequent collection is feasible.

7. Special Circumstances

OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards establish the requirements fulfilled by this form.

8. Federal Register Notice/Outside Consultation

The Grants.gov Program Management Office managed by HHS published the current Application for Federal Financial Assistance form collection for public comment in the Federal Register for 60-day comment on October 4, 2021 (86 FR 54699). Interested individuals were invited to send comments regarding any aspect of this collection of information. No public comments were received.  

9. Payment/Gift to Respondents

Not applicable since there is no payment to respondents, other than remuneration of grantees.

10. Confidentiality

The grant-making agencies will maintain the authoritative copy of all application materials and data.  The information will be consistent with OMB policies related to the administration of Federal grants as well as agency policies and practices for access to electronic and paper records.  If application forms are submitted through the Grants.gov Apply mechanism, Grants.gov will maintain only transmission records pertaining to the files.  Grants.gov will not maintain application materials and data. 

11. Sensitive Questions

Not applicable since there are no sensitive questions.

12. Burden Estimate

As these are Common Forms, burden is reported only for HHS. By aggregating the agency’s estimates as reported from the Grants.gov data call, an estimate of the total burden of the information collection was developed.

HHS receives approximately 12675 submissions of the SF-LLL and 3952 Certification Regarding Lobbying form. HHS estimates that it takes applicants approximately 1 hour on average to complete the SF-LLL and 0.5 hours on average to complete the Certification Regarding Lobbying form. Cumulatively, HHS reports that the total burden to applicants to be 14651 burden hours annually for the SF-LLL and Certification Regarding Lobbying forms.

Section A. Estimated Annualized Burden Hours to Respondents

Disclosure of Lobbying Activities (SF-LLL) and Certification Regarding Lobbying Forms

Estimated Annualized

Burden to Respondents

Form	Number of Annual Respondents	Number of Responses per Respondent	Total Annual Responses	Average Burden on Respondent per Response in Hours	Total Burden Hours
SF-LLL	12675	1	12675	1	12675
Certification Regarding Lobbying	3952		3952	0.5	1976
TOTAL	16627	1	16627	1.5	14651

Section B. Burden Cost

Certification Regarding Lobbying Form

Estimated Annualized

Cost to Respondents

Cost To Respondents
Form	Type of Respondent	Hourly Wage Rate	Total Burden Hours	Total Respondent Cost
SF-LLL	Grant Writer	$30	12675	$380,250
Certification Regarding Lobbying	Grant Writer	$30	1976	$59,280
TOTAL			14651	$439,530

The Estimated Annualized Cost to Respondents assumes that the Hourly Wage Rate for a grant writer is $30. The Total Burden Hours times the Hourly Wage Rate produces the Total Respondent Cost which is $439,530.

13. Capital Costs

There is no projected incremental increase in the cost burden to respondents and record keepers associated with the use of the SF-LLL and the Certification Regarding Lobbying forms.

14. Cost to the Federal Government

There is no projected incremental increase in the cost burden to the Federal Government with the implementation of the SF-LLL and the Certification Regarding Lobbying forms.  Each agency currently has existing personnel, systems and processes (or other resources) in place to receive and review their grant applications.  Any additional cost for agency system development, maintenance and enhancements should not be attributed to use of the Certification Regarding Lobbying Form, and therefore its use is not expected to alter annualized Federal costs. 

	Cost to Government
Form	Total Annual Responses	Agency Personnel Time to Review (Hours)	Total Burden Hours on Agency Personnel	Average Grants Administrative Hourly Salary	Estimated Annual Cost to Federal Government for Form Review
SF-LLL	12675	1	12675	$39	$494,325
Certification Regarding Lobbying	3952	0.5	1976	$39	$77,064
TOTAL					$571,389

Agency personnel time to review the SF-LLL form is estimated at 1 hour per form. Based on 12675 responses per year, then 12675 hours are estimated personnel hours to review. Grants administrative personnel generally are in the GS9 - 15 range. Based on a step one average of these grades, an average hourly salary is $39 per hour. Therefore, 12675 hours x $39 = $494,325 of estimated annual cost to the federal government to review the form. Agency personnel time to review the Certification Regarding Lobbying form is estimated at 0.5 hour per form. Based on 3952 responses per year, then 1976 hours are estimated personnel hours to review. Grants administrative personnel generally are in the GS9 - 15 range. Based on a step one average of these grades, an average hourly salary is $39 per hour. Therefore, 1976 hours x $39 = $77,064 of estimated annual cost to the federal government to review the form. The total cost to the government for 4040-0013 is $571,389.  

15. Program or Burden Change

The burden hours reflected in this ICR remain unchanged at 12,675 hours since the last ICR in 2018.

16. Publication and Tabulation Dates

There are no publication plans for collected data including summarizing or tabulating by Grants.gov.

17. Expiration Date

Three years from OMB approval.

18. Certification Statement

Not applicable since there are no exceptions to the certification.

B. Collections of Information Employing Statistical Methods

No statistical methods are employed in this information collection.