Supporting Statement for Paperwork Reduction Act Submissions
Continuum of Care Program Homeless Assistance Application—ESG Recordkeeping
OMB Number: 2506-0089
Introduction
This submission is to request a reinstatement of a currently approved collection for the recordkeeping burden associated with program requirements that Emergency Solutions Grants (ESG) program recipients will be expected to implement and retain. This submission is limited to the recordkeeping burden under the ESG program, which is covered by OMB control number 2506-0089. The requirements regarding ESG Reporting fall under the approved Consolidated Plan PRA Collection.
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.
On May 20, 2009, Congress passed the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009 (HEARTH Act). The HEARTH Act revises the Emergency Shelter Grants program and renames the program the ESG program. The change in the program’s name reflects the change in the program’s focus from addressing the needs of homeless people in emergency or transitional shelters to assisting people in quickly regaining stability in permanent housing after experiencing a housing crisis and/or homelessness. The key changes that reflect this new emphasis are the expansion of the homelessness prevention component of the program and the addition of new rapid re-housing assistance components.
The statutory provisions and the implementing interim regulations found at 24 CFR 576 that govern the program require recordkeeping requirements first captured in the 6-month clearance package approved in June 2012 and recorded in this current submission.
The ESG program places an emphasis on targeted and coordinated use of local resources. The implementing interim regulations require that ESG recipients consult with local Continuums of Care within their geographic areas (§ 576.400(a)) and requires recipients and subrecipients to coordinate ESG assistance to program participants with other targeted homeless services (§ 576.400(b)) and other mainstream resources available within the community (§ 576.400(c)).
All persons who receive ESG assistance must have an initial evaluation and periodic re-evaluations (every three months for homelessness prevention assistance and annually for rapid re-housing assistance) to ensure that they meet HUD’s eligibility criteria (§ 576.401(a) and (b)). The implementing regulations for the ESG program also require recipients to develop written standards to determine, among other things, the amount and type of assistance each eligible individual or family may receive when they present for assistance (§ 576.400(d)).
Once an individual or family becomes a program participant, the ESG recipient or subrecipient must connect the program participant to other mainstream resources to help the individual or family obtain and maintain housing stability (§ 576.401(d)), develop a housing retention plan (§ 576.401(e)), and ensure that the individual or family is residing in a unit or shelter that meets habitability standards (§ 576.401(d)).
The recipient must establish termination of assistance procedures and must follow them before terminating assistance to any program participant receiving ESG assistance (§ 576.402).
To ensure that programs carried out with ESG funds meet the needs of homeless persons and persons at risk of homelessness within the geographic area, ESG recipients and subrecipients, not including States, must have a homeless or formerly homeless person serve on the board or other decision-making body (§ 576.405).
The recipient and subrecipient must keep records verifying that all of the program requirements have been met (§ 576.500) and ensure that these records are maintained in a secure and confidential manner. Recipients must monitor subrecipients to ensure that program requirements are being met and take sanctions against subrecipients if the requirements are not being met (§ 576.501(c)).
Due to the repeal of Section 443 of the McKinney-Vento Homeless Assistance Act, ESG recipients initially had to follow the environmental review procedures under 24 CFR part 50, which assigns HUD all environmental review responsibilities. However, the President signed into law H.R. 4348 on July 6, 2012, which corrects certain provisions of the HEARTH Act, including the requirement that ESG recipients follow 24 CFR part 50. As a result, recipients and subrecipients assume environmental review responsibilities under 24 CFR part 58. This does not affect the burden hours calculation, as neither part 50 nor part 58 are under the purview of the regulations that govern this program. As a result of this and further clarification, however, we have removed the Environmental Review form from the collection package.
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.
.
This submission is a request for the reinstatement of a currently approved collection of the ESG Program PRA package.
HUD requires recipients of ESG funds to carry out certain program requirements and maintain records that the program requirements were carried out. HUD Field Offices, HUD Headquarters, and ESG recipients use this information to track compliance with the statutory and regulatory provisions. If HUD identifies that the recipient has not been meeting the requirements of this program, it may take the remedial actions set forth in § 576.501(b). Burden hours per response mainly for reporting and recording all responses related to regulations needed to be followed.
A3 Improved Information Technologies
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.
HUD does not require the use of any form to document compliance with program regulations; however, the implementing interim regulation allows communities to maintain documentation by microfilming, photocopying, or other similar methods, including electronic. HUD expects that some communities will maintain paper records, while others will maintain electronic records.
A4 Duplication 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.
No similar information exists. The planning and reporting requirements for this program are already covered in the Consolidated Plan & Annual Performance Report for Grantees, which is covered by OMB control number 2506-0117.
If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
There is no burden on small businesses or other small entities.
A6 Less Frequent Data Collection
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 no records are collected on this aspect of the program, program regulatory compliance will not be able to be determined. The information is collected on a program-by-program basis to permit ESG recipients to draw down ESG funds from the U.S. Treasury and to ensure ESG funds are used for eligible purposes. It is not possible to collect the information less frequently.
Explain any special circumstances that would cause an information collection to be conducted in a manner that would impose additional workload burden on recipients (see eight items listed in OMB guidance).
response more than quarterly – NA
response in fewer than 30 days – NA
more than an original and two copies of any document – NA
retain records for more than three years (other than health, medical, government contract, grant-in-aid, or tax records) – Yes
statistical surveys not designed to produce results than can be generalized to the universe of study – NA
statistical data classification not been approved by OMB – NA
a pledge of confidentiality that is not supported by 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 – NA
respondents to submit proprietary trade secret, or other confidential information - NA
ESG regulations at 24 CFR 576.500(y) require recipients to retain all records pertaining to each fiscal year of ESG funds for 5 years unless otherwise specified at 24 CFR 576.500(y)(1)-(3)."There are no other special circumstances that would cause this information collection to be conducted in a manner that would impose one or more of the additional requirements identified under this item
A8 Federal Register Notice/Outside Consultation
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.
In accordance with the Paperwork Reduction Act of 1995, the Department of Housing and Urban Development published a notice in the Federal Register February 28, 2023, vol 88 page 12693, announcing the agency’s intention to request an OMB review of data collection activities for the ESG. The notice provided a 60-day period for public comments and no comments were received.
A9 Payment/Gift to Respondents
Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.
Not applicable. No payment or gifts are provided to any respondents for any information.
Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.
§ 576.500(w) of the interim ESG regulations states that recipients and subrecipient must develop and implement procedures to ensure that all records containing personally identifying information will be kept secure and confidential; the address or location of any domestic violence, dating violence, sexual assault, or stalking shelter project will not be made public, except with written authorization of the person responsible for the operation of shelter; and the address or location of any housing of a program participant will not be made public, except as provided under a preexisting privacy policy of the recipient or subrecipient and consistent with state and local laws regarding privacy and obligations of confidentiality.
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.
Not applicable. The information collection request does not include any sensitive questions.
A12 Burden Estimate (Total Hours and Wages)
Estimate public burden: number of respondents, frequency of response, annual hour burden. Explain how the burden was estimated.
Exhibit A-1 below demonstrate how the public burden for ESG Data Collection was calculated based on estimated time and expenditures required to complete the record-keeping collection. The total burden for data collection from all recipients and subrecipients is estimated at 387,522 hours. The table estimates the amount of time required for each individual data collection activity including the number of times the activity is carried out during the year and the number of responses expected per activity. The total under number of respondents is for unique respondents and not a summary total of all individualized responses.
Exhibit A-1: Estimated Annual Burden Hours for ESG Data Collection
A |
B |
C |
D |
E |
F |
|
|
|
Information Collection |
Number of Respondents |
Response Frequency (average) |
Total Annual Responses |
Burden Hours Per Response |
Total Annual Hours |
Hourly Rate ** |
Burden Cost Per Instrument |
|
|
||||||||
|
||||||||
576.100(b)(2) Emergency Shelter and Street Outreach Cap |
360 |
1 |
360 |
1 |
360 |
45.14 |
16,250.40 |
|
576.400(a) Consultation with Continuums of Care |
360 |
1 |
360 |
6 |
2,160.00 |
45.14 |
97,502.40 |
|
576.400(b) Coordination with other Targeted Homeless Services |
2,360.00 |
1 |
2,360.00 |
8 |
18,880.00 |
45.14 |
852,243.20 |
|
576.400(c) System and Program Coordination with Mainstream Resources |
2,360.00 |
1 |
2,360.00 |
16 |
37,760.00 |
45.14 |
1,704,486.40 |
|
576.400(d) Centralized or Coordinated Assessment |
2,000.00 |
1 |
2,000.00 |
3 |
6,000.00 |
45.14 |
270,840.00 |
|
576.400(e) Written Standards for Determining the Amount of Assistance |
808 |
1 |
808 |
5 |
4,040.00 |
45.14 |
182,365.60 |
|
576.400(f) Participation in HMIS |
78,000.00 |
1 |
78,000.00 |
0.5 |
39,000.00 |
45.14 |
1,760,460.00 |
|
576.401(a) Initial Evaluation |
50,000.00 |
1 |
50,000.00 |
1 |
50,000.00 |
45.14 |
2,257,000.00 |
|
576.401(b) Recertification |
20,000.00 |
2 |
40,000.00 |
0.5 |
20,000.00 |
45.14 |
902,800.00 |
|
576.401 (d) Connection to Mainstream Resources |
78,000.00 |
3 |
234,000.00 |
0.25 |
58,500.00 |
45.14 |
2,640,690.00 |
|
576.401(e) Housing retention plan |
50,000.00 |
1 |
50,000.00 |
0.75 |
37,500.00 |
45.14 |
1,692,750.00 |
|
576.402 Terminating Assistance |
808 |
1 |
808 |
4 |
3,232.00 |
45.14 |
145,892.48 |
|
576.403 Habitability review |
52,000.00 |
1 |
52,000.00 |
0.6 |
31,200.00 |
45.14 |
1,408,368.00 |
|
576.405 Homeless Participation |
2,360.00 |
12 |
28,320.00 |
1 |
28,320.00 |
45.14 |
1,278,364.80 |
|
576.500 Recordkeeping Requirements |
2,360.00 |
1 |
2,360.00 |
12.75 |
30,090.00 |
45.14 |
1,358,262.60 |
|
576.501(b) Remedial Actions |
20 |
1 |
20 |
8 |
160 |
45.14 |
7,222.40 |
|
576.501(c) Recipient Sanctions |
360 |
1 |
360 |
12 |
4,320.00 |
45.14 |
195,004.80 |
|
576.501(c) Subrecipient Response |
2,000.00 |
1 |
2,000.00 |
8 |
16,000.00 |
45.14 |
722,240.00 |
|
Total |
78,000.00 |
|
546,116.00 |
|
387,522.00 |
|
17,492,743.08 |
|
Annualized Cost @ $45.14/hr (GS-12): $17,492,743.08
Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet 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 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 collection 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 additional costs to the respondents (other than the cost shown in item 12 above).
A14 Cost to the Federal Government
Provide estimates of annualized cost 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 also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
The cost to the government to review the records and compliance with program requirements (but not including the cost of reviewing the reports, follow-up management, or technical assistance) is estimated at $127,836.48. This is an update to the last review of this PRA Package.
A |
B |
C |
D |
E |
F |
|
|
Information Collection |
Number of Respondents |
Response Frequency (average) |
Total Annual Responses |
Burden Hours Per Response |
Total Annual Hours |
Hourly Rate ** |
Burden Cost Per Instrument |
HUD Monitoring |
118.00 |
1.00 |
118.00 |
24.00 |
2,832 |
45.14 |
$127,836.48 |
Total |
118.00 |
|
118.00 |
|
2,832 |
|
$127,836.48 |
*this figure is based on a GS-12 salary for 2023
Explain the reasons for any program changes or adjustments reported in Items 12 and 14 of the Supporting Statement
This submission is a request for the revision of a currently approved collection of the ESG Program PRA package.
There have been two changes to the recordkeeping burden hours since the last submission, approved April 28, 2020. The column that contains the cost per hour for a GS-12 and the total cost: This was updated to $45.14 and the total cost is now $17,492,743.08. This change is now reflected in the burden hours. Additionally, A14 has been updated with the new GS-12 hourly rate.
There has been one change to Section A7 “Special Circumstances. ESG does require applicants to hold records for 5 years. The update made is the following: “ESG regulations at 24 CFR 576.500(y) require recipients to retain all records pertaining to each fiscal year of ESG funds for 5 years unless otherwise specified at 24 CFR 576.500(y)(1)-(3).":
A16 Publication and Tabulation Dates
For collection 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.
HUD does not intend to publish any information as a result of this collection.
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 is not seeking approval to not display the expiration date for OMB approval of the information collection.
Explain each exception to the certification statement identified in item 19.
There are no exceptions to the signed certification.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Matthew Kyle Aronson |
| File Modified | 0000-00-00 |
| File Created | 2023-08-31 |