0575-0198 Sup Statement fy 22 10.26.22

2022 SUPPORTING STATEMENT

OMB No. 0575-0198

7 CFR 3570

Community Facilities Technical Assistance and Training Grant Program

A. Justification

1. Explain the circumstances that make the collection of information necessary.

The Community Facilities Technical Assistance and Training (TAT) is a competitive grant program which the Rural Housing Service (RHS) administers. Section 306 of the Consolidated Farm and Rural Development Act (CONACT), 7 U.S.C. 1926, was amended by Section 6006 of the Agriculture Act of 2014 (P.L. 113-79) to establish the Community Facilities Technical Assistance and Training Grant. Section 6006 authorized grants be made to public bodies and private nonprofit corporations (including Indian Tribes) that will serve rural areas for the purpose of enabling the grantees to provide to associations technical assistance and training with respect to essential community facilities authorized under Section 306(a) (1) of the Consolidated Farm and Rural Development Act (7 U.S.C. 1926(a)). Grants can be made for 100 percent of the cost of assistance.

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.

Eligible entities receive TAT grants to help small rural communities or areas identify and solve problems relating to essential community facilities. The grant recipients may provide technical assistance to public bodies and private nonprofit corporations. Public bodies and private nonprofit corporations may also use grant funds to hire professional services such as architectural and financial. The technical assistance is intended to assist in developing an application for USDA funding.

The TAT grant recipients can give technical assistance to nonprofit corporations and public bodies that are eligible for RHS assistance under the Community Facilities program. Public bodies include counties, cities, townships, incorporated towns and villages, boroughs, authorities, districts, other political subdivisions of a State and Native American tribes.

Applicants applying for TAT grants must submit an application, which includes an application form, narrative proposal, various other forms, certifications, and supplemental information. The Rural Development State Offices and the RHS National Office staff will use the information collected to determine applicant eligibility, project feasibility, and the applicant’s ability to meet the grant and regulatory requirements. Based on funding availability for each Fiscal Year and the dollar amount requested by applicants, it may not be possible to fund all applications for the amount requested. If a particular application/project cannot be funded for the full amount, the applicant will be requested to submit revised documents to reflect the revision in the scope of the project based on the amount that can be awarded. Failure to collect proper information could result in improper determinations of eligibility, improper use of funds, or hindrances in making grants authorized by the TAT and Solid Waste Management (SWM) programs.

The applicant will submit the following information:

Reporting Requirements – Non Forms

Documentation of Assistance Provided to Rural Development Employees

Applicants must identify and report any known relationship or association with a RUS employee such as close personal association, immediate family, close relatives, or business associates. This includes any assistance provided to employees.

Indirect Cost Rate Agreement.

The applicant’s indirect cost rate agreement with a recognizant Federal Agency must be submitted if their proposed budget includes indirect costs.

Statement of Compliance.

To assure compliance with Title VI of the Civil Rights Act of 1964, the applicant must provide a narrative of how they plan to notify eligible entities of the availability of the service being provided.

Evidence of Legal Existence and Authority.

The applicant must submit certified copies of organization documents and a certified list of directors and officers as evidence of the applicant’s legal existence and authority for the proposed project. The organizational documents can be charters, bylaws, or articles of incorporation. RHS uses the information to determine if the applicant has the proper authority to enter into a binding agreement to use grant funds.

Evidence of Tax Exempt Status.

Private nonprofit organizations eligible for TAT grants must have 501(c)(3) or 501(c)(4) tax-exempt status, designated by the Internal Revenue Service. An applicant must submit evidence of its tax-exempt status. RHS uses this information to ensure that the applicant meets the eligibility criteria mandated by law.

Narrative - Project Proposal

Applicants will provide a narrative of experience in providing services similar to those proposed. A brief description of successfully completed projects including the need that was identified and objectives accomplished. The narrative should document ability to administer technical assistance and training, financial resources available to pay operational costs and provide financial assistance to projects, and demonstrate secured commitments of financial support from other sources.

Latest Financial Information.

The applicant’s latest financial statement is used to help determine if the applicant is financially viable to complete their proposed scope of work.

Documentation of Matching Funds

The applicant is not required to provide matching funds for the projects. Priority will be given to those applicants who do provide at least twenty percent (20%) matching funds.

Scope of Work/Work Plan

RHS asks the applicant to provide a narrative discussing the proposed services to be provided and how the applicant will select projects that will be assisted with the grant funds. RHS uses the information in the scope of work to measure the performance of the grant recipient and the success of the project. The scope of work describes what will happen in a project, when, and what staff will be responsible. It provides details on the activities or tasks to be accomplished, objectives, timetables for task completion, and anticipated results. The applicant will provide a breakdown of costs (direct and indirect) including those costs funded by the grantee as well as any matching funds or other funding sources.

Budget Justification.

The budget justification demonstrates how the funds will be spent and provides details for proposed expenditures, calculations of costs, and explanations of unusual lines in the budget. It discusses how the budget supports the proposed project activities and explains how each budget item is essential to achieving project objectives. RUS uses this information to evaluate the cost effectiveness of the project and the adequacy of funding to carry out the activities of the project. The information will also be used to evaluate a grant recipient’s request for payments

Evidence of Financial Management System.

Applicant must provide evidence that a financial management system is in place or proposed. RHS uses the information to determine if the applicant will be able to adequately account for federal funds expended.

Documentation of each priority ranking criteria which include:

• List of beneficiaries to be served

• Type of technical assistance to be provided or contracted

• How the project will be evaluated and provide clearly stated goals and how those goals will be measured

• Need for the proposed service

• Personnel on staff or to be contracted to provide the proposed services

• Statement of how long the project will last

• Cost effectiveness of the project.

• Other factors for consideration such as emergency situation, training need identified, health or safety problems, geographical distribution of funds, State Office recommendations and how the project may address a Secretary’s initiative.

Reporting Requirements – Non Forms (Awardees)

Project Performance Report.

Grant recipients must submit a narrative progress report quarterly. The project performance report summarizes the project’s progress for the quarter and includes information needed to support expenditures claimed for the quarter. The last quarterly report may serve as the final report and must be submitted within 90 days of the project end date. Those items discussed in 3570.270 should be addressed. RHS uses this information to monitor performance, ensure schedules are met, projected work is accomplished, and objectives are achieved.

The project performance report meets the requirements of: OMB 2CFR Chapter 1, and Chapter II, Parts 200, 215, 220, 225, and 230 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”.

Audit.

Grantees expending $750,000 or more Federal funds per fiscal year will submit an audit conducted in accordance with OMB 2 CFR Chapter 1, and Chapter II, Parts 200, 215, 220, 225, and 230 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”.

Financial Statements.

Grantees expending less than $750,000 will provide annual financial statements covering the grant period, consisting of the organization’s statement of income and expense and balance sheet signed by an appropriate official of the organization. Financial statements will be submitted within 90 days after the grantee’s fiscal year

Reporting Requirements – Forms

RD 3570-4, “Community Facilities Technical Assistance and Training Grant Agreement”

The Grant Agreement is the official grant instrument between RHS and the TAT recipient. It outlines the terms and conditions of the grants, including each party’s obligations and remedial authorities available for nonperformance.

RHS has converted the non-form instrument RHS Bulletin 3570-1 into Form RD 3570-4. The emergency approval of this package was submitted before the conversion could be completed. Therefore, the Agency is submitting this form for approval with the regular submission of the package.

Form Burden Approved Under Other OMB Numbers

SF- 424, “Application for Federal Assistance.” (OMB No. 4040-0004)

Applicants use this form as a required cover sheet for applications submitted for TAT and SWM grants. The application is an official form required for all Federal grants and requests basic information about the applicant and the proposed project. This form is submitted as part of the pre-application and if the project is selected, as part of the formal application.

SF-424A, “Budget Information--Non-Construction Programs.” (OMB No. 4040-0006)

Applicants project costs and expenses for the grant project. The form also provides information on matching funds. This form is submitted as part of the pre-application and if the project is selected, as part of the formal application.

SF-424B, “Assurances--Non-construction Programs.” (OMB No. 4040-0007)

Applicants read and sign this form to indicate the organization’s intent to comply with the laws, regulations, and policies to which a grant is subject. This form is submitted as part of the pre-application and if the project is selected, as part of the formal application.

SF-LLL, "Disclosure of Lobbying Activities.” (OMB No. 4040-0013)

For grants over $100,000, applicant must certify that no Federal appropriated funds will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with the awarding of any Federal contract, the making of any Federal grant or Federal loan, and the extension, continuation, renewal amendment, or modification of any Federal contract, grant or loan.

SF -270 ,"Request for Advance or Reimbursement,” (OMB No. 4040-0012)

Will be completed by the grantee and submitted to either the State or National Office not more frequently than monthly.

SF 425, “Federal Financial Report.” (OMB No. 4040-0014)

Grant recipients must report the status of grant funds for TAT or SWM on the SF-425 on a quarterly basis. The use of this form complies with OMB Circular A-110.

RD 400-1, “Equal Opportunity Agreement” (OMB No. 0575-0201)

Applicants read and sign this form to agree that they will comply with the Equal Opportunity Clause under Executive Order 11246 of September 24, 1965.

RD 400-4, “Assurance Agreement.” (OMB No. 0575-0201)

Applicants read and sign this form to assure RHS that they will comply with Title VI of the Civil Rights Act of 1964.

The Agency has made the instructions to forms available on the USDA eForms website at https://forms.sc.egov.usda.gov/eForms/welcomeAction.do?Home.

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.

RHS is committed to meeting requirements of the e-Government Act, which requires Government agencies in general to provide the public the option of submitting information or transacting business electronically to the maximum extent possible. RHS will accept electronic applications for TAT Grants through Grants.gov.

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.

RHS collects information from applicants only who are applying for or who are receiving TAT grants. There will be no duplication in the collection of information required. If applicants are applying for other programs where similar information is required, the Agency would make every effort to use that information which is the same.

5. If the collection of information impacts small businesses or other small entities (item 5 of OMB Form 83-1), describe any methods used to minimize burden.

The term “small entity” has the same meaning as the term “small business,” “small organization,” and “small governmental jurisdiction” in accordance with 5 U.S.C. §601(6). The Small Business Administration (SBA) has established a Table of Small Business Size Standards that matches to the industries described in the North American Industry Classification System (NAICS). According to the standards established by the SBA, RHS believes a large majority of our Community Facilities program applicants, borrowers and grant recipients, are classified as small entities. The information to be collected for the administration of the grant program is the minimum that RHS needs to approve the grants and monitor performance. Small entities may be affected by the reporting burden, but only minimum information necessary is required to carry out the authorized programs.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The information collected under these programs is the minimum necessary to conform to the requirements of the program regulations established by law. Much of the information is collected when applicants file for grants or when the grants are closed. Information is collected when needed or required by departmental regulations and OMB circulars. Information cannot be collected less frequently and meet the requirements of the programs. Failure to collect proper information could result in improper determinations of eligibility or improper use of funds.

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

1. Requiring respondents to report information more than quarterly. There are no information requirements for reporting more than quarterly

2. Requiring written responses in less than 30 days. There are no information requirements for written responses in less than 30 days. However, grant recipients must notify RHS immediately of developments that have a significant impact on the grant-supported activities or that might materially impair the ability to meet the objectives of the grant.

3. Requiring more than an original and two copies. There are no such requirements.

4. Requiring respondents to retain records for more than 3 years. There are no such requirements unless any litigation, claim, or audit is started before the expiration of the 3-year period and has not been resolved and final action taken.

5. That is not designed to produce valid and reliable results that can be generalized to the universe of study. There are no such requirements.

6. Requiring use of statistical sampling which has not been reviewed and approved by OMB. There are no such requirements.

7. Requiring a pledge of confidentiality. There are no such requirements.

8. Requiring submission of proprietary trade secrets. There are no such requirements.

8. If applicable, identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection. Summarize public comments received 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, reporting format (if any), and on data elements to be recorded, disclosed, or reported.

As required by 5 CFR 1320.8(d), a 60-Day notice was published in the Federal Register on

August 23, 2022, Vol. 87, No. 147, pages 47183-47184. No comments were received.

El Dorado County Community Health Center 

3104 Ponte Morino Drive

Cameron Park, CA 95682

530.556.2007

This respondent felt that the length of time to prepare reports was rather lengthy and sometimes confusing, but understood the need to complete the forms. Since they are new to the completion process, they figured it would be easier for next time.

Boys and Girls Club of Eastern Panhandle

PO Box 1184

Martinsburg, WV

304-263-1832

This respondent reported that the information collection was a bit cumbersome, but in dealing with government funding and the demographic they are serving, documentation was something they were used to.

Potter’s Hill Fire Department

1307 NC-41,

Pink Hill, NC 28572

This respondent reported that the information collected was complex and required a lot of effort to get everything that was needed, but understood the need.

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

RHS has not made any such decisions or payments.

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

No assurance of confidentiality is provided. Under the Freedom of Information Act, the public can request most data collected from respondents. The information collected under the provisions of these programs is not considered to be confidential.

11. Provide additional justification for any question of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.

The information collected does not contain any questions of a sensitive nature that would be considered private.

12. Provide estimates of the hour burden for the collection of information.

This is the sixth funding cycle for Community Facilities. The application and award numbers are based up the 2021 funding cycle which had 42 applications submitted. 32 of those applications were determined to be complete and eligible applications and 14 awards:

Regulation	Number of Respondents	Total Annual Responses	Total Man-Hours	Total Hourly Wage	Total Costs
7 CFR 3570	42	609	1733	$29	$50,257

As indicated above, RHS estimates a cost of $50,257 for respondents to comply with this regulation. The cost is based on 42 organizations filing an application and 14 of them receiving a grant. The primary individuals submitting a grant application, pre-application, or required reports under this regulation would be a director or a professional financial operations staff member. The estimated total annual cost of the burden is $50,257.  The wage class used for intermediaries was $39 per hour and for recipients the wage class was $19 per hour, using an average wage of $29 per hour.  The dollar amounts used for the wage grade come from mean wages from the Bureau of Labor Statistics, May 2018 National Occupational Employment and Wage Estimates United States (http://www.bls.gov/oes/current/oes_nat.htm).  Mean wages by occupation for the following classes: Financial Specialist 13-2000 and Bookkeeping Accounting & Auditing Clerks 43-3031.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information for (a) capital and start-up cost and (b) operation, maintenance and purchase of services components.

There are no capital and start-up costs and purchase of services components involved with this collection.

14. Provide estimates of annualized cost to the Federal Government.

The annual cost, which includes benefits, travel, communication, supplies, etc., for RHS to develop and administer this initiative is $251,196.  These costs are based on; a GS-13 Program Director in each state spending one percent of their time, a GS-12 Community Programs Specialist in each state spending 4 percent of their time on this initiative; one GS-13 Community Programs Specialist in the National Office spending 10 percent of their time; a National Office Division Director spending one-half percent of their time; and a selection panel comprised of one Area Director and one Program Director at GS-13 salary, three Community Programs Specialists at GS-12 salary and one Asset Risk Management Specialist at GS-13 salary for one percent of their time.  There are no travel expenses for the review team since due to COVID, the team does not play to meet in person, but to conduct reviews virtually.   Below is a breakdown of the employee positions and grade levels that will administer this initiative.  Salaries are based on a Step 5 for each grade level for the “rest of the US” as of January 2022.

	Number of People	Grade	Salary	Time	Cost
National Office
Division Director	1	15	$143,720	0.005	$719
Community Programs Specialist	1	13	$103,396	0.1	$10,3396
State Office*
Program Director	48	13	$103,396	0.01	$49630
Community Programs Specialist	48	12	$86,592	0.04	$166257
Review Panel
Area Director & Program Director	2	13	$103,396	0.01	2,067
Community Programs Specialist	3	12	$86,592	0.01	$2,597
Asset Risk Management Specialist	1	13	$103,396	0.01	$1,034
Travel Expenses					$0
Total Government Cost					$232,645

The annualized cost to the federal government reflects updated salary cost and a shifting of responsibility for program delivery to the Rural Development state office as well a different mix of individuals participating in the panel review process.

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

There was a removal of some forms that are now being included as a Civil Rights Common Form that has impacted the number of burden hours and responses. There was an increase in burden hours and a decrease in the number of responses. This decrease is due to an overall decrease in the number of applicants. The annualized cost to the federal government reflects updated salary cost and a shifting of responsibility for program delivery to the Rural Development state office as well a different mix of individuals participating in the panel review process.

16. For collection of information whose results will be published, outline plans for tabulation and publication.

RHS has no plans to publish the information collected under the provisions of these programs.

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 agency is not seeking approval to not display the expiration date.

18. Explain each exception to the certification statement identified in item 19 on OMB 83-1.

There are no exceptions requested.

B. Collection of Information Employing Statistical Methods.

This collection does not employ statistical methods.

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