1660-NW153 - Supporting Statement A - 2023 04 17 clean

April 17, 2023

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 – NW153

Title: State, Tribe, and Territory Disaster Case Management Federal Award

Form Number(s):

1. DCM Federal Award Application (FF-104-FY-22-204)

2. DCM Federal Award Modification Request (FF-104-FY-22-206)

3. DCM Federal Award Request for Appeal (FF-104-FY-22-207)

4. DCM Federal Award Monthly Reporting (FF-104-FY-22-208)

5. DCM Federal Award Budget Workbook (FF-104-FY-22-209)

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(1)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

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. Provide a detailed description of the nature and source of the information to be collected.

Section 426 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), Pub. L. 93-288, as amended and codified at 42 U.S.C. § 5189d, authorizes the President to provide case management services to survivors of declared major disasters to identify and address disaster caused unmet needs. Under this authority, the Federal Emergency Management Agency (FEMA) provides Federal funding through a grant or cooperative agreement to States, Tribes, and Territories (STT) to supplement and expand their existing capacity to provide case management services to survivors of Presidentially declared major disasters that include Individual Assistance. In extraordinary circumstances, the STT may request that FEMA provide an opportunity for a local government agency or qualified private organization to apply for the Disaster Case Management (DCM) Federal Award directly. As part of its disaster response and recovery mission, FEMA provides technical assistance and accepts applications from STTs requesting Federal funding for DCM.

As part of the application process, the STT collects information from local organizations on the ground in the declared areas to determine what activities have occurred from the date of the incident and what resource and capabilities exist, gathers information regarding long-term recovery group activities and the estimated population to serve, and submits the STT service delivery and work plans.

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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

Since FEMA issues the awards for DCM through a grant or cooperative agreement, an STT is required to fill out the forms that fall within the Standard Forms 424 (SF-424) Form Families, which represent the government wide standard data sets and forms for grant application packages. These forms were developed in partnership with Federal grant-making agencies and the applicant community and have been approved by OMB.

In addition to the Standard Forms, FEMA has developed five additional forms that an STT will utilize when applying for funding, modifying the award, or appealing FEMA’s determination regarding the application, as well as reporting on current awards. These forms request specific information as it pertains to current and future activities, justification for the program, and estimated costs for program implementation. In addition to the Standard Forms, the FEMA forms will be used to determine whether or not a STT is in need of Federal funding through a DCM Federal award to supplement their current case management activities.

FF-104-FY-22-204, DCM Federal Award Application serves as the written narrative for the application. The information collected within this form pertains to activities from the date of the incident, resources and capabilities, the estimated population to serve, service delivery plan and work plan. FEMA uses this information to assess whether DCM is the appropriate mechanism to assist survivors with meeting their disaster-caused unmet needs.

FF-104-FY-22-206, DCM Federal Award Modification Request is used when an STT wants to modify the DCM Federal Award they have received by requesting an extension to the period of performance, supplemental funding, or a significant change to their plan of services. Similar to the application, this form requests information regarding the current activities and justification for the additional time and/or funding requested and/or significant change to their plan of services. FEMA uses the information provided by the STT to make a determination on the modification request.

FF-104-FY-22-207, DCM Federal Award Request for Appeal is used when an STT wants to appeal a DCM denial determination. This form requests information such as a brief description of the purpose of the appeal as well as new, justifying information that was not included in the original application or modification that pertains to the appeal. FEMA uses the information collected in this form to make a determination on the appeal request.

FF-104-FY-22-208, DCM Federal Award Monthly Report is used to collect monthly aggregate data from program activities. FEMA uses this information to assess the programmatic activity, as well as for predictive modeling, to help FEMA troubleshoot and provide technical assistance throughout the lifecycle of the award, and for any other issue that may arise and needs programmatic data.

FF-104-FY-22-209, DCM Federal Award Budget Workbook serves as the mechanism for the STT to identify costs and provide the justification for each cost associated with operating DCM in the impacted area. FEMA uses the information collected within this document to ensure the program is reasonable, feasible, and allocable.

The following Standard Forms are required for this collection. The forms are approved for use under the OMB Control Number identified for each.

SF-424: Application for Federal Assistance is a standard form used by applicants as a required face-sheet for pre-applications and applications submitted for Federal assistance. It is used by Federal agencies to obtain application certification and is approved for use under OMB No. 4040-0004.

SF-424A: Budget Information for Non-construction Programs is a standard form used by applicants to submit budget data when applying for a grant or cooperative agreement where the major purpose is not construction. The information can include a budget narrative that is used to relate items to program activities and to justify and explain budget items. It is approved for use under OMB No. 4040-0006.

SF-424B: Assurances for Non-Construction Programs is a standard form used by applicants to certify compliance with important Federal requirements when applying for a grant or cooperative agreement where the major purpose is not construction. It is approved for use under OMB No. 4040-0007.

SF-425/425A: Federal Financial Report/Report Attachment is a standard form used by recipients to report the status of financial expenditures for Federal grants; SF-425A is attached when reporting multiple grants. It is approved for use under OMB No. 4040-0014.

SF-LLL: Disclosure of Lobbying Activities is a standard form used by applicants as a required agreement to comply with all requirements of the awarding agency. It is approved for use under OMB No. 4040-0013.

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.

STT recipients currently complete the forms via written or electronic means and submit the forms through email or mail directly to FEMA. Once received, FEMA keeps paper files in a locked cabinet and electronic files behind the FEMA firewall. This process enables flexibility to the applicant to choose the means of submission that best accommodates their resources. Additionally, FEMA is working to develop an electronic system that will offer a consolidated and secure place for applicants to create and submit the required forms.

Usability Testing has been conducted on this collection. As result, there is no change to this collection at this time.

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. 

FEMA has significantly reduced the number of questions that the STT is required to fill out, preventing the STT from having to reiterate the information they already provided to FEMA in the major disaster declaration request (a related but separate process, which precedes the DCM application process). This allows the STT to only focus on the DCM specific information needed for FEMA to consider their DCM application for federal funding.

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

Small businesses or other small entities may partner with the DCM Federal Award recipient informally as a recovery stakeholder interested in providing resources to address disaster caused unmet needs. While the STT may request to have a qualified private organization to be the direct recipient of the DCM award in lieu of the STT, such private organizations have historically been larger entities experienced in providing DCM services to the population impacted by the major disaster declaration. In any instance, FEMA offers technical assistance to the applicant through active communication, as well as written job aids.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

Without the use of these instruments, FEMA cannot award any Federal dollars to be used for DCM. Additionally, data within each DCM application may differ, meaning determinations on whether or not a program is warranted may differ between the STTs. Without these instruments, STTs may provide too much information, placing an undue burden on them while they are also in the midst of responding to the disaster.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner (See 5 CFR 1320.5(d)(2)):

1. Requiring respondents to report information to the agency more often than quarterly.

As outlined in the Notice of Award, recipients must provide monthly, aggregate data utilizing the Report form. This information is used to assist in the monitoring of programmatic and operational activities as well as allows the Federal partners to deliver technical assistance to the recipient, ensuring program outcomes are achieved and critical services are delivered to survivors. All other forms are not required for respondents to report information more than quarterly.

2. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

This information collection does not require respondents to prepare a written response in fewer than 30 days after receipt of it.

3. Requiring respondents to submit more than an original and two copies of any document.

This information collection does not require respondents to submit more than an original and two copies of any document.

4. Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.

This information collection does not require respondents to retain records (other than health, medical, government contract, grant-in-aid, or tax records) for more than three years.

5. 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.

This information collection does not include a statistical survey.

6. Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

This information collection does not use a statistical data classification that has not been reviewed and approved by OMB.

7. That includes a pledge of confidentiality that is not supported by authority established in statue 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.

This information collection does not include a pledge of confidentiality that is not supported by established authorities or policies.

8. 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.

This information collection does not require respondents to submit trade secrets or other confidential information.

8. Federal Register Notice: 



a. Provide a copy and identify the date and page number of publications 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. Specifically address comments received on cost and hour burden.

A 60-day Federal Register Notice inviting public comments was published on September 19, 2022, at 87 FR 57214. Two comments were received. Neither comment was relevant to this collection.

Comment 1 (FEMA-2022-0012-0002): The first comment was not germane.

Comment 1 (FEMA-2022-0012-0003): The second comment was not germane.

A 30-day Federal Register Notice inviting public comments was published on April 17, 2023, at 88 FR 23449. The public comment period is open until May 17, 2023.



b. 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 format (if any), and on the data elements to be recorded, disclosed, or reported.

The information provided by STTs for the DCM Federal award application is not shared with persons outside of the agency.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

FEMA provides technical assistance and consultation to respondents applying for DCM funding. FEMA trains, mentors, and provides guidance to a cadre of Project and Grants officers responsible for providing the respondent with on-site technical assistance and guidance.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

The Department of Homeland Security (DHS) granted interim approval for the DCM Federal Award through a Systems Privacy Threshold Analysis (PTA) approved by DHS on May 22, 2022. A Forms PTA for FEMA Form FF-104-FY-22-208 DCM Federal Award Monthly Report was approved by DHS on March 23, 2023. A Forms PTA for FEMA Form FF-104-FY-22-209, DCM Federal Award Budget Workbook was also approved by DHS on March 23, 2023.

Privacy Impact Assessment (PIA) compliance is provided by the following existing PIA’s:

• DHS/FEMA/PIA-049 Individual Assistance (IA);

• DHS/FEMA/PIA-013 Grant Management Programs;

• DHS/FEMA/PIA-052 Grant Management Modernization; and

• DHS/FEMA/PIA-056 Administered Disaster Case Management Program.

This collection is covered by two existing System of Record Notices (SORN):

• DHS/FEMA-008 Disaster Recovery Assistance Files, published April 30, 2013, at 78 FR 25282; and

• DHS/FEMA-016 Disaster Case Management (DCM) Files, published January 10, 2022, at 87 FR 1171.

There are no assurances of confidentiality provided to the respondents for this information collection.

11. Provide additional justification for any question 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.

There are no questions that are of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:



a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

Forms completed by STT governments:

FEMA Form FF-104-FY-22-204, DCM Federal Award Application: is estimated to have 14 respondents times one response per year for a total of 14 annual responses (14 x 1 = 14). It is estimated that each response will require 20 burden hours to complete, therefore 14 responses times 20 hours equals 280 total annual burden hours (14 x 20 = 280).

FEMA Form FF-104-FY-22-206 DCM Federal Award Modification Request: is estimated to have 10 respondents times one response per year for a total of 10 annual responses (10 x 1 = 10). It is estimated that each response will require 5 burden hours to complete, therefore 10 responses times 5 hours equals 50 total annual burden hours (10 x 5 = 50).

FF-104-FY-22-207 DCM Federal Award Request for Appeal: is estimated to have 3 respondents times one response per year for a total of 3 annual responses (3 x 1 = 3). It is estimated that each response will require 3 burden hours to complete, therefore 3 responses times 3 hours equals 9 total annual burden hours (3 x 3 = 9).

FF-104-FY-22-208 DCM Federal Award Monthly Report: is estimated to have 14 respondents times 12 responses per year for a total of 168 total response (14 x 12 = 168). It is estimated that each response will require 1 hour to complete, therefore 168 responses times 1 hour equals 168 total annual burden hours (168 x 1 = 168).

FF-104-FY-22-209 DCM Federal Award Budget Workbook: is estimated to have 14 respondents times 1 response per year for a total of 14 total responses (14 x 1 = 14). It is estimated that each response will require 5 hours to complete, therefore 14 responses times 5 hours equals 70 total burden hours (14 x 5 = 70).

After conducting usability testing there is no change to the burden hours as listed in the OMB inventory.

 b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

Please see the responses to 12a above and 12c below.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.61 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13¹.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respondents	Responses per Respondent	Total Number of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate ($)	Total Annual Respondent Cost ($)
State, Local, and Tribal Governments	DCM Federal Award Application (FF-104-FY-22-204)	14	1	14	20	280	$76.19	$21,333
State, Local, and Tribal Governments	DCM Federal Award Modification Request (FF-104-FY-22-206)	10	1	10	5	50	$76.19	$3,810
State, Local, and Tribal Governments	DCM Federal Award Request for Appeal (FF-104-FY-22-207)	3	1	3	3	9	$76.19	$686
State, Local, and Tribal Governments	DCM Federal Award Monthly Report (FF-104-FY-22-208)	14	12	168	1	168	$76.19	$12,800
State, Local, and Tribal Governments	DCM Federal Award Budget Workbook (FF-104-FY-22-209)	14	1	14	5	70	$76.19	$5,333
Total		55		209		577		$43,962

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.61.² For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.61, and the entry for the “Avg. Hourly Wage Rate” would be $73.27.

According to the U.S. Department of Labor, Bureau of Labor Statistics the May 2021 Occupational Employment and Wage Estimates the wage rate category for Project Management Specialists (SCO 13-1082) is 47.32 per hour.³ The Project Management Specialists category accurately represents the majority of State, Tribal, and Territorial Government respondents. Including the wage rate multiplier of 1.61, the fully-loaded wage rate is $76.19 per hour. The estimated burden hour cost to respondents is $43,962 (= 577 × $76.19) annually.

The following Standard Forms (SF) are utilized for the FEMA grant programs. Approval for the collection of this information is provided under a government-wide OMB control number used throughout the Federal government; burden hours specific to these forms are not submitted for approval of this collection: Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respondents	Responses per Respondent	Total Number of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate ($)	Total Annual Respondent Cost ($)
State, Local, and Tribal Governments	Application for Fed Assistance, SF-424 (OMB No. 4040-0004)	14	1	14	1.1	15.4	$76.19	$1,173
State, Local, and Tribal Governments Government	Budget Info Non-Construction Programs, SF-424A (OMB No. 4040-0006)	14	1	14	1.8	25.2	$76.19	$1,920
State, Local, and Tribal Governments	Assurances for Non-construction Programs, SF-424B (OMB 4040-0007)	14	1	14	0.5	7	$76.19	$533
State, Local, and Tribal Governments	Attachment   SF-425/425A (OMB 4040-0014)	14	4	56	1.0	56	$76.19	$4,267
State, Local and Tribal Governments	Disclosure of Lobbying Activities / SF LLL  (OMB 4040-0013)	14	1	14	0.15	2.1	$76.19	$160
Total		70		112		105		$8,053

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

The cost estimates should be split into two components:

1. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing 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.

There are no operation or maintenance costs associated with this information collection.

2. .Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling, and testing equipment, and record storage facilities.

There are no capital or start-up costs associated with this information collection.

14. 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Costs are outlined below.

Annual Cost to the Federal Government
Item	Cost ($)
Contract Costs	$0
Staff Salaries1 [Three of GS 13, Step 5 employees spending approximately 20% of time annually to review and provide technical support to States, Tribes, and Territories applying for a DCM Federal award] [$126,949 × 0.2 × 3 x 1.452 = $110,446]	$110,446
Facilities [cost for renting, overhead, etc. for data collection activity]	$0
Computer Hardware and Software [cost of equipment annual lifecycle]	$0
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	$0
Travel [Three of GS-13, Step 5 employees × 3 trips for technical assistance and monitoring of program × $2,500 per trip][3 × $2,500]	$22,500
Total	$132,946
1 Office of Personnel Management 2023 Pay and Leave Tables for the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA locality. Available online at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/DCB.pdf . Accessed December 29, 2022. 2 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1.  Available at https://www.bls.gov/news.release/archives/ecec_03182022.pdf.  Accessed March 29, 2022.  The wage multiplier is calculated by dividing total compensation for all workers of $40.35 by wages and salaries for all workers of $27.83 per hour yielding a benefits multiplier of approximately 1.45.



15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A “Program increase” is an additional burden resulting from a Federal Government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A “Program decrease”, is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal Agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

An “Adjustment” denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data Collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
DCM Federal Award Application (FF-104-FY-22-204)	0	280	280			0
DCM Federal Award Modification Request (FF-104-FY-22-206)	0	50	50			0
DCM Federal Award Request for Appeal (FF-104-FY-22-207)	0	9	9			0
DCM Federal Award Monthly Report (FF-104-FY-22-208)	0	168	168			0
DCM Federal Award Budget Workbook (FF-104-FY-22-209)	0	70	70			0
Total	0	577	577	0	0	0

Explain: This is a new collection.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
DCM Federal Award Application (FF-104-FY-22-204)	$0	$21,333	$21,333			$0
DCM Federal Award Modification Request (FF-104-FY-22-206)	$0	$3,810	$3,810			$0
DCM Federal Award Request for Appeal (FF-104-FY-22-207)	$0	$686	$686			$0
DCM Federal Award Monthly Report (FF-104-FY-22-208)	$0	$12,800	$12,800			$0
DCM Federal Award Budget Workbook (FF-104-FY-22-209)	$0	$5,333	$5,333			$0
Total	$0	$43,962	$43,962	$0	$0	$0

Explain: This is a new collection.



16. For collections 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.

There are no outline plans for tabulation and publication of data for this information collection.

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

This collection does not seek approval to not display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.



This collection does not seek exception to “Certification for Paperwork Reduction Act Submissions.”

1 For the purposes of the charts included in this document, “State” refers to all fifty States, Territories and the District of Columbia. Local Governments and private qualified organizations are rarely direct recipients for the STT DCM Federal Award and were not considered in these calculations.

2 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1.  Available at https://www.bls.gov/news.release/archives/ecec_03182022.pdf. Accessed August 17, 2022. The wage multiplier is calculated by dividing total compensation for State and local government workers of $54.96 by Wages and salaries for State and local government workers of $34.09 per hour yielding a benefits multiplier of approximately 1.61.

3 Information on the mean wage rate from the U.S. Department of Labor, Bureau of Labor Statistics is available online at: https://www.bls.gov/oes/2021/may/oes_nat.htm#31-0000. Accessed August 17, 2022.

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