OMB 2502-0625, Supporting Statement A_OGC Comments

Supporting Statement for Paperwork Reduction Act Submissions

Eviction Counseling Survey

OMB Control Number: 2502-0625

Forms:

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.

The Office of Housing Counseling is responsible for the administration of the Department’s Housing Counseling Program, authorized by Section 106 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701w and 1701x). The Housing Counseling Program supports the delivery of a wide variety of housing counseling services to homebuyers, homeowners, low-to moderate–income renters, and people experiencing homelessness. The primary objectives of the program are to expand homeownership opportunities, preserve homeownership, and improve access to affordable housing. The housing counselors provide guidance and advice to help families and individuals improve their housing conditions.

Housing counseling agencies play an important role in helping households at risk of eviction, including securing rental assistance funds and pursuing other eviction prevention programs and strategies. Pursuant to 24 CFR 214.300, participating agencies that provide rental housing counseling must address issues related to the rental of residential property, which may include eviction prevention.

Given how quickly the eviction landscape is changing and the increase in rental instability, it is critical that HUD better understand how counseling agencies are assisting households with eviction prevention. The Eviction Counseling Survey will improve HUD’s ability to guide counseling agencies as they continue to support consumers with rental and eviction counseling. The survey is also a vital tool for the Office of Housing Counseling to address the disproportionate impact of evictions on under-represented communities, including communities of color, and low-to-moderate income communities. Addressing this disproportionate impact is in line with critical elements of HUD’s strategic plan.

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.

The “Eviction Counseling Survey” is an online survey instrument developed by HUD’s Office of Housing Counseling in partnership with HUD’s Office of Policy Development and Research. Most of the HUD-Certified Housing Counseling agencies will be invited to complete the survey on a voluntary basis.

HUD’s Office of Housing Counseling will use the information collected through the survey to improve support to housing counseling agencies in providing effective and innovative counseling services for households facing or at risk of eviction. Specifically, the Office of Housing Counseling will use the survey to:

• Gather critical data about the extent to which HUD-approved counseling agencies are providing services to households at risk of or facing eviction.

• Identify, develop, and implement guidance for collecting data on households at risk of eviction (pre- and post-counseling).

• Improve the quality and breadth of eviction-related services offered by counseling agencies.

• Advance an outreach campaign to increase participation in housing counseling programs within targeted communities of color.

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.

The “Eviction Counseling Survey” will be conducted online using the SurveyMonkey survey application. Using SurveyMonkey minimizes respondent burden, allowing the counseling agencies to answer the questions and transmit the survey to HUD by way of a submit button. No additional steps are required. If the agency does not complete a question, the application will prompt them to fill in an answer before allowing them to move to the next set of questions. HUD intends to launch the survey immediately after approval of the PRA by sending housing counseling agencies an email with an invitation to complete the survey and a link to the survey.

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.

While the Office of Housing Counseling collects basic information on the number of households served through rental counseling and eviction counseling, it does not collect information included in the survey on more specific rental and eviction counseling topics such as: how agencies are providing eviction counseling, how they are identifying eviction clients, what challenges they face in assisting eviction clients, and how they track eviction outcomes. Therefore, the survey does not duplicate other sources for this information.

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 burden.

Some housing counseling agencies may be small not-for-profit institutions. Keeping the survey short and using SurveyMonkey to deliver the survey online are ways to minimize burden. The survey is only collecting information essential for HUD to better support agencies in providing effective eviction counseling.

6. 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 HUD were not permitted to conduct the survey, the Office of Housing Counseling would be missing vital information on how best to support its housing counseling agencies in providing eviction counseling, which could result in some households missing out on innovative and effective services.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner: (PLEASE ANSWER EACH BULLET SEPARATELY)

* requiring respondents to report information to the agency more often than quarterly;

Not Applicable

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Not Applicable

* requiring respondents to submit more than an original and two copies of any document;

Not Applicable

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

Not Applicable

* 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;

Not Applicable

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

Not Applicable

* 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

Not Applicable

* requiring respondents to submit proprietary trade secrets, 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.

Not Applicable

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), 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. 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. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), a 60-day Federal Register Notice soliciting public comments was announced in the Federal Register on August 30, 2023, Volume 88, Page 59936. One public comment request was received from Mr. Jim Armstrong for a copy of the documents associated with this information collection, which HUD provided to the commenter on September 7, 2023. A copy of HUD’s response is included in the collection package.

A 30-day Federal Register Notice inviting public comments was published on 11/07/202, Volume 88 Page 76839. No comments were received.

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

There are no payments or gifts to respondents with respect to this collection.

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

There is no PII collected in this survey. HUD is committed to protecting the privacy of individuals’ information stored electronically or in paper form, in accordance with federal privacy laws, guidance, and best practices.

	11. 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. There are no questions of a sensitive nature included with this collection. 12. Provide estimates of the hour burden of the collection of information. The statement should: * Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 desirable. 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. * 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. * Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.
		Estimated Annualized Burden Hours and Costs
Information Collection / Affected Public		Form Name / Form Number Collection Tool	Number of Respondents	Frequency of Response	Responses Per Year	Average Burden Hours Per Response	Annual Burden Hours	Hourly Cost per Response (Hourly Wage Rate)	Total Annual Respondent Cost
Not for Profit Institutions		Eviction Counseling Survey	1,500	1	1,500	.50	750	$53.74	$40,305.00
TOTALS			1,500		1,500		750		$40,305.00

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.46 multiplier to reflect a fully-loaded wage rate.

“Type of Respondent” should be entered exactly as chosen in Question 3 of the OMB Form 83-I

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.46. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.46, and the entry for the “Avg. Hourly Wage Rate” would be $62.06.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm) the median wage rate category for Business and Financial Operations Occupations (13-0000) is estimated to be $36.81 (hourly wage rate) x 1.46 (the wage rate multiplier) =$53.74 (fully loaded wage rate), therefore, the estimated burden hour cost to respondents for Business and Financial Operations Occupations is estimated to $40,305.00 annually.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden 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 and 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 collections 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 recordkeeping, capital, start-up or maintenance costs associated with this information collection.

14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs: N/A	$0
Staff Salaries: (4) GS - 13, step 3 employees spending approximately 25% of time annually reviewing the reports and analyzing the data from this survey. (1) (GS-13, Step 3 - $113,944.00 = $113,944.00 x 1.46 (wage rate multiplier) =166,353.24 x .25 of time spent = $41,589.56. (times 4 employees)	$166,358.24
Facilities [cost for renting, overhead, etc. for data collection activity]	N/A
Computer Hardware and Software [cost of equipment annual lifecycle]	N/A
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	N/A
Travel	N/A
Printing [number of data collection instruments annually]	N/A
Postage [annual number of data collection instruments x postage]	N/A
Other	N/A
Total	$166,358.24

* Note: The “Salary Rate” includes a 1.46 multiplier to reflect a fully-loaded wage rate.

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

As for the Eviction Counseling Survey, the previously approved burden hours will remain the same with, an estimate of 750 burden hours. There are no program changes.

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.

The survey results will be analyzed and may be shared with other HUD departments, housing counseling agencies, and external stakeholders such as Congress. HUD’s Office of Housing Counseling may also share survey results at OHC sponsored events, such as OHC’s Annual Conference. No complex analytical techniques will be used. The analysis will be tabulation and cross-tabulation of closed-ended survey responses and narrative summaries of open-ended responses.

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.

HUD will display the expiration date for OMB approval of this information collection.

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

HUD does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved in this collection.

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