Amended Supporting Statement for USAID ADS 303 Standard Provisions

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
OMB CONTROL NUMBER:
United States Agency for International Development (USAID)
Automated Directives System (ADS) Chapter 303 Standard
Provisions Information Collection (amended)
ADS 303 section affected: 303.4.2, “Internal Mandatory
References”
Internal Mandatory References affected:
1. ADS 303maa, “Standard Provisions for U.S. Nongovernmental
Organizations,” Standard Provisions: M9, M17, M18, M20,
M23, M28, M30, RAA1, RAA2, RAA3, RAA6, RAA9, RAA12, RAA13,
and RAA25;
2. ADS 303mab, “Standard Provisions for Non-U.S.
Nongovernmental Organizations,” Standard Provisions: M2,
RAA3, RAA15, RAA19, and RAA23; and
3. ADS 303mat, “Standard Provisions for Fixed Amount Awards to
Nongovernmental Organizations,” Standard Provision: RAA5
A. Justification.
1. Administrative requirements. Agreement officers (AOs)
insert the above referenced standard provisions in USAID
assistance awards as required (provisions beginning with “M”) or
as applicable (provisions beginning with “RAA”). These standard
provisions require recipients of USAID assistance awards to
submit information to USAID. This clearance covers the
information that recipients must submit to comply with the terms
and conditions of the standard provisions. All of these
information collections affect ten or more recipients over any
12-month period, thus requiring OMB approval under the PRA. The
specific information collection required by each standard
provision is briefly described below:
● M2. ACCOUNTING, AUDIT, AND RECORDS (MARCH 2021).
An audit report must be submitted to USAID within 30 days
after receipt of an auditor’s report, but no later than
nine months after the end of the period audited. (ADS
303mab)
● M9, DEBARMENT, SUSPENSION, AND OTHER RESPONSIBILITY
MATTERS (JUNE 2012).
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The recipient agrees to notify the AO immediately upon
learning that it or any of its principals have been subject
to certain actions pertaining to responsibility matters.
(ADS 303maa; duplicate information collection at 303mab M12
and 303mat M4)
● M17, TRAVEL AND INTERNATIONAL AIR TRANSPORTATION (DECEMBER
2014).
This provision requires that the recipient document one of
the allowable exceptions from the applicable cost
principles in the event that the cost for airfare exceeds
the customary standard commercial airfare (coach or
equivalent) or the lowest commercial discount airfare. (ADS
303maa; duplicate information collection at 303mab RAA9)
● M18, OCEAN SHIPMENT OF GOODS (JUNE 2012).
This provision requires the recipient to contact USAID’s
Transportation Division via email to determine the flag and
class of vessel to be used for any ocean transportation of
goods purchased or financed with USAID funds under the
award. (ADS 303maa; duplicate information collection at
303mab RAA10 and 303mat RAA6)
● M20, TRAFFICKING IN PERSONS (April 2016).
If the estimated value of services required to be performed
under the award outside the United States exceeds $500,000,
the recipient must submit to the AO an annual
“Certification regarding Trafficking in Persons,
Implementing Title XVII of the National Defense
Authorization Act for Fiscal Year 2013” and must implement
a compliance plan to prevent the activities described
above. (ADS 303maa; duplicate information collection at
303mab M15 and 303mat M6)
● M23, USAID IMPLEMENTING PARTNER NOTICES (IPN) PORTAL FOR
ASSISTANCE (JULY 2014).
All recipients receiving a USAID award are required to
register with the USAID IPN Portal online. Recipients must
utilize the IPN Portal to review and sign bilateral
amendments. The recipient has a choice of submitting a
signed copy to the AO electronically or via hardcopy. (ADS
303maa; duplicate information collection at 303mab M21 and
303mat M9)
● M28, MANDATORY DISCLOSURES (NOVEMBER 2020).
2

Requires applicants and recipients to disclose all
violations of Federal criminal law involving fraud,
bribery, or gratuity violations potentially affecting
award, to USAID Inspector General and copy the AO. The
recipient must include this mandatory disclosure
requirement in all subawards and contracts under this
award. (ADS 303maa; duplicate information collection at
303mab M26 and 303mat M14)
● M30, CONFLICT OF INTEREST (August 2018).
The recipient must disclose any conflict of interest,
including organizational conflicts of interest, and the
recipient’s approach for resolving the conflict of interest
to the cognizant AO for the award within ten (10) calendar
days of the discovery of the conflict of interest. (ADS
303maa; duplicate information collection at 303mab M28 and
303mat M16)
● RAA1, NEGOTIATED INDIRECT COST RATES - PREDETERMINED
(NOVEMBER 2020).
This provision requires any nonprofit without a previously
established indirect cost rate with a Federal agency to
submit an initial indirect cost proposal immediately after
notice of award and no later than three months after
effective date of award. Recipients with previously
established indirect cost rates must submit a new proposal
within six months after close of each FY. If USAID is the
cognizant agency (or no cognizant agency designated),
recipients must submit four copies of the audit report,
proposed indirect cost rate, and supporting cost data to
USAID. (ADS 303maa)
● RAA2, NEGOTIATED INDIRECT COST RATES - PROVISIONAL
(Nonprofit) (NOVEMBER 2020).
Organizations that have previously established indirect
cost rates must submit a new indirect cost proposal to the
cognizant agency for indirect costs within six months after
the close of each fiscal year. A nonprofit organization
which has not previously established an indirect cost rate
with a Federal agency must submit its initial indirect cost
proposal immediately after the organization is advised that
a Federal award will be made and, in no event, later than
three months after the effective date of the Federal award.
If USAID is the cognizant agency or no cognizant agency has
been designated, the recipient must submit four copies of
the audit report, along with the proposed final indirect
cost rates and supporting cost data. (ADS 303maa)
3

● RAA3, NEGOTIATED INDIRECT COST RATE - PROVISIONAL (Profit)
(DECEMBER 2014).
Within six months after the close of the recipient’s fiscal
year, the recipient must submit to the cognizant agency for
audit the proposed final indirect cost rates and supporting
cost data. If USAID is the cognizant agency or no
cognizant agency has been designated, the recipient must
submit three copies of the proposed final indirect cost
rates and supporting cost data. (ADS 303maa)
● RAA3, INDIRECT COSTS - NEGOTIATED INDIRECT COST RATE
AGREEMENT (NICRA) (NOVEMBER 2020).
Within the earlier of 30 days after receipt of the audit
report or nine months after the end of the audit period,
the recipient must submit to the AO the proposed final
indirect cost rates with supporting data. (ADS 303mab)
● RAA5, FLY AMERICA ACT RESTRICTIONS (AUGUST 2013)
In the event that the recipient selects a carrier other
than a U.S. Flag Air Carrier for international air
transportation, in order for the costs of such
international air transportation to be allowable, the
recipient must document such transportation in accordance
with this provision and maintain such documentation in
accordance with the record retention requirements of this
award. (ADS 303mat)
● RAA6, VOLUNTARY POPULATION PLANNING ACTIVITIES –
SUPPLEMENTAL REQUIREMENTS (JANUARY 2009).
The recipient must notify USAID when it learns about an
alleged violation in a project. The recipient must
document the patient's informed consent by a written
consent document in a language the patient understands and
speaks, which explains the basic elements of informed
consent. (ADS 303maa)
● RAA9, TITLE TO AND CARE OF PROPERTY (COOPERATING COUNTRY
TITLE) (NOVEMBER 1985).
This provision requires the recipient to prepare and
establish a property control system and submit an inventory
schedule and disposition report to the AO within 90 days
after. (ADS 303maa; similar information collection at
303mab M7)
● RAA12, INVESTMENT PROMOTION (NOVEMBER 2003).
4

This provision requires the recipient to notify AO and
provide detailed description of proposed activity related
to investment promotion. (ADS 303maa; duplicate information
collection at 303mab RAA14 and 303mat RAA10)
● RAA13, REPORTING HOST GOVERNMENT TAXES (DECEMBER 2022).
Requires recipients to submit an annual report on host
government taxes. (ADS 303maa; duplicate information
collection at 303mab RAA11 and 303mat RAA7)
● RAA15, COST SHARE (JUNE 2012).
This provision requires the recipient to provide supporting
records for in-kind contributions from third parties. (ADS
303mab)
● RAA19, PROTECTION OF HUMAN RESEARCH SUBJECTS (JUNE 2012).
This provision requires assurance of compliance by either
obtaining a Federal-Wide Assurance (FWA) from the U.S.
Department of Health and Human Services or various
submittals (justification memorandum or a written
assurance)directly to the AOR for USAID approval. (ADS
303mab; duplicate information collection at 303mat RAA11)
● RAA23, VOLUNTARY POPULATION PLANNING ACTIVITIES –
SUPPLEMENTAL REQUIREMENTS (JANUARY 2009).
The recipient must notify USAID when it learns about an
alleged violation in a project and must notify USAID about
violations in a project affecting a number of people over a
period of time that indicate there is a systemic problem in
the project. In addition, the recipient must retain copies
of informed consent forms and certification documents for
each voluntary sterilization for a period of three years
after performance of the sterilization procedure. (ADS
303mab; duplicate information collection at 303mat RAA15)
● RAA25, PATENT REPORTING PROCEDURES (NOVEMBER 2020).
This provision requires that the recipient must
use the National Institutes of Health EDISON Patent
Reporting and Tracking system (http://www.iedison.gov) to
fulfill its disclosure obligations under 37 CFR
401.14(c)(1). The recipient must also submit reports on
utilization of subject inventions annually to the AOR under
37 CFR 401.14(h), and the last report must be provided
within 90 days of the expiration of the agreement. (ADS
303maa; duplicate information collection at 303mab RAA12
and 303mat RAA8)
5

2. Uses of information. AOs use this information to ensure
compliance in accordance with the PRA requirement, 2 CFR 200, 2
CFR 700, and the applicable standard provision.
3. Consideration of information technology. USAID uses
improved information technology to the maximum extent
practicable. Where both the Government agency and recipients are
capable of electronic interchange, the recipient may submit this
information collection requirement electronically.
4. Efforts to identify duplication. There are several
provisions with the same requirement but mostly duplicative or
very slightly different language to address Non-US NGOs, US
NGOs, and/or Fixed Amount Awards. We did not list second and/or
third occurrences of the same or substantially the same standard
provision as a separate provision, but have noted multiple
appearances in parentheses in Section A.1. above at the end of
the provision description. For example, a Debarment and
Suspension standard provision is included as M9 in ADS 303maa,
M12 in ADS 303mab, and M4 in ADS 303mat, but is only listed on
first occurrence in this document to avoid unnecessary
duplication. However, the burden estimates listed later in this
supporting statement account for all possible respondents. These
provisions are separated as to what type of entity they apply
to: Non-US NGOs, US NGOs, or in Fixed Amount Awards. These
provisions are listed in separate documents because some of them
apply to all three types of entities, but some may not be
applicable. Although some of the provisions are duplicated in
these various documents, they do not apply to an awardee in the
performance of an award more than once.
5. If the collection of information impacts small businesses or
other entities, describe methods used to minimize burden. The
burden applied to small businesses is the minimum consistent
with applicable laws, Executive Orders, regulations, and prudent
business practices.
6. Describe consequences to Federal program or policy
activities if the collection is not conducted or is conducted
less frequently. Collection of information on a basis other
than solicitation-by-solicitation and award-by-award is not
practical.
7.

Special circumstances for collection. Not applicable.

8.

Efforts to consult with persons outside the agency.
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A. A 60-day notice was published by USAID in the Federal
Register at 87 FR 9563, on February 22, 2022. A subsequent
60-day notice was published by USAID to amend the
information collection for RAA13, Reporting Host Government
Taxes at 87 FR 21606 on April 12, 2022.
B. A 30-day notice was published by USAID in the Federal
Register at 87 FR 26723, on May 5, 2022. A subsequent 30day notice was published by USAID to amend the information
collection for RAA13, Reporting Host Government Taxes at 88
FR 38478 on 06/13/2023.
9. Explanation of any decision to provide any payment or gift
to respondents, other than remuneration of contractors or
grantees. Not applicable.
10. Describe assurance of confidentiality provided to
respondents. This information is disclosed only to the extent
consistent with prudent business practices, current regulations,
and statutory requirements.
11. Additional justification for questions of a sensitive
nature. No sensitive questions are involved.
12 & 13. Estimated total annual public hour and cost burden.
There are no Governmentwide systems for collecting the reporting
requirements for the provisions outlined above. Some of the
provisions are collected on a routine basis while some reporting
is ad hoc, based on the specifics of the award and type of
awardee.
United States Agency for International Development
● M2. ACCOUNTING, AUDIT, AND RECORDS (MARCH 2021).
Estimated respondents/yr............................
50
Responses per respondent (approximately).............x
1
Total annual responses.............................
50
Estimated hrs/response................................x
4
Estimated total burden hrs.........................
200
Hourly rate*..........................................x $59
Estimated cost to the public...................
$ 11,800
● M9, DEBARMENT, SUSPENSION, AND OTHER RESPONSIBILITY
MATTERS (JUNE 2012).
Estimated respondents/yr.............................
Responses per respondent (approximately).............x
Total annual responses..............................
7

10
1
10

Estimated hrs/response................................x
4
Estimated total burden hrs..........................
40
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 2,360
● M17, TRAVEL AND INTERNATIONAL AIR TRANSPORTATION (DECEMBER
2014).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x
4
Estimated total burden hrs..........................
40
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 2,360
● M18, OCEAN SHIPMENT OF GOODS (JUNE 2012).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x
4
Estimated total burden hrs..........................
40
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 2,360
● M20, TRAFFICKING IN PERSONS (April 2016).
Estimated respondents/yr.............................
50
Responses per respondent (approximately).............x
1
Total annual responses..............................
50
Estimated hrs/response................................x
8
Estimated total burden hrs..........................
400
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 23,600
● M23, USAID IMPLEMENTING PARTNER NOTICES (IPN) PORTAL FOR
ASSISTANCE (JULY 2014).
Estimated respondents/yr.............................
250
Responses per respondent (approximately).............x
1
Total annual responses..............................
250
Estimated hrs/response................................x
4
Estimated total burden hrs.......................... 1,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$59,000
● M28, MANDATORY DISCLOSURES (NOVEMBER 2020).
Estimated respondents/yr.............................
Responses per respondent (approximately).............x
Total annual responses..............................
8

10
1
10

Estimated hrs/response................................x
4
Estimated total burden hrs..........................
40
Hourly rate*..........................................x $59
Estimated cost to the public....................
$2,360
● M30, CONFLICT OF INTEREST (August 2018).
Estimated respondents/yr.............................
25
Responses per respondent (approximately).............x
1
Total annual responses..............................
25
Estimated hrs/response................................x
8
Estimated total burden hrs..........................
200
Hourly rate*..........................................x $59
Estimated cost to the public....................
$11,800
● RAA1, NEGOTIATED INDIRECT COST RATES - PREDETERMINED
(NOVEMBER 2020).
Estimated respondents/yr.............................
100
Responses per respondent (approximately).............x
1
Total annual responses..............................
100
Estimated hrs/response................................x 40
Estimated total burden hrs.......................... 4,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$236,000
● RAA2, NEGOTIATED INDIRECT COST RATES - PROVISIONAL
(Nonprofit) (NOVEMBER 2020).
Estimated respondents/yr.............................
100
Responses per respondent (approximately).............x
1
Total annual responses..............................
100
Estimated hrs/response................................x 40
Estimated total burden hrs.......................... 4,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$236,000
● RAA3 (ADS 303maa), NEGOTIATED INDIRECT COST RATE PROVISIONAL (Profit) (DECEMBER 2014).
Estimated respondents/yr.............................
100
Responses per respondent (approximately).............x
1
Total annual responses..............................
100
Estimated hrs/response................................x 40
Estimated total burden hrs.......................... 4,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$236,000
● RAA3 (ADS 303mab), INDIRECT COSTS - NEGOTIATED INDIRECT
COST RATE AGREEMENT (NICRA) (NOVEMBER 2020).
Estimated respondents/yr.............................
100
9

Responses per respondent (approximately).............x
1
Total annual responses..............................
100
Estimated hrs/response................................x 40
Estimated total burden hrs.......................... 4,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$236,000
● RAA5, FLY AMERICA ACT RESTRICTIONS (AUGUST 2013)
Estimated respondents/yr.............................
25
Responses per respondent (approximately).............x
1
Total annual responses..............................
25
Estimated hrs/response................................x
4
Estimated total burden hrs..........................
100
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 5,900
● RAA6, VOLUNTARY POPULATION PLANNING ACTIVITIES –
SUPPLEMENTAL REQUIREMENTS (JANUARY 2009).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x
8
Estimated total burden hrs..........................
80
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 4,720
● RAA9, TITLE TO AND CARE OF PROPERTY (COOPERATING COUNTRY
TITLE) (NOVEMBER 1985).
Estimated respondents/yr.............................
30
Responses per respondent (approximately).............x
1
Total annual responses..............................
30
Estimated hrs/response................................x 16
Estimated total burden hrs..........................
480
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 28,320
● RAA12, INVESTMENT PROMOTION (NOVEMBER 2003).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x
8
Estimated total burden hrs..........................
80
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 4,720
● RAA13, REPORTING HOST GOVERNMENT TAXES (DECEMBER 2022).
Estimated respondents/yr............................. 4,800
10

Responses per respondent (approximately).............x
1
Total annual responses.............................. 4,800
Estimated hrs/response................................x
1
Estimated total burden hrs.......................... 4,800
Hourly rate**......................................x 102.80
Estimated cost to the public.......................$493,440
● RAA15, COST SHARE (JUNE 2012).
Estimated respondents/yr.............................
50
Responses per respondent (approximately).............x
1
Total annual responses..............................
50
Estimated hrs/response................................x 24
Estimated total burden hrs.......................... 1,000
Hourly rate*..........................................x $59
Estimated cost to the public....................
$59,000
● RAA19, PROTECTION OF HUMAN RESEARCH SUBJECTS (JUNE 2012).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x 24
Estimated total burden hrs..........................
240
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 14,160
● RAA25, PATENT REPORTING PROCEDURES (NOVEMBER 2020).
Estimated respondents/yr.............................
10
Responses per respondent (approximately).............x
1
Total annual responses..............................
10
Estimated hrs/response................................x 16
Estimated total burden hrs..........................
160
Hourly rate*..........................................x $59
Estimated cost to the public....................
$ 9,440
Estimated total cost to the public................ $

1,679,340

* Based on the OPM GS-12/step 5 salary ($43.10 an hour) plus
36.25% fringe and overhead burden rate, the one mandated by OMB
memorandum M-08-13 for use in public-private competition,
rounded to the nearest dollar, or $59 an hour. Reference Salary
Table 2022-RUS, Effective January 2022, found at www.opm.gov.
** Based on the OPM GS-15/step 5 salary ($69.55) plus 110%
overhead at 25% effort and OPM GS-12/step 5 salary ($42.08) plus
110% overhead at 75% effort resulting in an hourly burden of
$102.80. Reference Salary Table 2022-RUS, Effective January
11

2022, found at www.opm.gov.
14. Estimated cost to the Government. Time required for
Government-wide review is estimated at 16 hours per response.
United States Agency for International Development
All Provisions excluding Reporting Host Government Taxes
Total annual responses...............................
Review time per response (hours).................... x
Review time per year (hours)........................
Hourly rate*.......................................
x
Estimated Government Cost ........................ $

960
16
15,360
$59
906,240

Reporting Host Government Taxes
There are two stages in this reporting that require federal
employee effort. The first is after public respondents submit
the reports to a designated point of contact at the overseas
post, either at USAID or the US embassy; the second is when that
office forwards the reported information to the Bureau for
Foreign Assistance (FA) in the State Department, who then
compiles the data reported from all overseas posts, prepares the
report, and submits it to Congress.
USAID has approximately 112 overseas offices, but the number of
respondents per office varies widely, from as few as just one to
over 150. The federal employee hourly burden per respondent will
also vary because the effort to process the reports depends on
what is reported; some reports will simply say no tax was
imposed, while others may report that a tax was imposed and
whether it was reimbursed by the foreign government. Surveying
even a few posts is unlikely to result in a reliable hourly
federal employee burden, since the individuals responsible for
serving as the point of contact at post are also collecting
reports from non-USAID respondents, and some posts may have a
higher proportion of non-USAID reports while others may have
only USAID reports. USAID believes, however, that most reports
submitted are from USAID-funded assistance awards.
For this justification, USAID estimates that each post is
spending approximately two hours to collect reports from USAID’s
respondents and compile them into a single report to FA.
Stage One: Review of reports to designated point of contact
Hourly rate***..........................................$85.40
Review time per year (hours).................................2
12

Yearly rate............................................$170.80
Total posts..............................................x 112
Review time per response (hours).................... x
16
Portion of this cost associated with Assistance Awards: x 70%
Estimated Government Cost ........................ $
13,391
Stage Two: Submittal of report to Congress
Hourly rate****..........................................$138.18
Review time per year (hours).............................x
130
Yearly cost............................................ $17,963
Portion of this cost associated with Assistance Awards: x
70%
Estimated Government Cost ........................ $
12,574
Total cost of Stage One and Two .................. $
25,965
Total Cost to the Federal Government for all provisions: $932,205
***USAID assumes that the designated point of contact overseas is
a relatively senior financial analyst or controller and is
assisted by a mid-level financial analyst. The former spends a
half hour on this task while the mid-level analyst spends an hour
and a half. USAID estimates this portion of the federal burden
cost as follows:
Senior Financial Analyst/Controller - Foreign Service Class 2,
Step 5: hourly rate is $58.64
Mid-level financial analyst – Foreign Service Class 4, Step 4:
hourly rate is $37.38. (Per Department of State 2021 Foreign
Service pay schedule with an overseas locality payment of 20.32%
and an overhead rate of 100%).
****Staff at the GS 14 -15 level spend approximately 120-140
hours per year preparing the report to Congress. This effort is
for all USG agencies subject to the reporting requirement.
However, most of the reports are from USAID contractors and
recipients. As such, USAID assumes 130 hours and bases the
hourly cost on a GS 15 Step 1 rate in the 2021 locality pay area
of Washington-Baltimore, DC-MD-VA-WV. USAID assumes an overhead
rate of 100%.
15. Explain reasons for program changes or adjustments reported
in Item 13 or 14. USAID is implementing revisions to the
Reporting Host Government Taxes provision of the ADS Chapter 303
Standard Provisions Collection. The Foreign Tax Reporting
collection is revised to comply with current statutory
requirements. Sec. 7013, Pub. L. 116-260, 143 Stat. 1182, the
13

annual Department of State, Foreign Operations, and Related
Programs Appropriations Act (SFOAA), and similar provisions in
prior years’ SFOAAs, mandate that agencies take certain actions
to prevent taxation of assistance provided with funds
appropriated in an SFOAA, or to obtain full reimbursement of all
taxes paid. The reporting requirement was revised in 2014 (in
Sec. 7013, Pub. L. 113-76, 128 Stat. 5) to redefine the taxes
that must be reported, and USAID is now revising our assistance
policy and required procedures in an update to Automated
Directives System (ADS 303) Grants and Cooperative Agreements to
Non-Governmental Organizations.
16. Outline plans for published results of information
collections. Results will not be tabulated or published.
17. Approval not to display expiration date.

Not applicable.

18. Explanation of exception to certification statement.
applicable.

Not

B. Collections of Information Employing Statistical Methods.
Statistical methods are not used in this information collection.

14