2024 Emergency Collection Supporting Statement A_ 3.28.24

51March 28, 2024

Supporting Statement for
Paperwork Reduction Act Submissions

OMB Control Number: 1660-NW176

Title: FY 2024 Preparedness Grants Portfolio

Form Number(s):

1. FF-207-FY-23-100 EOCGP -Formal Investment Justification

2. FF-207-FY-23-101 EMPG -Work Plan

3. FF-207-FY-23-102 IBSGP-Associated Investment Justification Form

4. FF-207-FY-23-103 IBSGP-Associated detailed Budget

5. FF-207-FY-23-104 IBSGP-Vulnerability Assessment and Security Plan

6. FF-207-FY-23-106 (formerly 087-0-0-1), Controlled Equipment Request Form

7. FF-207-FY-21-115 (formerly 089-25), NSGP Investment Justification

8. FF-207-FY-21-114 (formerly 089-24) NSGP Prioritization of Investment Justification Form

9. FF-008-FY-23-105 Shelter and Services Program (SSP) Application Worksheet

10. FF-008-FY-23-106 Shelter and Services Program (SSP) FEMA A-Number Submission Template

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 east 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.

The purpose of the FY 2024 Preparedness Grants Portfolio collection is to support immediate needs in response to delivering and supporting grant programs that help the Nation before, during, and after disasters to make the country more resilient. The instruments under this collection include information required for recipients to apply for grant awards and receive funding, for FEMA to monitor awards for compliance, and to comply with applicable laws and regulations. The applicable laws and regulations are included as attachments.

This new collection is being submitted under the Emergency Process for approval of a valid OMB control number for a period of 6 months. FEMA is submitting an emergency request because: (1) this information is essential to the mission of the Agency, (2) this information is necessary prior to the expiration of time periods established under PRA, (3) public harm is reasonably likely to result if normal clearance procedures are followed, and (4) the use of normal clearance procedures is reasonably likely to cause a statutory deadline to be missed.

These forms will be part of a generic collection (1660-NW172) for which FEMA is going through the clearance process. FEMA recently completed the 60-day Federal Register Notice for the generic collection and is awaiting posting of the 30-day Federal Register Notice.

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.

The information is used by FEMA’s Grants Programs Directorate to evaluate applications, monitor grants for performance and compliance, and respond to requests from Congress. See below for details on each instrument.

FF-207-FY-23-100 EOCGP - Formal Investment Justification  

As part of the FY 2024 Emergency Operations Center (EOC) Grant Program application process, applicants must develop a formal Investment Justification (IJ) that addresses the proposed EOC construction or renovation project identified for federal funding support. The Investment Justification must be consistent with the project authorized for funding in accordance with the Congressionally Directed Spending (CDS) outlined in the Joint Explanatory Statement accompanying the Further Consolidated Appropriations Act, 2024 (Pub. L. No. 118-47).  

 

FEMA has developed guidelines that establish the required IJ content and helps ensure that submissions are organized in a consistent manner while addressing key data requirements. This IJ template may be used by applicants to complete and submit their IJ. If applicants do not wish to use this form, they must follow the requirements detailed in the FY 2024 EOC Grant Program Notice of Funding Opportunity (NOFO). Failure to address these data elements in the prescribed format, including the strict formatting guidelines, could potentially result in the rejection of the Investment Justification from review consideration. 

 

FF-207-FY-23-101 EMPG -Work Plan  

This document provides details, timeline, and milestones on proposed projects for the Emergency Management Performance Grant (EMPG) Program. The work plan must demonstrate how proposed projects address gaps, deficiencies, and capabilities in current programs and the ability to provide enhancements consistent with the purpose of the program and guidance provided by FEMA. All EMPG applicants must submit a Work Plan that outlines the State’s/Territory’s emergency management sustainment and enhancement efforts, including new and ongoing activities and projects, proposed for the applicable fiscal year EMPG Program period of performance. Prior to submission of the Work Plan, the applicant must work with the Regional Administrator (RA) or designated Regional EMPG Program Manager to ensure that the common set of agreed-upon priorities are properly addressed in the Work Plan. In addition, the Work Plan must include a detailed budget-build and Budget Narrative that enumerates all expenses associated with project execution, including management and administration costs. The instructions for the EMPG Work Plan can be found in the Preparedness Grants Manual, Chapter 12 and the EMPG Notice of Funding Opportunity (NOFO).  

 

FF-207-FY-23-102 IBSGP - Associated Investment Justification Form  

The purpose of this form is for applicants to develop a single formal Investment Justification (IF) for the Intercity Bus Security Grant Program (IBSGP) that addresses the initiative being proposed for funding, including Management and Administration (M&A) costs. The IJ must demonstrate how proposed activities address gaps and deficiencies (identified in a current vulnerability assessment) in current programs and capabilities, and link to one or more core capabilities identified in the National Preparedness Goal. 

 

FF-207-FY-23-103 IBSGP - Associated detailed Budget  

The Budget Detail Worksheet may be used as a guide to assist applicants in the preparation of the required budget and budget narrative. 

 

FF-207-FY-23-104 IBSGP - Vulnerability Assessment and Security Plan  

The purpose of this form is for applicants to certify that they have had a vulnerability assessment completed and a security evaluation preparedness plan developed or updated within the past three years. 
  

FF-207-FY-23-106 (formerly 087-0-0-1) - Controlled Equipment Request Form 

FEMA form 087-0-0-1 “Controlled Equipment Request” is being reinstated to comply with requirements specified in Section 70914 of the Build America, Buy America Act (BABAA) (Pub. L. No. 117-58, §§ 70901-52). FEMA form 087-0-0-1 “Controlled Equipment Request” was initially developed to collect required information as part of the implementation of Executive Order (EO) 13688: Federal Support for Local Law Enforcement Equipment Acquisition, issued January 16, 2015, which established a Prohibited Equipment List and a Controlled Equipment List Report for the purpose of identifying actions that can improve federal support for the appropriate use, acquisition, and transfer of controlled equipment by state, local, tribal, territorial, and private grant recipients.  

 

One of the requirements of the report is to collect information on the grant recipient, their policies, training, record keeping, etc. FEMA form 087-0-0-1 includes only fields required to comply with the recommendations (which were accepted by the President). As part of implementing the recommendations report, FEMA Grants Program Directorate (GPD) will conduct compliance reviews, consistent with each grant program’s statutory or other authorities. The focus of these reviews will be conducted as part of routine advanced monitoring as appropriate by the GPD. GPD may provide part or all of the information collected to the Federal Interagency Law Enforcement Equipment Working Group (LEEWG) for those purposes. The LEEWG consist of many agencies across the federal government, as well as other state and local agencies/organizations. For further information on the LEEWG, the following link has been provided: https://www.whitehouse.gov/the-press-office/2015/01/16/executive-order-federal support-local-law-enforcement-equipment-acquisition. The LEEWG is required to track controlled equipment inventory and sanctions. On occasion, grant applicants will apply for funding to purchase the same equipment from multiple federal agencies. The working group database, once implemented, will allow federal agencies to check for redundant applications or existing sanctions prior to awarding funds for controlled equipment. GPD does not and will not maintain a database. Until a system is in place for the working group to accept the information, the information on the form will be kept in electronic format in the FEMA GO system with the official grant file; and information is only retrieved by organization/state/grant file name. 

 

FF-207-FY-21-115 (formerly 089-25) - NSGP Investment Justification

Submitted with the application, this document provides narrative details on proposed activities (Investments) that will be accomplished with Nonprofit Security Grant Program (NSGP) grant funds. Investment Justifications (IJs) must demonstrate how proposed projects address gaps and deficiencies in current programs and capabilities and the ability to provide enhancements consistent with the purpose of the program and guidance provided by FEMA. The data from the IJ is collected to assist decision-making at all levels, although, it is primarily used by individual application reviewers. NSGP uses a multi-phase review process. First the states score the IJs from nonprofit organizations using NSGP’s scoring criteria and rank them based on consideration of need and impact. Next, FEMA staff review the IJs to ensure projects are allowable and applicants meet eligibility requirements. Staff also consider information from security reviews that DHS conducts for each nonprofit organization. Finally, a final score is calculated, with multipliers and bonus points added to scores for applications meeting certain criteria. The final results of the scoring process are used to make funding recommendations to the Secretary of Homeland Security.

FF-207-FY-21-114 (formerly 089-24) – NSGP Prioritization of Investment Justification

This form is used by the State Administrative Agency (SAA) to create a prioritized list of applicants from within the state and, if applicable, any high-risk urban areas in the state as designated by the Urban Area Security Initiative (UASI). For each nonprofit organization that applied to the SAA for funding, the SAA adds their application details (e.g., nonprofit organization name, IJ title(s), requested amount(s)) to the prioritization form and answers questions about the applicant (e.g., if the nonprofit previously received NSGP funding). Additionally, the SAA scores each complete application package and ranks them in the prioritization form. FEMA uses the information collected in the prioritization forms to inform funding recommendations to the Secretary of Homeland Security.

 

FF-008-FY-23-105 - Shelter and Services Program (SSP) Application Worksheet

As part of the FY 2024 Shelter and Services Program (SSP) application process, applicants must complete a formal project worksheet that addresses the evaluation criteria specified in the NOFO and provides additional information and certifications. The application worksheet also collects additional information for the competitive version of the program, requiring competitive applicants to enter data related to criteria used to score their applications. The SSP is authorized in the Further Consolidated Appropriations Act, 2024 (Pub. L. No. 118-47). 

The Federal Emergency Management Agency (FEMA) has developed guidelines that ensure submissions are organized in a consistent manner while addressing key data requirements. This project worksheet template may be used by applicants to complete and submit their application. Failure to address these data elements in the prescribed format could potentially result in the rejection of the application worksheet from review consideration.

FF-008-FY-23-106 - Shelter and Services Program (SSP) FEMA A-Number Submission Template
The intention of the SSP is to replace the Emergency Food and Shelter Program – Humanitarian (EFSP-H). A March 28, 2023 report from the Office of the Inspector General (OIG) recommended two ways FEMA can improve oversight of humanitarian relief funds. One recommendation was for recipients to provide receipts and supporting documentation for reimbursement. The other was for recipients to provide supporting documentation, such as Alien Registration Numbers (A-numbers), for families and individuals they assisted. The collection of A-numbers is essential to validate how many noncitizen migrants each applicant assisted.   

 

FEMA has reasonably determined the collection of A-numbers is necessary to perform one of its statutory missions or functions. See 6 U.S.C. 314(a)(12), which directs the FEMA Administrator to supervise grant programs administered by the Agency, and Title II of the Further Consolidated Appropriations Act, 2024 (Public Law No. 118-47). 
 

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.

To the extent possible, GPD uses Adobe or Excel fillable forms for the following forms:

• FF-207-FY-23-106 (formerly 087-0-0-1), Controlled Equipment Request Form

• FF-207-FY-23-100 EOCGP -Formal Investment Justification

• FF-207-FY-23-101 EMPG -Work Plan

• FF-207-FY-21-115 (formerly 089-25), NSGP Investment Justification

• FF-207-FY21-114 (formerly 089-24) NSGP Prioritization of Investment Justification Form

• FF-008-FY-23-105, Shelter and Services Program (SSP) Application Worksheet

• FF-008-FY-23-106, Shelter and Services Program (SSP) FEMA A-Number Submission Template

In all other cases, FEMA provides detailed guidance or a suggested template for the collection. Grant files are maintained/stored in the FEMA GO System, which are GPD systems for managing applications and awards. 

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.

This information is not collected in any other forms, and therefore is not duplicated elsewhere.

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

Except for FEMA Form FF-207-FY-21-115, NSGP Investment Justification, FEMA does not believe that this information collection has a significant economic impact on small businesses or other small entities. FEMA anticipates the use of a separate form in the future for small businesses if it is determined there is an impact on those entities.

For FEMA Form FF-207-FY-21-115, NSGP Investment Justification, FEMA has worked in recent years to remove and consolidate repetitive/irrelevant questions, resulting in fewer questions overall. FEMA has also provided clarity on sections that have historically been ambiguous.

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 this collection, FEMA could not review grant applications and award millions of dollars of federal funds that support the FEMA mission. Additionally, FEMA could not exercise comprehensive financial management, ensure the efficient and effective use of Federal funds, or fulfill monitoring requirements. Collection of this information supports fulfilling the requirements of applicable laws and regulations, including 2 CFR 200.

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.

This information collection does not require 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:

1. Provide a copy and identify the date and page number of publication 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.

As this an emergency request, comments for these instruments were not solicited prior to approval by OMB. However, these forms will be covered by a generic collection (1660-NW172) that FEMA is moving through the normal clearance process. FEMA recently completed the 60-day Federal Register Notice for the generic collection and is awaiting posting of the 30-day Federal Register Notice for comment.

For general collection 1660-NW172, a 60-day Federal Register Notice inviting public comments was published on 12/12/2023, 88 FR 86141. No comments were received.

FEMA is anticipating the 30-Day Federal Register Notice to post sometime in March 2024.

2. 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.

FEMA consults with federal, state, local, tribal governments, territories, and nonprofit organizations on a regular basis throughout the year such as Headquarters and Regional FEMA staff, and State Administrative Agencies/previous year grant recipients. FEMA uses teleconferences, email communications, and issue-specific conferences to meet with representatives.

3. 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 consults on a regular basis with federal, state, and local and nonprofit stakeholders on a variety of issues. These consultations involve discussions regarding the nature of information needed by FEMA to manage the grant programs. Partners offer comments and suggestions about their reporting practices. 

FEMA staff review and adjudicate all comments, questions, and inquiries, received through stakeholder outreach efforts. These types of interactions can affect future iterations of the grant programs in several ways. For example, responses to questions posed by recipients at times result in formal “Frequently Asked Questions” (FAQs) documents which are circulated to wider stakeholder audiences. These FAQs are distributed at various times and venues, including program guidance release, award announcement, and after-action conferences.

Additionally, questions may signal to FEMA leadership that clarification on a particular matter is warranted, and as a result, information bulletins are issued to stakeholders. FEMA developed the Stakeholder Engagement Plan to report on the processes it utilizes to incorporate stakeholder input for grant guidance development and award distribution.

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

No payment or gifts are issued to respondents.

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

Privacy Threshold Analysis (PTA) forms were completed by FEMA and approved by the DHS Privacy Office. The PTA for the EOC, IBSGP, and NSGP forms was approved on February 27, 2023. The PTA for the EMPG Work Plan was approved on June 14, 2022. The PTA for the SSP forms was approved on June 22, 2023. The PTA for the Controlled Equipment Request form was approved on February 27, 2023.

The instruments in this collection are a privacy sensitive collection requiring Privacy Impact Assessment, PIA coverage. These forms are covered by an existing PIA, DHS/FEMA 013 – Grant Management Programs, approved by DHS on March 31, 2023. No Privacy Act Statement nor SORN coverage is required for the forms.

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 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.

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

1. 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. Consolation 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.

Please see the table under 12c for the response to 12a.

2. 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 table under 12c for the response to 12b.

3. 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 1.45 (1.61 for State and local government employees)¹ and this total should be entered in the cell for “Avg. Hourly Wage Rate.” The cost to the respondents of contracting out to 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
Type of Respondent	Form Name/ Form No.	No. of Respondents	No. of Responses per Respondent	Total No. of Responses	Avg. Burden Per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
State, Local or Tribal Government	EMPG Work Plan	58	1	58	86.50	5,017	$68.81	$345,219.77
State, Local or Tribal Government	EOCGP - Formal Investment Justification	69	1	69	8.00	552	$68.81	$37,983.12
Business or other for-profit	IBSGP - Associated Investment Justification Form	56	1	56	5.00	280	$61.97	$17,351.60
Business or other for-profit	IBSGP - Associated detailed Budget	56	1	56	5.00	280	$61.97	$17,351.60
Business or other for-profit	IBSGP - Vulnerability Assessment and Security Plan	56	1	56	0.08	4.48	$61.97	$277.63
State, Local or Tribal Government	Controlled Equipment Request Form	119	1	119	0.75	89.25	$68.81	$6,141.29
Business or other for-profit	Controlled Equipment Request Form	56	1	56	0.75	42	$61.97	$2,890.02
Not-for-profit Institution	NSGP Investment Justification/FEMA Form 089-25	2,030	1	2,030	4.00	8,120	$61.97	$503,196.40
State, Local or Tribal Government	NSGP Prioritization of Investment Justification 089-24	56	1	56	15.5	868	$68.81	$59,727.08
State, Local or Tribal Government; not-for profit institutions	SSP Application Worksheet	500	1	500	0.75	375	$68.81	$25,803.75
State, Local or Tribal Government; not-for profit institutions	SSP FEMA A-Number Submission Form	200	1	200	16.00	3,200	$68.81	$220,192.00
Total		3,256		3,256		18,827.73		$1,236,134.26

Note: The “Avg. Hourly Wage Rate” for each respondent include a wage 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 1.45. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.45, and the entry for the “Avg. Hourly Wage Rate” would be $61.64.

According to the U.S. Department of Labor, Bureau of Labor Statistics, the May 2022 Occupational Employment and Wage Estimates wage rate for local government employees (Emergency Management Directors (bls.gov)) is $42.74 per hour. Including the wage rate multiplier of 1.61 for state and local workers, the fully-loaded wage rate is $68.81 per hour. Including the wage rate multiplier of 1.45 for all other workers, the fully-loaded wage rate is $61.97 per hour. Therefore, the burden hour cost is estimated to be $1,236,134.26 annually.

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 systems 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 operation or maintenance costs for respondents associated with this 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 storge facilities.

There are no capital or start-up costs for respondents associated with this 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.

Annual Cost to the Federal Government
Item	Cost ($)
Contract Costs: There is one contract that supports this effort: The MetaPhase Consulting Programmatic and Administrative Support (PAS) for the Grants Program Directorate (GPD). This contract supports the development of all preparation programs. The total cost for this contract is $3.0 M. Approximately 2/10 of the contract ($600,000) provides support for this collection	$600,000
Staff Salaries: [4 GS 13 Step 5 ($133,692) at 50%-time x 1.45 loaded wage rate = $387,706.80 (4 * $133,692 * .5 * 1.45= $387,706.80)] [2 GS 14 Step 5 ($157,982) at 37.5% of time x 1.45 loaded wage rate = $171,805.43 (2 * 157,982 * .375 * 1.45 = $171,805.43)] [1 GS 15 Step 5 ($185,824) at 16.7% of time x 1.45 loaded wage rate = $44,997.28 (1 * $185,824* .167 * 1.45 = $44,997.28)]	$604,509.51
Facilities [cost for renting, overhead, etc. for data collection activity]	$
Computer Hardware and Software [cost of equipment annual lifecycle]	$
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	$
Travel (not to exceed)	$
Total	$1,204,509.51
1 Office of Personnel Management 2024 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/2024/DCB.pdf. Accessed February 27, 2024. 2 Wage rate includes a 1.45 multiplier to reflect the fully-loaded wage rate.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of 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 regulation 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 collection 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
EMPG Work Plan				5,017	5,017	0
EOCGP - Formal Investment Justification				552	552	0
IBSGP - Associated Investment Justification Form				280	280	0
IBSGP - Associated detailed Budget				280	280	0
IBSGP - Vulnerability Assessment and Security Plan				5	4	-1
Controlled Equipment Request Form				42	131	89
NSGP Investment Justification/FEMA Form 089-25				2,086	8,120	6,034
NSGP Prioritization of Investment Justification 089-24	840	868	28
SSP Application Worksheet	2	375	373
SSP FEMA A-Number Submission Form				48	3,200	3,152
Total	842	1,243	401	8,310	17,584	9,274

Explain:

For most instruments, the changes in burden hours are adjustments reflecting correction of data entry, rounding, and calculation errors entered under Questions 12 and/or 15 in prior collections. For example, the NSGP Investment Justification burden hour calculation was corrected under Question 12 above to reflect the correct number of burden hours that should have been entered in a previous collection.

For the NSGP Prioritization of Investment Justification, the increase is a program increase as the instrument is collecting additional information from respondents on whether Investment Justifications contain disallowed costs.

For the SSP Application Worksheet, the increase is a program change as the instrument was edited to collect additional information from applicants to score their applications to the competitive version of the program.

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
EMPG Work Plan				$329,315.88	$345,219.77	$15,903.89
EOCGP - Formal Investment Justification				$36,233.00	$37,983.12	$1,750.12
IBSGP - Associated Investment Justification Form				$18,379.00	$17,351.60	-$1,027.40
IBSGP - Associated detailed Budget				$306.00	$17,351.60	$17,045.60
IBSGP - Vulnerability Assessment and Security Plan				$5,858.00	$247.88	-$5,610.12
Controlled Equipment Request Form				$2,757.00	$8,726.83	$5,969.83
NSGP Investment Justification/FEMA Form 089-25				$296,136.00	$503,196.40	$207,060.40
NSGP Prioritization of Investment Justification 089-24	$42,630.00	$59,727.08	$17,097.08
SSP Application Worksheet	$148.56	$25,803.75	$25,655.19
SSP FEMA A-Number Submission Form				$3,127.68	$220,192.00	$217,064.32
Total	$42,778.56	$85,530.83	$42,752.27	$692,112.56	$1,150,269.20	$458,156.64

Explain:

For most instruments, the changes in burden cost are adjustments due one or more of the following:

• Corrections of data entry, rounding, and calculation errors entered under Questions 12 and/or 15 in prior collections.

• Use of distinct average hourly wage rates calculated using wage rate multipliers for state, local, or tribal government respondents vs. non-governmental respondents.

• Changes to average hourly wage rates provided by the Bureau of Labor Statistics’ Occupational Employment and Wage Statistics.

For the NSGP Prioritization of Investment Justification, the increase is a program increase as the instrument is collecting additional information from respondents on whether Investment Justifications contain disallowed costs.

For the SSP Application Worksheet, the increase is a program change as the instrument was edited to collect additional information from applicants to score their applications to the competitive version of the program.

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 outlined plans for tabulation and publication of data for this information collection beyond the Act’s requirement to submit annual reports to Congress describing the claims submitted under the Act.

17. If seeking approval no 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 state identified in Item 19 “Certification for Paperwork Reduction Act Submission,” of OMB Form 83-I.

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

1 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1.  Available at Employer Costs for Employee Compensation Summary - 2023 Q03 Results (bls.gov). Accessed February 27, 2024.  The wage multiplier is calculated by dividing total compensation for all workers of $43.93 by wages and salaries for all workers of $30.35 per hour yielding a benefits multiplier of approximately 1.45.

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