Supporting Statement Part A_ConnectHome_2577-New

SUPPORTING STATEMENT - PART A

ConnectHomeUSA Goals and Performance Metrics Collection 2577-New

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.

On October 17, 2023, HUD issued a Federal Register Notice asking Public Housing Agencies, Multifamily owners/operators, and tribes to apply to join the ConnectHomeUSA initiative.

This initiative encourages selected communities to design a comprehensive program that helps residents obtain free or affordable in-home Internet service, computer devices and the training to use them. Selected communities will participate for a three-year period. HUD is proposing a three-part reporting process. The first part will ask communities to provide basic community information; the second will ask for goal setting, and the third will be a quarterly report that communities will use to track progress against their goals.

HUD requests approval to collect information on three Forms:

1. General Community Overview Form

This form will give HUD CHUSA staff an overview of the characteristics of the participating CHUSA community. It will be used once to capture general information such as contact information, type of community (tribe, public housing, or multifamily); geography (e.g. rural, urban); and building type (multi-dwelling unit, scattered site, etc.); demographics, and Internet Service Providers serving the community. This form will also provide us with information about other HUD grant programs the CHUSA communities may be participating in. It will be requested only once, at the outset of participation. This form can be found here: General Community

2. Goal setting

This form is a goal-setting template that will help communities plan their three-year participation and quantify their goals in three key areas: total number of units (apartments) they wish to connect to Internet service; total number of computer devices they wish to distribute to residents; and the total number of residents that will complete digital skills training. The purpose of this form is to provide communities with the opportunity to develop a project plan and define their goals during their CHUSA involvement. This form will be requested only once, at the outset of a community’s participation. This form can be found here: Goal-setting

3. Quarterly Reporting Form

This form will allow CHUSA communities to:

• Track and compare progress against goals.

• Identify areas of weak performance.

• Identify areas of excellence; and

• Earn electronic badges related to their accomplishments in key areas.

Quarterly reporting throughout the three-year commitment in ConnectHomeUSA (CHUSA) program is critical for:

• Providing participating communities with the opportunity to share their program’s success and identifying areas needing support from HUD.

• Allowing communities to demonstrate achievement of specific quantitative and qualitative metrics that signal progress and eventually help communities bridge to a higher tier of participation; and

• Allowing communities to receive distinctive electronic badges from HUD for each metric attained.

This form can be found here: Reporting

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 information will be used by ConnectHomeUSA HUD Headquarters staff to understand the full range of communities that are participating, the successes they are having and any challenges they may be experiencing. This information will help HUD staff understand how best to assist communities that are falling behind in their stated goals. More specific information is provided for each form below:

• General Community Overview Form

In addition to asking for general community information, this form will also be used to gain an understanding about where CHUSA communities will target their efforts (i.e., their full housing portfolio, type of resident population to be served, geography, and existing Internet Service Providers (ISPs). It will be requested only once, at the outset of participation.

• Goal setting

This form will be used once at the outset of communities’ participation to help them quantify the goals they want to achieve for units connected to Internet service, computer devices, distributed, and number of residents trained in digital skills over a three-year period.

• Quarterly Reporting

The Quarterly Reporting form will be used to track communities’ progress, successes, and challenges. It will provide insight into where communities need extra support, inform the development of CHUSA technical assistance resources, and guide regional discussions.

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 to adopt this means of collection. Also describe any consideration of using information technology to reduce burden.

The collection of information involves Microsoft Forms and requires electronic submission. Communities will receive an electronic copy of their submission.

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 is a new collection, there is no existing method for tracking the data we seek.

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.

The information collected has no significant impact on small businesses or other small entities. Participating communities are public housing authorities, federally recognized tribes, and multifamily owners/operators, that will submit the same Microsoft Forms. However, in general, efforts have been made to minimize the burden placed on all participants, while at the same time ensuring that sufficient information is collected for programming purposes.

5. Describe the consequences of 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.

Without this reporting system, HUD will not have the ability to track participating communities’ progress. This will in turn impact HUD’s ability to assist communities that are falling behind, or conversely, recognize communities that are excelling.

In addition, having data will allow communities to meet certain benchmarks that will allow them to earn badges and eventually graduate to more advanced tiers within the program.

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

• requiring respondents to report information to the agency more 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.

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 than 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.

Not applicable

• Enquiring respondents 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

5. If Applicable, provide a copy and identify the date and page number of publications 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.

HUD published two “Notices of Proposed Information Collection for Public Comments” (60- & 30-day FRN) in the Federal Register, Volume 89, No.59 Page 20994, on March 26, 2024, and Volume 89, No.59 Page 20994, on March 26, 2024, respectively. No public comments were received on either of the FRN notices.

9. Accordingly, HUD is not making changes to the information collection currently. However, to reduce burden and duplicate entering of information, at a future point, HUD will work to incorporate this requirement as a module in the Operating Fund Web Portal. Where data exists in HUD systems, at that time, HUD will utilize that data in a manner so as not to require re-entry of the data by the PHA, reducing burden.

• Describe efforts to consult with people 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 the data elements to be recorded, disclosed, or reported.

• Consultations 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 preclude consultation in a specific situation. These circumstances should be explained.

No consultation occurred outside the agency since this is a new collection and is not required to be

completed since new communities have not been selected. Consultation may occur once the program is underway.

10. Explain any decision to provide any payment or gift to respondents, other than renumeration

of contractors or grantees.

No payment or gifts will be provided to participants.

10. Describe any assurance of confidentiality provided to respondents and the basis for

assurance in statutes, regulation or agency policy.

Communities will report using Microsoft Forms, submission is received by HUD staff, HUD staff will maintain the data internally. There will not be any personally identifiable information submitted (other than the name and telephone number for person submitting the form). And only aggregated data across the program (which will be de-identified) may be shared publicly (e.g., highlighted on CHUSA’s HUD website.)

10. 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 people from whom the information is requested, and any steps to be taken to obtain their consent.

None of the forms contain questions of a sensitive nature.

10. Estimates of the hour burden and cost of this collection to the Federal Government:

Information Collection (Form)	Number of Respondents	Frequency of Response	Total Annual Responses	Burden Hours per Response	Total Annual Burden Hours	Hourly Cost	Total Annual Cost
General Community Form	150	1	150	1	150	$22.46	$3,369
ConnectHome USA Goal-Setting Form	150	3	450	1	450	$22.46	$10.107
ConnectHomeUSA Quarterly Reporting	600	4	2,400	1	2,400	$22.46	$53,904
Total	900	8	3000	3	3000	$22.46	$69,380

*This is a new collection.

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

It is estimated to take 2.5 hours for the Federal government to review Forms 1-3 found in the table above.

The estimated annualized cost to the Federal Government for reviewing the ConnectHome General Community Form, line 1, is based on an average annual salary of Headquarters staff of $94,199 or $49.06 per hour, which is the 2023 General Pay Scale salary for a GS 12 Step 1. This form is short and straightforward and will be required only once. We anticipate a maximum of 30 minutes review per form. At $49.06 per hour ($24.53 for 30 minutes) for an estimated 75 hours for one year (150 hours/2), the total cost is $1,839.00.

The estimated annualized cost to the Federal Government for reviewing the ConnectHome Goal-Setting Form, line 2, is based on an average annual salary of Headquarters staff of $94,199 or $49.06 per hour, which is the 2023 General Pay Scale salary for a GS 12 Step 1. At $49.06 per hour for an estimated 150 hours per year, the annual cost is $7,359.00.

The estimated annualized cost to the Federal Government for reviewing the ConnectHomeUSA Quarterly Reporting, line 3, is based on an average annual salary of Headquarters staff of $94,199 or $49.06 per hour, which is the 2023 General Pay Scale salary for a GS 12 Step 1. At $49.06 per hour for an estimated 600 hours per year, the annual cost is $29,436.00.

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

There are no changes to report since this is a new collection.

16. For collection 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.

Currently, there are no plans to use the data to publish a report. The totals achieved by the communities may be aggregated and posted to the CHUSA website to show the aggregated impact of the program.

17. For collection 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.

Currently, there are no plans to use the data to publish a report. The totals achieved by the communities may be aggregated and posted to the CHUSA website to show the aggregated impact of the program.

18. Explain each exception to the certification statement identified in item 19.

There is no exception to Item #19 “Certification of Paperwork Reduction Act Submission.”

B. Collections of Information Employing Statistical Methods
None.