Supporting Statement A

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A.	JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
The U.S. Election Assistance Commission (EAC) provides grants to state and territorial election offices to secure elections. To provide timely and accurate review of these grants, it is necessary to continue using our current approved Progress Report (EAC-PR; OMB Control #3265-0026). The EAC Progress Report meets the reporting requirements outlined in the OMB grants policy in the Code of Federal Regulations, Title 2, Part 200, § 200.329: Monitoring and reporting program performance.
2. Indicate how, by whom, and for what purpose the information is to be used.
Data from these progress report forms will be used for grant monitoring, feedback to grantees, technical assistance, long-term planning, and reporting to Congress.
EAC has developed this form to collect quantitative data on program activities, including staffing, voting processes, security and training, communication, expenditure activity, subawards, and other activities unique to HAVA funding. These reports also collect qualitative data on grant progress, problems encountered, and grantees' assessments of how they used the funds. 
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.
The EAC will continue to use its online platform to streamline and facilitate data entry and review through an established online form submission. The EAC will offer grantees two process options to record their responses: 1) independently through the online platform and 2) by interview through telephone or virtual meeting format.
In the interview format, EAC staff will ask grantees the same questions as on the online form and record their responses. All interview-based responses will be transcribed by EAC staff into the online form on the online platform. The grantee will subsequently review, certify, and submit the online form. 
We will post the report access and guidance on our website as well as email notification of this information to our 56 grantees. The online submission format significantly reduces grantee burden and facilitates streamlined data collection directly to the EAC. 
4. Describe efforts to identify duplication.
EAC does not expect its grantees to report HAVA funding expenditures and activities to any other source. Where possible, EAC has mirrored the federal standardized data elements for progress reporting to reduce variance across federal grants in grantee tracking.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This information collection does not impact small businesses or other small entities. Only states and territories are required to submit reports. The EAC has made efforts to limit the information requested and burden on all participants. The information sought is limited to information necessary to meet the requirements listed in response to Question 1. EAC is requesting that grantees use a secure online system to certify and submit the form, thereby eliminating paper submissions.
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 the EAC does not collect this information, it will be unable to perform necessary oversight for its HAVA grants and the EAC. In addition, if the EAC does not collect this information, it will be unable to report to Congress the necessary performance data related to HAVA funding.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
There are no special circumstances applicable to this information collection.
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 5CFR 320.8(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 in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside of EAC.
PREVIOUS 60-Day Notice:
Publication Date: 08/03/2026
Document Citation: 91 FR 48847
Page: 48847-48848 (2 pages)
Document Number: 2026-15611
Public Comments
This proposed information collection was previously published in the Federal Register on August 3, 2023, and allowed 60 days for public comment. One comment was received that encouraged the use of the Progress Report and offered suggestions for improving data collection and use. The EAC will consider the data analysis suggestions as it processes data gathered from the Progress Report. The additional information collection recommended would increase the burden hours and will not be pursued at this time. 
30-Day Notice:
Publication Date: 11/6/2026
Document Citation: 91 FR 70078
Page: 70078
Document Number: 2026-22712
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
The EAC does not provide any payment or gift to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
The EAC may collect the information requested by OMB-approved government-wide collection cited in § 200.327, 200.328, and 200.329. Providing information is mandatory. The penalty associated with failing to respond is noncompliance and will require corrective action by the grantee. Public Law 93-573 (Privacy Act of 1974) requires that respondents be informed of the purpose and uses to be made of the information collected. The information collected will be used to oversee grant progress and report that progress to Congress. Progress reports are grant records and may be made public on our website.
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.
There are no questions of a sensitive nature.
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. 
The estimated response burden is based on submission times for our previously approved progress report. Based on the online form, we estimate the average time required to complete the report is 1 hour.
The table below summarizes the burden estimate for the EAC-PR.
 
EAC Grant  
Instrument 
Total number of respondents 
Total number of responses per year  
Average burden hours per response 
Annual burden hours 
251 
EAC-PR 
29 
2 
1 
58 
101 
EAC-PR 
12 
2 
1 
24 
Election Security 
EAC-PR 
56 
1 
1 
56 
TOTAL 
 
 
 
 
138 
The estimated annualized cost of this burden is $3,576.96, calculated by multiplying the annualized burden (138 hours) by an hourly rate of $25.92 (GS-8/Step 5 hourly basic rate).  
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
There are no capital or start-up costs associated with this information collection.
14. Provide estimates of annualized cost to the Federal government.
The estimated annual cost to the Federal Government is $3,576.96.
15. Explain the reasons for any program changes or adjustments reported in Items 13 (or 14) of OMB Form 83-I.
The burden hours have been updated to reflect 2026 GS pay scales. 
16. For collections whose results will be published, outline the plans for tabulation and publication.
Grantee report submissions may be publicly released on the EAC’s website. EAC will submit to Congress an annual report of expenditures across all HAVA funding, with an update to the oversight committees at mid-year.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
Not applicable to this collection.
18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I.
The EAC does not request an exception to the certification of this information collection.