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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1. Identification of the Information Collection

1(a) Title of the Information Collection

Monthly Progress Reports (Renewal), EPA ICR Number 1039.14, OMB Control Number 

2030-0005. 

1(b) Short Characterization/Abstract 

Per 48 CFR 1552.211 regulations, the Office of Acquisition Management (OAM) requires 

contractors to provide the Contract Contracting Officer’s Representative (COR) a report detailing 

the following: a) what was accomplished on the contract during that period, b) expenditures for the 

same period of time, and c) what remains to be done. Through this report, the Contract COR is 

able to monitor the efficiency and cost effectiveness of the work being performed. This 

information is collected because appropriate Government surveillance of contractor performance 

is required to give reasonable assurance that efficient methods and effective cost controls are used 

for various cost-reimbursable and fixed-rate contracts. EPA estimates that approximate 266 

contracts are subject to these reporting requirements. Monthly progress reports are submitted 

electronically and stored as a paper copy, and on the electronic contract-writing system EAS 

Acquisition System (EAS) in accordance with applicable record retention schedules. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The Federal Acquisition Regulation (FAR) 16.301-3(a)(4) and 16.601(c)(1) require that 

cost reimbursement, time-and-material and labor-hour contracts are monitored in terms of 

financial and technical efficiency. Environmental Protection Agency Acquisition Regulation 

(EPAAR) clause 1511.011-72 prescribes the clause for progress reports, which is used for these 

types of contracts. EPAAR clause 1552.211-72, Monthly Progress Report, provides the specific 

requirements of the report. 

2(b) Practical Utility/Users of the Data

Progress reports will be used by the Contract COR to monitor the contractor's progress 

under a specific contract. If problems with the contractor's performance arise, the contracting 

officer may also review the progress reports to determine what action may need to be taken. 

3. Nonduplication, Consultations, and other Collection Criteria

3(a) Nonduplication
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Monthly progress reports are unique to each individual contract. Information concerning 

the financial and technical progress of a contractor under a specific contract is not available from 

other sources. 

3(b) Public Notice Required Prior to ICR Submissions to OMB

An announcement of a public comment period for the renewal of this ICR was published in 

the Federal Register (80 FR 6703) on February 6, 2015. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

Four contractors’ employees were consulted in regards to the accuracy of the number totals 

in 6(b)(i). One of the four had changed employers and was unavailable for comment. Another 

two employees were contacted and asked for consultation, but declined to respond. The fourth 

contractor employee responded that they thought our estimated contractor hourly rate was a bit 

high. The employee also thought that our estimated 24.25 hours per monthly progress report 

would be low if there were many tasking documents (e.g., task orders) to include in the report.

1. Ms. Lea Ann Smith, Alion Science and Tech 703-752-7655

2. Ms. Tracy Allison, CSC Inc. 703-870-3647

3. Mr. David Dobb, Techlaw 360-871-8750

4. Mr. Ed Sussenguth, Tetra Tech 510-302-6333

3(d) Effects of Less Frequent Information Collection

Many EPA contracts involve complex services requiring numerous contractor employees 

and extensive funding. It is imperative that the Agency be aware of the actions the contractor is 

taking and the amount of funding expended on a monthly basis. Less frequent collection would 

jeopardize the Agency's ability to determine the reasonableness of costs and to take timely action 

in the event of technical or cost problems under its complex contracts. 

3(e) General Guidelines

This information collection follows OMB's general guidelines, with the exception of 

requiring the information be submitted more often than quarterly. Monthly progress reports are 

mandatory for those holding Agency contracts with progress reporting requirements. 

Progress reports are required on a monthly basis. Contracts requiring progress reports 

generally run from three to five years. Most contractors invoice once a month under these 

contracts. By submitting the progress report with the invoice, the contractor gives the Contract 

COR, who is responsible for monitoring the contract, an opportunity to review the financial 

information contained in the progress report, and compares it to the invoice. Monthly review of 

this information allows the Agency to promptly note when performance or cost problems arise,
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and take immediate action. This monthly information is required because of the complex nature of 

the work performed. 

3(f) Confidentiality

Information collected under this request, particularly cost and pricing data, is treated as 

Confidential Business Information (CBI). This information is protected from public release in 

accordance with the Agency's confidentially regulation, 40 CFR Part 2.

3(g) Sensitive Questions

No sensitive questions will be asked in this collection. 

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The majority of respondents are anticipated to fall into one of the following NAICS codes: 

511210 for prepackaged computer software, 541511 for computer processing services, 541710 for 

computer-related services, and 541620 for environmental consulting services. 

4(b) Information Requested 

(i) Data Items

The monthly progress reports submitted by contractors provide the following information:

(i) Progress made during the reporting period, including percent of project completed, 

description of the action of work accomplished, and a schedule of deliverables for the 

reporting period.

(ii) Difficulties encountered and remedial action taken during the reporting period, and 

anticipated activity during the subsequent reporting period. 

(iii) A list of outstanding actions awaiting the contracting officer's authorization. 

 (iv) Cumulative costs at the contract level for: the amount claimed for the current reporting 

period, the amount obligated, originally invoiced, paid, suspended, disallowed and 

remaining approved for the cumulative period and contract life. 

(v) Labor hours consisting of a list of employees, their labor categories, and the number of 

hours worked. 

(vi) Labor hours expended and direct labor hours and costs detailed for the current 

reporting period. 
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(vii) Labor hours negotiated, expended and remaining; and labor hours and costs detailed 

for the contract period and cumulative contract life. 

(viii) The estimated labor hours and costs to be expended during the next reporting period. 

(ix) The current dollar ceilings, net amount invoiced, and remaining amounts in funding 

categories. 

(x) Unbilled allowable costs for the current reporting period and cumulative for the 

contract. 

(xi) Actual average direct labor costs compared with the negotiated average for the current 

contract period. 

(xii) Similar financial status information to that already outlined, at the work assignment 

level or task/delivery order level. 

(ii) Respondent Activities

Respondents are required to compile and submit monthly progress reports that contain the 

data items in 4(b)(i).

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

 Once the information is received by the Agency, it is reviewed by the Contract COR

against existing financial data, contractor deliverables and agency records for verification. If no 

discrepancies are noted, the report is placed in the contract file. 

5(b) Collection Methodology and Management

 Many respondents prepare their reports by computer. Software programs are available 

which easily track financial data. Submissions are accepted in many formats so long as the 

required data is provided. Various software programs are used by the Agency to monitor 

contractor activity under contracts requiring progress reports. 

5(c) Small Entity Flexibility

 Most contractors invoice once a month under service contracts. Progress reports are 

required on a monthly basis so that charges on the invoice can be reconciled with financial and 

technical information provided in the progress report. 
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5(d) Collection Schedule

Contractors are required to submit monthly progress reports.

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

The overall respondent burden is estimated to be 24.25 hours per monthly response, and a 

total annual burden of 77,406.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

Contractor burden is based on historical data. Collection activity hours are estimated to 

have decreased about three percent since the last clearance received in 2011, due mainly to 

improved tracking software, and increased familiarity with EPA reporting requirements.

Collection activity hourly rates are estimated to have increased since the last clearance received in 

2011, by a cumulative inflation escalation rate of 4.6 percent from January 2012 to December 

2014.

 Collection Activity Hours Per Month Rate Cost

1. Gather information 9.31 $103.62 $ 964.70

2. Compile and Process 14.94 $ 85.73 $1280.81

 information

 TOTALS 24.25 $2,245.51

In most instances, the contractor's project or program manager manages the effort under 

the contract and prepares the progress report. The information gathering is performed by the 

assistant project manager or other finance staff members. Compilation and information processing 

is performed by a data entry clerk or other finance staff members. 

The prior ICR calculated that EPA had 203 active contracts requiring monthly progress 

reports in 2008. This figure has increased to 266 in 2014. The increase in contract number is due 

in part to shorter-value and shorter-length contracts being awarded due to budget uncertainty; e.g., 

continuing funding resolutions, sequestration budget cuts.

These estimated 266 contracts each require a monthly progress report (266 contracts x 12 

months each = 3,192 responses). Respondents on average take 24.25 hours per month to complete 

each response. Therefore, total annual burden hours is 77,406 hours (24.25 hours per response x 

3,192 responses). The annual labor cost to respondents based on the figures shown above is 
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$7,167,668 ($2,245.51 per response x 3,192 responses). Contractors are reimbursed for these costs 

under the applicable contract. 

(ii) Estimating Capital/ Start-up Costs and Maintenance Costs

Because it will not be necessary for respondents to acquire any capital goods to provide the 

requested information, EPA has not estimated any capital/start-up costs. 

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs 

Operating and maintenance costs consist of postage and photocopying, are estimated at 

$12.50 per response x 3,192 responses = $39,900. 

6(c) Estimating Agency Burden and Cost

Agency burden estimates were developed by procurement personnel who work with the 

types of contracts addressed in this ICR. On the average, the same amount of time is required to 

review the data for each type of contract. Progress reports are reviewed by the Contract COR and 

contracting officer responsible for the contract. Agency burden is calculated as follows:

Collection Activity Hours Per Month Rate Cost

Audit/review data submissions 2 $63.52 $127.04

Burden hours for the contracting officer and the Contract COR are combined for a total of 

two (2) hours. Calculations are based on both these individuals being GS-13s. Estimate includes 

GS-13 salary at $39.70 per hour, multiplied by a factor of 1.6 to reflect benefits, which yields a 

loaded rate of $63.52. Therefore, total annual agency burden is summarized as follows: Total 

burden hours = 3,192 responses x 2 hours per response = 6,384 hours. Total burden costs: $127.04

per response x 3,192 responses = $405,512. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

There are an estimated 266 active contracts that each require a monthly progress report 

(266 contracts x 12 months each = 3,192 responses). Respondents on average take 24.25 hours per 

month to complete each response. Therefore, total burden for one year is 77,406 hours (24.25 

hours per response x 3,192 responses). The annual labor cost to respondents based on the figures 

shown above is $7,167,668 ($2,245.51 per response x 3,192 responses). 

6(e) Bottom Line Burden Hours and Cost Tables

(i) Respondent Tally

Total Number of Respondents: 266

Total Annual Responses: 3,192
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Total Burden Hours: 77,406 hours

Total O&M Costs: $39,900

Total Labor Costs: $7,167,668

Total Burden Costs: $7,207,568

(ii) The Agency Tally

Total Burden Hours: 6,384 hours

Total Burden Costs: $ 405,512

6(f) Reasons for Change in Burden

There is an increase of 16,506 hours in the total estimated respondent burden compared 

with the ICR currently approved by OMB. Collection activity hourly rates are estimated to have 

increased since the last clearance received in 2011, by a cumulative inflation escalation rate of 4.6 

percent. The increase in contract number is due in part to shorter-value and shorter-length 

contracts being awarded due to budget uncertainty; e.g., continuing funding resolutions, 

sequestration budget cuts.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 24 hours per response. “Burden” means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose or provide information to or 

for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and verifying 

information; processing and maintaining information; disclosing and providing information; 

training personnel to be able to respond to a collection of information; searching data sources; 

completing and reviewing the collection of information; and transmitting or otherwise disclosing

the information. An agency may not conduct or sponsor, nor is a person required to respond to, a

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OARM-2011-0748, which is available for public viewing at the 

Office of Environmental Information (OEI) Docket in the EPA Docket Center (EPA/DC), EPA 

WJC West, Room 3334, 1301 Constitution Avenue, NW, Washington, D. C. The EPA Docket 

Center Public Reading Room is open from 8:30 a. m. to 4:30 p. m., Monday through Friday, 

excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the 

telephone number for the docket center is (202) 566-1927. Also, you can send comments to the 

Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, 

NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket 
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ID No. EPA-HQ-OARM-2011-0748 and OMB Control Number 2030-0005 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.