Page **1** of **8 SUPPORTING STATEMENT**  **ENVIRONMENTAL PROTECTION AGENCY 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  Monthly Progress Reports (Renewal) , EPA I CR 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 Offi cer’s Representative (COR) a report detailing the following: a) what was accomplished on th e contract during that period, b) expenditures fo r 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 a ppropriate Government surveillance of contractor performance is required to give reasonable assurance that efficient methods and effective cost contro ls are used for various cos t - reimbursable and fixed - rate contracts . EPA estimates that approximate 266 contracts are subject to the se reporting requirements. Monthly progress reports are submitted electronically

and stored as a paper copy , and on the electronic contract - writing sy stem 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 ty pes of contracts . EPAAR clause 1552 . 211 - 72 , Monthly Progress Report , provides the specific requirement s 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 c ontracting o fficer 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**Page **2** of **8**

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 source s . **3(b) Public Notice Required Prior to ICR Submissions to OMB** An announcement of a public comment period for the renewal of thi s IC R 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 c ontractors’ employees were consulted in regards to the accuracy of the number totals in 6 (b)(i). One of the four had changed emplo ye rs and was unavailable for comment. Another two employees were contacted and asked for consultation, but declined to respo nd. 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. L ea 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**  M any 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 o f 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) Genera l Guidelines**  This information collection follows OMB's general guidelines , with the exception of requiring the information be submitted more often than quarterl y . Monthl y progress reports are mandatory

for those holding Agency contracts with progress rep orting requirements . Progress reports are required on a monthly basis . Contracts requiring progress reports generall y run from three to five years . Most contractors invoice once a month under these contracts . By

submitting the progress report with the i nvoice , 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 th e Agency to promptly

note when performance or cost problems arise ,Page **3** of **8**

and take immediate action . This monthly information is required because of the complex nature of the work performed . **3(f) Confidentiality** In formation 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 confidentiall y 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 NAI CS 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 ) D ifficulties encountered and remedial action taken durin g the reporting period , and anticipated activity during the subsequent reporting period . ( iii ) A list of outstanding actions awaiting the c ontracting o fficer's authorization . ( iv) Cumulative costs at the contract level for: the amount claimed for th e 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 numb er of hours worked . (vi ) Labor hours expended and direct labor hours and costs detailed for the current reporting period .Page **4** of **8**

(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 b y 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) C**  **ollection Methodology and Management** Many respondents prepare their reports by computer . Software programs are available which easil y track financial data . Submissions are accepted in m any format s so long as the required data is provided . Various software programs are used b y 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 .Page **5** of **8**

**5(d) Collection Schedule**  C ontractors are required to submit monthly progress reports. **6. E**  **stimating 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 improve d tracking software, and increas ed 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 b y the assistant project manager or other finance staff members . Compilation and information processing is performed b y 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 2 66 contracts each require a monthly progress report ( 2 66 contracts x 12 months each = 3,192 responses) . Respondents on average take 2 4.25 hours per month to complete each response . Therefore, total annual burden hours is 77,406 hours (2 4.25 hours per response x 3,192 responses) . The annual labor cost to respondents based on the figures shown above isPage **6** of **8**

$ 7,167,668 ($ 2 , 245.51 per response x 3,192 response s) . 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 photocop yi ng, 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 wi th the ty pes of contracts addressed in this IC R . On the average, the same amount of time is required to review the data for each type of contract . Progress reports are reviewed b y the Contract COR and c ontracting o fficer responsible for the contract . Agenc y 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 a s 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 monthl y 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 ye ar 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) Responde**  **nt Tally** Total Number of Respondents: 266 Total Annual Responses: 3,192Page **7** of **8**

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 I CR currentl y approved b y OMB. Collection activity hourl y 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 uncert ainty; 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 2 4 hours per response . “ Burden ” means the total time, effort, or financial resources expended b y 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 utiliz e technology and s ys tems 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; search ing data sources; completing and review ing the collection of information; and transmitting or otherwise disclos ing 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 m ethods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA - HQ - OARM - 20 11 - 0 748 , which is available for public viewing at the Office of Environment al Information (OE I) 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 holiday s . 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 Affair s, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA DocketPage **8** of **8**

ID No . EPA - HQ - OARM - 20 11 - 0 748 and OMB Control Number 2030 - 00 05 in any correspondence . **Part B of the Supporting S tatement**  This part is not applicable because no statistical methods were used in collecting this information.