**ICR SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **1. Identification of Information Collection**  **1(a) Title of Information Collection**  Contractor Cumulative Claim and Reconciliation (Renewal) , EPA ICR No. 0246. 1 2 , OMB Control No. 2030

- 0016. **1(b) Short Characterization** The Federal Acquisition Regulation (FAR) 4.804

- 5 states that the office administering a contract is responsible for initiating administrative close out following phy sical completion of the contract. Funds status review is a mandatory part of contract close out. It includes settlement of interim or disallowed costs and settlement of indirect cost rates. After a contract completion under a cost reimbursement ty pe contract, the contractor submits EPA Form 1900

- 10 which summarizes all cost incurred in perfo rmance of the contract and sets f orth the final indirect rates. This form is reviewed b y the contracting office to determine the final costs reimbursable to the contractor. A copy of the form is attached to this request. **2. Need and Use of the Collecti**  **on 2(a) Need/Authority for the Collection**  FAR 52.216
- 7 states that the Government will pay only the costs determined to be allowable b y the contracting officer in accordance with FAR 31.2. Furthermore, FAR 52.216

- 7 states that indirect cost rates shall be established for each fiscal ye ar at the close of a contractor’s fiscal year. EPA Form 1900
- 10 summarizes this information for the entire contract period and provides a basis for cost review by contracting, finance, and audit personnel. As stated previousl y, FAR 4.804
- 5 mandates that the office administering the contract shall ensure that the costs and indirect cost rates are settled. **2(b) Practical Utility/Users of the Data** In formation collected on the 1900

- 10 will be used by the contracting, financial, and audit personnel to determine the final amount of costs reimbursable to the contractor. EPA personnel and auditors from the Defense Contract Audit Agency (DCAA), if request ed, will review the information in order to determine the final contract costs prior to final payment under the contract. **3. Non**  **- Duplication, Consultations, and Other Collection Criteria**  **3(a) Non**  **- Duplication** 2

In formation collected is contract

- specific. Cumulative contract cost information, as requested, is not available from any other source. **3(b) Public Notice Required Prior to ICR Submission to OMB**  The Federal Register document required under 5 CFR 1320.8(d), soliciting comments on this collection of information w as published on 02 / 06 /20 15 ( 80 FR 6702 )

. **3(c) Consultations**  The following vendors were contacted to discuss collection activities: **Firm Person Contacted**  **Phone** Great Lakes Environmental Center Ms. L inda Hay s 231
- 941
- 2230 Environmental Mgt Support Mr. Thomas Heim 301
- 589
- 5318 ext.15 Battelle Memorial Institute Ms. Gina Crabtree 614
- 424
- 5097 Cadmus Group, Inc. Mr. Alan Seferian 617
- 673
- 7000 Each firm indicated the financial information requested is kept routinely for compan y records and for audit purposes. Two of the firms contacted felt the information collection was burdensome as one indicated that the form was redundant to oth ers previously submitted and the other indicated that their costs are tracked b y period of performance rather than fiscal ye ar. **3(d) Effects of Less Frequent Collection**  The information is collected only once at contract closeout. This information is re quired b y the Federal Acquisition Regulation to be collected at that time. **3(e) General Guidelines**  These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. **3(f) Confi**  **dentiality/Sensitive Questions** In formation collected under this request, particularly cost and pricing data, is treated as CBI. This information is protected from public release in accordance with the Agency's confidentially

regulation, 40 C.F.R. Part 2.2 01 et seq. **4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes**  All contractors who have completed an EPA cost reimbursement ty pe contract will be required to submit EPA Form 1900

- 10. These contractors represent a wide range of industries which include, but are not limited to: 541511, C ustom C omputer P rogramming, 54163

Management and Consulting Services, 6215 Medical Laboratories, and 541380, Testing Laboratories. **4(b) Information Requested**  A cop y of the reporting form is attached as Attachment A.

**(i) Data Items**  Data requested in EPA Form 1900

- 10 (attached) has not changed since the last OMB review. This information includes major cost elements such as direct labor, direct material and supplies, equipment, travel, subcontract costs, consultant fees, indirect costs and fixed fees. Indirect costs are broken down showing base ye ar and rate for each cost center for each ye ar of contract performance. Please note that EPA has omitted the e xpiration date from form 1900

- 10. As stipulated in 5 CFR 1320.8(b)(1), the collection of information should display a currentl y valid OMB Control Number and, if appropriate, an expiration date. Due to the fact that this form has been in use for a number of ye ars without change , and since the collection activity and use of the form continue to be required, it is not appropriate to include the expiration date on the form.

**(ii) Respondent Activities**  In order to complete the EPA Form 1900

- 10, respondents must total all cost s incurred under the contract, including costs for direct labor, all equipment, materials and supplies, travel, subcontracts, consulting fees, indirect costs, and fees. During contract performance, this information is included on the contractor’s monthly invoice for reimbursement. To calculate total contract costs, the contractor adds the cost from each invoice submitted under the contract. If costs were claimed on an invoice that w as disallowed, the contractor would subtract the disallow ed amount from the total. Negotiated indirect cost rates are applied to the base costs in order to determine the indirect costs for each cost center. This information is also contained in the contractor’s invoices, and in correspondence concerning allo wable costs and negotiated agreements on indirect rates. None of the information collected under this I CR must be created or researched. Rather, the data is comp il ed from various existing sources and summarized for this information collection. After the data is compiled, it must be reviewed for accuracy against existing records. It is customary business practice for a contractor to maintain the ty pe of financial performance information required to complete EPA Form 1900

- 10.
**5. T**  **he Information Collected**

**– Agency Activities, Collection Methodology, and**  **Information Management 5**  **(a) Agency Activities** 4

Once EPA Form 1900
- 10 is reviewed b y the Agency, the data is reconciled with Agency records, and audited. If the information collected is correct, final co ntract pay ment is made. **5 (b)**  **Collection Methodology and Management** In formation submitted is checked against Agency records such as invoices, correspondence, and negotiated agreements. Respondents have the option of reporting in their own computerized format provided all the required data is present. Completed forms, after review, become part of the contract files and will not be disclosed outside the Government. **5 (c)**  **Small Entity Flexibility** Data requested is required by the Federal Acquisition Regulation. It is not possible to develop separate or simplified require ments for small businesses or other small entities because the information required is necessary to complete the closing out of a contract, an alternate collection of information for small businesses is not appropriate. **5(d) Collection Schedule**  Data is collected once at contract completion. Generall y, this is after a five year period of performance. **6. Estimating the Burden and Cost of the Collection**  **6(a) Estimating Respondent Burden Hours**  Respondent burden hours are estimated at 6.3 hours per respondent. For the 5 respondents, total annual burden hours are estimated at 31.5. 5 Respondents x 6.3 hours per respondent = 31.5 Total Annual Burden Hours **6(b) Estimating the Respondent Burden Costs**  Respondent burden costs are estimated at $688.13 per respondent. For the 5 respondents, total annual labor cost is estimated at $3,440.65. 5 Respondents x 688.13 labor cost per respondent = $3,440.65 Total Annual L abor Cost **(i) Estimating Labor Costs**  The annual lab or cost to all respondents is estimated at $ 3,440.65 based on the following calculations. Contractors may claim the cost of completing this form under the appropriate contract. **ACTIVITY TIME TO COMPLETE**  **AVG RATE/HR COST** 5

1. Gather information 10 5.0 minutes $1 19.18 $ 208.56 2. Compile data 135.0 minutes $1 19.18 $ 268.15 3. Review data 82.5 minutes $1 19.18 $ 163.87 4. Complete form 60.0 minutes $4 7.55 $ 47.55 **Total 382.5 minutes**  **$688.13** Step 1 thru 3 of the collection activity is normall y perform ed b y an Administrative Manager. Administrative support personnel are responsible for completing step 4
. The cost associated with this effort was estimated using a loaded hourl y rate based upon the National Compensation Survey : Occupational Wages in the United States , 20 13; published b y the U.S. Department of Labor, Bureau of Labor Statistics. This data was published in the National Compensation Survey : Occupational Wages in the United States, 20 13 in May of 20 13 , and represents the most current survey data available ( http://www.bls.gov/cpi/ )

. Since the labor rates used in this estimate are from 20 13 , a Consumer Price Index (CPI) escalation factor of 2.1 % (based upon the CPI from May 2013 to May

2014 ) was applied for each ye ar to determine an average wage for 2014
. T he escalated hourl y labor rate is multiplied by an estimated loading factor of 2.95 (*see below) to reflect industries’ overhead , fringe benefits, and g eneral and administrative costs. The following are the loaded labor rates used in the calculations in the table above: Administrative Manager: 2013 = $ 39.57 2014 = ( $ 39.57 x 1.0 21) = $40.40 x 2.95 = $ 119.18 Administrative Support: 2013 = $ 15.79 2014 = ($ 15.79 x 1.021 ) = $ 16.12 x 2.95 = $ 47.55 * 2.95 is a factor recommended b y EPA cost analyst as representative of labor related burdens experienced b y EPA contractors. The cost for each labor category was determined by first dividing the hourly labor rate b y 60 minutes to obtain the per minute rate. Then, the per minute rate is multipl ied by the minutes to complete each activity to obtain the cost. EPA processed approximately 5 contract closeouts in the previous year using EPA Form 1900
- 10. As indicated above, each form takes 382.5 m inutes, or about 6.3 hours to complete. The 5 yearl y actions, multiplied by the cost to process one action, $688.13, are used to determine the above annual cost burden to the respondents. The 5 yearl y actions, multiplied by 6.3 hours equates to an annual h ourl y burden of 31.5 hours. The amount of time required to complete each of the tasks involved is based on consultations with contractors, contractor consultation with their subcontractors and Agency experience. Also respondents have pointed out that the c omplexity of the contract to be closed out and the timeliness of consulted subcontractors increases the amount6

of time needed to gather the required information. Most firms keep all of their financial data required for completion of this form in a computer database.

**(ii) Estimating Capital and Operations and Maintenance Costs**  Operating and Maintenance Costs, which include such items as file storage, photocopying, and postage, are minimal for this effort, and are estimated at $12.00 per action for a total annual burden of $60.00 (5 ye arly actions x $12.00). 5 Annual Respondents x $12.00 O&M = $60.00 Annual O&M Costs

**(iii) Capital/Start**  **- up Operating and Maintenance (O&M) Costs**  Because it will not be necessary for respondents to acquire an y capital goods to provide the requested information, EPA included no capital or start

- up costs in the burden estimate.
**6(c) Estimating Agency Burden and Cost**  Annual agency

burden is estimated at $132.25. This takes 30 minutes per response at $52.90 an hour for a cost of $26.45 per respondent. Once the Agency

receives the information, it is reviewed by the emplo ye e conducting contract close

- out. Annual Agency burden is estimated at $132.25 calculated as follows: ACTIVITY TIME REQUIRED RATE COST 1. Review data against 30 minutes $52.90 $26.45 Agency records 5 Yearl y Actions x $26.45 cost = **$132.25** Generally , the individual closing out the contract is a GS

- 12 grade level. The wage rate was calculated b y taking the GS

- 12 median hourl y rate ($33.06) and multiplying it by a factor of 1.6 to account for benefits ($52.90)

. The cost per action was determined b y first dividing the hourly labor rate b y 60 minutes to o btain the per minute rate. Then the per minute rate is multipl ied by

the minutes to complete the review of one action to obtain the cost. As described above, 5 ye arl y actions were multiplied by the cost, $26.45, to review an action in order to calculate th e Agency

burden. **6(d) Estimating the Respondent Universe and Total Burden Costs** 7

EPA estimates that it will process a pproximately

5 respondent forms per ye ar during the next three years for a total of 15 respondent forms. The average annual respondent burden and cost over the next three ye ars is estimated to be 31.875 labor hours multiplied by 3 years (for estimated 15 respondents total) for a total of 95.625 respondent burden hours

. **6(e) Bottom Line Burden Hours and Cost Tables**  **(i) Responde**  **nt Tally** The average annual respondent burden for one year is estimated to be 31.875 labor hours (for estimated 5 respondents total) with a labor cost of $3440.65.

Respondents Hours Labor Cost O&M Cost Total Cost Annual 5 31.875 $3,440.65 $60 $3,500.65 3 Years 15 95.625 $10,321.95 $180 $10,501.95

**(ii) The Agency Tally**  Annual agency cost is estimated at $132.25.

Agency Actions Hours Cost per Action Total Cost Annual 5 2.5 $26.45 $132.25 3 Years 15 7.5 $26.45 $396.75 **6(f) Reasons for Change in Burden**  There is a decrease of 48 hours in the total estimated respondent burden compared with the ICR currentl y approved by OMB. This is due to the decreased number of contracts closed in the past period. However, there has been an increase of individual respondent burden hours of 2.375 hours (142.5 minutes per response)

. The increase in the burden from the previous approval is based on the respondents’ increased time needed per action due is likel y due to the complexity of some of the contracts to be closed out and the timeliness of consulted subcontractors; which results in more information to be compiled and reviewed, as well as increases the amount of time needed to gather the required information. **6(g) Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is es timated to average 6 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review i nstructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information;8

adjust the existing way s to comply with an y previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the inform ation. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 C FR 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 I CR under Docket ID Number EPA

- HQ
- OARM
- 2011
- 0 997 , which is available for online viewing at www.regulations.gov , or in person viewing at the Office of Environmental Information (OE I) Docket in the EPA Docket Center (EPA/DC), EPA 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 OEI Docket is (202) 566

- 1752. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronicall y. When in the sy stem, select “search,” then key in the Docket ID Number identified above. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA
- HQ
- OARM
- 2011
- 0997 and OMB Control Number 2030

- 0 016 in any correspondence

.9



## EP**A United States Environmental Protection A**  **gency Contractor's Cumulative Claim and Reconciliation**  **OMB No. 2030 -**  **0016**
1. Contractor's Address (include zip code) 2. Contract No.
3. Total amounts claimed under this contract ( less disallowances concurred by the contractor and disallowances not subject to appeal ) and approved on Public Vouchers Nos. to ( including completion vouchers). **Item Am**  **ount** Direct Labor $ Direct Material and Supplies $ Equipment $ Travel $ Subcontract Costs $ Other Direct Costs $ Consultant Fees $ Fix ed Fee $ Indirect Costs (Total From Section 4) $ **Total A mount Claimed**  $ 4. Reconciliation of Indirect Costs Claimed. Record the amount of indirect costs calculated, for each cost center, using neg otiated final indirect cost rate(s). Use provisional rate(s) if final rates are not negotiated for any fiscal year period(s). Use the reverse side of this form, if necessary, to display all years and cost centers. Cost Center Cost Center Cost Center Cost Center Cost Center FY Base Rate Indirect Costs FY Base Rate Indirect Costs FY Base Rate Indirect Costs **Totals** No monies or other benefits may be paid unless this report is completed and filed as required in the EPA billing instructions

. I certify that the information provided on this form and attachments thereto are accurate and complete. I acknowledge that any knowingly false or misleading information may be punishable by fine and/or imprisonment under applicable law. Name and Title (Print or Type) Signature Date

EPA Form 1900
- 10 (Rev. 3
- 06) Previous Edition is Obsolete10 **Paperwork Reduction A ct Notice**  Public reporting burden for this collection of information is estimated to average 40 minutes per response, including the time for searching existing data sources, gathering and maintaining data, and completing and reviewing data. Send comments regarding this burden estimate or any other aspect of this collection of information (including suggestions for reducing this burden) to:

(1) Manager , Policy and Oversight Service Center (mail code 3802R) U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Wa shington, DC 20460; and (2) Paperwork Reduction Project (OMB No. 2030
- 0016) Office of Information and Regulatory Affairs Office of Management and Budget Wa shington, DC 20503. **Cost Center Cost Center**  **Cost Center Cost Center**  **Cost Center FY**  **Base Rate**  **Indirect Costs FY**  **Base Rate**  **Indirect Costs FY**  **Base Rate**  **Indirect Costs FY**  **Base Rate**  **Indirect Costs FY**  **Base Rate**  **Indirect Costs**

**Totals**

No monies or other benefits may be paid unless this report is completed and filed as required in the EPA billing instructions.