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**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form**
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System Post Award Budget Drawdown e**  **- Form**  Revised: 12/4/2013 

### A. Justification **1. Explain the circumstances that make the collection of information necessary.**  **Identify any legal or administrative requirements that necessitate the collection. Attach a**  **hard copy of the appropriate section of each statute and regulation**  **mandating or auth orizing the collection of information**  **, or**  **you may provide a valid**  **URL link or paste the applicable section**  **. Please limit pasted text to no longer than 3**  **pages. Specify the review type of the collection (new, revision, extension,**  **reinstatement with change, reinstatement without change)**  **. If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed**  **sections, if applicable.** Department staff is working on developing the post award functions of the electronic grant m anagement system, G5. In response to grant monitors need for a better reporting mechanism for grantee budgets, the G5 team developed a new electronic budget form for grantees to complete . This new electronic form requires grantees to detail the budget categories from which they are expending funds in order for Department grant monitors to track more carefully the drawdowns and financial management systems of grantees. Although this form may b e used by all grantees, at this time only grantees on cost reimbursement or route pay ment status will be required to use this form when reporting their budget, requesting funds, and accessing funds. Current Department regulations sections §74.20

- 74.2 8 and §74.50

- 74.53 address the financial management and reporting requirements of grantees. The new form developed in G5 serves as the mechanism for grantees to report expenditures and track their spending in order to ensure compliance with Department regulations. The currentl y used budget form, the SF 524, is not comprehensive enough to meet the needs of grant monitors to efficiently and effectively

monitor this sub

- set of grantees. This new data collection will enhance the ability o f grant monitors to track the budgeting of grantees and the management of their funds. **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 cu**  **rrent collection.** Grant monitors will be using the budget information provided by the grantees to determine if their planned costs are reasonable, allocable, and allowable with the Department’s regulations and the governing statute of the applicable program. The information provided will be detailed enough for grant monitors to see how program funds are being spent and from which budget categories the funds will be taken. This new collection will also enable grant monitors to see if funds are being transf

erred from one budget category to another and will expedite their review of funding requests.2

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form 3.**  **Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection te**  **chniques or forms of information technology, e.g. permitting electronic submission of responses,**  **and the basis for the decision of adopting this means of collection. Also describe any consideration given to using technology to reduce burden.**  The new electronic form and all information provided by grantees will be submitted electronically

through the Department’s grant management system, G5. Grantees are familiar with this system because they u se the system to submit performance reports, to manage administrative functions of their grants, and to view pay ments. P lacing the new form in the G5 system increases the efficiency o f budget requests by

grantees and budget reviews by p rogram monitors. **4. Describe ef** 

**forts to identify duplication. Show specifically**  **why any similar information already available cannot be used or modified for use for the purposes**  **described in Question**  **2 above.**  Currently, grantees on cost reimbursement or route pay ment submit budget requests using the paper SF 524 along with receipts. This process is extremely burdensome to grantees as well as grant monitors who must review each receipt and accounting documentation, which comes in a different format for each grantee. This new electronic form would eliminate the need for this paper pro cess and the new electronic format would facilitate an easier submission and approval of budget documents. **5. If the collection of information impacts small businesses or other small entities,**  **describe any methods used to minimize burden. A small entity may be (1) a small**  **business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any not** **** **for -** **profit enterprise that is independently owned and operated and is no t dominant**  **in its field; or (3) a small government jurisdiction, which is a government of a city, county, town, township, school district, or special district with a population of less**  **than 50,000.** The development of the electronic form is a large improvement from the current financial reporting mechanism in place. Actually, this new collection will decrease the impact and burden on small businesses currently on route pay

ment or cost reimbursement by allowing them to submit information electronically which expedites when the grant monitor will receive the information, eliminates the cost of postage, and by facilitating an easier review of financial documents by

grant monitors result s in grantees receiving their funds in a more timely manner. **6. Describe the**  **consequences 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.** The development of the new budget reporting form decreases the Federal government’s risk of the misuse of program funds because grantees will be required to demonstrate how they intend to spend the money

in order to receive the funds. Currentl y grantees are able to access their funds with little to no oversight from grant monitors. This collection is increasingly important as the grantees that will be using this form have demonstrated their inability to follow appropriate Federal financial guidelines and practices.3

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form**
**7. Explain any special circumstances that would cause an info**  **rmation collection to be conducted in a manner:** 
 **requiring respondents to report information to the agency more often than quarterly;** 
 **requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of i** **t;**
 **requiring respondents to submit more than an original and two copies of any document;** 
 **requiring respondents to retain records, other than health, medical, government contract, grant** **- in**  **- aid, or tax records for more than three years;** 
 **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;**
 **requiring the use of a statistical data classification that has not been reviewed and approved by OMB;** 
 **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 that unnecessarily**  **impedes sharing of data with other agencie s for compatible confidential use; or** 
 **requiring respondents to 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 exten t permitted by law.**  No information will be collected in the manner covered under any of the special circumstances outlined. **8. As**  **applicable, state that the Department has published the 60 and 30 Federal**  **Register notices as required by 5 CFR 1320.8(d), solic**  **iting 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.**  **Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instruction and record**  **keeping, disclosure, or reporting format (if any), and on the dat a elements to be**  **recorded, disclosed, or reported. Consultation 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 activit y is the same as in prior periods. There may be**  **circumstances that may preclude consultation in a specific situation. These circumstances should be explained.** 4

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form** The Department is currently publishing the necessary information to solicit comments from the public regarding this new reporting mechanism. All comments received will be reviewed and appropriate changes will be made to address applicable concerns. **9. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of contr actors or grantees**  **with meaningful justification .**  The Department will not provide any paym ents or gifts to respondents. **10. Describe any assurance of confidentiality provided to respondents and the basis for**  **the assurance in statute, regulation, or agency poli cy. If personally identifiable**  **information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the**  **date a Privacy Impact Assessment was completed as indicate**  **d on the ICRAS’ Part 2 IC form**  **. A confidentiality statement with a legal citation that authorizes the pledge**  **of confidentiality**  **should be provided. Requests for this information are in**  **accordance with the following ED and OMB policies: Privacy Act of 1974, OMB**  **Circular A -**  **108**

**– Privacy Act Implementation** 

**– Guidelines and Responsibilities,**  **OMB Circular A -**  **130 Appendix I**

**– Federal Agency Responsibilities for Maintaining**  **Records About Individuals, OMB M -**  **03 -**  **22**

**– OMB Guidance for Implementing the**  **Privacy Provision s of the E**  **- Government Act of 2002, OMB M** **- 06**  **- 15** 

**– Safeguarding**  **Personally Identifiable Information, OM:6 -**  **104**

**– Privacy Act of 1974 (Collection,**  **Use and Protection of Personally Identifiable Information) .**  **If the collection is subject to the Privacy Act, the**  **Privacy Act statement is deemed sufficient with respect to confidentiality. If there is no expectation of confidentiality, simply state**  **that the Department make s**  **no pledge about the confidentially of the data.** There is no assurance of confidentiality

. **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. The justification should include the reasons why the**  **agency conside rs the questions necessary, the specific uses to be made of the**  **information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.**  This reporting form does not include questions ab out sexual behavior and attitudes, religious beliefs, or other items that are commonl y considered sensitive and private. **12. Provide estimates of the hour burden of the collection of information. The**  **statement should:**
 **Indicate the number of respondents by aff ected public type (federal government,**  **individuals or households, private sector**

**– businesses or other for** **- profit, private**  **sector**

**– not**  **- for** **- profit institutions, farms, state, local or tribal governments),**  **frequency of response, annual hour burden, and an e xplanation of how the**  **burden was estimated, including identification of burden type: recordkeeping, reporting or third party disclosure. All narrative should be included in**  **Question 12. Unless directed to do so, agencies should not conduct special surveys**  **to obtain information on which to base hour burden estimates. Consultation with a**  **sample (fewer than 10) of potential respondents is desirable. If the hour burden**5

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form**

**on respondents is expected to vary widely because of differences in activity, size, or com** **plexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for**  **customary and usual business practices.**
 **If this request for approval covers more than one form, provide se parate hour**  **burden estimates for each form .**  **(The table should at minimum**  **include Respondent types,**  **Number of Respondent**  **s and Responses, Hours/Response, and**  **Total Hours)**
 **Provide estimates of annualized cost to respondents of the hour burdens for collection**  **s of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information**  **collection activities should not be included here. Instead, this cost should be included in**  **Question 14.** 

**Post Aw**  **ard Draw Down Form**
**Respondent Ty**  **pe # of** 

**Respondents # of** 

**Responses Hours per** 

**Response Total** 

**Burden Hours**  **Reporting**

**Requirement Cost per** 

**Respondent Total Costs per** 

**Respondent Burden by**  **Af fected**  **Entity :**  **Private Sector**  Not
-for profits 762 6,096 1.00 6,096 Reporting $40 $243,840 **Sub -** **total** 762 6,096 6,096 40 243,840 **State, Local, or Tribal**  **Governments** Public Institutions 1,831 14,648 1 14,648 Reporting $40 $585,920 Private Institutions 47 376 1 376 Reporting $40 $15,040 State, Local, or Tribal Governments 1,172 9,376 1 9,376 Reporting $40 $375,040 **Sub -** **total** 3,050 24,400 24,400 $976,000
**Total 3,812**  **30,496 30,496**  **$1,219,840 CURRENT**  **INVENTORY** Current # of Respondents 0 0 0 Current # of Responses 0 0 0 Current Inventory of Hours 0 0 0 Difference **3,812 30,496**  **30,496** Document Type Form Available Electronically? Yes6

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form**

Can be submitted Electronically? Yes Percent Reporting Electronically? 100% Obligation to Respond? Required to

Obtain or Retain a Benefit Frequency? Other **13. Provide an estimate of the total annual cost burden to respondents or record**  **keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in**  **Question s 12 and 14.)** 
 **The cost estimate should be split into two compon ents: (a) a total capital and**  **start -**  **up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates**  **should take into account costs associated with generating, mainta ining, and**  **disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition,**  **expected useful life of capital equipment, the discount rate(s), and the time period over**  **which costs will be incurred. Capital and start -**  **up costs include, among other items, preparations for collecting information such as purchasing**  **computers and software; monitoring, sampling, drilling and testing equipment; and acquiring and maintaining rec**  **ord storage facilities.**
 **If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contracting**  **out information collection services should be a part of this cost burden estimate.**  **In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60**  **- day pre**  **- OMB submission public**  **comment process and use existing economic or regulatory impact analysis associated with t**  **he rulemaking containing the information collection, as appropriate.** 
 **Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory**  **compliance with requirements not associated with the information collection, (3)**  **for reasons other than to provide information or keep records for the government**  **or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly c**  **osts (i.e., the monetization of the hours) captured above in**  **Question 12**  **.** Total Annualized Capital/Startup Cost: $0 Total Annual Costs (O&M): $1,219,840 Total Annualized Costs Requested: $1,219,840 **14. Provide estimates of annualized cost to the Federal government. Also, provide a**  **description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support** 7

**[ICR No. 2004.01] 1855**  **- NEW**  **- G5 System**  **Post Award Budget Drawdown e -**  **Form staff),**  **and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from**  **Questions 12, 13, and 14 in a single table.**  **Post A ward Draw Down Form** 

# of Em ployees Am ount of

Responses Reviewed Ti meto

review each response Hourly

Cost Per Hour Cost to Federal Government 3,812 30,496 0.50 hrs $ 30.00 $

457,440.00 **15. Explain the reasons for any program changes or adjustments. Generally,**  **adjustments in burden result from re -**  **estimating burden and/or from economic phenomenon outside of an agency’s control (e.g., correcting a burden estimate or an**  **organic increase in the s ize of the reporting universe). Program changes result from**  **a deliberate action that materially changes a collection of information and generally are result of new statute or an agency action (e.g., changing a form, revising**  **regulations, redefining the res pondent universe, etc.). Burden changes should be**  **disaggregated by type of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion), type of collection (new,**  **revision, extension, reinstatement with change , reinstatement without change) and**  **include totals for**  **changes in burden hours , responses**  **and cost s**  **(if applicable) .**  This is a new collection and all burden is new. **16. For collections of information whose results will be published, outline plans for**  **tabulati on and publication. Address any complex analytical techniques that will be**  **used.** Results of collected information will not be published. **17. Provide the time schedule for the entire project, including beginning and ending**  **dates of the collection of informat ion, completion of report, publication dates, and**  **other actions.** The expectation is for the form to be functional in the Department’s Grant Management S ys tem G5 by the spring of 2014. At that time, grantees will be able to use the electronic form for repo rting purposes on their individual schedules. **18. If seeking approval to not display the expiration date for OMB approval of the**  **information collection, explain the reasons that display would be inappropriate.** The Department will display on the form the expiration date for the OMB approval as required. **19. Explain each exception to the certification statement identified in the Certification**  **of Pap erw**  **ork Reduction Act.** There are no exceptions to the certification statement.