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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 authorizing 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 

management 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 be used by

all grantees, at this time only grantees on cost reimbursement or route payment status will be 

required to use this form when reporting their budget, requesting funds, and accessing funds.

Current Department regulations sections §74.20-74.28 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 currently 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 of 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 current 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 transferred from one budget category to another and will expedite their review of 

funding requests. 
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[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 techniques 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 use the system to submit performance reports, to manage 

administrative functions of their grants, and to view payments. Placing the new form in the G5 

system increases the efficiency of budget requests by grantees and budget reviews by program 

monitors. 

4. Describe efforts 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 payment 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 process 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 notfor-profit enterprise that is independently owned and operated and is not 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 payment 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 results 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. Currently 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. 
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[ICR No. 2004.01] 1855-NEW - G5 System Post Award Budget Drawdown e-Form

7. Explain any special circumstances that would cause an information 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 it;

 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 agencies 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 extent 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), soliciting 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 data 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 activity is the same as in prior periods. There may be 

circumstances that may preclude consultation in a specific situation. These 

circumstances should be explained.
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[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 contractors or grantees with meaningful justification.

The Department will not provide any payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy. 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 indicated 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 Provisions 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 makes 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 considers 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 about sexual behavior and attitudes, religious 

beliefs, or other items that are commonly 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 affected 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 explanation 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 
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[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 complexity, 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 separate hour

burden estimates for each form. (The table should at minimum include 

Respondent types, Number of Respondents and Responses, Hours/Response, and 

Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections 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 Award Draw Down Form

Respondent 

Type

# of 

Respondents

# of 

Responses 

Hours per 

Response

Total 

Burden 

Hours 

Reporting 

Requirement

Cost per 

Respondent

Total Costs per 

Respondent

Burden by

Affected 

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? Yes
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[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 Questions 12 and 14.)

 The cost estimate should be split into two components: (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, maintaining, 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 record 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 the 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 costs (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 
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[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 Award Draw Down Form

# of 

Employees

Amount of 

Responses 

Reviewed

Time to 

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 size 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 respondent 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 costs (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 

tabulation 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 information, completion of report, publication dates, and 

other actions.

The expectation is for the form to be functional in the Department’s Grant Management System 

G5 by the spring of 2014. At that time, grantees will be able to use the electronic form for 

reporting 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 Paperwork Reduction Act.

There are no exceptions to the certification statement.