Attachment A

SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) TITLE OF THE INFORMATION COLLECTION

Contractor Cumulative Claim and Reconciliation (Renewal), EPA Form 1900-10. 

Information Collection Request (ICR) 0246.11, OMB Control No. 2030-0016. 

(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 physical completion of the 

contract. Funds status review is a mandatory part of contract closeout. It includes settlement of 

interim or disallowed costs and settlement of indirect cost rates. 

Under a cost reimbursement type contract, when the contract is completed, the contractor

submits EPA Form 1900-10 which summarizes all cost incurred in performance of the contract 

and sets forth the final indirect rates. This form is reviewed by the contracting office to determine 

the final costs reimbursable to the contractor. A copy of the form is attached to this request. 

2. NEED FOR AND USE OF THE COLLECTION

(a) NEED/AUTHORITY FOR THE COLLECTION

FAR 52.216-7 states that the Government will pay only the costs determined to be 

allowable by 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 year 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 previously, 

FAR 4.804-5 mandates that the office administering the contract shall ensure that the costs and 

indirect cost rates are settled. 

(b) USES/USERS OF THE DATA

Information 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 requested, will review the 

information in order to determine the final contract costs prior to final payment under the contract. 

3. THE RESPONDENTS AND THE INFORMATION REQUESTED

(a) RESPONDENTS/NORTH AMERICAN INDUSTRY CLASSIFICATION (NAICS) 

CODES
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All contractors who have completed an EPA cost reimbursement type 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, Custom Computer Programming, 5416 

Management and Consulting Services, 6215 Medical Laboratories, and 541380, Testing 

Laboratories.

(b) INFORMATION REQUESTED

(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 year and rate for each cost center for each year of 

contract performance. 

Please note that EPA has omitted the expiration date from form 1900-10. As stipulated in 5 CFR 

1320.8(b)(1), the collection of information should display a currently 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 years 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 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 was disallowed, the contractor would subtract the 

disallowed 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 allowable costs and negotiated agreements on indirect rates. None of 

the information collected under this ICR must be created or researched. Rather, the data is 

complied 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 type of financial performance information 

required to complete EPA Form 1900-10. 
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4. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

(a) AGENCY ACTIVITIES

Once EPA Form 1900-10 is reviewed by the Agency, the data is reconciled with Agency

records, and audited. If the information collected is correct, final contract payment is made. 

(b) COLLECTION METHODOLOGY AND MANAGEMENT

Information 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. 

(c) SMALL ENTITY FLEXIBILITY

Data requested is required by the Federal Acquisition Regulation. It is not possible to 

develop separate or simplified requirements 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. 

(d) COLLECTION SCHEDULE

Data is collected once at contract completion. Generally, this is after a five year period of 

performance.

5. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

(a) NONDUPLICATION

Information collected is contract-specific. Cumulative contract cost information, as 

requested, is not available from any other source.

(b) Consultations

The following vendors were contacted to discuss collection activities:

FIRM PERSON CONTACTED PHONE

Eastern Research Group Ms. Gail Schubert (781)647-7350

Compusearch, Inc. Mrs. Virginia Baxter (703) 481-3699 X307

InfroPro, Inc. Ms. Eileen Anderson (703)226-2529

 Each firm indicated the financial information requested is kept routinely for company 

records and for audit purposes. None of the firms contacted felt the information collection was 

burdensome and each recognized the contract.
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(c) EFFECTS OF LESS FREQUENT COLLECTION

The information is collected only once at contract closeout. This information is required 

by the Federal Acquisition Regulation to be collected at that time.

(d) GENERAL GUIDELINES

This information collection meets all OMB guidelines with the exception of two: (1) small 

entities have to follow the same collection procedures as other respondents and (2) Confidential 

Business Information (CBI) is requested. Item one is addressed in paragraph 4(c). CBI is 

protected from release to the public by 40 CFR Part 2.

(e) Information 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 2.201 et seq.

(f) 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

will be published on or about 12/19/2011 (73 FR 67152). 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

(a) ESTIMATING RESPONDENT BURDEN

(i) Labor Costs

The annual labor cost to respondents is estimated at $8,251.00 based on the following 

calculations. Contractors may claim the cost of completing this form under the appropriate 

contract.

 ACTIVITY TIME TO COMPLETE RATE COST

1. Gather information 180.0 minutes $104.90 $313.20

2. Compile data 27.5 minutes $104.90 $ 47.85

3. Review data 27.5 minutes $104.90 $ 47.85

4. Type form 5.0 minutes $43.84 $ 3.65

 Total 240 minutes $412.55

Step 1 thru 3 of the collection activity is performed by an administrative manager. 

Administrative support personnel are responsible for completing step 4. 

The cost associated with this effort was estimated using a loaded hourly rate based upon 

the National Compensation Survey: Occupational Wages in the United States, 2007; published by

the U.S. Department of Labor, Bureau of Labor Statistics. This data was published in the National 
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Compensation Survey: Occupational Wages in the United States, 2007 in April of 2007, and 

represents the most current survey data available.

Since the labor rates used in this estimate are from 2007, an escalation factor of 4% (based 

upon Defense Contract Audit Agency) was applied for each year to determine an average wage for 

2008. The escalated hourly labor rate is multiplied by an estimated loading factor of 2.95 (*see 

below) to reflect industries’ over head, fringe benefits, and general and administrative costs. 

The following are the loaded labor rates used in the calculations in the table above:

Administrative Manager:

2007 = $35.15

2008 = ($35.15 x 1.04) = $35.56 x 2.95 = $104.90

Administrative Support:

2007 = $14.29

2008 = ($14.29 x 1.04) = $14.86 x 2.95 = $43.84

* 2.95 is a factor recommended by EPA cost analyst as representative of labor related burdens 

experienced by EPA contractors.

The cost for each labor category was determined by first dividing the hourly labor rate by 

60 minutes to obtain the per minute rate. Then the per minute rate is multiplied by the minutes to 

complete each activity, to obtain the cost. 

EPA processed approximately 20 contract closeouts in the previous year using EPA Form 

1900-10. As indicated above, each form takes 240 minutes, or about 4 hours to complete. The 20 

yearly actions, multiplied by the cost to process one action, $412.55, are used to determine the 

above annual cost burden to the respondents. The 20 yearly actions, multiplied by 4 hours equates 

to an annual hourly burden of 80 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 complexity of 

the contract to be closed out and the timeliness of consulted subcontractors increases the amount 

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) Capital/Start-up Costs

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

requested information, EPA included no capital or start-up costs in the burden estimate.

(iii) Operating 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 $240.00 (20 yearly actions x $12.00).
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(b) ESTIMATING AGENCY BURDEN & COST

Once the Agency receives the information, it is reviewed by the employee conducting 

contract close-out. Annual Agency burden is estimated at $516.00 calculated as follows:

ACTIVITY TIME REQUIRED RATE COST

1. Review data against 30 minutes $51.60 $25.80

 Agency records

Generally, the individual closing out the contract is a GS-12 grade level. The wage rate 

was calculated by taking the GS-12 median hourly rate ($32.25) and multiplying it by a factor of 

1.6 to account for benefits. The cost per action was determined by first dividing the hourly labor 

rate by 60 minutes to obtain the per minute rate. Then the per minute rate is multiplied by the 

minutes to complete the review of one action to obtain the cost. As described above, 20 yearly

actions were multiplied by the cost, $25.80, to review an action in order to calculate the Agency

burden.

(c) REASONS FOR CHANGE IN BURDEN

In the last OMB clearance, respondent burden hours were estimated at 32 hours per year

(40 minutes per response). The current estimate is 80 hours per year (240 minutes per response)

for an overall increase of 48 hours (200 minutes per response). The increase in the burden from 

the previous approval is based on the respondents’ increased time needed per action 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. A comparison of the last 

OMB approval and the present request is shown below.

Prior Approval Present Request

47 contracts (closed out) 20 contracts (closed out)

32 hours per year 80 hours per year

40 minutes per response 240 minutes per response

7. BURDEN STATEMENT

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

estimated to average 240 minutes per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or 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 
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information, processing and maintaining information, and disclosing and providing information; 

adjust the existing ways to comply with any 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 information. An 

agency may not conduct or sponsor, and a person is not 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-2011-0997, which is available for public viewing at the 

Office of Environmental Information (OEI) 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 holidays. 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 through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket. Use EDOCKET 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 electronically. Once in the 

system, select “search,” then key in the docket ID number identified above. 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 Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OARM-2011-0997 and OMB Control Number 2030-

0016 in any correspondence.
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 EPA United States Environmental Protection Agency

 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 Amount

Direct Labor $

Direct Material and Supplies $

Equipment $

Travel $

Subcontract Costs $

Other Direct Costs $

Consultant Fees $

Fixed Fee $

Indirect Costs (Total From Section 4) $

Total Amount Claimed $

4. Reconciliation of Indirect Costs Claimed. Record the amount of indirect costs calculated, for each cost center, using negotiated 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 Obsolete
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Paperwork Reduction Act 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

 Washington, DC 20460; and

(2) Paperwork Reduction Project (OMB No. 2030-0016)

Office of Information and Regulatory Affairs

Office of Management and Budget

Washington, 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.