Attachment A SUPPORTING STATEMENT
1. ID ENTIFICATION OF THE INFORMATION COLLECTION (a) TIT LE OF THE INFORMATION COLLECTION Contractor Cumulative Claim and Reconciliation (Renewal) , EPA Form 1900
- 10. In formation Collection Request (ICR) 0246. 1 1 , 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 phy sical 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 ty pe 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 b y the contracting office to determine the final costs reimbursable to the contractor. A copy of th e 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 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 inf ormation for the entire contract period and provides a basis for cost review b y 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. (b) USES/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 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 AMERI CAN INDUSTRY CLASSIFICATION (NAICS) CODES2

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 t o: 541511, C ustom C omputer P rogramming, 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 ye ar and rate for each cost center for each ye ar 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 Contro l 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 expi ration 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, c onsulting 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 disallowed amount from the total. Negotiated indirect cost rates are applied to the base costs in order to determine the indirect costs for each co st 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 I CR 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 ty pe of financial performance information required to complete EPA Form 1900

- 10.3

4. THE INFORMATION COLLECTED
- AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT (a) AGENCY ACTIVITIES Once EPA Form 1900
- 10 i s reviewed b y 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 In formation submitted is checked against Agency reco rds 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 wil l not be disclosed outside the Government. (c) SMALL ENT ITY 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. Generall y, this is after a five year period of performance. 5. NONDUPLICATION, CONSUL TAT IONS, AND OTHER COLLECTION CRITERIA (a) NONDUPLICATION In formation collected is contract

- specific. Cumulative contract cost information, as requested, is not available from an y other source. (b) Consultations The following vendors were contacted to discuss collection activities: **FIRM PERSON CONTACTED**  **PHONE** Eastern Research Group Ms. Gail Schubert (7 81 )6 47
- 7350 Compusearch, Inc. M rs . Virginia Baxter (703) 481

- 3699 X307 In f roPro, Inc. Ms. Eileen Anderson ( 703 ) 226
- 2529 Each firm indicated the financial information requested is kept routinely for compan y records and for audit purposes. None of the firms contacted felt the information collection was burdensome an d each recognized the contract.4

(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 GUIDELI NES 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) C onfidential B usiness Information (CBI) is requested. It em 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, particularl y 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 I CR Submission to OMB: The Federal Register document required under 5 CFR 1320.8(d), soliciting comments on this collection of information w ill be published on or about 1 2 / 1 9 /20 11 (7 3 FR 67152 )

. 6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION (a) ESTIMAT ING RESPONDENT BURDEN (i) Labor Costs The annual labor cost to respondents is estimated at $ 8 , 251 .0 0 based on the following calculati ons. Contractors may claim the cost of completing this form under the appropriate contract. ACTIVITY TIME TO COMPLETE RATE COST 1. Gather information 1 8 0 .0 minutes $ 104.90 $ 313.20 2. Compile data 27.5 minutes $ 104.90 $ 47.85 3. Review data 27.5 minutes $ 10 4 .9 0 $ 47.85 4. Ty pe form 5 .0 minutes $ 4 3
. 8 4 $ 3. 65 Total 2 4 0 minutes $ 412
. 5 5 Step 1 thru 3 of the collection activity is perform ed by

an administrati ve 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 , 200 7 ; published by the U.S. Department of Labor, Bureau of Labor Statistics. This data was published in the National5

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 200 7 , an escalation factor of 4% (based upon Defense Contract Audit Agency) was applied for each year to determine an average wage for 200 8
. T he escalated hourly labor rate is multiplied by an estimated loading factor of 2.95 (*see below) to reflect industries’ over head, 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: 200 7 = $ 3 5
. 15 20 0 8 = ( $ 3 5
. 15 x 1.04 ) = $35.56 x 2.95 = $ 10 4 .9 0 Administrative Support: 200 7 = $ 14.2 9 2 00 8 = ($ 14. 29 x 1.04) = $ 14.86 x 2.95 = $ 4 3
. 8 4 * 2.95 is a factor recommended b y EPA cost analyst as representative of labor related burdens experienced b y EPA contract ors. 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 proces sed approximately 20 contract closeouts in the previous y ear using EPA Form 1900
- 10. As in dicated above, each form takes 240 minutes, or about 4 hours to complete. The 20 ye arl y actions, multiplied by the cost to process one action, $412.55, are used to d etermine the above annual cost burden to the respondents. The 20 ye arl y actions, multiplied by 4 hours equates to an annual hourl y burden of 80 hours. The amount of time required to complete each of the tasks involved i s based on consultations with contr actors , 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 g ather 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 prov ide 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 $1 2 .00 per action for a total annual burden of $ 240 .00 (20 yearl y actions x $12.00)

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(b) ESTIMATING AGENCY BURDEN & COST Once the Agency

receives the information, it is reviewed by the emplo ye e conducting contract clos e - 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 $ 2 5
. 80 Agency records Generally , the individual closing out the contract is a GS

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

- 12 median hourl y rate ($3 2
. 2 5) and multiplying it by a factor of 1.6 to account for benefits. The cost per action was determined b y first dividing the hourl y 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 the review of one action to obtain the cost. A s described above, 20 ye arly actions were multiplied by the cost, $25.80, to review an action in order to calculate the Agency burde n. (c) REASONS FOR CHANGE IN BURDEN In the last OMB clearance, respondent burden hours were estimated at 3 2 hours per year (40 minutes per response) . The current estimate is 80 hours per ye ar (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 contract s to be closed out and the timeliness of consulted subcontracto rs ; which results in more information to be compiled and review ed , 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 ye ar 80 hours per ye ar 40 minutes per response 2 4 0 minutes per response
7. BURDEN STATEMENT The annual public reporting and recordkeeping burden for this co llection of information is estimated to average 240 minutes 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 i ncludes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying7

information, processing and maintaining information, and disclosing and providing inform ation; 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 transm it 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 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 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 colle ction 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 public 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 tel ephone number for the OE I 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 sy stem, select “search,” then key in the docket ID number identified above. Also, you can send comments to the Office of Informatio n 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
- 20 11
- 0 997 and OMB Control Number 2030

- 00 16 in any

correspondence

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## 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 Su pplies $ 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 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 a ny 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 Obsolete9 **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 suggesti ons for reducing this burden) to:

(1) Manager , Policy and Oversight Service Center (mail code 3802R) U.S. Environmental Protection Agency 1200 Pennsylvania Av enue, 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**  **I ndirect 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 instruction s.