ICR
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
Title:
General
Administrative
Requirements
for
Assistance
Programs:
EPA
Administrative
Capability
Questionnaire
EPA
ICR
Number
0938.10,
OMB
Control
Number
2030­
0020
This
is
a
request
for
an
addition
to
an
existing
Information
Collection
Request
(
ICR)
which
is
due
to
expire
on
December
31,
2005.
The
existing
ICR
authorizes
the
collection
of
information
under
EPA's
General
Requirements
for
Assistance
Programs
(
OMB
Control
Number
2030­
0020),
that
establishes
the
minimum
management
requirements
for
all
recipients
of
EPA
grants
or
cooperative
agreements
(
assistance
agreements).
40
CFR
part
30,
"
Grants
and
Agreements
with
Institutions
of
Higher
Education,
Hospitals,
and
Other
Non­
Profit
Organizations"
establishes
the
management
requirements
for
institutions
of
higher
education,
hospitals,
and
other
non­
profit
organizations
as
well
as
procurement
requirements
for
non
governmental
recipients.
40
CFR
part
31,
"
Uniforms
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments",
includes
the
management
requirements
for
states
and
local
governments
as
well
as
Indian
Tribal
governments.
These
regulations
include
only
those
provisions
mandated
by
statute,
required
by
OMB
Circulars,
or
added
by
EPA
to
ensure
sound
and
effective
financial
assistance
management.

The
proposed
addition
to
the
existing
collection
reflects
EPA's
need
to
establish
procedures
for
assessing
administrative
capability
of
non­
profit
organizations
applying
for
EPA
grants.
Under
the
proposed
procedures,
EPA
will
require
non­
profit
applicants
to
complete
a
checklist
entitled
"
EPA
Administrative
Capability
Questionnaire"
(
Appendix
A)
and
return
it
to
EPA
with
supporting
documentation.
The
response
to
the
form
will
become
a
major
basis
for
assessing
administrative
capability
and
deciding
whether
to
award
grants
to
the
non­
profit
applicants.
Applicants
that
provide
information
that
demonstrates
they
are
administratively
capable
will
be
"
certified"
for
the
next
four
years,
and
therefore,
would
not
have
to
resubmit
the
questionnaire
and
supporting
documents
in
the
next
four
years
unless
administrative
management
issues
arise
before
the
certification
period
has
ended.
Note
that
much
of
the
information
to
be
collected
in
the
proposed
questionnaire
is
currently
being
collected
from
recipients
during
EPA's
post­
award
monitoring
activities.
Further,
the
information
to
be
collected
involves
management
systems
which
non­
profit
applicants
are
required
to
establish
by
40
CFR
part
30.

2.
Need
for
and
use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection.
In
applying
for
a
non­
construction,
discretionary
grant
from
EPA,
each
applicant
is
currently
required
to
complete
and
submit
Standard
Form
(
SF)
series
forms
SF424,
SF424A,
and
SF424B.
By
signing
the
SF424B
,
"
Assurances
­
Non­
Construction
Programs",
the
applicant
is
assuring
compliance
with
various
statutory
and
regulatory
requirements
(
40CFR
part
30
­
Grants
and
Agreements
with
Institutions
of
Higher
Education,
Hospitals,
and
Other
Non­
Profit
Organizations)
and
is
assuring
that
it
"[
h]
as
the
legal
authority
to
apply
for
Federal
assistance
and
the
institutional,
managerial
and
financial
capability
(
including
funds
sufficient
to
pay
the
non­
Federal
share
of
the
project
cost)
to
ensure
proper
planning,
management
and
completion
of
the
described
in
this
application".
Despite
this
assurance,
EPA's
Office
of
Inspector
General
and
the
Office
of
Grants
and
Debarment
within
EPA's
Office
of
Administration
and
Resources
Management
have
documented
numerous
instances
of
non­
profit
recipients
that
have
inadequate
administrative
systems
to
manage
EPA
funds
or
lack
the
capability
to
successfully
perform
the
project
scope
of
work.
For
this
reason
EPA
needs
to
address
such
issues
before,
rather
than
after
a
grant
is
awarded.

2(
b)
Practical
Utility/
Users
of
the
Data
The
pre­
award
information
will
be
used
to
qualify
and
select
non­
profit
grant
applicants
for
funding.
The
information
is
necessary
to
ensure
adequate
fiscal
control
and
accountability
for
EPA
funds
and
to
deter
waste,
fraud,
and
abuse.

3.
Non
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non
duplication
There
is
no
other
source
for
this
information.

3(
b)
Public
Notice
Required
Prior
to
ICR
submission
to
OMB
EPA's
plans
for
this
data
collection
and
the
questionnaire
itself
were
published
the
Federal
Register
notice
describing
EPA's
electronic
docket
at
69
FR
51462
(
August
19,
2004).
During
the
prescribed
comment
period,
no
comments
were
received.

3(
c)
Consultations
EPA
has
completed
several
questionnaire
pre­
tests
with
both
experienced
and
inexperienced
potential
non­
profit
applicants.
The
pre­
test
results
were
used
to
refine
both
the
questionnaire
instructions
and
questions.
The
results
confirmed
the
Agency's
initial
estimate
respondent
burden
of
4
hours.
Further,
during
the
Public
Law
106­
107
workgroup
process,
EPA
learned
that
the
Department
of
Justice
(
DOJ)
has
a
similar
form
for
all
of
its
grant
applicants
entitled
"
Accounting
Systems
and
Financial
Capability
Questionnaire",
OMB
Control
Number
1121­
0021.
The
estimated
respondent
burden
for
that
form
is
4
hours.

3(
d)
Effects
of
Less
Frequent
Collection
A
re­
certification
effort
after
four
years
should
satisfy
EPA's
fiduciary
responsibilities
while
minimizing
respondent
burden.
EPA
plans
to
re­
evaluate
this
frequency
during
the
next
renewal
cycle
currently
scheduled
to
expire
on
12/
31/
05.
3(
e)
General
Guidelines
To
minimize
the
burden
on
respondents
the
data
collection
instrument
(
Questionnaire
B
Appendix
A)
has
undergone
frequent
re­
writes
to
make
it
easier
to
understand.
Therefore,
all
non­
profit
respondents
should
benefit
from
the
"
plain
language".

3(
f)
Confidentiality
No
pledge
of
confidentiality
is
given
for
respondents
answers,
certifications,
or
supporting
documentation.

3(
g)
Sensitive
Questions
No
sensitive
information
will
be
collected
under
this
proposed
questionnaire.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
primary
recipients
of
the
proposed
questionnaire
will
be
non­
profit
organizations
seeking
large
(
greater
than
$
200,000)
grants
from
EPA.
If
additional
resources
become
available,
this
$
200,000
cut
off
may
be
lowered
to
increase
coverage
of
EPA's
non­
profit
applicant
pool.

Major
Standard
Industrial
Codes
include,
but
are
not
limited
to:
8399,
8221
and
8211.
The
Standard
Industrial
Code
for
all
respondents
under
EPA's
existing
ICR
(
OMB
Control
Number
2030­
0020)
is
919.

4(
b)
Information
Requested
Respondents
will
be
completing
and
submitting
the
proposed
questionnaire
(
Appendix
A)
along
with
requested
supporting
documentation.
The
information
requested
will
be
used
to
make
awards
to
non­
profit
organization
seeking
large
EPA
grants.

5.
The
Information
Collected
B
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
The
completed
questionnaire
will
be
analyzed
to
determine
the
administrative
capabilities
of
non­
profit
organizations
prior
to
awarding
EPA
grant
funds.
Current
plans
are
to
enter
questionnaire
responses
into
EPA's
Grantee
Compliance
Database
to
assist
in
both
tracking
grantee
performance
and
re­
certification
status.

5(
b)
Collection
Methodology
and
Management
Respondents
are
encouraged
to
use
the
internet
to
submit
both
completed
questionnaires
and
requested
supporting
documentation.
Naturally,
if
the
potential
applicants
do
not
have
internet
access
they
will
be
provided
EPA's
mailing
address
to
submit
responses
5(
c)
Small
Entity
Flexibility
Given
EPA's
regulations
and
the
need
for
this
pre­
award
information
(
consistent
across
potential
recipients)
there
is
simply
no
room
for
small
entity
flexibility.
Hopefully,
small
entities
will
benefit
from
EPA's
"
plain
language"
efforts
to
make
both
the
questionnaire
and
instructions
easier
to
understand.

5(
d)
Collection
Schedule
Responses
to
this
proposed
questionnaire
will
be
reviewed
in
accordance
with
the
requirements
of
40
CFR
part
30
B
Grants
and
Agreements
with
Institutions
of
Higher
Education,
Hospitals,
and
Other
Non­
profit
Organizations.
The
Agency
also
plans
to
conduct
periodic
onsite
reviews
to
ensure
recipient
compliance
with
applicable
requirements.
Recipients
will
be
required
to
retain
all
records
for
3
years
following
submission
of
the
Financial
Status
Report.
Current
plans
are
to
re­
certify
applicants
on
a
four
year
cycle.

6.
Estimating
The
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
One
hundred
(
100)
respondents
at
4
hours
each
equals
400
total
respondent
burden
hours.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
B
EPA
estimates
that
75%
of
these
4
hours
will
be
used
by
the
applicant
(
3
hours)
and
the
remaining
25%
by
secretarial/
administrative
staff
(
1
hour).
The
Agency
further
estimates
that
$
50.50
represents
the
average
hourly
wage
rate
of
several
nonprofit
applicant
professional
staff,
and
$
17.25
represents
the
average
hourly
wage
rate
for
two
non­
profit
administrative/
clerical
positions.

Therefore:
Professional
Wage
Rate
at
$
50.50
for
300
hours
equals
$
15,150.00,
and
Administrative/
Clerical
Wage
Rate
at
$
17.25
for
100
hours
equals
$
1,725.00
yielding
a
total
estimated
respondent
labor
cost
of
$
16,875.00.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs.
EPA
estimates
costs
at
$
0.00
(
iii)
Capital/
Start­
up
Operating
and
Maintenance
(
O&
M)
Costs.
EPA
estimates
start
up
and
maintenance
costs
at
$
0.00
(
iv)
Annualizing
Capital
Costs
Yielding
annual
total
capital
cost
of
$
0.00.
6(
c)
Estimating
Agency
Burden
and
Cost
The
agency
estimates
that
it
would
take
a
GS­
13
step
1
(
or
equivalent)
approximately
3
hours
to
analyze
and
enter
completed
responses
into
the
Grantee
Compliance
Database.
As
of
January
2004
EPA
Headquarter
GS­
13'
s
earned
$
72,108.00,
which
fully
burdened
of
benefits
(
X
36%)
would
add
$
25,958.88,
yielding
an
annual
total
of
$
98,066.88.
That
translate
to
an
hourly
rate
of
$
46.99.
Therefore
the
total
labor
cost
to
the
Agency
would
be
$
46.99
X
3
hours
X
100
responses
or
$
14,097.00.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
Agency
estimates
that
the
respondent
universe
for
this
data
collection
effort
will
be
non­
profit
organizations
seeking
EPA
grant
awards
of
more
than
$
200,000.
Judging
from
last
years
applicant
pool
this
would
be
approximately
100.
NOTE:
Situations
may
arise
where
it
would
be
desirable
to
apply
this
instrument
to
non­
profit
applicants
who
are
at
or
under
the
$
200,000
cut
off.
This
would
be
on
a
limited
case­
by­
case
basis
where
EPA
learns
of
significant
weaknesses/
deficiencies
that
could
compromise
a
non­
profit's
administrative
capability.
EPA
estimates
that
this
should
not
arise
in
more
than
20
non­
profit
organizations
over
the
first
year.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
B
Respondent
bottom
line
burden
hours
come
in
at
400
hours
which
costs
out
at
$
16,875.00.
(
ii)
The
Agency
Tally
B
Agency
bottom
line
burden
hours
come
in
at
300
hours
which
costs
out
at
$
14,097.00.

6(
f)
Reasons
for
Change
in
Burden
The
inclusion
of
this
proposed
data
collection
to
our
existing
Information
Collection
Request
(
OMB
control
number
2030­
0020
B
expiration
date;
12/
31/
2005)
would
increase
the
total
burden
hours
currently
at
176,169
by
400
hours
for
a
new
total
of
176,569.

6(
g)
Burden
Statement
The
annual
public
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average
4
hours
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
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
No.
OARM­
2004­
0001,
which
is
available
for
public
viewing
at
the
Office
of
Environmental
Information
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
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
Office
of
Environmental
Information
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.
(
OARM­
2004­
0001)
and
OMB
control
number
(
2030­
0020)
in
any
correspondence.
