  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

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.  

THE RESPONDENTS AND THE INFORMATION REQUESTED

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

	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.


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.

(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 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).

(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 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. 

EPA Form 1900-10 (Rev. 3-06)

Previous Edition is Obsolete

          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





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

Paperwork Reduction Project (OMB No. 2030-0016)

Office of Information and Regulatory Affairs

Office of Management and Budget

Washington, DC 20503.

Office of Information and Regulatory Affairs, Office of Management and
Budget, Washington, D.C.  200503.



	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.



 PAGE   

  PAGE   9 

		Attachment A

 

