                             SUPPORTING STATEMENT
                                       
Title:  General Administrative Requirements for Assistance Programs (OMB Control Number 2030-0020; EPA ICR No. 0938.23).  

1.  Necessity of Collection 	

This is a request for a renewal of an existing Information Collection Request (ICR). This ICR authorizes the collection of information under EPA's General Regulation for Assistance Programs that establishes the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements).  For awards made prior to December 26, 2014, 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. For awards made prior to December 26, 2014, 40 CFR Part 31, "Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments," includes the management requirements for States, local governments, and Indian Tribal governments. These regulations include only those provisions mandated by statute, required by Office of Management and Budget (OMB) Circulars, or added by EPA to ensure sound and effective financial assistance management. For awards made on or after December 26, 2014, 2 CFR 200 and EPA's implementation of 2 CFR 200 at 2 CFR 1500 "Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards" establishes the management requirements for all entity types. 40 CFR Part 35 outlines policies and procedures for assistance agreements to State, interstate, and local agencies and Indian Tribes and Intertribal Consortia for pollution abatement and control programs (listed in Subparts A and B). For all awards, 40 CFR Part 33 "Participation by Disadvantaged Business Enterprises in Procurement under Environmental Protection Agency (EPA) Financial Assistance Agreements" establishes DBE utilization requirements for all entity types. These regulations include only those provisions mandated by statute or added by EPA to ensure sound and effective financial assistance management with respect to DBE utilization.

This ICR combines all of these requirements under OMB Control Number 2030-0020.  
      
EPA award officials will use the information required by these regulations to make assistance agreement awards, to make assistance payments, and to verify that the recipient is using Federal funds appropriately to comply with Federal requirements.

This ICR is necessary because of the information collection and reporting requirements included in EPA regulations at 40 CFR Parts 30, 31, 33, 35, and 2 CFR Parts 200 and 1500. For some existing grants awarded prior to December 26, 2014, 40 CFR Parts 30 and 31 implement OMB Circulars A-21, A-87, A-102, A-110, A-122, and A-133. For assistance agreements awarded on or after December 26, 2014, 2 CFR Part 1500 implements OMB regulations in 2 CFR Part 200. For all awards, 40 CFR Part 33 establishes DBE utilization requirements for all entity types. These regulations include only those provisions mandated by statute or added by EPA to ensure sound and effective financial assistance management with respect to DBE utilization. These regulations set forth pre-award, post-award, and after-the-grant requirements. This information is needed by EPA project officers, grant specialists, DBE coordinators, and finance officials to manage/oversee recipient programmatic and financial performance under all EPA assistance agreements.

2.   How, By Whom, and For What Information is Collected

The pre-award information is used by EPA to qualify and select assistance agreement applicants for funding. The post-award information is used to ensure that recipients are complying with statutory and regulatory requirements and to monitor recipient performance. The after-the-grant information is used to meet reporting and recordkeeping requirements and to close out awards. The information is necessary to ensure minimum fiscal control and accountability for EPA funds and to deter waste, fraud, and abuse.

The primary recipients of EPA assistance agreements are State and local governments, Indian Tribes, educational institutions, and not-for-profit institutions. The information requested is used to make awards, pay recipients, and collect information on how Federal funds are being spent.

Standard Industrial Classification Codes for respondents include 8211, 8221, 8399, and 919. The corresponding North American Industry Classification System (NAICS) Codes for respondents include, but are not limited to, 61111, 61131, 813212, 813219, 813311, 813312, 813319 and 92119.

3. Electronic Submission

Grants.gov, originally called the E Grants Initiative, was a mandate of the President's Fiscal Year 2002 Management Agenda, which directed agencies to "...allow applicants for Federal Grants to apply for and ultimately manage grant funds online through a common Web site, simplifying grants management and eliminating redundancies."

Grants.gov implements the requirement in the Federal Financial Assistance Management Improvement Act, Public Law 106 107, to develop a simple, unified source to electronically find, apply, and manage grant opportunities. Grants.gov is the central Federal electronic portal created in response to the Act.  

Grants.gov Workspace allows an applicant to create an application package from an opportunity posted on Grants.gov. The applicant can complete the application within Workspace or download the application forms and complete the package offline based on agency instructions. The application package generally includes a standard set of OMB approved forms. After an applicant completes the required application package, they can be submitted electronically to Grants.gov, which transmits the application to the funding agency.

The Office of Grants and Debarment has constructed an electronic repository for Pre-Award activities within the Agency's Next Generation Grants System (NGGS) which receives, as the funding agency, the applications data and stores them for program retrieval and review. As applications are selected for funding, the data will be migrated and processed through other downstream activities within NGGS for eventual award.

EPA requires the use of Grants.gov as the EPA standard for the submission of initial applications for competitive and non-competitive assistance agreement awards.

4. Non-duplication, Consultations, and Other Collection Criteria

There is no other source for this information.    

5. Impact on Small Businesses

EPA believes the reporting requirements discussed in this ICR do not place an unreasonable burden on small entities; the estimated burdens cannot be further reduced for small entities. EPA requires the information requested to make award decisions, properly manage assistance agreements, maintain records, and monitor performance. This requested information may, in some cases, be dependent on the type of entity (e.g., state agency, non-profit organization, individual, etc.) but is not dependent on an entity's relative size. EPA takes active steps to minimize the burden on small entities in the form of guidance materials and electronic forms. In most cases, the requirements do not impose a large burden on small entities because the information required is simple and straightforward.

6. Consequences of Non-Collection or Less Frequent Collection

Without the data compiled by using the forms, it would be impossible for EPA to manage any of its Federal assistance programs.  Rational, fair grant awards would be extremely difficult to make, and financial and technical managerial information would not be available for assessing the status of grant efforts. Decreasing the frequency of data collection would have similar negative impacts. The effect of less frequent collection is that EPA would be unable to comply with OMB or statutory requirements for assistance agreements.

7. Special Reporting Requirements

The information collection is consistent with the guidelines set forth in 5 CFR 1320.6 of the Paperwork Reduction Act Guidelines. There are no known special circumstances that would require reporting on an alternative timeline or methodology.

In 1996, the regulations of Part 30 were revised to reflect "plain English." Since then, EPA has continued to use plain English. As a result, EPA's assistance agreement regulations and other documents are easier to understand by all organizations, large and small. The information collection is consistent with 5 CFR 1320.5(d)(2).

8. 60-Day FR Notice and Efforts to Consult with Grantees

*THIS CONTENT WILL BE UPDATED AFTER THE PUBLICATION OF THE 1ST FEDERAL REGISTER NOTICE.*

Consultations: We have received continuous feedback from applicants and recipients about this information collection.  Administering EPA assistance agreements requires constant recipient contact, such as written correspondence, telephone calls, and in-person meetings.  OGD is both sensitive and responsive to recipients regarding burden, duplication, availability of data, clarity of instructions, and other concerns that are raised. OGD improves EPA assistance agreement forms and collection methods in an effort to address recipient concerns and streamline their activities.  Frequent applicant and recipient feedback and informal consultations are a significant component of the evaluation of EPA assistance agreement forms, and these contacts have been particularly useful in developing burden estimates. 

The purpose of this ICR is to request clearance for EPA assistance agreement forms that are used by respondents on a regular basis and made publicly available in several different locations (e.g., various websites) in both electronic and hardcopy format.  To evaluate the accuracy of its burden estimates, EPA consulted with the following assistance agreement recipient organizations:
 
*THE LIST OF RECIPIENT ORGANIZATIONS WHO WERE CONTACTED WILL BE ADDED AFTER CONSULTATIONS ARE CONDUCTED IN THE SUMMER/FALL OF 2023.*  

9. Payment or Gift to Respondents

Successful applicants receive an award of federal financial assistance.

10. Assurance of Confidentiality

All information submitted to the agency in response to the ICR will be managed in accordance with applicable laws and EPA's regulations governing treatment of confidential business information at 40 CFR Part 2, Subpart B. Any information determined to constitute a trade secret will be protected under 18 U.S.C. § 1905.

11. Questions of Sensitive Nature

Sensitive questions are not associated with the information collection activities performed under Public Law 107-118.

12. Hour Burden 


*EPA IS COMPILING RECENT STATISTICS TO PREPARE AN UPDATED ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE AND BURDEN HOURS FOR EACH REQUIREMENT.*   


13. Estimate for total annual cost burden (not including hour burden)


* EPA IS COMPILING RECENT STATISTICS TO PREPARE AN UPDATED ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE AND BURDEN HOURS FOR EACH REQUIREMENT. EPA WILL UPDATE THE TOTAL ANNUAL COST BURDEN AFTER THE NEW ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE AND BURDEN HOURS FOR EACH REQUIREMENT IS DETERMINED.*   




14. Annualized Costs to the Federal Government


* EPA IS COMPILING RECENT STATISTICS TO PREPARE AN UPDATED ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE AND BURDEN HOURS FOR EACH REQUIREMENT.  EPA WILL UPDATE THE ANNUALIZED COSTS TO THE FEDERAL GOVERNMENT AFTER THE NEW ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE AND BURDEN HOURS FOR EACH REQUIREMENT IS DETERMINED.*   


15. Reasons for Program Changes or Adjustments on Burden Worksheet

 * EPA IS IN THE PROCESS OF UPDATING THE REASONS FOR CHANGE IN BURDEN AND BURDEN STATEMENT BASED ON IDENTIFIED PROGRAM CHANGES AND BURDEN ADJUSTMENTS.*  
 
16. Published Results

Results from this ICR are not published formally. They are used to calculate agency-level accomplishments and site-specific impacts on publicly available EPA websites.

17. Approval for not displaying OMB Expiration Date

N/A

18. Exceptions to the "Certification for Paperwork Reduction Act Submissions"

N/A

                                  APPENDIX A

              Annual Estimate of EPA Assistance Agreement Awards

* EPA IS COMPILING RECENT STATISTICS TO PREPARE AN UPDATED ESTIMATE OF RESPONDENTS BY APPLICATION/AWARD TYPE.*   

                              Type of Information
                             Number of Respondents
Competed Grants

                                       


                                       
Not Competed Grant Awards
                                       
Fellowship Applications
                                       
                              TOTAL
                                       




                                  APPENDIX B

                         Forms Covered Under this ICR
                                       
* EPA IS IN THE PROCESS OF REVIEWING THE LIST OF FORMS AND REQUIREMENTS BELOW TO IDENTIFY POTENTIAL UPDATES BASED ON PROGRAM CHANGES.*   


