1
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
Information
Collection
Request
(
ICR)
1039.09,
OMB
Control
No.
2030­
0005,
covers
an
Agency
requirement
for
contractors
to
submit
technical
and
financial
progress
reports
under
cost
reimbursement,
indefinite
quantity,
time
and
material,
and
labor
hour
types
of
contracts.
The
information
collection
is
entitled:
Monthly
Progress
Reports,
Submission
of
Invoices,
and
Related
Information.
The
current
ICR
expires
on
February
28,
2003.

(
b)
SHORT
CHARACTERIZATION
Appropriate
Government
surveillance
of
contractor
performance
is
required
to
give
reasonable
assurance
that
efficient
methods
and
effective
cost
controls
are
being
used
for
various
cost
reimbursable
and
fixed
rate
contracts.

On
a
monthly
basis,
the
Agency
requires
contractors
to
provide
the
Project
Officer
with
a
report
detailing
(
a)
what
was
accomplished
on
the
contract
during
that
period,
(
b)
what
remains
to
be
done,
and
(
c)
expenditures
for
the
same
period
of
time.
This
allows
the
Project
Officer
to
monitor
the
efficiency
and
cost
effectiveness
of
the
work
being
performed.
These
progress
reports
become
part
of
the
contract
file.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
FAR
16.301­
3(
b)
and
16.601(
b)(
1)
require
that
cost­
reimbursement,
time
and
material
and
labor
hour
contracts
be
monitored
in
terms
of
financial
and
technical
efficiency.
Environmental
Protection
Agency
Acquisition
Regulation
(
EPAAR)
1511.011­
72
prescribes
the
clause
for
progress
reports
which
is
used
for
these
types
of
contracts.
EPAAR
clause
1552.211­
72,
Monthly
Progress
Report,
provides
the
specific
requirements
of
the
report.

(
b)
USE/
USERS
OF
THE
DATA
Progress
reports
will
be
used
by
the
Project
Officer
to
monitor
the
contractor's
progress
under
a
specific
contract.
If
problems
with
the
contractor's
performance
arise,
the
Contracting
Officer
may
also
review
the
progress
reports
to
determine
what
action
may
need
to
be
taken.

3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
(
a)
RESPONDENTS/
NORTH
AMERICAN
INDUSTRY
CLASSIFICATION
SYSTEM
2
(
NAICS)
CODES
The
majority
of
respondents
fall
into
one
of
the
following
NAICS
codes:
511210
for
prepackaged
computer
software,
541511
for
computer
processing
services,
541710
for
computer­
related
services,
or
339
for
miscellaneous
services.

(
b)
INFORMATION
REQUESTED
Under
this
ICR,
respondents
will
be
required
to
provide
the
following
information:

­
Progress
made
during
the
reporting
period
including
percent
of
project
completed,
description
of
the
action
of
work
accomplished,
and
a
schedule
of
deliverables
for
the
reporting
period;

­
Specific
discussions
of
difficulties
encountered
and
remedial
action
taken
during
the
reporting
period
and
anticipated
activity
during
the
subsequent
reporting
period;

­
A
list
of
outstanding
actions
awaiting
the
Contracting
Officer's
authorization;

­
Cumulative
costs
at
the
contract
level
for:
the
amount
claimed
for
the
current
reporting
period,
the
amount
obligated,
originally
invoiced,
paid,
suspended,
disallowed
and
remaining
approved
for
the
cumulative
period
and
contract
life;

­
Labor
hours
consisting
of
a
list
of
employees,
their
labor
categories,
and
the
number
of
hours
worked;

­
Labor
hours
expended
and
direct
labor
hours
and
costs
detailed
for
the
current
reporting
period.

­
Labor
hours
negotiated,
expended
and
remaining,
and
labor
hours
and
costs
detailed
for
the
cumulative
contract
period
and
cumulative
contract
life.

­
The
estimated
labor
hours
and
costs
to
be
expended
during
the
next
reporting
period.

­
The
current
dollar
ceilings,
net
amount
invoiced
and
remaining
amounts
in
several
categories.

­
Unbilled
allowable
costs
for
the
current
reporting
period
and
cumulative
for
the
contract.

­
Actual
average
direct
labor
costs
compared
with
the
negotiated
average
for
the
current
contract
period.

­
Similar
financial
status
information
to
that
already
outlined,
but
at
the
work
assignment
3
level
or
delivery
order
level.

4.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY
AND
INFORMATION
MANAGEMENT
(
a)
AGENCY
ACTIVITIES
Once
the
information
is
received
by
the
Agency,
it
is
reviewed
by
the
Project
Officer
against
existing
financial
data,
contractor
deliverables
and
agency
records
for
verification.
If
no
discrepancies
are
noted,
the
report
is
placed
in
the
contract
file.

(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
Many
respondents
prepare
their
reports
by
computer.
Software
programs
are
available
which
easily
track
financial
data.
Submissions
are
accepted
in
any
format
so
long
as
the
required
data
is
provided.
Various
software
programs
are
used
by
the
Agency
to
monitor
contractor
activity
under
contracts
requiring
progress
reports.

(
c)
SMALL
BUSINESS
FLEXIBILITY
Only
the
minimum
information
necessary
to
ensure
the
contractor
is
performing
in
a
technically
effective
and
cost
efficient
manner
is
required.
Because
the
information
requested
is
vital
to
the
effective
monitoring
of
Agency
contracts,
separate
or
simplified
procedures
cannot
be
developed
for
small
businesses.

(
d)
COLLECTION
SCHEDULE
Most
contractors
invoice
once
a
month
under
service
contracts.
Progress
reports
are
required
on
a
monthly
basis
so
that
charges
on
the
invoice
can
be
reconciled
with
financial
and
technical
information
provided
in
the
report.

5.
NONDUPLICATION,
CONSULTATION
AND
OTHER
COLLECTION
CRITERIA
(
a)
NONDUPLICATION
Monthly
progress
reports
are
unique
to
each
individual
contract.
Information
concerning
the
financial
and
technical
progress
of
a
contractor
under
a
specific
contract
is
not
available
from
any
other
source.

(
b)
CONSULTATIONS
For
this
ICR
action,
the
following
firms
and
individuals,
which
currently
have
a
significant
number
of
contracts
with
the
Agency,
were
called
to
discuss
the
use
of
and
the
amount
of
time
it
4
takes
to
complete
the
information
request:

Name
Affiliation
Phone
Ms.
Brenda
Smith
Techlaw
(
703)
818­
3000
Mr.
Richard
Grazioli
Lockheed
Martin
(
732)
225­
4931
Mr.
Jack
Sulima
Gannet
Fleming
(
404)
522­
1381
ext.
117
Individuals
consulted
indicated
the
information
requested
is
readily
available.
The
individuals
consulted
indicated
that
they
understood
the
need
for
the
information
collection
and
did
not
find
the
collection
excessively
burdensome.
Estimated
time
to
complete
the
information
collection
was
considered
in
"
Respondent
Burden
Estimate."

(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
Most
EPA
contracts
involve
complex
services
requiring
numerous
contractor
employees
and
extensive
funding.
It
is
imperative
that
the
Agency
be
aware
of
the
actions
the
contractor
is
taking
and
the
amount
of
funding
expended
on
a
monthly
basis.
Less
frequent
collection
would
jeopardize
the
Agency's
ability
to
determine
the
reasonableness
of
costs
and
to
take
timely
action
in
the
event
of
technical
or
cost
problems
under
its
contracts.

(
d)
GENERAL
GUIDELINES
This
information
collection
follows
OMB's
general
guidelines
with
the
exception
of
requiring
the
same
information
from
small
entities
as
other
respondents
and
requiring
the
information
to
be
submitted
more
often
than
quarterly.
Monthly
progress
reports
are
mandatory
for
those
holding
Agency
contracts
with
reporting
requirements.

Progress
reports
are
required
on
a
monthly
basis.
Contracts
requiring
progress
reports
generally
run
from
three
to
five
years.
Most
contractors
invoice
once
a
month
under
these
contracts.
By
submitting
the
progress
report
with
the
invoice
the
contractor
gives
the
Project
Officer,
who
is
responsible
for
monitoring
the
contract,
an
opportunity
to
review
the
financial
information
contained
in
the
progress
report,
and
compare
it
to
the
invoice.
Monthly
review
of
this
information
allows
the
Agency
to
promptly
note
when
performance
or
cost
problems
arise
and
take
immediate
action.

This
information
is
required
because
of
the
complex
nature
of
the
contracts
used.
Every
contractor,
even
small
entities,
must
provide
the
information
in
order
for
the
Agency
to
adequately
monitor
the
contracts.

(
e)
Information
collected
under
this
request,
particularly
cost
and
pricing
data,
is
treated
as
Confidential
Business
Information
(
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.
5
(
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
was
published
on
07/
26/
2002,
64
FR
43177.
No
comments
were
received.

6.
ESTIMATING
THE
BURDEN
AND
THE
COST
OF
THE
COLLECTION
(
a)
ESTIMATING
RESPONDENT
BURDEN
(
i)
Labor
Costs
Respondent
burden
is
based
on
historical
data
and
figures
provided
during
the
consultations
referred
to
in
paragraph
5(
b).
Collection
activity
hours
have
decreased
slightly
since
last
clearance
received,
due
mainly
to
improved
tracking
software,
and
increasing
familiarity
with
EPA
reporting
requirements.

Collection
Activity
Hours
Per
Month
Rate
Cost
1.
Gather
information
23.00
$
90.23
$
2,075.29
2.
Compile
and
Process
13.25
$
44.56
$
590.42
information
TOTALS
36.25
$
2,665.71
In
most
instances,
it
is
the
contractor's
project
manager
who
manages
effort
under
the
contract
and
ultimately
prepares
the
progress
report.
The
information
gathering
is
performed
by
the
assistant
project
manager.
Compilation
and
information
processing
is
performed
by
a
data
entry
clerk.
EPA's
Cost
Advisory
and
Financial
Analysis
Division
estimates
the
loaded
rate
for
an
assistant
project
manager
to
be
$
90.23
per
hour
and
the
loaded
rate
for
a
data
entry
clerk
to
be
$
44.56
per
hour.
These
figures
are
consistent
with
current
rates
paid
under
Agency
contracts.

EPA
currently
has
324
active
contracts
of
the
type
which
require
progress
reports.
These
324
contracts
each
require
a
monthly
progress
report
(
324
contracts
x
12
months
each
=
3,888
responses).
Respondents
take
36.25
hours
per
month
to
complete
each
response.
Therefore,
total
burden
for
one
year
is
140,940
hours.
The
annual
cost
to
respondents
based
on
the
figures
shown
above
is
$
10,364,280
($
2,665.71
per
response
x
3,888
responses).
Contractors
are
reimbursed
for
these
costs
under
the
applicable
contract.

(
ii)
Capital/
Start­
up
Costs
Because
it
will
not
be
necessary
for
respondents
to
acquire
any
capital
goods
to
provide
the
requested
information,
EPA
has
not
estimated
any
capital/
start­
up
costs.

(
iii)
Operating
and
Maintenance
Costs
6
Operating
and
maintenance
costs
consist
of
postage
and
photocopying,
are
estimated
at
$
10.00
per
response
x
3,888
responses
=
$
38,880.00.

(
b)
ESTIMATED
AGENCY
BURDEN
AND
COST
Agency
burden
estimates
were
developed
by
procurement
personnel
who
work
with
the
types
of
contracts
addressed
in
this
clearance.
On
the
average,
the
same
amount
of
time
is
required
to
review
the
data
for
each
type
of
contract.
Progress
reports
are
reviewed
by
the
Agency
Project
Officer
and
Contracting
Officer
responsible
for
the
contract.
Agency
burden
is
calculated
as
follows:

Collection
Activity
Hours
Per
Month
Rate
Cost
Audit/
review
data
submissions
2
$
30.00
$
60.00
Burden
hours
for
the
contracting
officer
and
the
project
officer
are
combined
for
a
total
of
two
(
2)
hours.
Calculations
are
based
on
both
these
individuals
being
GS­
13s.
Estimate
includes
GS­
13
salary
at
$
31.84
per
hour,
multiplied
by
a
factor
of
1.16
to
reflect
benefits,
which
yields
a
loaded
rate
of
$
36.93.
Therefore,
total
annual
agency
burden
is
summarized
as
follows:
Total
burden
hours:
3,888
responses
x
two
hours
per
response
=
7,776
hours.
Total
burden
costs:
$
60.00
per
response
x
3,888
responses
=
$
233,280.

(
c)
REASONS
FOR
CHANGE
IN
BURDEN
In
the
last
OMB
clearance,
respondent
burden
was
estimated
at
177,045
hours.
The
current
estimate
is
140,940
hours
for
an
overall
decrease
of
36,105
hours.
A
comparison
of
the
last
OMB
approval
and
the
present
request
is
presented
below:

Prior
Approval
Present
Request
407
contracts
324
contracts
4,884
responses
3,888
responses
36.25
hours
per
response
36.25
hours
per
response
The
total
number
of
contracts
and
corresponding
responses
have
decreased
since
the
previous
approval,
resulting
in
an
overall
decrease
in
burden
cost.

7.
BURDEN
STATEMENT
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
36.25
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,
7
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.

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.
OEI­
2002­
0012,
which
is
available
for
public
viewing
at
the
Office
of
Environmental
Information
(
OEI)
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
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.
OEI­
2002­
0012
and
OMB
Control
Number
2030­
0005
in
any
correspondence.
