1
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
Contractor
Cumulative
Claim
and
Reconciliation,
EPA
Form
1900­
10.
Information
Collection
Request
(
ICR)
0246.07,
OMB
Control
No.
2030­
0016.
The
current
ICR
expires
March
31,
2000.

(
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.
Each
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.
Only
EPA
personnel
and
auditors
form
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.
2
3.
THE
RESPONDENTS
AND
THE
INFORMATION
COLLECTED
(
a)
RESPONDENTS/
SIC
CODES
All
contractors
who
have
completed
an
EPA
cost
reimbursement
type
contract
will
be
required
to
submit
form
100­
10.
These
contractors
represent
a
wide
range
of
industries
which
include,
but
are
not
limited
to:
7371,
custom
computer
programming,
7392
Management
and
Consulting
Services,
8071
Medical
Laboratories,
and
8734,
Testing
Laboratories.

(
b)
INFORMATION
REQUESTED
(
I)
DATA
ITEMS
Data
requested
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.

(
ii)
RESPONDENT
ACTIVITIES
In
order
to
complete
the
form
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
contact
costs,
the
contractor
adds
the
cost
form
each
invoice
submitted
under
the
contract.
If
costs
were
claimed
on
an
invoice
that
were
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
incurred
for
each
cost
center.
This
information
is
also
contained
int
he
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
3
Once
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.

(
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
Booze,
Allen,
&
Hamilton
Mrs.
F.
Walls
(
202)
951­
2842
UP&
C
Catalytic
Mr.
P.
Gallagher
(
202)
422­
3555
Dynamic
Corp.
Ms.
T.
Ridenbaugh
(
301)
468­
2500
All
of
these
firms
have
recently
completed
a
cost
reimbursement
type
contract
with
EPA.
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
necessity
of
collecting
this
information
in
order
for
EPA
to
make
final
payment
under
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
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.
No
sensitive
information
is
requested.

(
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.

(
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
August
9,
1999,
64
FR
43177.
No
comments
were
received.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
(
a)
ESTIMATING
RESPONDENT
BURDEN
(
I)
Labor
Costs
The
annual
cost
to
respondents
is
estimated
at
$
1,151.15
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
15
minutes
$
28.50
$
7.13
2.
Compile
data
10
minutes
$
28.50
$
4.75
3.
Review
data
10
minutes
$
28.50
$
4.75
4.
Type
form
5
minutes
$
12.97
$
1.08
Total
40
minutes
$
17.71
A
contractor
employee,
comparable
in
position
to
a
Government
employee
at
the
GS­
12
grade
level,
would
be
required
to
gather,
compile,
and
review
the
data.
The
wage
rate
was
calculated
by
taking
the
GS
­
1
2
median
hourly
rate
($
24.57)
and
multiplying
it
by
a
factor
of
1.
16
to
account
for
benefits.
A
typist,
equivalent
to
a
Federal
GS­
05,
would
complete
the
actual
form.
The
wage
rate
for
a
typist
was
calculated
by
taking
the
GS­
05
median
hourly
rate
($
11.18)
and
multiplying
it
5
by
a
factor
of
1.
16
to
account
for
benefits.
EPA
processes
an
average
of
65
contract
closeouts
a
year
using
EPA
Form
1900­
10.
As
indicated
above,
each
form
takes
40
minutes,
or
.66
hours
to
complete.
The
65
yearly
actions,
multiplied
by
.66
equates
to
an
annual
hourly
burden
of
42.9
hours.
The
amount
of
time
required
to
complete
each
of
the
tasks
involved
in
completing
the
form
is
based
on
consultations
with
contractors
and
Agency
experience.
Most
firms
keep
all
financial
data
required
for
completion
of
this
form
in
a
computer
data
base.

(
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
int
he
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
$
10.00
per
action
for
a
total
annual
burden
of
$
650.00.
This
cost
will
not
be
recorded
on
the
OMB
83­
1
form
because
it
is
under
$
1,000.00
(
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
$
926.25
calculated
as
follows:

ACTIVITY
TIME
REQUIRED
RATE
COST
1.
Review
data
against
30
minutes
$
28.50
$
14.25
Agency
records
Generally,
the
individual
closing
out
the
contract
is
a
GS­
12
grade
level.
The
hourly
rate
for
a
GS­
12
is
calculated
as
described
in
paragraph
(
a)
above.
Also,
as
described
above,
65cases
per
year
were
used
to
calculate
Agency
burden.

(
c)
REASONS
FOR
CHANGE
IN
BURDEN
There
is
negligible
change
in
burden
since
the
last
clearance.
Respondent
burden
has
increased
by
$
17.55
from
$
1133.60
to
$
1151.15.
The
increase
is
due
solely
to
an
increase
in
labor
rates
over
the
past
three
years.
The
time
required
to
prepare
the
information
collection
and
the
number
of
information
collections
has
not
changed
since
the
last
clearance.
6
7.
BURDEN
STATEMENT
Public
reporting
for
this
collection
of
information
is
estimated
to
average
40
minutes
per
response
which
includes
the
time
for
reviewing
the
request,
searching
existing
data
sources,
gathering
and
maintaining
the
information
requested,
and
responding.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
401
M
St.,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

Burden
time
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,
to
develop,
acquire,
install
and
utilize
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
to
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
to
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
to
search
the
data
sources;
to
complete
and
review
the
collection
of
information;
and
to
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
number
for
EPA's
regulations
are
listed
in
40
CFR
Part
9,
and
48
CFR
Chapter
15.
