When an agency wishes to collect information from 10 or more people, it must follow steps outlined in the Paperwork Reduction Act (PRA) and the implementing regulations for the PRA.1 An agency must publish a notice in the Federal Register and provide 60 days for public comment on the information collection request. After the comment period, the agency submits the information collection request to the Office of Information and Regulatory Affairs [OIRA, a part of the White House Office of Management and Budget (OMB)] with a supporting statement.2 Concurrent with this submission, the agency publishes a second notice in the Federal Register asking the public to submit any comments on the information collection to OMB. After waiting 30 days for public comments, OIRA has an additional 30 days within which to approve or disapprove the information collection. The agency must seek re-approval (and repeat the entire process) of all information collections every 3 years (or sooner as required by OMB).
As part of the information collection request process, the agency must calculate the burden of the information collection and demonstrate its “practical utility.” The standards for information collection are found at 44 U.S.C.3 § 3506(c)(3)(A). Each agency must certify that the information collection, “is necessary for the proper performance of the functions of the agency, including that the information has practical utility and that its efforts, “reduce(s) to the extent practicable and appropriate the burden on persons who shall provide information to or for the agency.”4 OIRA must “minimize the Federal information collection burden, with particular emphasis on those individuals and entities most adverse-
1Controlling Paperwork Burdens on the Public, 5 CFR 1320 (2010).
2The supporting statement must include answers to 18 questions. For collections of information collections employing statistical methods, an additional five questions must be answered. The questions and cover sheet may be found at http://www.whitehouse.gov/sites/default/files/omb/inforeg/83i-fill.pdf.
3United States Code. The U.S. Code is a consolidation and codification by subject matter of the general and permanent laws of the United States.
4See Federal Agency Responsibilities, 44 U.S.C.§ 3506(c)(3)(C).
ly affected,” and “maximize the practical utility of and public benefit from information collected by or for the Federal Government.”5
APPROVAL OF AGENCY GRANT APPLICATION FORMS
National Institutes of Health
National Institutes of Health (NIH) grant application forms are approved by OMB under OMB Number 0925-0001. Burden hours to complete the documents are estimated by NIH in Table F-1.
The agency also specifies the cost associated with this burden using a dollar value of $35/hour (this implies the agency assumes that much of the information collection is performed by administrative personnel).
NIH is also listed as one of the users of grants.gov form SF-424 (Application for Federal Assistance). The OMB Number is 4040-0001 for the basic form and 4040-0004 for supplemental information (each form is approved separately by OMB). The online grants.gov approvals are approved for 1 hour per application. The physical version of the primary form lists the burden as varying by agency [(from 15 minutes for the U.S. Agency for International Development to 4.4 hours for the Department of Health and Human Services (HHS)]. The physical version of the supplemental form lists the burden as varying from 1.07 hours [Department of Defense (DOD)] to 120 hours [National Science Foundation (NSF) and the Department of Homeland Security (DHS)]. HHS lists burden hours as 58 hours.
It is unclear how this 58-hour estimate (or the 4.4-hour estimate for completing the SF-424 for HHS grants) relates to the 24-hour estimate approved for HHS by OMB or whether HHS has OMB approval for this estimate.
National Science Foundation
NSF grant application forms are approved by OMB under OMB Number 3145-0058. NSF estimates that applicants expend an average of approximately 120 burden hours for each proposal submitted. NSF expects to receive approximately 51,600 proposals in FY 2015, which would result in a total of 6,192,000 burden hours.
This is the extent of the detail that NSF provides on its estimates. The agency does not monetize its estimate.
For NSF, the 120-hour estimate matches the approved burden estimate for form SF-424 that appears on grants.gov.
5See Federal Agency Responsibilities, 44 U.S.C.§ 3505(c).
|Estimates of Hour Burden|
|Information Collection Number or Form||Number of Respondents||Frequency of Response||Average Time (hours) Per Response||Annual Burden Hours|
|PHS 398 [paper]||8,389||1||35||293,615|
PHS 398 [electronic]
SOURCE: Courtesy of Stuart Shapiro.
Other agencies rely, in part, on the grants.gov approval for their PRA approval. However, it appears that there is variation amongst agencies with regard to the approval of supplemental materials. For example, the Department of Energy requires a “budget justification” for its grants. Under OMB Number 1910-5162, the agency has approval for 24 burden hours. However, the actual supplemental burden for form SF-424 is listed as 1.5 hours. It is unclear whether these numbers refer to different things.
On form SF-424, DOD burden hours are listed as only 1.07 hours. However, DOD grant websites contain numerous DOD forms that do not have OMB Numbers on them,6 suggesting that these forms have not been approved for information collection by OMB as required by the PRA.
6For example, the Office of Naval Research, Science, and Technology website, http://www.onr.navy.mil/Contracts-Grants/submit-proposal/contracts-proposal/cost-proposal.aspx or the Army Research Laboratory website, http://www.arl.army.mil/www/default.cfm?page=218.
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