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OMB Control No: 2502-0574	ICR Reference No: 202101-2502-002
Status: Historical Active	Previous ICR Reference No: 201705-2502-007
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: Office of Housing Counseling – Agency Performance Review
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 08/03/2021
	Date Received in OIRA: 02/23/2021
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	08/31/2024	36 Months From Approved	08/31/2021
Responses	353	0	455
Time Burden (Hours)	353	0	4,323
Cost Burden (Dollars)	0	0	0

Abstract: HUD-approved agencies are non-profit and government organizations that provide housing services. The information collected allows HUD to monitor and provide oversight for agencies approved to participate in the Housing Counseling Program. Specifically, the information collected is used to ensure that participating agencies comply with program policies and regulations and to determine if agencies remain eligible to maintain an approval status. Housing counseling aids tenants and homeowners in improving their housing conditions and in meeting the responsibilities of tenancy and homeownership.

Authorizing Statute(s): US Code: 12 USC 1701x Name of Law: Housing and Urban Development Act of 1968
US Code: 12 USC 1701w Name of Law: Housing and Urban Development Act of 1968

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 81945	12/17/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	86 FR 10993	02/23/2021
Did the Agency receive public comments on this ICR? No

Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Office of Housing Counseling – Agency Performance Review	HUD 9910
Office of Housing Counseling – Agency Performance Review	HUD 9910

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	353	455	-102
Annual Time Burden (Hours)	353	4,323	-3,970
Annual Cost Burden (Dollars)	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: This is a revision of a currently approved collection, however, OHC requests renaming this collection to “Office of Housing Counseling - Agency Performance Review.” The removal of the word “biennial” from the title is because the timing of an agency’s performance review is based on a risk rating model. As such, the lower the risk, the longer the HCA’s HUD approval is in effect. First, OHC revised the “Grant Management” section to include questions required under 2 CFR Part 200, Subpart E and to eliminate redundancies, outdated references, questions irrelevant to grant analysis, or where verification was impractical. The revisions reduced the number of questions in the “Grant Management” section by half—from twelve to six, while simultaneously strengthening analysis of grant expenses and ensuring proper and consistent application of uniform grant procedures. Second, OHC revised form HUD-9910 “Maintaining Approval Criteria” section in Part A to include a question that addresses the agency’s ongoing regulatory duty to screen for ineligible participants. The new question asks the reviewer to verify whether the agency maintains policies to screen for ineligible participants. Including this question resolves a key OIG recommendation to clarify the documentation to be produced during a performance review to demonstrate compliance with 24 CFR 214.103(c). For the present renewal, OHC has made a correction to form HUD-9910. Line item #82 used to give the respondent the option of replying Yes, No, or N/A. Underneath line item #82, however, were items a-d where the respondent answered line item #82. Thus, the Yes, No, and N/A boxes were “blacked out” specifically online item #82, which is now line item #77 on the revised form HUD-9910. This collection has rectified those inaccuracies by obtaining the most current data and computing the tables accurately so they comport with OMB’s Supporting Statement requirements. The previous responses were 455, which has been decreased to 353 respondents. The decrease of 102 responses is the result of two factors: first, there has been a decrease in the total number of HCAs since the last collection, and secondly, the most current data has been utilized to complete the table. There has also been a significant decrease in the burden hours per response. In the last collection, 4,323 burden hours were reported. The new collection reports 353 burden hours since the annual reporting hours per response has changed from 9.5 hours to 1 hour for a respondent to complete and return form HUD-9910. OHC believes that the misunderstanding of the last preparer contributed to this difference. As previously mentioned in Sections 3 and 8, plans are underway to further streamline form HUD-9910 and fully automate it in a new HUD system called HCAMS, HUD system P301, which has been in development for several years. A new module has been created that will replace the paper form HUD-9910 and enable HCAs to complete the form on-line, thus further reducing the reporting burden. The module has just completed the final testing phase. Once OMB 2502-0574 (this collection) has been approved by OMB, then a new PRA collection will be submitted for the agency performance review module which will be the first module to be activated in the HCAMS system.

Annual Cost to Federal Government: $3,279,655

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

Agency Contact: Colleen Weiser 202 275-6288 colleen.a.weiser@hud.gov

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