Office of Housing Counseling – Agency Performance Review
Revision of a currently approved collection
No
Regular
08/08/2023
Requested
Previously Approved
36 Months From Approved
08/31/2024
353
353
3,354
353
0
0
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.
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
This is a revision of a currently approved collection. OHC has made a correction to Item 13 on the OMB 83-I form. The total annual hours requested has increased from 353 to 3353.5 hours. The increase is a result of the time it takes to complete Part B and Part C of the form which not only requires responses to the question, but also the time it takes to gather and submit verification/documentation to support the agency’s response. The last collection did not take into account the time it takes to collect the documentation for the form.
OHC revised form HUD-9910 “Maintaining Approval Criteria” section in Part A to include two new questions: one that addresses the agency’s ongoing regulatory duty to screen for ineligible participants. This 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).
The first new question, line item #9 of the form HUD 9910, has been added to verify if the agency maintains policies to screen for ineligible participants, including agency’s directors, partners, officers, principals, or employees. Line item #9 of the form was inadvertently excluded from the last collection.
The second new question, line item #66a, addresses whether the counselors that provide housing counseling are HUD certified counselors as required by the Housing Counseling Certification Requirements Final Rule which was implemented in August 2021 as a result of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010, which amended Section 106 of the Housing and Urban Development Act of 1968.
Another question revised is question 55f which was an incomplete sentence that was missing information pertaining to an agency providing information on comparable products from at least 3 different lenders. The sentence is now complete with the added information.
In the last collection, 353 burden hours were reported. The new collection reports 3353.5 burden hours since the annual reporting hours per response has changed from 1 hour to 9.5 hours for a respondent to complete and return from HUD-9910. The last preparer did not consider the time it took to collect the documentation to support the agency responses. The form specifically requests the agency to submit verification/documentation of its responses.
Item 14 of the Supporting Statement has also changed. The annual cost to the Federal Government has increased due to the increase in the 2022 salaries on the GS Pay Scale.
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.
$3,412,401
No
No
No
No
No
No
No
Teri Ames 202 402-3025
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form HUD 9910 Office of Housing Counseling – Agency Performance Review
2502-0574 30 day.pdf
Support Statement A 2502-0574,.docx
Office of Housing Counseling – Agency Performance Review