Overview
Title
60-Day Notice of Proposed Information Collection: Public Housing Contracting With Resident-Owned Business/Application Requirements
Agencies
ELI5 AI
The Department of Housing and Urban Development wants to know what people think about their plan for how public housing groups work with businesses owned by the people living there. They're asking if what they're doing is helpful and how they can make it better without making it too hard for anyone.
Summary AI
The Department of Housing and Urban Development (HUD) is seeking approval from the Office of Management and Budget (OMB) for collecting information about public housing agencies contracting with resident-owned businesses. This document outlines the need for public comment over a period of 60 days regarding these information collection procedures. HUD wants feedback on whether the information collection is necessary, the accuracy of the estimated burden, and ways to improve the process while reducing the burden. The notice also details compliance requirements for contracts with resident-owned businesses and the associated costs in terms of hours and financial impact on public housing agency staff.
Abstract
HUD is seeking approval from the Office of Management and Budget (OMB) for the information collection described below. In accordance with the Paperwork Reduction Act, HUD is requesting comment from all interested parties on the proposed collection of information. The purpose of this notice is to allow for 60 days of public comment.
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Sources
AnalysisAI
The document, titled "60-Day Notice of Proposed Information Collection: Public Housing Contracting With Resident-Owned Business/Application Requirements," is a formal notice published by the Department of Housing and Urban Development (HUD). This notice informs the public about HUD's intent to seek approval from the Office of Management and Budget (OMB) for collecting information related to public housing agencies (PHAs) entering contracts with resident-owned businesses. The document invites public comment over a 60-day period, which ends on March 26, 2021.
General Summary
The primary goal of this notice is to inform and involve the public regarding HUD's efforts to collect specific information on contracting procedures between PHAs and resident-owned businesses. Such collections are often routine, aiming to ensure compliance and improve processes while fulfilling regulatory requirements. From a practical standpoint, HUD seeks public input to determine the necessity and efficiency of this information collection, the burden it places on agencies, and ways to enhance its overall utility.
Significant Issues and Concerns
A few significant issues warrant attention. Firstly, the document estimates that 76 PHAs are respondents to the collection process, derived from approximately 2% of 3,775 total PHAs. However, the document lacks a comprehensive explanation of how this percentage was calculated or whether it accurately represents the participation landscape.
The cost estimation provided for conducting the information collection is $43,776, based on PHA staff salaries. Yet, this figure assumes a uniform wage rate without accounting for regional variations. Salaries may significantly differ across various regions, thus potentially undermining the estimate's accuracy.
Additionally, the text briefly mentions that a number of PHAs have opted to leave the program but does not explore the reasons or implications of these departures. This gap in discussion could be important, as the loss of participants might influence the program's effectiveness or financial viability.
Public Impact
Broadly, the document serves as a regulatory oversight mechanism to ensure that PHAs and resident-owned businesses comply with federal housing regulations. It aims to standardize and improve contract processes to better manage public housing resources.
However, the complexity of the regulatory language and references could alienate or confuse members of the public who might wish to contribute to the consultation process. Simplifying these elements could encourage broader participation and more meaningful feedback.
Impact on Stakeholders
For public housing agencies, compliance with these collection processes involves administrative work and financial costs, estimated at around 24 hours of work. The notice could thus have a mixed impact; on one hand, it maintains regulatory standards, while on the other, it may distract from the core activities of providing housing services.
Resident-owned businesses stand to benefit from clarified and improved contracting processes, potentially leading to increased business opportunities and partnerships with PHAs. However, complex compliance requirements could serve as a barrier for smaller resident-owned enterprises or those lacking sufficient administrative resources.
In conclusion, this document highlights HUD's procedural steps to ensure regulatory adherence while inviting public participation to shape the future of these operations. Balancing the regulatory burden on PHAs with beneficial outcomes for resident-owned businesses seems to be a central objective, and stakeholder feedback will be crucial in achieving this balance.
Financial Assessment
The document under review provides insight into the financial elements of a proposed information collection by the Department of Housing and Urban Development (HUD). It requests approval from the Office of Management and Budget (OMB) for the said proposal and opens the floor for a public comment period. A close analysis of the financial references gives a clearer understanding of the costs involved and the impact on public housing agencies (PHAs).
Financial References and Spending
The document discusses several financial aspects related to HUD's proposal. It provides detailed calculations regarding the estimation of costs associated with the proposed information collection. Specifically, the document estimates the number of respondents at 76 PHAs. This estimation is based on the understanding that 2% of the 3,775 PHAs participate in contracting with resident-owned businesses. Interestingly, the analysis highlights that this number has decreased because some PHAs have chosen to leave the program.
HUD further outlines the cost implications by stating that the estimated total burden hours required for the information collection is 1,824 hours. This is derived from multiplying the 76 estimated respondents by the 24 hours anticipated for the procurement process. At a calculated average hourly wage of $24—based on a $51,000 per year national average PHA staff salary—the total estimated cost for these activities is $43,776.
Issues Related to Financial Estimates
The financial estimates, as provided, raise several issues that warrant further exploration:
Assumptions in Respondent Estimation: The document states the estimated number of PHAs as 76. However, it has limited detail on how exactly this 2% was derived or whether it considered variations in PHA size, location, or financial capacity. The estimate might benefit from additional clarity and transparency regarding the methodology used for arriving at this figure.
Regional Salary Variations: While the calculation of costs uses a national average, there is no account for potential variations in staff salaries across different regions. This could have significant implications, as regional salary discrepancies may lead to inaccuracies in estimating the true financial impact on each PHA.
Impact of PHAs Leaving the Program: The document acknowledges that some PHAs have left the program, influencing the current estimated number and cost calculations. However, it falls short of providing an analysis of whether this trend poses financial risks or benefits to remaining PHAs, or how it impacts overall program sustainability.
In conclusion, while the document lays out a clear foundation for understanding the financial implications of the proposed information collection, there are notable gaps where further detail and clarity could enhance comprehension and accuracy. Addressing these financial issues would improve transparency and ensure a more accurate understanding of the potential fiscal impacts on public housing entities.
Issues
• The document states the estimated number of respondents is 76 PHAs, but there is no detailed explanation on how this number was derived besides mentioning 2% of 3,775 PHAs. More clarity on the calculation process might be beneficial.
• The document indicates a specific cost estimation calculation ($43,776), but there is no information about potential variations in PHA staff salaries across different regions, which could affect the accuracy of this estimate.
• There is no discussion on the potential impact (positive or negative) of PHAs leaving the program mentioned in the text.
• The language regarding compliance requirements across different dates (before and after December 26, 2014) could be made clearer by providing a concise comparison or a chart for better understanding.
• Some technical terms and references to specific regulations (e.g., 24 CFR 85.36(h)) might be difficult for those unfamiliar with regulatory codes to understand. Simplifying or explaining these references could enhance clarity.
• The document does not address potential consequences or next steps if the proposed information collection is not approved by OMB.
• Though public comments are requested, there's no information on how these comments would be utilized or if any feedback would lead to changes in the proposal.