FR 2024-29512

The recent notice from the U.S. Agency for International Development (USAID), published in the Federal Register, addresses the agency’s intentions to obtain approval from the Office of Management and Budget (OMB) for a new information collection system. This system is intended to support USAID’s grants and cooperative agreements by establishing three new Standard Provisions. These provisions focus on activity monitoring, evaluation, and learning plans, as well as the planning, collection, and submission of digital information, both with and without a data management plan. The agency is seeking public comments on this proposal with a deadline of January 15, 2025.

Summary of the Document

The notice articulates the requirements for the proposed information collection and highlights the agency's initiative to enhance the management of development assistance programs using public funds. USAID emphasizes its commitment to prudent management by gathering pertinent information from grant applicants and recipients. Additionally, this information will be utilized to ensure that applicants are capable of managing development assistance competently.

Issues and Concerns

One significant concern is the lack of clarity around how the estimated total public burden cost, amounting to $7,299,775, is calculated. This absence of detailed explanation might raise doubts about the accuracy and justification of the projected expenses. Furthermore, the document employs complex language in certain sections, which could pose challenges for laypeople or smaller organizations in understanding the implications and requirements. There's also the question of whether these changes might favor specific organizations in the grant application process, which is not addressed in the notice.

Another issue is the lack of transparency regarding the burden hours assigned to each new Standard Provision. Specifically, the document does not clarify how the estimates of 65 hours, 53 hours, and 9 hours per response were derived. Additionally, the notice does not clearly outline the expected impact or benefits of the new provisions on USAID’s broader goals, leaving the necessity and effectiveness of the proposed collection somewhat ambiguous.

Broad Public Impact

The public could be significantly impacted by these changes, particularly organizations that regularly apply for USAID grants. If the proposed system leads to more streamlined and efficient management of funds, it could enhance trust in USAID’s processes and ensure that development assistance is being utilized effectively. However, smaller organizations or individuals unfamiliar with bureaucratic processes might find it challenging to comply with the new requirements due to their complexity and perceived burden.

Impact on Specific Stakeholders

For USAID grant applicants and recipients, these proposed Standard Provisions could represent both challenges and opportunities. On one hand, the additional requirements can increase administrative burdens, potentially discouraging some applicants. On the other hand, the structured approach to information collection could improve program effectiveness and accountability, ultimately benefiting organizations that are well-equipped to meet the new expectations. Furthermore, stakeholders who submit substantial and relevant comments could potentially influence the final form of these provisions, thereby shaping how USAID funds are managed and utilized in the future.

In summary, the notice indicates a shift towards improved management practices within USAID’s grant processes, while highlighting various concerns related to transparency, complexity, and inclusiveness. Stakeholders and the broader public should consider participating in the comment period to express their opinions and potentially shape the future of USAID’s grant management system.

The document under review pertains to a proposed information collection by the U.S. Agency for International Development (USAID), seeking public comment in accordance with the Paperwork Reduction Act of 1995. The focus of this commentary is on financial references and allocations as outlined in the notice.

Estimated Financial Burden

A central financial reference in the document is the "Estimated Total Public Burden (in cost): $7,299,775". This figure represents the estimated cost to the public associated with the proposed information collection requirements tied to USAID's grants and cooperative agreements. This estimation is based on the burden hours projected for respondents who are required to comply with the new Standard Provisions as part of their engagement with USAID.

Relation to Issues Identified

1. Lack of Calculation Detail:
One primary issue is the document's lack of specificity regarding how the $7,299,775 total is calculated. The absence of detailed methodology behind this financial estimate raises concerns about transparency and the justification of the costs involved. Understanding the components that contribute to this total is crucial for assessing whether the financial burden is reasonable and necessary.

2. Burden Hours Without Explanation:
The document lists the estimated burden hours required per response for each of the new Standard Provisions: 65 hours for the Activity Monitoring, Evaluation, and Learning Plan, 53 hours for the Submission of Digital Information with a Data Management Plan, and 9 hours without such a plan. While these hours contribute to the overall financial burden estimate, the lack of explanation on how these figures were derived could lead to skepticism regarding their accuracy and the corresponding cost implications.

Financial References and Broader Implications

Beyond the immediate question of calculating the $7,299,775 total cost, the document does not clearly elucidate the financial implications these costs have on smaller organizations or individual respondents. For many entities, especially smaller NGOs or those with limited resources, the financial burden posed by these requirements can be significant. It is important for USAID to ensure that these financial obligations do not disproportionately affect the ability of smaller or under-resourced organizations to participate in funding opportunities.

Finally, while the document engages with public comment on the necessity and utility of the information collection, the perceived financial burden may impact stakeholders' feedback. Providing clearer financial rationales and ensuring that costs are justified and equitable are important steps for USAID in addressing these concerns. Transparency about financial calculations not only aids in gaining public trust but also in making informed adjustments that serve both the agency's objectives and the public interest effectively.