Overview
Title
30-Day Notice of Proposed Information Collection: Public Housing-Contracting With Resident-Owned Businesses; OMB Control No.: 2577-0161
Agencies
ELI5 AI
The government wants to know what people think about rules for how local housing groups can work with businesses owned by the people who live there. They are asking for ideas on how to make these rules easier and simpler.
Summary AI
The Department of Housing and Urban Development (HUD) is requesting public comments on a proposed information collection regarding contracting with resident-owned businesses. This notice provides an additional 30 days for public input, with comments due by January 17, 2025. HUD aims to ensure compliance with specific requirements for contracts, including licenses and certifications, for public housing agencies working with resident-owned businesses. The goal is to enhance the quality and clarity of the information collected while minimizing the burden on those responding to the collection.
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 an additional 30 days of public comment.
Keywords AI
Sources
AnalysisAI
The document under review is a notice published by the Department of Housing and Urban Development (HUD) in the Federal Register. It seeks public comments on a proposed information collection process regarding contracts with resident-owned businesses within public housing schemes. Specifically, HUD is requesting an extension of an already approved information collection, emphasizing compliance with certain rules and regulations, including licenses and certifications. This notice opens up a 30-day period for public comments, ending on January 17, 2025.
General Overview
The document aims to gather input from interested parties on the need, accuracy, and efficiency of the proposed information collection process. HUD intends to enhance the clarity and quality of collected data, ensuring it aligns with the agency's functions and its utility for stakeholders. The underlying objective is to streamline the procurement process for Public Housing Agencies (PHAs) contracting with resident-owned businesses.
Significant Issues and Concerns
Several concerns arise from this notice. Firstly, while the document outlines the procedural requirements for contracting with resident-owned businesses, it lacks clarity on the reasons why some PHAs might be opting out of this program. Understanding this trend could provide deeper insights into the program's operational challenges or areas needing adjustment.
Moreover, the section soliciting public comment features potential redundancy—points 4 and 5 both discuss minimizing the burden of information collection, possibly causing confusion among those providing feedback.
Another issue involves the cost estimation provided, which appears to focus only on the salary component. This calculation does not consider additional overheads or resources necessary for the process, which could understate the true financial impact on PHAs.
Additionally, the salary figures used are derived from a commercial job listing site, ZipRecruiter, which may not accurately reflect public sector compensation averages, leading to inaccuracies in cost estimations.
Impact on the Public and Stakeholders
For the general public, this document is a procedural notice, but it holds significance for stakeholders involved in public housing. Public Housing Agencies and resident entrepreneurs, in particular, could be impacted. The document’s emphasis on strict compliance requirements may impose additional administrative tasks on PHAs, affecting their operational workload and financial planning. On the other hand, if successfully executed, the clarified guidelines and streamlined processes can provide clearer pathways for resident entrepreneurs to engage with public housing contracts, potentially expanding their business opportunities.
For stakeholders concerned with governmental transparency and efficiency, this notice illustrates an effort by HUD to involve public voices in shaping policy execution. However, it also highlights areas where the agency's data collection and public feedback mechanisms might be improved, suggesting a need for HUD to adopt more robust approaches to policy implementation feedback.
Concluding Remarks
Overall, while the HUD notice seeks to engage stakeholders in refining the process of contracting with resident-owned businesses, it leaves certain gaps that need addressing to optimize stakeholder engagement and resource allocation. Greater transparency regarding PHA participation trends and a more comprehensive cost estimation could enhance the notice's utility and relevance to its audience. Moreover, clearer communication in the solicitation of public comments can help ensure that feedback is focused and constructive.
Financial Assessment
The Federal Register notice in question outlines a proposed information collection process related to public housing contracts with resident-owned businesses, supervised by the Department of Housing and Urban Development (HUD). This process involves financial considerations that are crucial to understanding the cost implications for Public Housing Agencies (PHAs) engaging with resident-owned businesses.
Summary of Financial References
The document highlights that the national average salary for PHA staff, utilized for cost calculations, is $64,590 per year or $30.95 per hour. This figure is derived from ZipRecruiter, which might not fully reflect the nuances of public sector compensation but instead offers a broad estimate. The estimated cost for these activities hinges on this hourly rate multiplied by the total estimated number of hours spent by PHAs on procurement processes. Specifically, the calculation is projected as 75 PHAs times 24 hours per procurement process, resulting in a cumulative 1,800 hours. This results in a total projected cost of $55,710.
Relation to Identified Issues
A significant noted issue is that the cost calculation exclusively considers staff salary, with no mention of overhead or additional resources that might be required for the implementation or support of these activities. This particularly might understate the total expenses involved. Moreover, the reliance on a commercial source like ZipRecruiter for salary data, rather than data specific to public sector standards or comprehensive reports, might lead to inaccuracies or an incomplete picture of the actual costs involved.
Another issue worth noting is the absence of a detailed explanation for the decrease in PHAs engaging in these types of contracts. Without understanding why only 2% of PHAs (or 75 out of 3,763) participate in such contracts, it becomes challenging to anticipate the financial needs or shifts within the program. This information gap could have implications for future funding and support strategies from HUD.
Lastly, the duplication of points 4 and 5 in the solicitation of public comments regarding minimizing collection burdens might confuse stakeholders about their input's focus. A clearer distinction or consolidation could help draw more precise comments, especially around financial burdens.
Overall, while the document provides a baseline financial projection for labor involved in information collection processes, addressing aforementioned issues such as broader cost considerations and clarifying participant trends will offer a more robust understanding of financial commitments.
Issues
• The document does not provide a clear justification or examples of why some PHAs are leaving the program, which might help understand staffing or spending decisions.
• There is a potential for overlap or duplication in points 4 and 5 under the solicitation of public comment section regarding minimizing burden, which might lead to confusion among respondents.
• The estimated cost calculation is based solely on salary and does not account for any overhead or additional resources that might be required, which could underrepresent the true costs.
• The estimated average PHA staff salary is taken from ZipRecruiter, a commercial job posting and salary estimation site, which may not be fully representative or authoritative for public sector salary standards.
• There is no specific explanation for the decline in the number of PHAs contracting with resident-owned businesses, which makes trend analysis difficult for stakeholders.
• The document contains legal references to specific CFR parts without providing a brief context or summary, which might be difficult for non-expert readers to understand.