ML22014A075
| ML22014A075 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/2022 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML22014A073 | List: |
| References | |
| OMB 3150-0109 | |
| Download: ML22014A075 (6) | |
Text
DRAFT SUPPORTING STATEMENT FOR INVOICE SUBMISSIONS BY CONTRACTORS FOR NRC CONTRACTS/ORDERS
(3150-0109)
EXTENSION
Description of the Information Collection The U.S. Nuclear Regulatory Commissions (NRC) Office of Admini stration (ADM), Acquisition Management Division (AMD) provides contractors with an invoice template and instructions for how to properly prepare invoices so that they are complete and accurate. AMD requires contractors to follow the instructions when submitting invoices to the NRC to ensure that billed costs are proper for payment. Use of the invoice template is v oluntary; contractors may submit a voucher/invoice in alternate format provided all requirements of the billing instructions are sufficiently addressed. Invoices that are not prepared in acco rdance with the instructions may be rejected.
The invoices provide NRC with costs incurred during the performance and through the final payment of the contract/order, to ensure compliance with the te rms and conditions of the contract. The invoice provides a summary description of the se rvices performed or products submitted for the invoice period and specifies the section or C ontract Line Item Number (CLIN) or SubCLIN in the contract pertaining to the required deliverab le(s). These instructions and template stipulate the items and level of detail in which suppo rting cost data must be submitted to facilitate the NRCs review of costs billed. The Invoicing Processing Platform (IPP) is a Web-based system that provides one integrated, secure system to sim plify the management of vendor invoices, is more efficient invoice processing while aut omating invoice collection, validation and approval workflows. Contractors can manage thei r receivables more easily using one system to transact with multiple agencies.
A. JUSTIFICATION
To support the submission of invoices and supporting documentat ion, the NRC supplies contractors billing instructions with templates to follow durin g their preparation.
- 1. Need for the Collection of Information
The cost information is needed for license fee recovery and to ensure costs incurred are allowable and allocable and that the amount requested is proper for payment.
- 2. Agency Use of Information Vouchers/invoices and supporting documentation are reviewed by the Bureau of Fiscal Service, Administrative Resource Center, NRCs cognizant Contra cting Officer, and the NRCs cognizant Contracting Offi cers Representative. Taken together, the review ensures costs are billed per the contract rates and the costs i ncurred are commensurate with work performed. The instructions provide contractors with a clear idea of the level 2
of detail required to support their voucher/invoice submissions. Receipt of properly prepared vouchers/invoices expedites the review process and per mits prompt payment.
- 3. Reduction of Burden Through Information Technology The NRC has issued Guidance for Electronic Submissions to the NRC which provides direction for the electronic transmission and submittal of docu ments to the NRC.
Invoices/vouchers shall be submitted electronically to the NRC through the Invoice Processing Platform (IPP) at www.ipp.gov. It is estimated that approximately 100% of the responses are filed electronically.
To reduce the burden on contractors, contractors were requested, effective May 1, 2008, to electronically submit all vouchers/invoices to the NRC. How ever, contractors still have the option of submitting a hardcopy voucher/invoice. Vouc her/invoices are submitted electronically 100 percent of the time. IPP can help federal agencies avoid Prompt Payment penalties by supporting more efficient invoice p rocessing while automating invoice collection, validation and approval workflow s. Vendors can manage their receivables more easily using one system to transact with multiple agencies.
- 4. Effort to Identify Duplication Use Similar Information
No sources of similar information are available. There is no d uplication of requirements.
- 5. Effort to Reduce Small Business Burden
The collection represents the minimum information required for submission of a proper voucher/invoice and required supporting documentation required for review in order to ensure costs billed are proper for payment. Proper documentati on is required in order to justify and issue payment to all contractors, regardless of siz e. The NRC does attempt to pay small businesses more quickly in order to reduce the bur den.
- 6. Consequences to Federal Program or Policy Activities if the Col lection Is Not Conducted or is Conducted Less Frequently If the collection was not conducted, and the NRC did not receiv e proper documentation to support invoice payments to contractors, it is likely that t he number of improper payments would increase.
- 7. Circumstances Which Justify Variation from OMB Guidelines There are no variations from OMB guidelines.
- 8. Consultation Outside the NRC
Opportunity for public comment on the information collection re quirements for this clearance package has been published in the Federal Register.
- 9. Payment or Gift to Respondents None.
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- 10. Confidentiality of Information Confidential and proprietary information is protected in accord ance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
- 11. Justification for Sensitive Questions Normally sensitive information considered private or personal i s not required or requested. This information is only required when contracts co ntaining sensitive material are processed. Proprietary data is protected under th e Freedom of Information Act and 10 CFR Part 9.
- 12. Estimate of Annual Burden Hours and Cost
The $288 hourly rate used in the burden estimates is based on t he Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Av erage cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2021 ( 86 FR 32146, June 17, 2021).
The burden estimates for this information collection are based on a projected 36 active fee billable and non-fee billable cost-reimbursement contracts/ task orders (i.e., 36 respondents). These contracts are divided into the following t ype of contracts:
- Seven (7) contracts have no task orders (TOs) associated with them, and are generally billed monthly, with an average of 7 billings per con tract (49 billings annually).
- Five (5) contracts have TOs which are for projects not related to license fees, and are generally billed monthly, with an average of 65 billing s per contract (325 billings annually).
- 24 contracts have TOs which are for projects related to licens e fees, and are generally billed monthly, with an average of 14 billings per contract (336 bills annually). [NOTE: These contracts require 336 annual burden ho urs for reparation of fee recoverable work, associated with Task Orders ; and the licensing fee costs, generally, applies to contracts for plant inspections, licensing actions or other site-specific activities.]
- The total hourly burden reporting for this collection is 1046 hours0.0121 days <br />0.291 hours <br />0.00173 weeks <br />3.98003e-4 months <br />.
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Estimated Annual Reporting Requirements
Contract/Task Number Avg. # Annual Total # Burden per Total Cost @
Order Type of Invoices Responses Responses Response Annual $288/Hr.
Contracts per TO per (Hours) Burden Respondent/ Hours Task Order
NRC Cost Type Contracts No Task 7 N/A 7 49 149 $14,112 Order or License Fee Recovery Contract Task Order - 5 65 5 325 1 325 $93,600 Not License Fee Related Task Order - 24 14 24 336 1 336 $96,768 License Fee Related License Fee Recovery Cost Contracts Preparation of 24 14 24 336 1 336 $96,768 License Fee Recovery Cost Summary for License Fee Related Task Orders Total 36 710 1046 $301,248
- 13. Estimate of Other Additional Costs
There are no additional costs.
- 14. Estimated Annual Cost to the Federal Government
The staff has developed estimates of annualized costs to the Fe deral Government related to the conduct of this collection of information. Thes e estimates are based on staff experience and subject matter expertise and include the b urden needed to review, analyze, and process the collected information and any relevant operational expenses.
Total cost to the agency is $602,496.
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Estimated Annual Cost to the Federal Government
Contract/Task Number Avg. # Annual Total # Burden per Total Cost @
Order Type of Invoices Responses Responses Response Annual $288/Hr.
Contracts per TO per (Hours) Burden Respondent Hours NRC Cost Type Contracts No Task 7 N/A 7 49 298 $28,224 Order or License Fee Recovery Contract Task Order - 5 65 5 325 2 650 $187,200 Not License Fee Related Task Order - 24 14 24 336 2 672 $193,536 License Fee Related License Fee Recovery Cost Contracts Preparation of 24 14 24 336 2 672 $193,536 License Fee Recovery Cost Summary for License Fee Related Task Orders Total 36 710 2092 $602,496
- 15. Reasons for changes in Burden or Cost
The number of responses increased from 696 to 710. The number of annual burden hours increased from 568 to 1,046. The burden increase is pri mary due to an increase in the number of fee-related contracts and tasks orders. The c hange in responses is the result of two offsetting factors. There is an increase in resp onses due to an observed increase in the average number of invoices per task order. Thi s increase was partially offset by a decrease due to a change in how the agency is calcu lating the number of responses to better reflect the structure of the contracts.
- 16. Publication for Statistical Use:
Results will not be tabulated or published.
- 17. Reason for Not Displaying the Expiration Date
The OMB clearance expiration date is displayed.
- 18. Exceptions to the Certification Statement:
Not Applicable.
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B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information does not employ statistical metho ds.