ML25093A113
| ML25093A113 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/2025 |
| From: | NRC/EDO |
| To: | |
| Shared Package | |
| ML25093A099 | List: |
| References | |
| OMB 3150-0109 | |
| Download: ML25093A113 (6) | |
Text
DRAFT SUPPORTING STATEMENT FOR INVOICE SUBMISSIONS BY CONTRACTORS FOR NRC CONTRACTS/ORDERS (31500109)
EXTENSION Description of the Information Collection The U.S. Nuclear Regulatory Commissions (NRC) Office of Administration, 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 voluntary; 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 accordance 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 terms and conditions of the contract. The invoice provides a summary description of the services performed, or products submitted for the invoice period and specifies the section or Contract Line-Item Number (CLIN) or SubCLIN in the contract pertaining to the required deliverable(s). These instructions and template stipulate the items and level of detail in which supporting cost data must be submitted to facilitate the NRCs review of costs billed. The Invoice Processing Platform (IPP) is a Web-based system that provides one integrated, secure system to simplify the management of vendor invoices, is more efficient invoice processing while automating invoice collection, validation and approval workflows. Contractors can manage their receivables more easily using one system to transact with multiple agencies.
A.
JUSTIFICATION To support the submission of invoices and supporting documentation, the NRC supplies contractors billing instructions with templates to follow during 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 Contracting Officer, and the NRCs cognizant Contracting Officers Representative. Taken together, the review ensures costs are billed per the contract rates and the costs incurred are commensurate with work
2 performed. The instructions provide contractors with a clear idea of the level of detail required to support their voucher/invoice submissions. Receipt of properly prepared vouchers/invoices expedites the review process and permits 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 documents to the NRC.
Invoices/vouchers shall be submitted electronically to the NRC through the IPP at www.ipp.gov. It is estimated that approximately 99 percent of the responses are filed electronically.
To reduce the burden on contractors, effective May 1, 2008, contractors were requested to electronically submit all vouchers/invoices to the NRC. However, contractors still have the option of submitting a hard copy voucher/invoice. Voucher/invoices are submitted electronically 99 percent of the time. IPP can help Federal agencies avoid prompt payment penalties by supporting more efficient invoice processing while automating invoice collection, validation and approval workflows. 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 duplication 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 to ensure costs billed are proper for payment. Proper documentation is required to justify and issue payment to all contractors, regardless of size. The NRC does attempt to pay small businesses more quickly to reduce the burden.
- 6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or is Conducted Less Frequently If the collection was not conducted, and the NRC did not receive proper documentation to support invoice payments to contractors, it is likely that the number of improper payments would increase.
- 7. Circumstances Which Justify Variation from Office of Management and Budget (OMB)
Guidelines There are no variations from OMB guidelines.
- 8. Consultation Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register.
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- 9. Payment or Gift to Respondents None.
- 10. Confidentiality of Information Confidential and proprietary information is protected in accordance with NRC regulations at Title 10 of the Code of Federal Regulations (10 CFR) 9.17(a) and 10 CFR 2.390(b).
- 11. Justification for Sensitive Questions Normally, sensitive information considered private or personal is not required or requested.
This information is only required when contracts containing sensitive material are processed.
Proprietary data is protected under the Freedom of Information Act and 10 CFR Part 9.
- 12. Estimate of Annual Burden Hours and Cost The $317 hourly rate used in the burden estimates is based on the NRCs fee for hourly rates as noted in 10 CFR 170.20, Average 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 2024 (89 FR 51789; June 20, 2024).
The burden estimates for this information collection are based on a projected 67 active fee billable and non-fee billable cost-reimbursement contracts/task orders. These contracts are divided into the following type of contracts:
Eight contracts have no task orders associated with them.
Twelve Task Order, Not License Fee Related, and are generally billed monthly, with an average of 2.2 billings per contract (26 billings annually).
Forty-seven Task Order, License Fee Related, and are generally billed monthly, with an average of 14.7 billings per contract (691 billings annually).
The total hourly burden reporting for this collection is 717 hours0.0083 days <br />0.199 hours <br />0.00119 weeks <br />2.728185e-4 months <br />.
4 Estimated Annual Reporting Requirements Contract/Task Order (TO) Type Number of Contracts Avg. #
Invoices per TO Total #
Responses Burden per
Response
(Hours)
Total Annual Burden Hours Cost at
$317 per hour NRC Cost Type Contracts No Task Order or License Fee Recovery Contract 8
N/A 0
1 0
$0 Task Order-Not License Fee Related 12 2.2 26 1
26
$8,242 Task Order-License Fee Related 47 14.7 691 1
691
$219,047 License Fee Recovery Cost Contracts Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders 47 14.7 691 1
691 219,047 Total 67 717 717
$227,289
- 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 Federal Government related to the conduct of this collection of information. These estimates are based on staff experience and subject matter expertise and include the burden needed to review, analyze, and process the collected information and any relevant operational expenses.
Total cost to the agency is $454,578 as calculated by the table below.
5 Estimated Annual Cost to the Federal Government Contract/Task Order Type Number of Contracts Avg. #
Invoices per TO Total #
Responses Burden per
Response
(Hours)
Total Annual Burden Hours Cost at
$317 per hour NRC Cost Type Contracts No Task Order or License Fee Recovery Contract 8
N/A 0
2 0
$0 Task Order-Not License Fee Related 12 2.2 26 2
52
$16,484 Task Order-License Fee Related 47 14.7 691 2
1382
$438,094 License Fee Recovery Cost Contracts Preparation of License Fee Recovery Cost Summary for License Fee Related Task Orders 12 0
0 2
0
$0 Total 79 717 1434
$454,578
- 15. Reasons for changes in Burden or Cost Since 2022, the number of contracts increased from 36 to 67; and the average number of invoices per TO responses increased from 710 to 717. The number of annual burden hours decreased from 1046 to 717. However, there is a dramatic decrease in invoices per TO for non-license fee related and a small change in the invoices per TO for license fee related contracts. The substantial change in responses is the result of a decrease in responses due to an observed decrease in the average number of invoices per TO for non-license fee related items.
The fee rate increased from $288 to $317.
- 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.
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- 18. Exceptions to the Certification Statement Not Applicable.
B.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS The collection of information does not employ statistical methods.