ML18340A256

OMB Draft Supporting Statement Invoice Submissions by Contractors 2018

ML18340A256
Person / Time
Issue date:	12/31/2018
From:	Office of Administration
To:
Gladhill V, 415-5611
Shared Package
ML18341A316	List: ML18340A256
References
3150-0109
Download: ML18340A256 (6)

Text

DRAFT SUPPORTING STATEMENT FOR INVOICE SUBMISSIONS BY CONTRACTORS FOR NRC CONTRACTS/ORDERS (3150-0109)

REVISION 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 Invoicing 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. Vendors 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 (ARC), AMD and the NRC Contracting Officers Representative (COR). Taken together, the review ensures costs are billed per the contract rates and the costs incurred are commensurate with work 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.

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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 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. However, contractors still have the option of submitting a hardcopy voucher/invoice. Voucher/invoices are submitted electronically 100 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 in order to ensure costs billed are proper for payment.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or is Conducted Less Frequently Contractors are required to complete and submit vouchers/invoices and attachments once each month unless otherwise authorized by the Contracting Officer. The consequence of not collecting the data, or of less frequent collection, would be withholding of reimbursement to the contractor of costs incurred as the work progresses.

The provisions of Federal Acquisition Regulation (FAR) Clause 52.216-7, require payment be made upon request, but (except for small business concerns) not more often than once every two weeks.

7. Circumstances Which Justify Variation From OMB Guidelines To ensure prompt payment is made to the contractor, the contractor must electronically submit a proper voucher/invoice, including supporting documentation, which is reviewed and approved by NRC. If it is determined that the voucher/invoice was properly prepared, payment will be made 30 calendar days from receipt of the proper voucher/invoice, September 14, 2011 memorandum titled Accelerating Payments to Small Businesses for Goods and Services, small business payments are generally 2

made within 15 days of receipt of a proper invoice/voucher.

The agency-designated billing office for submittal of the voucher/invoice is the ARC.

The payment process begins once NRC electronically receives a proper invoice. NRC sends the voucher/invoice electronically to the COR and AMD for review and approval.

The COR reviews and approves the electronic copy, and then it is electronically sent to AMD for final review and approval. After AMD reviews and approves the voucher/invoice, it is electronically sent to ARC for final processing (payment).

8. Consultation Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package has been published in the Federal Register.

9. Payment or Gift to Respondents None.

10. Confidentiality of Information Confidential and proprietary information is protected in accordance 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 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 Burden and Burden Hour Cost The $275 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions 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 2018 (83 FR 29622, June 25, 2018).

The burden estimates for this information collection are based on a projected 23 active contracts (i.e., 23 respondents). These 23 contracts are divided into the following type of contracts:

• Eight contracts have no task orders (TOs) associated with them, and are billed monthly (i.e., 8 bills annually).

• Four contracts have TOs which are for projects not related to license fees, and have a total of six(6) TOs and an average of four billings annually per TO.

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• 11 contracts have TOs for license fee recoverable projects with a total of 113 TOs and an average of four billings per TO.

• The 11 contracts listed above require an additional 220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> for contractors to prepare the License Fee Recovery Cost Summary, which has a total of 113 TOs and is prepared an average of four times per year.

The total hourly reporting burden for this collection is 348 hours0.00403 days <br />0.0967 hours <br />5.753968e-4 weeks <br />1.32414e-4 months <br />, which is described in the table below.

ANNUAL REPORTING REQUIREMENTS Contract/Task Number of Avg. # Annual Total # Burden per Total Cost @

Order Type Contracts Invoices Responses Responses Response Annual $275/Hr.

per TO per (Hours) Burden Respondent Hours NRC Cost Type Contracts No Task 8 NA 8 64 0.5 32 $8,800 Order or License Fee Recovery Contract Task Order - 4 12 4 192 0.5 96 $26,400 Not License Fee Related Task Order - 11 10 4 440 0.5 220 $60,500 License Fee Related License Fee Recovery Cost Contracts Preparation of 11 10 4 440 0.5 220 $60,500 License Fee Recovery Cost Summary for License Fee Related Task Orders Total 23 696 348 $97,500 The license fee recovery section of the billing instructions is included in cost type contracts that include fee recoverable work. The section on licensing fee costs generally applies to contracts for plant inspections, licensing actions or other site-specific activities.

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13. Estimate of Other Additional Costs There are no additional costs.

14. Estimated Annualized 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.

These costs are fully recovered by fee assessments to NRC licensees pursuant to 10 CFR Part 171. Total cost to the agency is $251,900.

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 $275/Hr.

Contracts per TO per (Hours) Burden Respondent Hours NRC Cost Type Contracts No Task 8 NA 8 64 1.0 64 $17,600 Order or License Fee Recovery Contract Task Order - 4 12 4 192 1.0 192 $52,800 Not License Fee Related Task Order - 11 10 4 440 1.0 440 $121,000 License Fee Related License Fee Recovery Cost Contracts Preparation of 11 10 4 440 0.5 220 $60,500 License Fee Recovery Cost Summary for License Fee Related Task Orders Total 23 1136 916 $251,900 5

15. Reasons for Changes in Burden or Cost The number of responses decreased from 1,506 to 696 and the number of burden hours decreased by 404 (from 752 to 348 hours0.00403 days <br />0.0967 hours <br />5.753968e-4 weeks <br />1.32414e-4 months <br />) and decreased in the number of cost type contracts projected within the next 3 years (from 41 to 23). Specific changes are described below:

• Contracts which have no TOs or license fee recovery associated with them and provide for monthly billing decrease by 14 contracts (from 22 to 8).

• Four contracts which have TOs associated with them have no license fee recoverable.

• TOs associated with the 11contracts with recoverable license fees decrease by 7 (from 120 TOs to 113 TOs.)

Also, the number of active cost type contracts decreased (from 41 to 23), annual reporting costs decreased (from $209,808 to $97,500) and estimated annual cost to the Government decreased (from $337,869 to $251,900), the decrease in the number of cost contracts is due to NRC awarding less cost contracts and a decrease in the cost for professional effort from $279 to $275 per hour.

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.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS The collection of information does not employ statistical methods.

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