OMB NEG Supporting Statement final 3 14 07

Supporting Statement

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 of the OMB Form 83-I is checked "yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The information collection is necessary for the U.S. Department of Labor (DOL)/ Employment and Training Administration (ETA)’s award of National Emergency Grants (NEG) which are discretionary grants intended to temporarily expand the service capacity at the state and local area levels by providing funding assistance in response to significant dislocation events for workforce development and employment services and other adjustment assistance for dislocated workers and other eligible individuals as defined in sections 101, 134 and 173 of the Workforce Investment Act (WIA)(P.L. 105-220): sections 113, 114 and 203 of the Trade Adjustment Assistance Reform Act of 2002 (P.L. 107-210): and 20 CFR 671.140.

Funds are available for obligation by the Secretary under Sections 132 and 173 of the

WIA, and Section 203 of the Trade Act of 2002. Applications will be accepted on an ongoing basis as the need for funds arises at the state and local level.

The provisions of WIA and the Regulations define four NEG project types:

► REGULAR, which encompasses plant closures, mass layoffs, and multiple layoffs in a single community.

► DISASTER, which includes all eligible FEMA-declared natural and manmade disaster events.

► TRADE–WIA DUAL ENROLLMENT, which provides supplemental funding to ensure that a full range of services is available to trade-impacted individuals eligible under the Trade Adjustment Assistance program provisions of the Trade Act of 2002.

► TRADE HEALTH INSURANCE COVERAGE ASSISTANCE, which provides specialized health coverage, support services, and income assistance to targeted individuals defined in the Trade Adjustment Assistance Reform Act of 2002.

Five electronic forms are employed by the National Emergency Grant program and are appended to this Supporting Statement :

ETA 9103, Cumulative Planning Form;

ETA 9104, Quarterly Report;

ETA 9105, Employer Data Form;

ETA 9106, Project Synopsis, and

ETA 9107, Project Operator Data Form.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

For the application information collection, the purpose is to judge whether to approve an application requesting grant funds. Specifically, the purpose of the grant application forms is to provide the grant officer with the necessary information during the application review process, to make consistent and objective funding decisions based on the stated funding request evaluation criteria.

For the quarterly reports information collection, the purpose is to assure accountability and to measure actual project performance to date.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

In compliance with the Government Paperwork Elimination Act, the information collection is fully in an electronic format. Electronic applications allow for ease of completion and timeliness of submission by the applicant, and timely processing of the application by the grant officer. Specifically, e-applications will be made through the DOL/ETA Grantee Reporting System Internet website for NEGs at http://etareports.doleta.gov. An instructional User’s Guide has been prepared for the e-application system. Moreover, in order to reduce the reporting burden for the applicants, as well as in order to ensure the completeness and consistency of the information provided, automated edit checks are programmed into the e-application system. The authorized signatory of the applicant is issued a unique Personal Identification Number (PIN). The entry of this PIN constitutes the authorized signature.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information collection avoids duplication because, although the eligible circumstances for NEG funding are of a recurring nature, the specific applications are unique. Therefore, the collected information will differ for each application. Moreover, the information collection will constitute the sole source of information for funding decisions regarding this assistance.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The information collection does not significantly impact small businesses or other small entities. NEG grantees are all States or local entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Pursuant to the WIA statutory rules and regulations relevant to the NEG program, if the information collection is not performed, NEG funds cannot be awarded or disbursed. The requested information collection has been designed in order to achieve compliance with those WIA statutory rules and regulations.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

There are no special circumstances concerning the information collected.

Although there is no fixed deadline for the information collection, we do request that applications for NEG grants be completed and submitted as early as possible, in order to provide timely workforce development and employment services and other assistance to eligible individuals under the NEG program.

8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

In accordance with 5 CFR 1320.5, a Federal Register Notice (Vol 71, No. 221, pp 66800 et seq, November 16, 2006), provided the general public and Federal agencies with a 60-day period to comment on the proposed collection. The following comments were received and are paired with their responses:

SECTION OF GUIDELINES	COMMENTERS	ISSUE/COMMENT	RESPONSE	DISPOSITION
Point of Contact	State of Georgia	The eApplication system should provide a section where states can list an alternate point of contact. Often the point of contact for grant close out is different than the point of contact when the application is initially processed.	Agree. Prior to implementing the Phase 3 upgrade to the eSystem, the Point of Contact was an automatic default to the Primary/Signatory. Provisions had not been made to recognize that the Primary/Signatory was, most often, not the creator of the electronic document, or the subject matter expert. Currently the applicant can designate two additional Points of Contact, who may be included on all communications regarding that application	Comment accepted. Point of Contact revisions to the eSystem have been implemented.
Project Operating Plan	State of Georgia	The Project Operating Plan should be incorporated into the eApplication system. This would help both ETA and states track the status of Project Operating Plans.	Current NEG grant management procedures require that grantees are submit the Project Operating Plan to their DOL Regional Office, which is the ETA division responsible for monitoring/tracking the grantees level of performance. Requiring that the POP should also be provided to the National Office staff and by which means would be most advantageous is being taken under consideration	Comment Accepted
Grantee Level Expenditures	State of Georgia	States could benefit if the eApplication system had a section which permitted “informational” services conducted at the local level to be reported. The system currently allows it under “Other” services, and that is efficient. Nonetheless, it would better if it could be reported under its own section.	A review and revision of the t NEG reporting mechanism and procedure is a Program policy initiative. The eSystem can be adjusted to display the additional report fields if it is determined that informational services will be reported separately from “Other”.	Comment Accepted for Consideration
Funding/Monitoring Reports	State of Georgia	Due to the varied reporting requirements it would be useful if the system alerted states when these reports (monitoring, other non-financial) were due – especially since these reports may impact future incremental funding.	Agree. The Version 3 update to the eSystem provided for an Alert Flag icon to be displayed that advises the grantee on what date a report is due. A designation link is also included that, when activated, transfers the user directly to the report that is to be completed.	Comment accepted. Report alert revisions to the eSystem have been implemented.
Burden Hour Table	State of New York	The estimated average time response indicated in the reporting burden estimate table is understated. The time estimated does not cover time needed to input information related to modifications nor the time needed to develop the information.	The burden time indicated to create an eSystem document is a mean/ average estimation. It is acknowledged that NY’s experience may have been at the high end of the variable. Conversely there applicants who complete the process in less than average time. Considering that the NEG program office has not received any similar complaints about the process, it is also noted that the majority of NEG grantees are comfortable with the average time estimation. The time needed to develop the information has not been noted as an issue previously. It is comparable to the time it would have taken to develop the information if the NEG application was still paper process.	Comment Accepted
Cost Rate	State of New York	The mean hourly rate used to determine the state and local burden is understated. The mean rate used appears to be at the secretarial level whereas it is necessary for professional staff to complete the eApplication.	Prior to the implementation of the NEG eSystem hard copy grants were created and submitted by state and local workforce development professionals who commanded various hourly rates. The mean hourly rate was developed to accommodate the average of those variable rates. Considering that the NEG program office has not received any similar complaints about the process, it is also noted that the majority of NEG grantees are comfortable with the mean hourly rate that is in place.	Comment Accepted
On-line Help	State of Maine	The online help component is not always informative. It could be greatly improved by adding a topic index and help on topics to allow more problem solving around procedures for revising reports, requesting modifications etc.	The eSystem Help file is a static resource, designed to assist the user to understand the system’s components and better navigate the electronic process. Assistance with submission requirements and procedures is provided by the User Guide and NEG program eSystem personnel. Electronic malfunctions are referred to the ETA ProTech Help Desk. A review of the eSystem Help component will be scheduled to assure that the information is current and accurate	Comment Accepted

COMMENTS NOT REQUIRING SPECIFIC RESPONSE

Positive

STATE	COMMENT
State of Maine	The eApplication and its reporting system are convenient and easy to use. Technical assistance from both Federal Project Officers and Technical Help Desk is responsive, timely, and more than satisfactory.
State of Maine	We support the extension of current data collection procedures for NEG applications and reporting.
State of Montana	Because the application and reporting procedures are conducted through an on-line system, the time involved at the State (grantee) level – whether submitting a new or modified application or providing quarterly reports on an active NEG – is less burdensome and much more efficient than a traditional process. There are still a few glitches in the system regarding updating of data in a timely manner at the USDOL level, but overall the on-line process works well and is end user friendly. We encourage DOL/ETA to continue improving the on-line system and recommend that the current NEG Application and Reporting Procedures be extended.

COMMENTS NOT REQUIRING SPECIFIC RESPONSE

Negative

STATE	COMMENT
State of Maine	There are times when the E-system contains an error, usually in the dates associated with a project. When these errors are brought to the attention of the help desk, they are promptly corrected.
State of New York	The State recently submitted a paper modification request for its BRAC NEG. The State was informed the request had to be submitted via the e-system (though it had previously submitted a paper modification request). However, when attempting to comply, various fields and edit checks within the e-system did not align with the proposed modification. Since the original and the first BRAC NEG modification requests were not in the e-system, submitting the second modification request was extremely difficult. Ultimately much time and effort were expended until ETA staff advised our finance offer that they (ETA) had to make changes in the system and the State needed to enter the initial request for BRAC funds into the e-system. Based on the above experience the State takes exception with USDOL’s assertion that its electronic system allows for ease of completion and timeliness of submission.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Once implemented, users of the NEG e-application system will be encouraged to provide DOL/ETA with feedback on its ease of use and user-friendliness and the system will be revised accordingly. Moreover, the grant officer consults regularly with applicants in order to elicit their views on problems with the application process.

Training and technical assistance has been and will continue to be provided to NEG applicants.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There will be no payments made, or gifts given, to respondents in association with the NEG program.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The information collection does not include confidential information, and therefore no assurances of confidentiality need to be provided to respondents.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons form whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a private, sensitive nature – such as sexual behavior or religious beliefs - asked in the information collection.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

A reporting burden estimate table is shown below:

Estimated Total Annualized Hour Burden
Reference	Expected Total Respondents*	Frequency	Expected Total Responses*	Avg. Time per Response	Expected Burden*
SF 424	150	1 per project	150	45 minutes	113.0 hours
Narrative Summary	150	1 per project	150	1.0 hour	150.0 hours
ETA 9103	150	1 per project	150	90 minutes	225.0 hours
ETA 9105	75	1 per project	75	30 minutes	38.0 hours
ETA 9106	150	1 per project	150	1.0 hour	150.0 hours
ETA 9107	100	1 per project	100	15 minutes	25.0 hours
TAA Certifi-cation Report	50	1 per project	50	30 minutes	25.0 hours
Reports: ETA 9104	150	quarterly per project	600	30 minutes	300.0 hours
Grant Modifications	140	1 per project	140	30 minutes	70.0 hours
* Actual number will vary, because the information collection is required to obtain a benefit.

Estimates of the total annualized hour burden and the annualized costs for the collection of this information are based upon the experience to date with similar National Emergency Grants (NEGs).

Mean hourly rate: $15.82

(Source: BLS Occupational Employment Statistics, “Employment and wages by major occupational groups, 2000” table, “Community and social services occupations”)

Annualized cost of hour burden: 15.82 $/hour*x1171hours = $18,525.22

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There is no cost burden for reporting.

The amount of funding used for administrative costs for the NEGs, including operating and maintaining, is expected to vary among the NEG recipients. In the NEG application procedures, the Department is providing that up to ten percent of the NEG may be used for administrative costs.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Estimates of annualized cost to the Federal government for this collection are based upon the experience to date with similar National Emergency Grant (NEG) programs. Operational expenses will include staff support, which is estimated to require an equivalent of one FTE at the GS-15 level, one FTE at the GS-14 level, five FTE at the GS-13 level, two FTE at the GS-12 level, one FTE at the GS-11 level and one FTE at the GS-7 level. These costs would total approximately $ 780,000 per year. There will be no need for additional equipment, overhead or printing costs to support this collection.

15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form 83-I.

There is no change in burden.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The results of the information collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

ETA will display the OMB control number and expiration date on the e-application and reporting forms ETA 9103, 9104, 9105, 9106 and 9107.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submission," of OMB 83-I.

There are no exceptions to the certification statement in item 19 of OMB Form 83-I.

B. Collection of Information Employing Statistical Methodology

This collection does not employ statistical methodology.

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