THE SUPPORTING STATEMENT
A. Justification
Circumstances Making the Collection of Information Necessary
The State Councils on Developmental Disabilities (Councils) are authorized in Subtitle B, of the Developmental Disabilities Assistance and Bill of Rights Act of 2000 (DD Act), as amended, [42 U.S.C. 15001 et seq.] (The DD Act). They are required to submit a five-year State plan. Section 124(a) [42 U.S.C. 15024(a)], states that:
Any State desiring to receive assistance under this subtitle shall submit to the Secretary, and obtain approval of, a 5-year strategic State plan under this section.
The requirement for a State plan is also further emphasized in the regulations in 45 CFR Part 1386:
(a) In order to receive Federal financial assistance under this subpart, each State Developmental Disabilities Council must prepare and submit to the Secretary, and have in effect, a State Plan which meets the requirements of sections 122 and 124 of the Act (42 U.S.C. 6022 and 6024) and these regulations.
<<Note: the regulations, including their citations, are currently being updated to reflect the changes in the Act as of 2000.>>
Additionally, data is collected in the State Plan and submitted to ADD for compliance with the Government Performance and Results Act of 1993 (GPRA). In the State Plans, the Councils provide to ADD future year targets for outcome performance measures. These targets are reported to Congress under GPRA.
This is an ongoing data collection, and does not represent a change in requirements.
Purpose and Use of the Information Collection
As required by the statute, the Council is responsible for the development and submission of the State plan, and is then responsible for implementation of the activities described in the plan. Further, the Council updates the Plan annually during the five years. The State plan provides information on individuals with developmental disabilities in the State, and a description of the services available to them and their families. The plan further sets forth the goals and specific objectives to be achieved by the State in pursuing systems change and capacity building in order to more effectively meet the service needs of this population. It describes State priorities, strategies, and actions, and the allocation of funds to meet these goals and objectives.
The State Plan is used in three ways. First, it is used by the individual Council as a planning document to guide it’s planning and execution processes. Secondly, it provides a mechanism in the State, whereby individual citizens as well as the State government, are made aware of the goals and objectives of the Council and have an opportunity to provide comments on them during its development. Finally, the State plan provides to the Department a stewardship tool; the staff of the Department provides some technical assistance to Councils and monitor compliance with Subtitle B of the DD Act, as an adjunct to on-site monitoring. The stewardship role of the State plan is useful both for providing technical assistance during the planning process, during the execution process, and also during program site visits.
Additionally, data is collected in the State Plan and submitted to ADD for compliance with the Government Performance and Results Act of 1993 (GPRA). In the State Plans, the Councils provide to ADD future year targets for outcome performance measures. These targets are reported to Congress under GPRA.
Use of Improved Information Technology and Burden Reduction
The State Plan is submitted electronically, and has been so submitted for ten years. Prior to that, Plans were submitted by hard copy only. A major consequence of the move to electronic submission of the State Plan is enhanced ability to review the State Plans and to manage the data in them.
Efforts to Identify Duplication and Use of Similar Information
A careful review of the Council Program Performance Report (PPR) submitted by the State Councils was conducted to avoid any duplication of program elements submitted.
The Financial Status Report (ADD-02B) was also reviewed for duplication with the budget section of the State Plan.
For each of the above two information collections (PPR and ADD-02B), there is no overlap, since the State Plan is prospective (what the State plans to do), while the other two (the PPR and ADD-02B) are retrospective (what the State actually did).
After efforts were made to identify duplication, described above, no similar information was found to exist to provide insight into the programmatic and fiscal planning of the Councils.
Impact on Small Businesses or Other Small Entities
The information collected does not involve, nor result in assignment of burden to any small business or other small entity. It is collected from 55 State agencies.
Consequences of Collecting the Information Less Frequently
Subtitle B, Section 124 of the DD Act requires a full revision of the State plan at least once every five years, with annual review of the plan. Less frequent collection of data than that prescribed by the requirements of the Developmental Disabilities Act, Section 124 would violate statute.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances governing the collection of data that are inconsistent with the established guidelines pursuant to 5 CFR 1320.5.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
The content of the State Plan format was developed by all 55 of the State Councils on Developmental Disabilities themselves in a massive collaborative effort coordinated by the National Association of Councils on Developmental Disabilities, under contract with ADD. Issues of the scope, content, availability of data, format, and clarity of instructions for the State plan format have been discussed with all of the Councils during the course of the development process. The Councils have had experience now using this version of this form, since this is an ongoing data collection and it represents no change in requirements.
A 60-day comment period was provided beginning 03/29/2011. The solicitation of comments for the proposed information collection was published in the Federal Register, volume 76, page 17421. There were several inquiries regarding the announcement, but none that resulted in comments being submitted.
Explanation of Any Payment or Gift to Respondents
No payments or gifts to respondents are planned.
Assurance of Confidentiality Provided to Respondents
There are no data collected that requires confidentiality, and hence no assurance of confidentiality is required.
Justification for Sensitive Questions
No data is directly collected that is of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
The following table summarizes the burden hour estimate for this information collection:
No. of States |
No. of Responses Per State |
Average Burden Hours Per State |
Total Hours |
55 |
1 |
367 |
20,185 |
The State’s estimates of their annual burden hours for this information collection varies very greatly from State to State, influenced by factors such size of the State and program complexity. A survey of a representative selection of States was conducted, focusing on geographic diversity, State-size diversity, and program funding level diversity, and the survey data illustrated this very broad range of burden hours. A nation-wide estimate for burden hours was calculated based on median survey values. The current approximation of annual burden hours for this information collection, derived from the survey data, is 367 hours per State per year, which works out to 20,185 hours nation-wide (i.e., 55x367).
The annualized cost of the hour burden, expressed in dollars is:
Average Cost/Hour |
Average Burden Hours/State |
Average Annual Cost/State |
Total Annual Cost |
$40 |
367 |
$14,680 |
$807,400 |
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There is no annual cost burden or startup cost to respondents resulting from collection of information for the PPR.
Annualized Cost to the Federal Government
This computation is based on an estimated $40 per hour for the efforts of a Program Specialist; this estimated hourly rate includes fringe benefits.
Program specialists will devote an estimated 400 hours every year to organize and review the Program Performance Reports and to generate analyses of the information therein for staff use.
Total Estimated Federal Costs:....................... $16,000
Explanation for Program Changes or Adjustments
There are program changes in that the instrument and content changed. The following are program changes: 1.) Section III(B) of the 5-Year State Plan template now specifies which information grantees should include as a part of their Comprehensive Review and Analysis and in completing the ‘Portrait of the State.’ 2.) Section III (C ) now asks grantees to summarize the state’s issues and challenges. Section IV (A) asks grantee to identify their own goal that relates to indicators of progress given rather than use pre-determined goals. This section also asks that an outline is included that describes objectives, implementation strategies, and a timeline. Section IV (B) includes more specific guidance on determining a self-advocacy goal. Section V requires the grantee to specifically identify its evaluation plan. Section VI now has budget information explained by goal and was previously described by area of emphasis.
These changes were made to better align the State Plan Template with the DD Act requirements for the program. While the Councils were required to submit plans that met the DD Act requirements, the former template for collecting this information was an awkward planning document. The changes made were intended to better support and make improvements in the template as a planning document for the Councils. To this end, the information collected remained the same, the format for providing that information was improved with the changes.
Despite the above changes there is no change in burden because there was no change in the information required. There is no adjustment.
Plans for Tabulation and Publication and Project Time Schedule
The results of this information collection are not planned to be published for statistical use.
The State plans are prepared by the Councils, made available in the States for public comment, submitted to the Governors' offices for approval, and finally submitted to the Regional Offices by August 15 of each year. Program personnel in the Regional Offices check the State plans for completeness and for compliance with the DD Act, and prepare program reviews and summaries of the information for use by ADD staff, and for program management studies. The information is then forwarded to the Central Office. Program personnel in ADD, Central Office, aggregate the data, do national analyses (sum, average, etc.), and other management studies.
The information collected within the State plan is mandated by legislation and once acquired becomes a public document following approval by the Commissioner, ADD. The information obtained is used by ADD to develop program priorities.
Additionally, data is collected in the State Plan and submitted to ADD for compliance with the Government Performance and Results Act of 1993 (GPRA). In the State Plans, the Councils provide to ADD future year targets for outcome performance measures. These targets are used to monitor accountability of the State Councils for their plans, and to maintain quality control for data in development of reports to Congress under GPRA.
The small amount of quantitative data is summed to show national totals for reports. Analysis and reporting of the data includes pie charts and bar charts.
The States submit the State plan once every five years, with annual review and amendments.
Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable.
Exceptions to Certification for Paperwork Reduction Act Submissions
Not applicable.
B. Statistical Methods (used for collection of information employing statistical methods)
This information collection does not employee statistical methods.
| File Type | application/msword |
| Author | ACF |
| Last Modified By | Bridget C.E. Dooling |
| File Modified | 2011-08-12 |
| File Created | 2011-08-12 |