This information collection is a
direct response to recommendations for strengthening LIHEAP program
integrity made by the Government Accountability Office in 2010 and
the LIHEAP Program Integrity Work Group, which consisted of a
sample of LIHEAP grantees. The purpose of this data collection is
to gauge the capacity of LIHEAP grantees to perform two critical
tasks. 1. To implement third-party verification of household data
obtained during the LIHEAP intake process, in order to strengthen
program integrity by reducing the risk of making LIHEAP benefit
payments to ineligible households or in the wrong amount. These
risks arise in large part when there are errors or fraud in the
reporting of household members' identity and income during the
LIHEAP intake process.
The information
collection is a direct response to recommendations for
strengthening LIHEAP program integrity made by the Government
Accountability Office (GAO) in 2010 and the LIHEAP Program
Integrity Work Group which consisted of a sample of LIHEAP
grantees. The information collection for both contracts are
essential tasks and are initially required in order for the
contractor to proceed with the major development of the web based
data collection tool and the implementation of the program
integrity recommendations such as third party verification of
household data. Clearance for the questionnaire could not be sought
prior to the award of the contracts, because the content
development of the instrument was as requirement under the two new
contracts that DEA entered into. DEA is finalizing the
questionnaire content for those assessments and can submit them as
soon as OMB is ready to receive them. At the same time, other tasks
under the contracts are contingent upon the information collected
by the survey. Without an expedited clearance, successful
completion of the contract tasks is at risk. Contractors have
projected that they will need to begin data collection through this
questionnaire in October 2013 in order to proceed with the other
tasks on a timely manner and meet their legal obligations per the
contracts with our office. Contractors are expected to submit other
required deliverables that depend on the results of this
questionnaire no later than April 18, 2014. These deliverables are
needed in order for grantees to make preparations in time to begin
the performance measures data collection on October 1, 2014. The
normal OMB clearance process would not be completed until after
these contractual deadlines. According to the 5 C.F.R. Part
1320.13, an agency head or Senior Official, or their designee, may
request OMB to authorize emergency processing of submissions of
collections of information in writing. Specifically, if the agency
cannot reasonably comply with the normal clearance procedures
because an unanticipated event occurred, expedited processing may
be used. In the instant case, P.L. 110-351 gives ACF a very narrow
window in which to provide technical assistance prior to the
effective date of the new sections of the Act. If we are unable to
obtain expedited clearance for the information collection, the
contractors' ability to deliver their required tasks and outputs
will be severely compromised and affect the planned training and
technical assistance services to grantees.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.