Generic for ACF Program Monitoring Activities
OMB Information Collection Request
0970 - NEW
Supporting Statement Part A - Justification
September 2020
Administration for Children and Families
U.S. Department of Health and Human Services
SUPPORTING STATEMENT A – JUSTIFICATION
Circumstances Making the Collection of Information Necessary
This information collection request (ICR) is for a new overarching generic clearance. The proposed Generic for ACF Program Monitoring Activities would allow Administration for Children and Families (ACF) program offices to collect standardized information from recipients that receive Federal funds to ensure oversight, evaluation, support purposes, and stewardship of Federal funds. The information is necessary to ensure compliance with Federal and programmatic requirements, monitor progress on recipient activities, and determine and respond to recipient needs such as Training and Technical Assistance (T/TA).
ACF is primarily a grant-making agency that promotes the economic and social well-being of families, children, individuals and communities with partnerships, funding, guidance, T/TA.
ACF program offices have evolving monitoring needs, dependent on both internal and external factors, such as but not limited to: current grantee activities, needs; uses of federal funds; changes to aspects of programs based on statutory authority, federal regulations or policy, and/or Congressional appropriations; availability of program office funds for site visits (v. desk monitoring); matters of importance related to national health and safety needs of the public, or other events that lead to program changes. There are times when standardized collections of information would be helpful for program offices as they monitor recipient activities and needs.
A generic clearance would allow program offices the flexibility to create tailored information collections based on current circumstances and to receive approval for these in a timely manner. This is important to allow for ACF’s:
monitoring of compliance with federal practice, guidelines and requirements,
quick understanding of and remediation to national, regional, and/or site-specific issues,
provision of support as needed,
accurate assessment of the efficiency and efficacy of recipient activities
documentation of promising practice, innovative services, and program strengths
flexible and responsive oversight of federal funds
Purpose and Use of the Information Collection
Program monitoring is a post-award process through which ACF assesses a recipient’s programmatic performance and business management performance. Monitoring activities are necessary to ensure timely action by ACF to support grantees and protect federal interests.
Program offices would use information collected under this generic clearance to monitor funding recipient activities and to provide support or take appropriate action, as needed. This could include:
Oversight and evaluation of grantee performance: technical/programmatic, financial, and business management.
Assessment of progress towards meeting Funding Opportunity Announcement objectives.
Confirmation of compliance with grant requirements: determining whether federal grants are being used for the purposes for which they are made and taking appropriate actions for non-compliance and enforcement.
Verification that programs/projects initiated by grantees are carried out in a manner consistent with the grantee’s approved project goals and objectives, and in a manner consistent with ACF’s expectations
Confirmation and assessment of grantee’s subrecipient partnerships.
Program assessment: collecting additional information on the status, activities, and accomplishments of grantees for reports that the HHS Secretary delivers to Congress, as well as office- and program-specific reports.
Day-to-day activities, activities performed at specified intervals, and periodic evaluations of grantee performance that are required by statute or policy.
Determination of certain aspects of continued performance (e.g., continued funding).
Determine if additional actions/support (e.g., T/TA) are needed to increase the potential for success or to protect federal interests (e.g., enforcement actions).
Pretesting of the monitoring tools
The information gathered will be used primarily for internal purposes, but aggregate data may be included in public materials such as Reports to Congress or program office documents. Any plans for sharing information gathered using this generic clearance will be described in each program-specific generic IC (GenIC).
The following are some example monitoring data that might be submitted as a GenIC:
Information about proposed approaches to demonstrating compliance with specific regulations
Interview data with grantee staff about implementation of required activities to identify potential needs for support
Assessment of project outputs and outcomes
Data about caseloads and information about barriers to processing certain caseloads
Survey data about changes to activities, processes, caseloads, etc. in response to a disaster or public health emergency
Example activities that would be out of scope for this generic include:
Information collections for federally-sponsored evaluations.
Information collections for GPRA performance measures.
Information included in the SF-PPR or suitable for the ACF generic PPR.
A program-specific GenIC will be submitted to OIRA for each individual request, along with the Generic Program Support submission template (Attachment A). See Attachments A-C for example GenICs.
Use of Improved Information Technology and Burden Reduction
Program offices may use some form of electronic collection, when appropriate. This could include web pages, email or other online data management systems. Grantees may be required to enter and retrieve information pertinent to their grants through electronic forms closely resembling the paper forms (i.e., fillable PDFs or tailored online data management systems). Use of information technology will be described in each program-specific GenIC.
Efforts to Identify Duplication and Use of Similar Information
No similar data are available. Program offices regularly review existing information available in materials such as grant applications, semi-annual and annual reports on performance progress and financial management, and documents or other materials developed by the grantee throughout the performance period. This information would be used in conjunction with data collected under these generic information collections, but would not duplicate existing information available to ACF.
Impact on Small Businesses or Other Small Entities
These collections will not have an adverse impact on small entities.
Consequences of Collecting the Information Less Frequently
Less frequent collection of information would impact ACF’s ability to effectively monitor funding recipient activities and to respond to recipient needs in a timely manner.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
In
accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13)
and Office of Management and Budget (OMB) regulations at 5 CFR Part
1320 (60 FR 44978, August 29, 1995), ACF published a notice in the
Federal Register announcing the agency’s intention to request
an OMB review of this information collection activity. This notice
was published on July 9, 2020, Volume 85, Number 132, page 41241, and
provided a sixty-day period for public comment. During the notice and
comment period, one comment received, which is attached. The comment
did not address the information collection’s utility, estimated
number of burden hours associated with the collection of the
information,
or other issues pertinent to the information collection.
Explanation of Any Payment or Gift to Respondents
There are no payments of gifts to respondents.
Assurance of Confidentiality Provided to Respondents
Contact information (ex. name, email address, phone number, etc) may be collected for the purpose of following up. Respondents will be informed of intended use of their contact information. Additionally, program offices may request client files to review if information on files is in compliance with program requirement (ex. existence of required information, type/content of information). The program offices will inform respondents that information collected will be used for purposes related to ACF’s monitoring of funding recipients. This could include sharing resulting information about the funding recipient in reports to Congress, for investigations by federal entities such as the HHS Office of the Inspector General and the US Government Accountability Office, or other related purposes.
Any assurances of confidentiality will be described in each program-specific GenIC.
Justification for Sensitive Questions
Information collections under this proposed generic clearance are not expected to include sensitive questions. Each program-specific GenIC will provide information about any potentially sensitive questions.
Estimates of Annualized Burden Hours and Costs
Burden estimates were calculated assuming annual responses from grantees. The average time per response is estimated based on ACF program office feedback in which estimated time for different types of proposed activities were estimated from 1 to 16 hours. We have estimated an average time of 10 hours, but expect a range of requests within GenIC submissions. Each program-specific GenIC will provide information about burden estimates.
Information Collection |
Number of Respondents |
Total Number of Responses per Respondent |
Average Burden Hour per Response |
Total Burden Hours |
Program Monitoring Forms |
1500 |
3 |
10 |
45,000 |
The costs per respondent is expected to vary based on program and the specific GenIC request. Each program-specific GenIC will provide information about cost estimates for that specific information collection. We have estimated a general overarching estimate here, based on Bureau of Labor Statistics data from 2019 for 21-0000 Community and Social Service Occupations
(job code 21-0000; https://www.bls.gov/oes/current/oes210000.htm). The mean national hourly wage for this occupation is $ $24.27. Multiplying this by two (to account for fringe benefits and overhead) results in an average hourly cost of $48.54. The estimate of annualized cost to respondents for hour burden is thus $48.54 times burden hours or $ 2,184,300 over three years, or $728,100 annually.
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There are no other costs associated with this information collection.
Annualized Cost to the Federal Government
Estimated costs to the federal government are based on an estimate of 10% of the time of a GS-13 and GS-14 to oversee information collection activities. We estimate costs to the federal government for all GenICs submitted under this generic to be about $200,000 annually. The costs will vary by program office and by activity, though, and each program-specific GenIC will provide information about costs to the federal government.
Explanation for Program Changes or Adjustments
This is a request for a new overarching generic clearance.
Plans for Tabulation and Publication and Project Time Schedule
Any plans to publish results will be described in individual ICs under this generic clearance.
Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable.
Exceptions to Certification for Paperwork Reduction Act Submissions
No exceptions.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Windows User |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |