ACL Memo Justification for no material change

DEPARTMENT OF HEALTH & HUMAN SERVICES

Administration for Community Living
Washington, D.C. 20201

To:

Julie Wise
Office of Information and Regulatory Affairs

From:

Tomakie Washington
Administration for Community Living

Re:

COVID-19 non-substantive modifications to the No Wrong Door Management Tool
under OMB# 0985-0062

Date:

March 10, 2021

The Office of Network Development (ONA) uses a subset of the OMB approved No Wrong Door
Management Tool (NWD MT) (OMB# 0985-0062) as the semi-annual reporting requirement for the 55
states and territories receiving ADRC COVID-19 Emergency CARES Act funding. This request is a nonsubstantive change to the currently approved NWD MT in order to collect metrics specific to CARES Act
funding and the changing landscape of the COVID-19 pandemic.
As background, the purpose of the NWD MT data collection is to provide a platform for documenting
key elements that are necessary to evaluate the progress of the NWD System model and to understand
and document the extent to which a state’s NWD System is streamlining and coordinating access to long
term services and supports (LTSS.) The NWD MT tracks key performance measures and identifies best
practices and technical assistance needs. It also supports ACL in tracking performance outcomes and
efficiency measures with respect to the annual and long-term performance targets established in
compliance with the Government Performance Results Modernization Act (GPRMA).
ACL proposes an update to the NWD MT with three additional metrics to allow grantees to report on 1)
activities paid for by CARES Act funds, 2) ADRC involvement in COVID-19 vaccine rollout, and 3)
state/territory specific legislation that define or dedicate ADRC/NWD programs and services. Without
clearly identifying CARES Act activities from other NWD activities, ACL will not be able to distinguish
services provided with the funding and will not be able to report on grantee’s critical COVID relief
efforts. In addition, to support priorities for vaccine rollout, specific time sensitive collection of this data
is needed from the states and territories.
Burden changes are minimal; all of the information is collected or known by state and territory
ADRC/NWD programs and would not necessitate new data collection processes for the grantees. In
addition, using a subset of questions from the NWD MT for the semi-annual reporting is already a
reduced burden from the approved data collection instrument. For these reasons, the proposed updates
fit the terms of clearance for a non-substantive/no material change request under the PRA.
Cc:
Kelly Cronin, Deputy Administrator
Center for Innovation and Partnership
Joseph Lugo, Director
Office of Network Advancement