Supporting Statement OGM PPR - Program Indicators 7-21-22 final

Supporting Statement OGM PPR - Program Indicators 7-21-22 final.docx

ACF Performance Progress Report - Program Indicators

OMB: 0970-0406

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ACF Performance Progress Report - Program Indicators



OMB Information Collection Request

0970 - 0406



Supporting Statement Part A - Justification


July 2022















Submitted By:

Office of Grants Management

Administration for Children and Families

U.S. Department of Health and Human Services




  1. Circumstances Making the Collection of Information Necessary

The Office of Grants Management (OGM), in the Administration for Children and Families (ACF) is proposing the continued collection of program performance data for ACF’s discretionary grantees. In 2016, OGM developed the ACF-OGM-SF-PPR-B to collect this data based on the basic template of the OMB-approved reporting format of the Program Performance Report. The form was renewed in 2019 with no changes. OGM now seeks to renew the ACF-OGM-SF-PPR-B for continued use by ACF with minor changes to improve the function of the form and utility to the federal government. This includes the addition of a program indicator to collect information on activities recipients conducted during the reporting period to address or advance equity. Addition of this program indicator supports the Biden-Harris Administration’s equity agenda as outlined in Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. Other minor updates are described in A15.


The requirement for grantees to report on performance is OMB grants policy. Specific citations are contained in: (1) 2 CFR 215 Uniform Administrative Requirements, cost Principles, and Audit Requirements for Federal Awards and (2) 45 CFR 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Department of Health and Human Services Awards.



  1. Purpose and Use of the Information Collection

OGM uses this data to determine if grantees are proceeding in a satisfactory manner in meeting the approved goals and objectives of the project, and if funding should be continued for another budget period.



  1. Use of Improved Information Technology and Burden Reduction

The current version of the form is available on the ACF Funding Opportunities web page under Forms, and the revised form will replace the current version once approved. Grantees can download the form, fill it out completely, and send it electronically to OGM, along with other necessary information. Electronic submission of this form is required. Electronic submission reduces burden and makes the process more efficient by eliminating delays inherent in a paper-based manual process.


  1. Efforts to Identify Duplication and Use of Similar Information

The ACF-OGM-SF-PPR-B provides specifics on the information needed in order for OGM to make an informed decision on continued funding for grantees. This request proposes a renewal, with minor revisions, of the form that has been in use by ACF since 2016 to collect grantee performance data. No other Federal agency collects the information required to evaluate these unique program criteria.

  1. Impact on Small Businesses or Other Small Entities

The information requested is the minimum amount needed to comply with program requirements. It cannot be reduced for small entities.


  1. Consequences of Collecting the Information Less Frequently

If this information is not collected, adequate data will not be available to evaluate current grantee projects and determine if funding should be continued. Reduced frequency is not possible as the annual frequency to solicit applications and make grant awards coincides with the annual appropriation of funds by Congress. Furthermore, not collecting data for competitive projects would be inconsistent with Departmental policy and other authorities.



  1. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances that require collection of data to be conducted in any manner referenced in 5 CFR 1320.5.


  1. 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 on April 21, 2022 (87 FR 23865) announcing the agency’s intention to request an OMB review of this information collection activity. This notice provided a sixty-day period for public comment. We did not receive comments.


  1. Explanation of Any Payment or Gift to Respondents

There are no payments or gifts to applicants. The only remuneration is the grant payment dispersed to those entities awarded a grant.



  1. Assurance of Confidentiality Provided to Respondents

Not applicable.



  1. Justification for Sensitive Questions

Questions of a sensitive nature are not asked.


  1. Estimates of Annualized Burden Hours and Costs

The ACF estimates 6,000 grantees will submit the proposed form annually. On average the burden hours per response is 1 hour. Frequency is semi-annually for the budget period. Therefore, the total hourly burden annually is expected to be 12,000 hours.


Total annualized dollar cost based on $74 hourly burden is $888,000 ($74 X 12,000 hours). Respondents vary in occupation greatly, so we estimated this using the mean hourly wage for managers within the Social and Community Service industry (Occupational Employment and Wage Statistics code: 11-9151 Social and Community Service Managers), which was $36.92 in 2021. To account for fringe benefits and overhead cost, we multiplied the mean wage by two.


ANNUAL BURDEN ESTIMATES

Instrument

Number or Respondents

Number of Responses per Respondent

Average Burden Hours Per Response

Total Annual Burden Hours

Estimated Hourly Wage

Total Annual Cost

ACF-OGM-PPR-B

6,000

2

1

12,000

$74

$888,000


  1. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

Not applicable.


  1. Annualized Cost to the Federal Government

It is estimated that, on average, there are 2 hours of labor on the part of government employees to review grantee Program Indicator reports in order to make an informed decision for continued funding. The average annual number of respondents is 6,000 which equates to 12,000 hours of staff time. Based on an average of $50 per hour (estimating an average for federal grants management staff at the GS-12 and GS-13 levels), in monetary terms this equates to $600,000 annually.



  1. Explanation for Program Changes or Adjustments

This is a request for an extension of a previously approved form with minor changes to improve the function of the form. Revisions include collection of the Unique Entity Identifier (UEI) instead of the DUNS, a rewording of the submission instructions to be more inclusive of all possible report submission methods utilized across ACF, and the addition of a program indicator to collect information on activities recipients conducted during the reporting period to address or advance equity.


Burden estimates have not changed.

  1. Plans for Tabulation and Publication and Project Time Schedule

Information in the Program Indicators report will not be published.


  1. Reason(s) Display of OMB Expiration Date is Inappropriate

There will be no exceptions to the practice of displaying the expiration date.



  1. Exceptions to Certification for Paperwork Reduction Act Submissions

Not applicable.



File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSupporting Statement - PPR - Program Indicators
AuthorACF
File Modified0000-00-00
File Created2022-07-27

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