SSA - Financial Rpts NonDisc Grant Recipients_0970-0510_Extension 2024_DRAFT

Generic Clearance for Financial Reports used

for ACF Non-Discretionary Grant Programs

OMB Information Collection Request

0970 - 0510

Supporting Statement Part A - Justification

May 2024

Type of Request: Revision

Submitted By:

Administration for Children and Families

U.S. Department of Health and Human Services

Summary

This request is for a revision to a previously approved overarching generic clearance. The title of the collection has been updated from ACF Mandatory Grant Programs to ACF Non-Discretionary Grant Programs. The proposed types of information collections and purpose and use of the collected information has not changed. This request includes the extension of multiple collections approved under this generic (GenICs) and requests updates to three of these GenICs through this revision process. The Child Care and Development Fund (CCDF) ACF-696 Financial Report for States and Territories and the CCDF ACF-696T Financial Report for Tribal Grantees have been updated to eliminate unused columns and subaccount codes as well as lines that were not funded or were funded once and will be closed. Additionally, the instructions for these forms were updated to reflect changes to the reports and current Office of Child Care and Office of Grants Management policies and program instruction to recipients. The Child Support Services Program Financial Reporting Forms (OCSS-34 and OCSS-396) have been updated to reflect an update to the program office’s name from the Office of Child Support Enforcement to the Office of Child Support Services.

1. Circumstances Making the Collection of Information Necessary

This information collection request (ICR) is to continue use of the umbrella generic: Generic Clearance for Financial Reports used for ACF Non-Discretionary Grant Programs (0970-0510) (Previously titled ACF Mandatory Grant Programs). Generic Information Collections (GenICs) under this umbrella consist of forms for recipients of non-discretionary grant funding to submit financial information to the Administration for Children and Families (ACF).

The authorities to collect and report the information requested on these forms are found in various statutes and Public Laws. For example, Titles IV-A, IV-D and IV-E of the Social Security Act, the “Child Care and Development Block Grant Act,” as amended, and the “Immigration and Nationality Act of 1952,” as amended. Non-discretionary grant funding recipients must have program administration plans approved by ACF and are required by several statutes and Federal regulations applicable to HHS programs, including 45 CFR Part 75, to maintain complete records and a system to report this information to ACF on a regular basis.

ACF programs require detailed financial information from their grant recipients that allows ACF to monitor various specialized cost categories within each program, to closely manage program activities, and to have sufficient financial information to enable periodic thorough and detailed audits.

The information included on the standard Federal Financial Report Form (SF-425; OMB #4040-0014) provides only minimal, bare-bones, non-program specific financial information insufficient for these purposes. This generic clearance allows ACF programs to efficiently develop and receive approval for financial reports that are tailored to specific funding recipients and the associated needs of the program. This umbrella generic is a mechanism that is available to all ACF non-discretionary grant programs to use to obtain OMB approval of financial forms. Currently (April 2024), only a small number of ACF’s non-discretionary grant program financial forms are covered under this umbrella; it does not cover all ACF non-discretionary grant program financial forms.

2. Purpose and Use of the Information Collection

Financial information that is specific to funding recipient activities and the requirements in a funding opportunity announcement is critical to allow ACF program offices the ability to track funding in appropriate ways, allowing programs to monitor use of ACF funds and ultimately protect federal interests.

The information collected through GenICs under this umbrella clearance is used to:

1. Monitor program operations and prepare technical assistance and guidance as needed

2. Assess the effect of program changes and make informed decision

3. Assist in the computation of the grant awards issued to each program’s grant recipients

4. Assist in the computation of the Child Support Enforcement program’s annual incentive payments

5. Determine that child support collections are being properly distributed (Child Support Enforcement Program only)

6. Ensure funding recipients are meeting funding requirements established by Congress

7. Produce annual financial and statistical reports as may be required by Congress and respond to periodic detailed inquiries from Congress

3. Use of Improved Information Technology and Burden Reduction

In accordance with ACF policy published in the Federal Register on June 28, 2013 (78 FR 38989 et. seq.) all grant recipients are required to electronically file financial reports online. ACF maintains OLDC, the “On Line Data Collection” system as the electronic online data entry portal for recipients of ACF grant funds.

All grant recipients for these programs submit their financial data online. The financial data entered by each grant recipients for these programs is transferred to GrantSolutions, or other programs, where it is available for thorough review and approval by Federal financial staff.

4. Efforts to Identify Duplication and Use of Similar Information

Information collected in these financial reports is not available through any other federal source.

5. Impact on Small Businesses or Other Small Entities

These forms are completed only by the state, territories, and tribal governmental agencies administering these programs. Small businesses and other entities are not involved.

6. Consequences of Collecting the Information Less Frequently

The financial data collected through the individual GenICs varies but is most commonly collected on a quarterly basis. The information is used extensively by each program to actively monitor program activities and to address needs in a timely manner, so is needed on a quarterly basis. Additionally, failure to collect this data on a quarterly basis would preclude the Department from accurately calculating and issuing these awards in a timely manner.

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

Collection of state financial data is consistent with guidelines. The information requested is necessary to satisfy statutory requirements.

8. 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 January 23, 2024 (89 FR 4306) and provided a sixty-day period for public comment. We received one comment on the proposed collection of information. The commenter expressed concerns that ACF had previously responded to, but in response to the recent inquiry, dated January 26, 2024 ACF provides the following response. 

• We have reviewed the OCSE 396 Report, Line 10 per this request and prior comments that we have received from this individual.  Our analysis has determined that 45 CFR 303.70 (e)(2)(iii) provides that the payment of a fee by the IV-D agency is not a reimbursable expense under the IV-D program. Rather, such amounts would be counted as program income.  Therefore, the authority does not permit states to claim FFP reimbursement for FPLS user fees, and there is no requirement that there be federal funding reimbursement for underpayments to states for FPLS user fees. We appreciate the concern regarding states ability to claim FFP for FPLS user fees, but ACF does not feel that any action is necessary. Please know that this response is intended to address all inquiries from this individual to ACF on this matter.

Prior to a new form being submitted for review under this umbrella generic, ACF will publish a notice in the Federal Register announcing the agency’s intention to request an OMB review of the form and providing a 14-day period for public comment on that specific GenIC. ACF will review any comments received and address them as appropriate. ACF will provide a copy of any comments received and will provide a description of how comments were considered in the submission form along with the request package for the GenIC.

If substantive revisions, such as changes to reporting requirements, are proposed to an approved GenIC, ACF will follow a similar process through which a notice in the Federal Register will be published to announce the agency’s intention to request an OMB review of the form and provide a 14-day period for public comment on the changes to that specific GenIC.

In addition to the solicitation for comments in the Federal Register, each of these financial reporting forms for each of these separate ACF non-discretionary grant programs is constantly being reviewed by ACF financial staff in headquarters and the ten Regional Offices. As needs for changes to the reporting requirements outlined in an approved form under this umbrella generic arise, ACF will engage stakeholders for advice and suggestions to assure the changes are rational and reasonable and meet the requirements of Federal law and the ability of grant recipients to provide the requested information. Stakeholders could include program grant recipients, affiliated advocacy groups, or others with a direct interest in these financial reporting requirements. If reporting requirements change in response to new legislation, the agency may need to conduct this stakeholder engagement after implementing the change(s) to reporting requirements. In such cases, ACF will engage stakeholders for feedback after implementation and work with OMB to make resulting changes, if necessary.

9. Explanation of Any Payment or Gift to Respondents

No payments or gifts to respondents will be provided to respondents.

10. Assurance of Confidentiality Provided to Respondents

Not applicable for these financial reports.

11. Justification for Sensitive Questions

Data collected are not of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

The total burden request under this extension includes the previously approved and ongoing burden and the estimated burden over the next 3 years. The total requested burden under this OMB # is 160,671 hours. The tables below provide details for these estimates.

Previously Approved and Ongoing

Information Collection Title	Total Number of Respondents	Annual Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Total Burden Hours
Child Care and Development Fund (CCDF) ACF-696 Financial Report for States and Territories	56	4	6	1,344	4,032
Child Care and Development Fund (CCDF) ACF-696T Financial Report for Tribal Grantees	221	1	7	1,547	4,641
Form CB-496: Title IV-E Programs Quarterly Financial Report	67	4	25	6,700	20,100
Child Support Services Program Financial Reporting Forms (OCSS-34 and OCSS-396)	168	4	14	9,408	28,224
Refugee Cash and Medical Assistance Federal Financial Report (ORR-2) Supplemental Data Collection	66	1	1.67	110	330
Refugee Support Services Federal Financial Report (SF-425) Supplemental Data Collection	53	4	4	848	2,544
Totals:				19,957	59,871

Estimated Burden and Costs for Future Requests

The following burden estimates are for future GenICs under this umbrella generic. Updated burden estimates are based on the use over the past three years and anticipated need in the upcoming three years.

Information Collection Title	Total Number of Respondents	Annual Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Total Burden Hours	Average Hourly Wage	Total Annual Cost
Non-discretionary Grant Financial Reports	700	4	12	33,600	100,800	$53.62	$1,801,632

The costs per respondent are 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 2022 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 $26.81.  Multiplying this by two (to account for fringe benefits and overhead) results in an average hourly cost of $53.62. 

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

Federal grant recipients are required to maintain extensive and accurate accounting records as a condition of receiving any federal grant. Any costs associated with collecting and maintaining this information is, generally, considered an administrative cost allocated to each program, as appropriate, and is eligible for federal funding. As such, there is no additional cost burden to respondents to provide the information being requested on these financial reporting forms.

14. Annualized Cost to the Federal Government

We estimate costs to the federal government for all GenICs submitted under this generic to be about $400,000 per year. This includes the initial cost of incorporating periodic form changes into online programming, using collected data in the computation of quarterly Notices of Award, tabulating and analyzing collected data, and publishing aggregate information in an annual report. 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.

15. Explanation for Program Changes or Adjustments

This request is for a revision to a previously approved overarching generic clearance. We have updated burden estimates to reflect ongoing data collections that are currently approved. The title of the collection has been updated from ACF Mandatory Grant Programs to ACF Non-Discretionary Grant Programs. This request also includes updates to three of the collections approved under this generic (GenICs): the Child Care and Development Fund (CCDF) ACF-696 Financial Report for States and Territories, the CCDF ACF-696T Financial Report for Tribal Grantees, and the Child Support Services Program Financial Reporting Forms (OCSS-34 and OCSS-396).

• CCDF ACF-696 Financial Report for States and Territories: ACF proposes minor updates to the ACF-696 form that include the removal of “CCDX2” which is a subaccount code not used by ACF; the removal of Column F for “Discretionary Disaster Relief Funds Construction and Major Renovation Grant Document Number CCDY” which is a program not funded by ACF; the removal of line 9(a) “was the state or territory unable to obligate at least 50% of the CCDF stabilization grants by December 11, 2021?” because this question relates to a subaccount for a program set to close by 9/30/2024; and the removal of the reallotted funds selection for COVID supplemental funds since the deadline to request reallotted funds for these subaccount awards is in the past. The instructions for this form were updated to account for the described changes, to clarify existing instructions, and to update language to reflect current Office of Child Care and Office of Grants Management policies and program instruction to recipients.

• CCDF ACF-696T Financial Report for Tribal Grantees: ACF proposes minor updates to the ACF-696 form that include the removal of “CCDX2” which is a subaccount code not used by ACF; the removal of Column F for “Discretionary Disaster Relief Funds Construction and Major Renovation Grant Document Number CCDY” which is a program not funded by ACF; the renaming of line 13a “total federal unliquidated” to “total federal obligations (not yet liquidated) (excluding construction/major renovation” to clarify what amount should be reported on this line; the addition of line 13b. “total federal obligations Into yet liquidated) for construction/major renovation” to distinguish between CCDF activities and activities for the construction or major renovation of CCDF projects; the removal of line 14(a) “was the tribal lead agency unable to obligate at least 50% of the CCDF stabilization grants by December 11, 2021?” because this question relates to a subaccount for a program set to close by 9/30/2024; and the removal of the reallotted funds selection for COVID supplemental funds since the deadline to request reallotted funds for these subaccount awards is in the past. The instructions for this form were updated to account for the described changes, to clarify existing instructions, and to update language to reflect current Office of Child Care and Office of Grants Management policies and program instruction to recipients.

• Child Support Services Program Financial Reporting Forms (OCSS-34 and OCSS-396): The title of these forms was updated to reflect the change in name of the program office from the Office of Child Support Enforcement to the Office of Child Support Services. References to the name within the forms and instructions were also updated.

16. Plans for Tabulation and Publication and Project Time Schedule

Information on these forms is published in aggregate and state-by-state or tribe-by-tribe formats and in combination with other programmatic data collected by ACF. The data are published following each fiscal year, once received from every grant recipient, in an annual report available to the general public. Any additional plans for sharing information will be specified in each program-specific GenIC. No complex analytical techniques are required.

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

Such approval is not being sought; the expiration date will be shown as needed.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

None.