Supporting statement redline update

Supporting Statement for Paperwork reduction Act Submission
Youth Homelessness Demonstration Program (YHDP)
OMB Number: 2506-0210

1. Explain the circumstances that make the collection of information necessary. Identify any
legal or administrative requirements that necessitate the collection. Attach a copy of the
appropriate section of each statute and regulation mandating or authorizing the collection of
information.
The Youth Homelessness Demonstration Program (YHDP) was designed with the goal to
prevent and end youth homelessness. In 2023, $72 million was made available to
communities to apply to identify, engage and respond to the needs of youth experiencing
homelessness. The purpose of the YHDP is to support in the development and
implementation of a coordinated community approach to preventing and ending youth
homelessness and sharing that experience with and mobilizing communities around the
country toward the same end. This goal includes assisting unaccompanied youth, including
pregnant or parenting youth, age 24 and under, and can be broken down into eight objectives:


Prevent and End Youth Homelessness. Provide funding, regulatory flexibility, and
technical assistance to help communities develop housing and services for youth
experiencing homelessness and make youth homelessness rare and, if it occurs, brief and
non-recurring.



Build national momentum. Motivate state and local homelessness stakeholders and
youth services providers, including Runaway and Homeless Youth providers across the
country to prevent and end youth homelessness by forming new partnerships, addressing
system barriers, conducting needs assessments, testing promising strategies, and
evaluating their outcomes.



Promote equity in the delivery and outcomes of homeless assistance. Recipients
should promote equity throughout the community's youth homeless response system for
youth who are disproportionally more likely to experience homelessness, such as Black,
Indigenous, Hispanic (non-white), and LGBTQ+ youth. Awarded communities will
promote equity throughout their youth homeless response system and all YHDP projects
will measure and demonstrate equitable delivery and outcomes. This includes identifying
barriers that led to any disparities in subpopulations being served and taking steps to
eliminate these barriers in the community's youth homeless response system.



Highlight the importance of youth leadership. Demonstrate effective models of strong
leadership and agency by youth with lived experience in the community. Create
replicable best practices of youth leadership for other communities.



Evaluate the coordinated community approach. Evaluate coordinated community
approaches to preventing and ending youth homelessness, including local and state
partnerships across sectors and other coordinated operational planning.



Expand capacity. Expand community capacity to serve youth experiencing
homelessness (particularly by using a Housing First approach), pilot new models of
assistance, and determine what array of interventions is necessary to serve the target
population in their community.



Evaluate performance measures. Evaluate the use of performance measurement
strategies designed to better measure youth outcomes and the connection between youth
program outcomes and youth performance measures on overall system performance for
the Continuum of Care (CoC); and



Establish a framework for Federal program and Technical Assistance (TA)
provider collaboration: Determine the most effective way for Federal resources to
interact within a state or local system to support a coordinated community approach to
preventing and ending youth homelessness.

Appropriations for the YHDP have been made available in Federal Fiscal Years (FFYs)
2016-2023. The most recent appropriation, the Consolidated Appropriations Act, 2023
(Public Law 117-328, approved December 29, 2022) made $72 million available to HUD “to
implement projects to demonstrate how a comprehensive approach to serving homeless
youth, age 24 and under, in up to 25 communities, including at least eight rural communities,
can dramatically reduce youth homelessness.” HUD awards YHDP funds through a Notice
of Funding Opportunity (NOFO) in order to identify those communities that will make best
use of the congressionally appropriated funds and provide HUD with the best opportunity to
meets the demonstration objectives. Without asking for this information, HUD will be
unable to meet the congressional mandate within the appropriations act.
Once communities have been selected, HUD must collect individual grant applications
related to the specific projects to be implemented.
Finally, HUD must collect the Coordinated Community Plan to meet the appropriations
requirement to “demonstrate how a comprehensive approach to serving homeless youth...can
dramatically reduce youth homelessness.” In HUD’s experience leading similar coordinated
community efforts (e.g., LGBTQ Youth Homelessness Prevention Pilot, OMB 2506-0204),
the planning process is a challenging and resource intensive endeavor, requiring systems
analysis, values sharing, priority negotiating, the creation of leadership structure, the
development of a logic model, and a plan for constant feedback and continuous process
improvement, among other things. The submission of a coordinated community plan will
allow HUD to assess the ability of the selected communities to appropriately use the funding
made available by Congress.

2. Indicate how, by whom and for what purpose the information is to be used. Except for a new
collection, indicate the actual use the agency has made of the information received from the
current collection
Information will be collected in two phases using an electronic submission process. The first
phase is the community selection application submission process, and the second phase
includes both the project application and coordinated community plan submission processes.
The community selection submission process will use grants.gov to coordinate electronic
submission of grant applications. The information collected will be used to rate community
selection applications, to determine eligibility for participation in the YHDP, to select
participating communities and to establish the amounts available for each community. It is
anticipated that applicantsApplicants, which must be collaborative applicants registered
under the CoC Program (see OMB 2506-0182), will respond to narrative prompts to
demonstrate the integration of the Youth Action Board into the CoC structure; Community
Need; Collaboration; Youth Collaboration; and Data and Evaluation Capacity. Additionally,
the community selection process will include twoa bonus point opportunities: Serving
Structurally Disadvantaged Areas and for Rural Areas.
Individual YHDP project applications will be submitted following the announcement of
community selection. The information collected will be used to determine project eligibility
and quality, whether the proposed project aligns with the community’s coordinated
community plan, and project award amounts. Applicants must be public or private
organizations and will use the HUD electronic grants management system, e-snaps, which is
the same form and process used during the CoC Program Competition (see OMB 25060112). Using the same information collection tools as the CoC Program Competition is
critical to ensure that the awarded project will be in compliance and prepared to apply under
the CoC Program when the first grant term expires if they apply for renewal.
Selected communities are required to develop a coordinated community plan to prevent and
end youth homelessness, which must be submitted electronically via email to HUD within 6
months of the site selection announcement. Communities may request up to a 2-month
extension of this deadline by sending an email. The information collected will be used to
determine HUD approval of a coordinated community plan, and will depend on threshold
criteria, including whether the plan addresses the mandatory structural components and key
HUD principles included in the NOFO that are essential to a successful youth homelessness
system.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology, e.g., permitting electronic submission of responses, and the
basis for the decision for adopting this means of collection. Also describe any consideration
of using information technology to reduce burden.

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HUD will require an electronic submission process for all phases of the YHDP to streamline
the application process and lessen reporting burden on applicants. The collection of
information for the YHDP is not automated in any way. Applicants will submit applications
electronically and reviewers will review and score applications manually. Applicants do have
the ability to request a waiver of the electronic application submission requirement.
4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for use for the purposes described in Item 2
above.
To avoid duplication of information, the community selection process and project
applications collect each data element only once, with one process focused on a system and
the other on a project level. The coordinated community plan is designed to develop a unique
product for the community. HUD has worked hard to eliminate overlap between the
different steps in the process and is requesting new information that has not been captured
from these communities for other federal government programs, regardless of whether the
applicant is a current or former recipient of federal government funds. The creation of an
electronic submission process is an attempt to lessen reporting burden on applicants.
5. If the collection of information impacts small businesses or other small entities describe any
methods used to minimize burden.
The need to consider all applications on an equal basis make it difficult to give special
consideration to the burden placed on small entities by the collection of information. Instead,
efforts were made to minimize the burden placed on all applicants, while at the same time
ensuring that sufficient information would be provided to allow HUD to determine and select
the best proposals.
6. Describe the consequence to Federal program or policy activities if the collection is not
conducted or is conducted less frequently, as well as any technical or legal obstacles to
reducing burden
The intent is for information to be collected one time for the purposes of this NOFO; it is
required to fully assess each applicant’s qualifications for the specific purposes of the YHDP.
All information collected is used to carefully consider applications for selection, funding, and
to determine whether the selected communities have met the expectations established by
Congress; if HUD collects less information, or collected it less frequently, the Department
could not accurately identify eligible sites, determine the eligibility of applicants for grant
funds, or ensure that funds were spent according to the intention of the appropriations.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:


requiring respondents to report information to the agency more than quarterly; does not
apply

requiring respondents to prepare a written response to a collection of information in fewer
than 30 days after receipt of it; does not apply
 requiring respondents to submit more than an original and two copies of any document;
does not apply
 requiring respondents to retain records other than health, medical, government contract,
grant-in-aid, or tax records for more than three years; does not apply
 in connection with a statistical survey, that is not designed to produce valid and reliable
results than can be generalized to the universe of study; does not apply
 requiring the use of a statistical data classification that has not been reviewed and approved
by OMB; does not apply
 a pledge of confidentiality that is not supported by authority established in statute or
regulation, that is not supported by disclosure and data security policies that are consistent
with the pledge, or which unnecessarily impedes sharing of data with other agencies for
compatible confidential use; or does not apply
 requiring respondents to submit proprietary trade secret, or other confidential information
unless the agency can demonstrate that it has instituted procedures to protect the
information's confidentiality to the extent permitted by law. does not apply


8. If applicable, provide a copy and identify the date and page number of publication in the
Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on
the information collection prior to submission to OMB. Summarize public comments
received in response to that notice and describe actions taken by the agency in response to
these comments. Specifically address comments received on cost and hour burden.


Describe efforts to consult with persons outside the agency to obtain their views on the
availability of data, frequency of collection, the clarity of instructions and recordkeeping
disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or
reported.



Consultation with representatives of those from whom information is to be obtained or
those who must compile records should occur at least once every 3 years -- even if the
collection of information activity is the same as in prior periods. There may be
circumstances that preclude consultation in a specific situation. These circumstances
should be explained.
Published in the Federal Register on April 10, 2023, vol 88, page 21204. No comments
were received.

9. Explain any decision to provide any payment or gift to respondents, other than renumeration
of contractors or grantees.
There will be no payments or gifts to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance
in statute, regulation or agency policy. If the collection requires a system of records notice
(SORN) or privacy impact assessment (PIA), those should be cited and described here.

Privacy Analysis and Impact Assessment is attached to this packet. No assurances of
confidentiality are offered.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private. This justification should include the reasons why the agency considers the questions
necessary, the specific uses to be made of the information, the explanation to be given to
persons from whom the information is requested, and any steps to be taken to obtain their
consent.
This information collection does not include any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are commonly
considered private. The information will collect program and system level data only, and no
personally identifiable information will be collected regarding current or future program
participants.
12. Provide estimates of the hour burden of the collection of information. The statement should:





Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should
not conduct special surveys to obtain information on which to base hour burden
estimates. Consultation with a sample (fewer than 10) of potential respondents is
desirable. If the hour burden on respondents is expected to vary widely because of
differences in activity, size, or complexity, show the range of estimated hour burden, and
explain the reasons for the variance. Generally, estimates should not include burden
hours for customary and usual business practices;
If this request covers more than one form, provide separate hour burden estimates for
each form and aggregate the hour burdens in chart below; and
Provide estimates of annualized cost to respondents for the hour burdens for collections
of information, identifying and using appropriate wage rate categories. The cost of
contracting out or paying outside parties for information collection activities should not
be included here. Instead, this cost should be included in Item 13.

The YHDP has two phases and three main components:
Phase 1
Component 1. Community Selection Application
 Narrative responses; and
 Required attachments
Phase 2
Component 2. Project Application
 Narrative, grid form, numeric, and multi-choice, responses: and
 Required attachments

Component 3. Coordinated Community Plan
 Narrative-based plan and logic model (template provided)
YHDP selected communities will be CoCs, or parts of CoCs, represented by the CoC
collaborative applicant. These entities have demonstrated experience completing a CoC
Program Competition CoC application, which is a longer a more comprehensive system-wide
homelessness system application process. The burden estimates are based on HUD’s long
experience with the CoC Program Competition and the understanding that all applicants by
definition will have experience responding to similar style and related homelessness system
questions.
YHDP project applicants will be local or state government entities, local public housing
authorities, Indian Tribes or tribally designated housing entities as defined in Section 4 of the
Native American Housing Assistance and Self-Determination Act of 1996 (25 U.S.C. 4103),
or public or private nonprofit entities. The application is designed to replicate the CoC
Program Competition project application which has been used in a similar form for several
years and with which many applicants for the YHDP will be familiar including the exact
project application questions. The burden estimates are based on HUD’s long experience
with the CoC Program Competition Project Application and the understanding that many
applicants will be current or former CoC Program project grant recipients and therefore will
have experience responding to the exact questions in the application.
YHDP coordinated community plans will be completed by each of the selected communities.
The burden estimates are based on HUD’s staff experience and input of previous year
applicants.
The required attachments include:


SF-424, Application for Federal Assistance.



HUD-424-B- Applicant Assurances and Certifications.



Non-profit certification, for non-profit applicants only.



Organization’s Code of Conduct (Most already on file accounted for during the CoC
Program Competition).



Acknowledgement of Application Receipt (HUD2993), for applicants submitting
paper applications only.

Approximately 150 applicants will submit applications for Component 1, 25 will submit an
average of 5 applications each for Components 2, and 25 will submit plans for Component 3.
Estimates of the public burden are shown in the table below:
Information
Collection

Number of
Respondents

Frequency
of Response

Responses
Per
Annum

Burden
Hour Per
Response

Annual
Burden
Hours

Hourly
Cost Per
Response

Annual Cost

Commented [UJ1]: New chart

Component 1. Community Selection
YHDP
SiteCommunity
Selection Narratives
SF-424- Application
for Federal
Assistance
HUD-424BApplicant Assurances
and Certifications
OMB-SF-LLLDisclosure of
Lobbying Activities
(where applicable)
Nonprofit
Certification
Organizations Code
of Conduct
Youth Action Board
Participation Letter
Public Child Welfare
Agency Commitment
Letter
Acknowledgement of
Application Receipt
(HUD-2993) (only
applicants granted
waiver to submit a
paper application)
Subtotal

150

1

150

24

3,600.00

53.67

$193,212.00

150

1

150

0.5

750

53.67

$4,025.250

150

1

150

0

0

$53.67

$0

10

1

10

0.17

1.70

$53.67

$91.240

150

1

150

0

0

$53.67

$0.00

150

1

150

0

0

$53.67

$0.00

150

1

150

0.5

75

53.67

$4,025.25

150

1

150

0.5

75

53.67

$4,025.25

10

1

10

0.17

0.34

$53.67

$18.250

150

3,827.04750.
00

150

205,397.24$2
01,262.50

Component 2. Project Application
YHDP Project
Application
Questions
SF-424- Application
for Federal
Assistance
HUD-2880Applicant/Recipient
Disclosure/Update
Report ((2501-0017))
(2501-0017)
OMB-SF-LLLDisclosure of
Lobbying Activities
(where applicable)
Subtotal

75125

51

125

8

1,000.00

53.67

$53,670.00

75125

51

125

0.08

100

$53.67

$536.700

75125

51

125

0.17

21.25

53.67

$1,140.49

75125

51

125

0.17

21.250

$53.67

$1,140.490

75125

1,052.50021.
25

125

$56,487.6854
,810.49

Component 3. Coordinated Community Plan
YHDP Plan Narrative
Logic Model
Certification of
Consistency with the
Consolidated Plan
(HUD-2991)

25
25

1
1

25
25

240
8

6,000.00
200

53.67
53.67

$322,020.00
$10,734.00

25

1

25

0.17

4.25

53.67

$228.10

(2506-0112)
Subtotal
Total Application
Collection

25
150

1

25
300

248.17

6,204.25
11,083.7910,
975.50

$332,982.10
$594,867.035
89,055.09

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting
from the collection of information. (Do not include the cost of any hour burden already
reflected on the burden worksheet shown in Items 12 and 14).






The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and
maintenance purchase of services component. The estimates should take into account
costs associated with generating, maintaining, and disclosing or providing the
information. Include descriptions of methods used to estimate major cost factors
including system and technology acquisition, expected useful life of capital equipment,
the discount rate(s) and the time period over which costs will be incurred. Capital and
start-up costs include, among other items, preparations for collecting information such as
purchasing computers and software; monitoring, sampling, drilling and testing
equipment; and record storage facilities;
If cost estimates are expected to vary widely, agencies should present ranges of cost
burdens and explain the reasons for the variance. The cost of purchasing or contracting
out information collection services should be a part of this cost burden estimate. In
developing cost burden estimates, agencies may consult with a sample of respondents
(fewer than 10) utilize the 60-day pre-OMB submission public comment process and use
existing economic or regulatory impact analysis associated with the rulemaking
containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions
thereof made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with
requirements not associated with the information collection, (3) for reasons other than to
provide information or keep records for the government, or (4) as part of customary and
usual business or private practices.

There are no capital costs to respondents or record keepers.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description
of the method used to estimate cost, which should include quantification of hours,
operational expenses (such as equipment, overhead, printing, and support staff), and any
other expense that would not have been incurred without this collection of information.
Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
Estimates of annualized cost to the Federal government (clerical and professional staff time)
Review each Community Selection Application ($53.67* per hr. x 2 hrs. x 150 applications

$16,101.00

Notification of Community Selection Applicants ($53.67* per hr. x .5 hrs. x 25 selected
sites)
Review each Project Application ($53.67* per hr. x 2 hrs. x 125 applications

$670.88

$13,417.50

Notification of Project Applicants ($53.67* per hr. x .5 hrs. x 50 awardees)

$670.88

Review each Coordinated Community Plan ($53.67* per hr. x 2 hrs. x 25 plans)

$2,683.50

Notification of Collaborative Applicants ($53.67* per hr. x .5 hrs. x 25 selected sites)
TOTAL

$670.88
$34,214.64

**This figure is based on a GS-13 salary from 2023 General Schedule (GS) Locality Pay Tables
** The number of CoCs is doubled to reflect the need for two reviewers of each application.

15. Explain the reasons for any program changes or adjustments reported in Items 12 and 14 of
the Supporting Statement.
This submission is to request a revision of a currently approved collection. This is a previous
program with adjustments in the burden cost and hours. The changes in burden cost are due
to increase in the GS hourly pay rate from $47.52 to $53.67 and a change to the estimated
number of communities selected (from 50 selected communities to 25). The changes in
burden hours are due to adding in need to review standard documents. Burden increase from
$30,860.25 to $34,214.64.
16. For collection of information whose results will be published, outline plans for tabulation and
publication. Address any complex analytical techniques that will be used. Provide the time
schedule for the entire project, including beginning and ending dates of the collection of
information, completion of report, publication dates, and other actions.
The results of this collection of information will not be published for statistical use.
17. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain the reasons that display would be inappropriate
No approval is sought to display the expiration date for OMB approval of the information
collection.
18. Explain each exception to the certification statement identified in item 19.