Supporting Statement TRIBAL PRA renewal 051507

Supporting Statement for the Tribal Child Support Enforcement Direct Funding Requests

Collection Number 0970-0218

1. Justification

1. Information Collection

The final rule within 45 CFR part 309, published in the Federal Register on March 30, 2004, contains a regulatory reporting requirement that in order to receive funding for a Tribal IV-D program a Tribe or Tribal organization must submit a plan describing how the Tribe or Tribal organization meets or plans to meet the objectives of section 455(f) of the Social Security Act, including establishing paternity, establishing, modifying, and enforcing support orders, and locating noncustodial parents. The plan is required for all Tribes requesting funding; however, once a Tribe has met the requirements to operate a comprehensive program, a new plan is not required annually unless a Tribe makes changes to its title IV-D program. Tribes and Tribal organizations must respond if they wish to operate a fully funded program. In addition, any Tribe or Tribal organization participating in the program will be required to submit form OCSE 34A. This paperwork collection activity is set to expire in April 2007.

2. Use of Information

The information collected is necessary to enable OCSE to determine whether an applicant Tribe or Tribal organization meets the requirements to receive direct funding to operate a child support enforcement program under 455(f) of the Social Security Act and implementing regulations at 45 CFR part 309. The Tribal Plan gives each Tribe a convenient method for developing a statement to be submitted to OCSE for approval describing the nature and scope of its program and giving assurances that the program will be administered in conformity with the requirements in title IV-D of the Act and the implementing regulations at 45 CFR part 309. The Tribal plan is analogous to a Tribe having a contract with OCSE in that it outlines the activities the Tribe will perform as required by law in consideration for receiving Federal funds to meet the costs of these activities. In this sense, the Tribal plan is the basis for making Federal funding available to the Tribal IV-D agencies in the costs of operating the Child Support Enforcement program.

Each Tribal IV-D program submits a “Quarterly Report of Collections,” Form OCSE-34A, within 30 days after the end of the first three quarters and 90 days after the end of the fourth quarter.

3. Burden Reduction

Tribal IV-D programs do not currently receive funding for automated systems. However, many Tribes have office automation and are capable of tracking this required information in an automated fashion. Therefore, the paperwork impact is minimal.

4. Duplication Identification

The collection of information requirements contained in this form does not duplicate any other reporting or recordkeeping requirements. In complying with those regulations that require information collection, agencies are specifically directed to use and build upon existing information, whenever it exists. It is the intent of these regulations that duplicity of efforts be avoided, and that information collection occurs only when information is not available from another source.

5. Small Business Burden

The collection of information requirements does not involve small businesses or entities.

6. Frequency of Information Collection

The Tribal IV-D agencies will, for the most part, submit new and revised plans to OCSE on a one-time only basis to reflect new Federal requirements. In addition, the Tribal IV-D programs will periodically amend their plans to reflect any material change in Tribal laws, organization, policy, or IV-D agency operation.

Each Tribal IV-D programs submits a “Quarterly Report of Collections,” Form OCSE-34A, within 30 days after the end of the first three quarters and 90 days after the end of the fourth quarter.

7. Special Circumstances

The collection of information does not involve any special circumstances.

8. Federal Register Notice

The 60 day notice was published in the Federal Register on March 12, 2007. (Volume 72, page 11027) The 30 day notice was published on April 5, 2007. (Volume 72, page 16795) No comments were received.

9. Payment or Gift to Respondents

No payment or gift is provided to respondents, other than remuneration of contractors or grantees.

10. Confidentiality

We do not assure confidentiality of the information collected.

11. Sensitive Nature

The required information collection does not involve asking questions of a sensitive nature.

12. Estimates of Respondents’ Hour Burden and Costs

We estimate that preparing and submitting the Tribal Plan and Form OCSE 34A to OCSE will not impose an increased total annual burden. This is not a new collection activity; it is an approval of an existing tool (0970-0218).

12.1 Respondents’ Hour Burden

The estimate of burden to respondents is based on the following assumptions:

• The 33 respondents include Tribes or Tribal organizations submitting the 45 CFR 309 Plan to receive direct funding, and any Tribal IV-D agency which makes a change to its already approved plan.

• The 49 respondents include all Tribes or Tribal organizations operating a Tribal IV-D program and receiving Federal funding.

Instrument	Number of Respondents	Number of Responses Per Respondent	Average Burden Hours Per Response	Total Burden Hours
45 CFR 309 Plan	33	1	480	15,840
Form OCSE 34A	49	4	8	1,568
Total			488 hours	17,408 hours

The annual burden hour estimate for Child Support is 17,408 hours per grantee.

Number of grantees affected: 49

Hours per respondent: 488

Cost per respondent: $8,784 estimated at 488 hours x $18.00 per hour.

2. Respondents’ Cost for Hour Burden

The estimate of costs to respondents is based on the following assumptions:

• Regional offices were polled to gain information about the average salary of an employee who would be working on this Tribal plan ($18 per hour).

• The cost to respondents cumulatively is 10 and 20% of the total cost. This is due to the Federal financial participation aspect of the Child Support Enforcement system, whereas the Federal government reimburses Tribal IV-D programs for 80-90% of total allowable costs. The costs are reimbursed to the Tribal IV-D agency at 90% for the first three years of operation of a program and at 80% thereafter.

Instrument	Total Annualized Cost	Respondents Cumulative Share of Cost (10%)	Average Annualized Share of Cost Per Respondent
45 CFR 309 Plan	$8,640.00	$864.00	$26.18
OCSE Form 34A	$576.00	$57.60	$1.17
Total	$9,216.00	$921.60	$27.35

Instrument	Total Annualized Cost	Respondents Cumulative Share of Cost (20%)	Average Annualized Share of Cost Per Respondent
45 CFR 309 Plan	$8,640.00	$1,728.00	$52.36
OCSE Form 34A	$576.00	$1,152.00	$2.35
Total	$9,216.00	$2,880.00	$54.71

13. Annual Costs to Respondents

There are no direct monetary costs to respondents other than their time to participate in the program.

14. Annualized Cost to the Federal Government

The annualized costs to the Federal Government for the hour burdens are based on an average wage rate of $30 per hour for Federal level employees who review submitted Tribal plans and OCSE forms 34A from respondents. Estimates regarding the hours spent processing each Tribal submission (4 hours for Tribal Plan and 1 hour for the 34A) were determined by past employees’ experiences in reviewing Tribal plans and forms 34A in OCSE.

Instrument	OCSE’s Administrative Costs	Respondent Reimbursement Cost (90% of Total Annualized Cost)	Administrative Cost Plus Respondent Reimbursement Cost
45 CFR 309 Plan	$3,960.00	$7,776.00	$11,736.00
OCSE 34A	$1,470.00	$518.40	$1,988.40
Total	$5,430.00	$2,2201.84	$13,724.40

Instrument	OCSE’s Administrative Costs	Respondent Reimbursement Cost (80% of Total Annualized Cost)	Administrative Cost Plus Respondent Reimbursement Cost
45 CFR 309 Plan	$3,960.00	$6,912.00	$10,872.00
OCSE 34A	$1,470.00	$460.80	$1,930.80
Total	$5,430.00	$7,372.80	$12,802.80

15. Change in Burden

The change in burden hours is due to a change in the number of Tribal programs we anticipate to be in operation. The original collection activity estimated a total of 150 Tribes operating IV-D programs. This table includes a more accurate estimate of the Tribal IV-D programs in operation.

16. Publication

Not applicable

16. Display of Expiration Date for OMB Not applicable

16. Exception to the “Certification for Paperwork Reduction Act Submission”

There are no exceptions to the certification statement.

SUPPORTING STATEMENT:

PART B- COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

The information collection requirements outlined in this report do not employ the use of statistical methods.