Revised JABG Supp Statement

SUPPORTING STATEMENT

OFFICE OF JUVENILE JUSTICE AND DELINQUENCY PREVENTION

Requirements: Data Collection Application in support of the Juvenile Accountability Block Grant Program

A.        JUSTIFICATION

1.         Necessity of Information Collection

The House of Representatives passed the Juvenile Accountability Incentive Block Grants (JAIBG) Act in 1997 under Title III of H.R. 3. Congress first funded the program through an appropriations act in fiscal year 1998 and authorized the Attorney General to provide grants under the JAIBG program for states and units of local government, to include tribal governments. They were to use these funds to support innovative, effective programs that reduce juvenile offending through accountability-based initiatives focusing on offenders and the juvenile justice system and that improve the efficiency of state juvenile justice systems. The Department of Justice Authorization Act of FY 2003 included provisions to change the name of the JAIBG program to the Juvenile Accountability Block Grants (JABG) program, expand the number and scope of the program areas, refine the program=s reporting and monitoring requirements, and include program funding as part of Title I (Part R, Chapter 46, Subchapter XII B F) of the Omnibus Crime Control and Safe Streets Act. This legislation stated that the changes would go into effect as of FY 2004. Hereinafter, this program will be referred to as JABG.

The JABG program provides Federal funds to the States and territories to encourage them and local jurisdictions to implement accountability-based programs and services and thereby strengthen the juvenile justice system. The State Relations and Assistance Division (SRAD) of OJJDP administers the JABG program, which gives the States (and territories) funding in the form of block grants. In turn, these States must pass on at least 75 percent of these funds to local units of government, absent a waiver approval from the OJJDP Administrator. States and territories are awarded funds based upon a formula derived from law enforcement expenditures and the number of violent crimes. Two important requirements of this funding are that recipients assess and report their funded activities on an annual basis, utilizing sub-grant information forms to collect critical data, and that OJJDP submit an annual Report to Congress describing the program=s accomplishments and outcomes.

2.         Needs and Uses

Congressional enactment of the Government Performance and Results Act (GPRA) in 1993 set a new direction for the appropriations process. Instead of basing program funding on prior year levels, funding would now be determined through a consideration of how well a program succeeded in meeting its stated goals and objectives. Under GPRA, Federal agencies are required to develop a multi year strategic plan that clearly defines their missions, strategic goals, and the resources needed to accomplish them. Agencies also are required to develop an annual performance plan, including quantifiable and measurable objectives associated with each goal, and performance indicators that monitor progress toward these goals and document the agencies= progress in achieving them. These documents provide the basis for the Executive branch to establish performance-based recommendations for crafting the President=s budget. This is shared with Congress to inform its decisions on resource allocation. The current administration has strongly supported this integration of performance information into the budgeting process by making it one of five Federal government-wide management priorities under the President=s Management Agenda.

In order to link budgets with performance, it was first necessary to create a common metric along which programs could be measured and compared. The Office of Management and Budget (OMB) developed the Program Assessment Rating Tool (PART) to provide a standardized and consistent methodology for analyzing and comparing Federal programs. PART consists of a standard series of 25 questions that draw upon available performance and evaluation information to enable OMB reviewers to reach conclusions about program strengths and weaknesses in four areas: Program Purpose and Design, Strategic Planning, Program Management, and Program Results/Accountability. Based upon a careful analysis of these areas, an OMB review team scores and assigns a program to one of five global effectiveness categoriesCAeffective,@ Amoderately effective,@ Aadequate,@ Aineffective,@ or Aresults not demonstrated.@ The latter category indicates that in OMB=s determination, the program=s performance information or performance measures (or both) are insufficient or inadequate.    

The JAIBG program was the first grant program within OJJDP to undergo an OMB PART review in 2002. This review resulted in a series of findings summarized below:

PROGRAM AREA	FINDINGS FROM REVIEW	TOTAL POINTS (OUT OF 100 PERCENT)
Program Purpose & Design	Program purpose was clear and met a specific need.	60 percent
	Program design contributed to meeting an identified need.
	The budget was aligned with the program=s goals.
Strategic Planning	The program has specific, easily understood outcome goals.	29 percent
	The program shows evidence of collaboration leading to meaningful actions in management and resource allocations.
	The program was not able to show that partners support its overall goals and measure and report on their performance as it relates to accomplishing those goals.
Program Management	The agency makes reasonable estimates and budgets well.	44 percent
	Funds are expended in a timely manner and for their intended purposes.
	The program did not demonstrate that States support program efforts by committing to its annual and/or long-term goals.
	The program did not show that Federal managers and States are held accountable for cost, schedule, and performance results.
Program Results	The program did not show that it collected State performance data on an annual basis and made them available to the public in a meaningful way	7 percent
	The program did not demonstrate adequate progress in achieving its long-term outcome goals

The JAIBG program received a rating of “Ineffective” from this PART review. These results indicated that the JAIBG program had a clearly defined mission and strategic goals. The program also had established initial partnerships with the States and territories and their subgrantees, and had taken some preliminary steps to identify and implement data collection on its activities. However, the JAIBG program could not produce sufficient systematic data to document that its partners supported agency goals, did not collect State performance data on an annual basis, and had not demonstrated adequate progress in achieving agency long-term outcome goals.

The sub grant information form will provide the means by which recipients receiving funds under the JABG program will report the budgeted use of that money and thereby satisfy the requirements of 28 CFR Part 31, Subpart B. That regulation creates requirements for specific information to be submitted, designates activities for which the funds may be used, and creates ratios of expenditures on certain activities. It also requires that certain assurances must be made about expenditure information

3. Use of Information Technology

The form is electronic and accessible via the Office of Justice Programs Grants Management System (GMS), thus reducing the burden required for the State to meet the reporting requirements.

3. Efforts to Identify Duplication

There is no duplicative effort based on the programmatic nature of this form. The information sought is not attainable from any other data source.

3. Minimizing Burden on Small Businesses

No information will be gathered from any small businesses.

3. Consequences of Not Conducting or Less Frequent Collection

The submission of information has been minimized to the least number of submissions possible. The data collection form is submitted electronically, by the State, within 30 days of the date that the local unit of government is authorized to obligate program funds under its subaward. A less frequent submission is not feasible and would delay the timely award and expenditure of Federal funds.

3. Special Circumstances

There are no special circumstances.

3. Public Comments and Consultations

On October 14, 1998, the OJJDP published proposed regulations in the Federal Register, at 63 FR 55069, for implementation of the JABG program. The comment period over which reviewers, including the public, were invited to comment ended November 13, 1998. Four comments were received from two State agencies. All comments have been considered by OJJDP in the issuance of a final policy. There has been no further opportunity for public comment since that time.

3. Provision of Payments or Gifts to Respondents

No payment or gift will be provided to the respondents.

10. Assurance of Confidentiality

The data will be obtained from public agencies and are, therefore, in the public domain. No assurance of confidentiality has been made to the respondents. The nature of the information requested is nonpersonal information based on requirements of the State to provide notice to the Attorney General regarding the proposed use of funds available under the JABG program.

3. Justification for Sensitive Questions

No information commonly considered as private is included in the requested information.

3. Estimate of Respondent=s Burden

The estimated burden for 56 respondents (recipients) is that each will submit one data collection form for each subaward within 30 days of making such award. Based upon previous submission of subaward information from other programs within SRAD, discussions with State Juvenile Justice Specialists, and individuals involved in providing technical assistance to States in developing the data collection and forms, it was determined that the reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The burden rate may vary depending on the number of subawards made to units of local government and/or other State agencies. A breakdown of times is as follows:

30 minutes read and clarify instructions

15 minutes search and gather information from data sources

15 minutes submit information electronically

The estimated annual burden rate will be 4,200 hours per respondent.

The Paperwork Reduction Act (PRA) Statement: This information to be collected has been cleared under the PRA of 1995, and agency may not conduct or sponsor and a person is not required to respond to the collection of information unless it displays a currently valid OMB number. The OMB number for this collection of information is 1121-0234. It is estimated that is would take a person or agency 20 minutes on average to complete this form, you may direct any comments regarding the accuracy of this burden estimate and suggestions for reducing the time to the JABG program, Office of Juvenile Justice and Delinquency Prevention, 810 7^th Street, N.W. Washington, D.C. 20531.

13. Estimate of Cost Burden

OJJDP will provide each recipient agency which is designated to develop and administer the JABG program with the necessary standardized forms and instructions which are required in developing and submitting the data collection. OJJDP does not contemplate a need of capital and start up costs, nor any costs associated with system and technology acquisitions. A cost of purchasing or contracting out information collection services will not be necessary.

14. Cost to Federal Government

The estimated cost to the Federal government is based upon the experience and activities associated with reviewing submission of subward information from other programs with SRAD. The activities and the resultant costs are based on the time to receive, review, make phone calls for clarification, and key data into system for each data collection form received. These activities and approximate hours are as follows:

A. OJJDP State Representative review for accuracy, analyze, discussion with recipient --0.5 (GS-12).

These activities total to approximately one half hour (0.5) per data collection form. A small calculator and word processor are the only equipment required and are presently available at no additional cost. The cost to the Federal government is estimated at $13.91 for staff time and is calculated as follows:

$18.40 = GS-12 ($36.79 per hour (average of base to step 12) x 0.5 hours)

$18.40 = Total for one (1) form to $1,380,00.00 for 75 forms

The estimated cost to the 56 respondents (state recipients) is based upon the time required for the state juvenile justice specialist (GS-12 equivalent) to review instruction, collect/generate information, and submit to OJJDP. It was determined that approximately 0.5 hours is involved in completing each form. The estimated average cost for one respondent on an annual basis will range from $18.40 for (1) form to $1,380.00 for 75 forms. There are no other anticipated costs to the respondent in complying with these requirements.

14. Reason for Change in Burden

The calculations for information reported in Item 13 and Item 14 are below.

* Explanation for Item 13, b. of Form 83-I: 4200 total annual respondents. Annual responses could total from 56 hours [one (1) form x 56 respondents x one (1) hour] to 4,200 hours [56 respondents x 75 forms x one (1) hour].

*Explanation for Item 14.a. of Form 83-I: $1,380.00 total annualized capital/startup costs. Annual costs could total $18.40 for one (1) from per respondent to $1,043.25 for 75 responses per respondent.

16. Anticipated Publication Plan and Schedule

The results of this collection of information are not planned to be published for statistical purposes.

17. Display of Expiration Date

Is not seeking approval to display the expiration date

18. Exception to the Certification Statement

No exceptions to the certification statement are being requested.

B. Collections of Information Employing Statistical Methods

1. Describe the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

The respondent universe for this collection is 56 States and territories of the U.S. (a list is attached). All respondents are required to submit complete information regarding their JABG subgrantees on an annual basis, with each new Block Grant award. Information is submitted through the Office of Justice Program’s Grants Management System (GMS). No sampling is done for this collection and there are no plans to implement sampling procedures in the future. The expected response rate for the universe is 100% and, based on previous collections, this is considered a realistic response rate. The response rate for 2006 was 100%.

2. Describe the procedures for the collection of information including:

1. Statistical methodology for stratification and sample selection.

2. Estimation procedure.

3. Degree of accuracy needed for the purpose described in the justification,

4. Unusual problems requiring specialized sampling procedures.

5. Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

The JABG subgrantee information is collected through the Office of Justice Programs’ Grants Management System (GMS), an online system used for the solicitation, application, awarding and administration of OJP (including OJJDP’s) grants. OJJDP’s State and Territorial grantees complete the subgrantee information form on GMS for each of the subgrantees receiving JABG funds through the State or Territory in the given Fiscal Year. This information is entered into GMS on an annual basis, at the time when subgrantees are selected by the specific State or Territory. (This occurs after the funds are awarded to the State or Territory by OJJDP.)

OJJDP has program staff assigned to each of the 56 respondents to ensure that they receive individualized assistance in completing their annual applications for funding and in completing subgrantee information through the Grants Management System. Attached is a list of OJJDP staff who serve as State Representatives for JABG applicant States and Territories. In addition, State and Territories can contact the Grants Management System (GMS) helpline at (888) 549-9901 for assistance in completing their information.

All States and Territories complete the information, there is no sampling or stratification that occurs. OJJDP does not use any estimation procedures in this collection. Information is collected annually.

3. Describe methods to maximize response rates and to deal with issues of non response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield “reliable” data that can be generalized to the universe studied.

As described in #2, OJJDP provides direct assistance to all respondents through State Representative Staff. In addition, technical assistance is provided through the GMS Helpline for respondents in submitting their information.

A primary factor that impacts response is that respondents are required to submit this information on an annual basis, as a condition of receiving funding through the JABG program. At the time in which they obligate their JABG Block Grant funds to subgrantees, State and Territorial grantees are required to enter this information into the GMS system. This is an integral part of their required reporting to OJJDP. Those respondents who are delinquent in reporting this information are subject to a hold on their funding from OJJDP, and these funds are not released until the information is complete. Grant awards to the 56 States and Territories include the following Special Conditions:

The recipient agrees to submit to the Office of Juvenile Justice and Delinquency Prevention a completed Subgrant Information Form for each subaward within 30 days of granting the subaward via the Office of Justice Programs Grants Management System.

The recipient agrees to submit its Annual Performance Report for the prior calendar year, no later than June 30 of each year, to the Office of Justice Programs, Grants Management System.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

There are no tests of procedures or methods for this collection. This is part of OJP’s overall GMS system.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other persons(s), who will actually collect and/or analyze the information for the agency.

Thomas Murphy

JABG Program Manager

Office of Juvenile Justice and Delinquency Prevention

(202) 353-8734

[email protected]

Janet Chiancone

Research Coordinator

Office of Juvenile Justice and Delinquency Prevention

(202) 353-9258

[email protected]