OMB No. 1205-0051
Supporting Statement for OMB Clearance of the
ETA 902, Disaster Unemployment Assistance Activities Report
A. Justification
Circumstances That Necessitate Collection.
Public Law 100-707 (Sections 410 and 423 of The Robert T. Stafford Disaster Relief and Emergency Assistance Act [the Stafford Act]) provides for assistance to eligible individuals who are unemployed due to a major disaster. State Workforce Agencies through individual agreements with the Secretary of Labor (Secretary), act as agents of the Federal government in providing Disaster Unemployment Assistance (DUA) to eligible applicants who are unemployed as a direct result of a major disaster.
The ETA 902 is a monthly report submitted by the states on DUA program activities once a disaster is declared by the President. Such report is prescribed by the Secretary under 20 CFR 625.8 and 625.9 and is necessary for oversight of the DUA program. This collection is also authorized under Section 303(a)(6) of the SSA.
2. Use of Information Collection.
The data obtained from the Form ETA 902 is used by the Employment and Training Administration (ETA), Office of Workforce Security (OWS) for DUA program and performance evaluation. The report includes information on the number of claimants who filed for DUA, including self employed individuals; number of claimants denied DUA benefits; the amount of benefits paid; the number of appeals filed; and the number of overpayments issued. The report is also used to monitor state agency expenditures and to support requests for additional administrative funds from the Federal Emergency Management Agency (FEMA) within the Department of Homeland Security (DHS), which provides the funds for administration and benefits for the DUA program. The data from these reports also allows OWS to do comparative analyses of states’ performance.
If these data were not available, OWS would not have sufficient information to monitor and assess states’ performance in administering the DUA program. Any attempts to identify risks to the program or resolve potential problems would be greatly hindered.
3. Use of Improved Technology.
The states are continually improving program operations and their information handling technologies and, where feasible, new methods are used for taking applications, and collecting and transmitting the data for these reports. For example, many states have implemented automated remote claims-taking systems, and automated recordkeeping. Reduction of burden through increased automation is always encouraged and supported. As with most unemployment insurance (UI) reports, the ETA 902 report is part of an electronic reporting system through which state UI agencies enter the data on a monthly basis and transmit the data to the ETA National Office.
4. Description of Effort to Identify Duplication.
FEMA/DHS has delegated authority to the Department of Labor for the DUA program. Neither FEMA nor any other agency collects information on the DUA program. The data requested are not available from any other source. Therefore, there is no duplication in the information being requested.
5. Collection of Information Involving Small Business.
The information collection does not involve small businesses or other small entities.
6. Consequences of Less Frequent Collection.
The ETA 902 report is due monthly. If these data were collected less frequently, ETA’s ability to carry out its oversight responsibilities and monitoring of the program would be greatly weakened. The funding needs projections would be more unpredictable. Effective accounting of DUA payments and other DUA expenditures would also be hindered. Claimants must certify for DUA on a weekly or bi-weekly basis, which coincides with the frequency required for regular unemployment insurance (UI) benefits. The monthly ETA 902 data collection allows the Department of Labor to assess the overall impact and effectiveness of the DUA program(s) administered by the states.
7. Special Circumstances.
As required by 20 CFR 625.19, states are requested to furnish to the Secretary such information and reports and make such studies as the Secretary decides are necessary or appropriate for carrying out the purposes of the DUA program. These reports and studies include, but are not limited to, monthly activity reporting on DUA activities (ETA 902).
Consultation Outside the Agency.
As required by 5 CFR 1320.8(d), ETA solicited comments on the proposed extension of approval for the ETA 902, DUA Activities Report through publication in the Federal Register, (Volume 73, No. 32, Pages 8905), February 15, 2008. No comments were received.
9. Payment/Gifts to Respondents.
No payment or gift is provided to respondents, other than remuneration of contractors or grantees.
10. Confidentiality Provided – Respondents.
The ETA 902 report does not identify individuals receiving benefits by name or social security number. No domestic secrets are involved. Therefore, confidentiality is not compromised.
11. Sensitive Information.
There are no items to be completed on the forms which involve sensitive information of a private nature or otherwise.
12. Estimated Annual Burden Hours.
There are approximately 50 Presidentially declared disasters each year nationwide occurring in about 30 states and about 30 of these disasters include DUA. Approximately 6 ETA 902 monthly activity reports are submitted per disaster (that includes DUA). Estimated average response time for a single report is one (1) hour. In addition, there is a final report submitted for each disaster activity, which averages one (1) hour for preparation of the report. In addition, Overpayment Notices averages approximately ¼ hour preparation per notice. Specific breakout of burden hours is as following:
Reporting of 902: 30 responses x 6 reports per year x 1 hour p/report = 180 hours annually.
Reporting of Final Report: 30 responses x 30 Final Reports per year x 1 hour p/report = 900 hours annually.
Issuances of Notice of Overpayment (NOO): 5,333 avg. annual OPs ÷ 1/4 avg. time p/report = 1,333 hours annually*
Total burden hours = 2,413
* This number is unusually large due to the unprecedented number of claims received as a result of Hurricanes Katrina and Rita during the three year period which the current OMB clearance has covered.
The current average hourly wage rate of state agency staff was obtained through consultation with staff from OWS’ Division of Fiscal and Actuarial Services. OWS estimates the average hourly wage rate to be $36.39 per hour.
2,413 x $36.39 per hour = $87,809 (annualized cost).
13. Estimate of the Total Annual Cost Burden to Respondents.
There are no other costs associated with this collection of information.
14. Estimates of annualized Cost to the Federal Government.
Cost to the Federal government cannot be estimated. DUA program information is generally data entered by the states and electronically transmitted to the ETA National Office computer, along with many other types of reports, where it is immediately available for use.
Reasons for Changes in Burden.
There has been a reduction in burden hours. The burden previously reported for cost expense has been taken out. Program office staff are unaware of any sort of reporting or burden at the state or Federal level associated with this item. It may have referred to standard forms that were used in the past, however there is no current or proposed reporting in this collection beyond the ETA 902, ETA 9130 and the narrative final report. Finally, the burden previously claimed for miscellaneous recordkeeping has been removed. With improved electronic reporting, many of the tasks previously described (e.g. microfilming, storage of paper documents) are not longer operational. The burden listed for submittal of the ETA 902 should represent an accurate estimate of all of the work associated with meeting the reporting requirements in this collection. Prior burden hours included forms states use for claims-taking and to process claimants’ information for determining DUA eligibility. These are operational forms and not required reports that states submit to OWS and should not be included in this burden collection. The ETA 9130 report (formerly S.F. 269) are accounted for under the existing collection number 1205-0461, and should not have been included in the hour burden for this collection.
16. Information of Publication.
There are no plans to publish the data for statistical use.
Waiver to Display OMB Expiration Date.
The OMB number and expiration date will be displayed as part of the Handbook instructions for the ETA 902 report.
18. Exceptions to Certification.
There are no exceptions to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission,” of OMB 83-1.
B. Collection of Information Employing Statistical Methods.
Statistical methods are not used in the collection of the ETA 902 information.
| File Type | application/msword |
| File Title | Supporting Statement for OMB Clearance of the |
| Author | thompson.miriam |
| Last Modified By | naradzay.bonnie |
| File Modified | 2008-06-20 |
| File Created | 2008-06-20 |