Justification 1-30-09

(1205-0455) SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL
UNDER THE PAPERWORK REDUCTION ACT OF 1995
TABLE OF CONTENTS

SECTION

PAGE

A. JUSTIFICATION .................................................................................................................................. 2
A.1 CIRCUMSTANCES NECESSITATING DATA COLLECTION ..................................................................... 2
A.2 HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE USED ............................... 4
A.3 USE OF TECHNOLOGY TO REDUCE BURDEN ....................................................................................... 5
A.4 EFFORTS TO IDENTIFY DUPLICATION ................................................................................................. 5
A.5 METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES ................................................................. 6
A.6 CONSEQUENCES OF LESS-FREQUENT DATA COLLECTION ................................................................. 6
A.7 SPECIAL CIRCUMSTANCES FOR DATA COLLECTION........................................................................... 6
A.8 FEDERAL REGISTER NOTICE AND CONSULTATION OUTSIDE THE AGENCY ....................................... 6
A.9 PAYMENT OF GIFTS TO RESPONDENTS ............................................................................................... 6
A.10 CONFIDENTIALITY ASSURANCES ...................................................................................................... 6
A.11 ADDITIONAL JUSTIFICATION FOR SENSITIVE QUESTIONS ................................................................ 7
A.12 ESTIMATES OF THE BURDEN OF DATA COLLECTION ........................................................................ 7
A.13 ESTIMATED COST TO RESPONDENTS .............................................................................................. 10
A.14 ESTIMATES OF ANNUALIZED COSTS TO FEDERAL GOVERNMENT.................................................. 10
A.15 CHANGES IN BURDEN ..................................................................................................................... 10
A.16 TABULATION OF PUBLICATION PLANS AND TIME SCHEDULES FOR THE PROJECT ......................... 10
A.17 APPROVAL NOT TO DISPLAY OMB EXPIRATION DATE ................................................................. 10

A.18 EXCEPTIONS TO OMB FORM 83-I ....................................................................................... 10
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS .......................... 11

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A.

JUSTIFICATION

This is a justification for the Department of Labor, Employment and Training Administration’s
(ETA) request to extend approval for the reporting and recordkeeping requirements of the
Prisoner Reentry Initiative (PRI). This reporting structure features standardized data collection
for program participants and quarterly progress and Management Information System (MIS)
report formats. All data collection and reporting is done by the faith-based and community
organization (FBCO) grantees or their subgrantees.
The quarterly progress reports provide a detailed, narrative account of program activities,
accomplishments, and progress toward performance outcomes during the quarter. The quarterly
performance reports include aggregate and participant-level information on demographic
characteristics, types of services received, placements, outcomes, and follow-up status.
Specifically, these reports collect data on individuals who receive employment training and
placement services, housing assistance, mentoring, and other services essential to reintegrating
ex-offenders through PRI programs.
The accuracy, reliability, and comparability of program reports submitted by grantees using
federal funds are fundamental elements of good public administration and are necessary tools for
maintaining and demonstrating system integrity. The use of a standard set of data elements,
definitions, and specifications at all levels of the workforce system helps improve the quality of
performance information that is received by ETA.

A.1 Circumstances Necessitating Data Collection
The Prisoner Reentry Initiative is a Workforce Investment Act (WIA) demonstration grant
designed to reduce recidivism by helping inmates find work when they return to their
communities. PRI programs incorporate employment training, mentoring, housing assistance,
and other reintegration services in coordination with businesses, One-Stop Centers, educational
institutions, local housing authorities, and the criminal justice system. In addition to reporting
participant information and performance-related outcomes, PRI grantees must demonstrate their
ability to establish effective partnerships with the criminal justice system, local Workforce
Investment Boards, local housing authorities, and other partner agencies. They must also
demonstrate the cost effectiveness of their projects. The reporting and recordkeeping system
incorporates each of these aspects necessary for program evaluation.
Five outcome measures are used to measure success in the PRI grants: entered employment rate,
employment retention rate, attainment of a degree or certificate, average six month post-program
earnings, and recidivism rate. Several of these conform to the common performance measures
implemented across federal job training programs as of July 1, 2005. By standardizing the
reporting and performance requirements of different programs, the common measures give ETA
the ability to compare across programs the core goals of the workforce system—how many
people entered jobs; how many stay employed; and how many successfully completed an
educational program. In addition to the five outcome measures, grantees report on a number of
leading indicators that serve as predictors of success. These include participation in education or
training, attainment of degrees and certificates, workforce preparation, mentoring, community
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service, reduced substance abuse, proportion of enrollees in stable housing, and proportion of
enrollees complying with parole conditions.
In applying for the PRI grants, FBCOs and their sub-grantees agree to submit participant data
and aggregate reports on enrollee characteristics, services provided, placements, outcomes, and
follow-up status. Grantees collect and report quarterly PRI performance data using an ETAprovided MIS. The MIS is a web-based case management and reporting application housed on
ETA’s servers.
As described in WIA Title I section 172, which addresses evaluation criteria of demonstration
projects such as PRI that are authorized under section 171(a-b), the PRI data is evaluated by
ETA to determine program effectiveness. This evaluation includes the extent to which the PRI
program improves the employment competencies of participants in comparison to comparably
situated individuals who did not participate in the program, and the extent to which the PRI
program increases the level of employment over that which would have existed in the absence of
the program [section 172(a)(1)(A)].
WIA section 172(a) further specifies that the evaluations must address:
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effectiveness of the performance measures relating to such programs and activities
effectiveness of the structure and mechanisms for delivery of services through such
programs and activities
impact of the programs and activities on the community and participants involved
impact of such programs and activities on related programs and activities
extent to which such programs and activities meet the needs of various demographic
groups
such other factors as may be appropriate

WIA section 185 broadly addresses reports, recordkeeping and investigations across programs
authorized under Title I of the Act. The provisions of section 185:
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require the Secretary to ensure that all elements of the information required for reports be
defined and reported uniformly [section 185(d)(2)]
direct each state, local board, and recipient (other than a sub-recipient, sub-grantee, or
contractor of a recipient) to prescribe and maintain comparable management information
systems, in accordance with the guidelines that shall be prescribed by the Secretary
designed to facilitate the uniform compilation, cross tabulation, and analysis of
programmatic, participant and financial data, on statewide, local area, and other
appropriate bases, necessary for reporting, monitoring, and evaluating purposes,
including data necessary to comply with section 188 [section 185(c)(2)]
require that recipients of funds under Title I shall maintain such records and submit such
reports in such form and containing such information as the Secretary may require
regarding the performance of programs and activities carried out under Title I [section
185(a)(2)]
require that recipients of funds under Title I shall maintain standardized records for all
individual participants and provide to the Secretary a sufficient number of such records to
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

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provide for an adequate analysis of the records [section 185(a)(3)]
specify that the reports shall include information about programs and activities carried
out under Title I pertaining to:
- relevant demographic characteristics (including race, ethnicity, sex, and age) and
other related information regarding participants
- programs and activities in which participants are enrolled, and the length of time
that participants are engaged in such programs and activities
- outcomes of the programs and activities for participants, including the
occupations of participants and placement for participants in nontraditional
employment
- specified costs of the programs and activities
- information necessary to prepare reports to comply with section 188 and 29 CFR
Part 37.37 [(a-b),(d-e)].
require that all elements of the information required for the reports described in section
185(d)(1)(A-E) above are defined and uniformly reported.

WIA section 189(d) requires the Secretary to prepare and submit to Congress an annual report
regarding the programs and activities carried out under Title I. The report must include:
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a summary of the achievements, failures and problems of the programs and activities in
meeting the objectives of Title I
a summary of major findings from research, evaluations, pilot projects, and experiments
conducted under Title I in the fiscal year prior to the submission of the report
recommendations for modifications in the programs and activities based on analysis of
such findings
such other recommendations for legislative or administrative action as the Secretary
determines to be appropriate

A.2 How, by Whom, and For What Purpose the Information is to be Used
Grantees carry out recordkeeping and reporting requirements with grant funds. As a
government-procured MIS is provided to all grantees, their implementation costs will be
minimized. Grant funds may also be used with the prior approval of the grant officer to upgrade
computer hardware and internet access to enable projects to use the MIS.
Grantees enter data into the MIS on individuals who receive services through PRI programs and
their partnerships with One-Stop Centers, local Workforce Investment Boards, employment
providers, the criminal justice system, and the local housing authority. These data are used by
the Department and ETA to evaluate performance and delivery of PRI program services.
Attachment A contains a list of the required data elements to be collected in the MIS and the
purpose for collecting each item. The MIS allows grantees to collect additional participant data
beyond those elements required by PRI.
ETA uses the data to track total participants, characteristics, services, and outcomes for released
prisoner participants. Additionally, ETA analyzes the data to (1) determine the delivery of core
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employment services within the WIA framework; (2) study performance outcomes vis-à-vis
performance measures, policies, and procedures; and (3) help drive the workforce investment
system toward continuous improvement of outcomes and integrated service delivery for released
prisoners. Common measures enhance ETA’s ability to assess the effectiveness of the PRI
program within the broader workforce investment system.
Within ETA, the data are used by the Offices of Workforce Investment, Financial and
Administrative Management, Policy Development and Research, Performance and Technology,
and Field Operations (including the regional offices). Other DOL users include the Offices of
the Assistant Secretary for ETA and Assistant Secretary for Policy.
The reports and other analyses of the data are made available to the public through publication
and other appropriate methods and to the appropriate congressional committees through copies
of such reports. In addition, information obtained through the MIS information and reporting
system is used at the national level during budget and allocation hearings for DOL compliance
with the Government Performance and Results Act (GPRA) and other legislative requirements,
and during legislative reauthorization proceedings.

A.3 Use of Technology to Reduce Burden
To comply with the Government Paperwork Elimination Act, ETA is streamlining the collection
of participant data and the preparation of quarterly reports to the extent feasible by providing a
web-based MIS/Case Management System and by providing uniform data elements and data
definitions to grantees across ETA programs. All PRI data and reports will be submitted to ETA
via the internet. Grantees will collect, retain, and report all information electronically through
the ETA-provided MIS.

A.4 Efforts to Identify Duplication
A hallmark of WIA Title I is increased accountability in exchange for optimal flexibility. Title I
has strengthened accountability by requiring more comprehensive performance standards and
establishing quarterly reports for demonstration projects. The data items identified in
Attachment A are needed on the individual MIS records to support the measures, and much of
these data are used by grantees to prepare the quarterly progress reports.
ETA has minimized the reporting burden by establishing the number of data elements required
commensurate with the level of resources expended and services received. Data items collected
by program reports and individual records are needed to: (1) account for the detailed services and
mentoring provided by multiple agencies to help participants get and keep well paying jobs and
obtain stable housing; (2) better identify overlapping and unproductive duplication of services;
and (3) reduce the effect of stove-piped data and generate performance information across
employment and training programs. Information provided through the PRI management
information and reporting system is not available through other data collection and report
systems.

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A.5 Methods to Minimize Burden on Small Businesses
For reporting purposes, the involvement of small businesses or other small entities who are not
grantees or sub-grantees is extremely limited. The only time contacting them may be required is
during the provision of a service. Methods to minimize the burden on small entities that are
grantees or subgrantees are discussed in other sections of this supporting statement.

A.6 Consequences of Less-Frequent Data Collection
29 CFR 95.51(b) (59 F.R. 38271, July 27, 1994), which governs monitoring and reporting
program performance under grants and agreements with non-profit organizations, states that
quarterly reports shall be due 30 days after the reporting period. If ETA did not comply with
these requirements, funding for demonstration programs would be compromised. In applying for
PRI grants, grantees agree to meet ETA’s reporting requirements as indicated in the Solicitation
for Grant Applications (SGA/DFA PY-04-08), which requires the submission of quarterly
reports within 30 days after the end of the quarter.

A.7 Special Circumstances for Data Collection
These data collection efforts do not involve any special circumstances.

A.8 Federal Register Notice and Consultation Outside the Agency
The public was given an opportunity to review and comment through the Federal Register notice
process. The notice was published in the Federal Register on July 17, 2008 (Vol. 73, No. 138, p.
41126 et seq.). No comments were received.

A.9 Payment of Gifts to Respondents
There are no payments to respondents other than the grant funds described in the Solicitation for
Grant Applications (SGA/DFA PY-04-08).

A.10 Confidentiality Assurances
ETA is responsible for protecting the confidentiality of the PRI participant and performance data
and maintaining the data in accordance with all applicable federal laws, with particular emphasis
on compliance with the provisions of the Privacy and Freedom of Information Acts. The
Department is working diligently to ensure the highest level of security whenever personally
identifiable information is stored or transmitted. All contractors that have access to individually
identifying information are required to provide assurances that they will respect and protect the
confidentiality of the data. ETA’s Performance and Technology Office (PROTECH) has been an
active participant in the development and approval of data security measures – especially as they
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apply to the web-based version of the PRI system.
A key concern is for the protection of participant social security numbers (SSNs), which is
voluntarily provided by the individual as part of this information collection request. The SSN is
being requested in order for grantees to properly determine that the individual is eligible to
participate in the PRI program, ensure data integrity, and, to the extent practicable, track program
participant outcomes through state wage record systems. The PRI system also includes a
statement that informs the individual where the information he/she has provided is being stored,
the name and location of the system, and that the information is protected in accordance with the
Privacy Act. When participant files are retrieved within the PRI system, only the last four digits
of the social security number are displayed. Any information that is shared or made public is
aggregated by grantee and does not reveal personal information on specific individuals.

A.11 Additional Justification for Sensitive Questions
While sensitive questions will be asked of participants in the proposed data collection, the
confidentiality of participants will be protected as discussed in section A.10. In addition,
security is built into the data collection system by the MIS contractor. Participant responses to
these sensitive questions allow ETA to comprehensively evaluate the effectiveness of the PRI
program.

A.12 Estimates of the Burden of Data Collection
The annual national burden for the PRI reporting system has three components: (1) the
participant data collection burden; (2) the quarterly narrative progress report burden; and (3) the
quarterly performance report burden. This response provides a separate burden for each of the
three components. In addition, a separate burden is provided for ETA-9140-A, a small related
grant program using essentially the same fields as ETA 9140 and approved by OMB on
November 30, 2007 (See OMB reference number 200708-1205-0006).
(1). Participant Data Collection Burden
The PRI participant data collection burden considers the amount of participant and
performance-related information collected and reported on the participant record that would not
have to be collected by the grantees as part of their customary and usual burden to run the
program. Thus the burden reflects the information collected solely to comply with the federal
reporting requirements.
The data collection burden varies by participant based on the range and intensity of services
provided by the grantee and its partnerships with One-Stop Centers, local Workforce Investment
Boards, employment providers, the criminal justice system, the grantee programs run by the U.S.
Department of Justice, and local housing authorities. For example, data collection may involve
acquiring information from the various partner agencies regarding employment training and
placement, housing assistance, mentoring, parole, and probation, in addition to the collection of
personal and demographic information by the grantees themselves.
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To arrive at the average annual figure of 1.8 hours per participant record, Mathematica, the
contractor which computed the original data for this submission when it was a new initiative,
assessed the time for entries based on scenarios postulating a variety of services possible for a
range of anticipated participants. This information, in turn, was based on similar programs of
this sort, including Justice Department programs.
Finally, PRI program managers consulted with grantees who have collected this information over
the past several years to verify that 1.8 hours, as an average figure devoted for MIS for the
estimated 6,610 participants, averaged out among the grantees, represented the best estimate of
time devoted to data entry for each participant, given the range of entries anticipated for each
participant, as described above. These grantees affirmed this estimate.
Regarding the estimated 6,610 participants for 2008, it is noted that the grantees are in different
years in their grants, and those in the final drawdowns are serving fewer participants than those
in their initial years of grant funded activity. To estimate the participants for 2008, the
initiative’s efficiency measure of $3,000 expended per participant was compared with the
program’s anticipated funding level, which determined the number of those who could be served
by each grantee. This estimate of the number of participants served through this grant program,
is also based on the MIS data collected thus far. By dividing the estimated 6,610 participants
among the 74 current grantees, one arrives at the average per grantee, given the broad range of
years into the grant and range of activities and number of potential participants represented by
each grantee, of 89.324 persons per grant: 6610 divided by 74 = 89.324.
Estimated National Count:

Record Type
Participant

Av Hrs.
PY 08
Per
Estimated
Record National Count
1.8

Annual
National
Burden Hours

Applicable
Hourly Rate

Annual National
Burden Dollars

11,898

$10.75

$127,904

6,610

Hourly rates used to calculate cost depend upon the type of organization administering the
program. For private non-profit grantees, the hourly rate is the average hourly earnings in the
Census Bureau’s social assistance industry category (May 2003, Current Employment Statistics
Survey, U.S. Census Bureau).
(2). Quarterly Narrative Progress Report Burden
The PRI quarterly narrative progress report burden involves providing a detailed account of all
activities undertaken during the quarter including in-depth information on accomplishments,
promising approaches, progress toward performance outcomes, upcoming grant activities, and
updates on product, curricula, and training development. It is assumed that each grantee will
spend approximately two days (16 hours) per quarter preparing this report. Information to be

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included in this quarterly narrative report is laid out in the PRI Solicitation for Grant Application
(SGA) and concomitant grant documents.

Report

Av Hrs. Per
Year Per
Grantee

Number of
Grantees

Annual National
Burden Hours

Applicable
Hourly Rate

Annual National
Burden Dollars

64

74

4,736

$10.75

$50,912

Quarterly
Narrative
Progress
Report

(3). Quarterly Performance Report Burden ETA – 9140
The quarterly performance report burden assumes that all grantees use the ETA-provided MIS
to generate quarterly performance reports (referred to as MIS Reports in SGA/DFA PY-04-08).
The MIS is designed to apply edit checks to participant data and to generate facsimiles of the
aggregate information on enrollee characteristics, services provided, placements, outcomes, and
follow-up status in quarterly report format. The burden includes reviewing and correcting errors
identified by the MIS in the participant-level data and generating, reviewing, and approving the
aggregate quarterly reports.

ETA 9140
Report

Av Hrs Per
Year Per
Grantee

16

Number of
Grantees

Annual
National
Burden Hours

Applicable
Hourly Rate

Annual
National
Dollars

74

1,184

$10.75

$12,728

Quarterly
Performance
Report

TOTAL ANNUAL HOURS, Narrative and Quarterly Performance Reports, 74 Grantees
64 hours + 16 hours = 80 hours annually OR 20 hours quarterly.
Grantees: 4 (times per year) x grantees (74) = 296 responses.
Burden Hours: Add 4,736 to 1,184 for a total of 5,920 for quarterly reporting.

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ETA 9140
Report and
Narrative
Report

Narrative and
Quarterly
Performance
Reports

Av Hrs Per
Year Per
Grantee

80

Number of
Grantees

Annual
National
Burden Hours

Applicable
Hourly Rate

Annual
National
Dollars

74

5,920

$10.75

$12,728

4. Quarterly Performance Report Burden, ETA 9140-A: ETA 9140-A, a slight variation
of ETA-9140, is being used by a grant program, Beneficiary-Choice Contracting
program, affiliated with this program.
Similarly, the hours estimated to complete ETA9140-A are 4 hours. There are five
participant grantees in the Beneficiary-Choice Contracting program; therefore, 4
quarterly reports x 5 grantees = 20 responses annually x 4 hours.

Report

Av Hrs Per
Year Per
Grantee
16

Number of
Grantees

Annual
National
Burden Hours

Applicable
Hourly Rate

Annual
National
Dollars

5

80

$10.75

$860.00

Quarterly
Performance
Report

For both programs, ETA 1940 and ETA 1940-A, the hours to complete the form is 4 hours.
There are 74 grantees using ETA-9140. Therefore, the 74 participant grantees in the PRI
program, filling out 4 quarterly reports, = 4 hours x 4 (times per year) x 74 (grantees), resulting
in an estimated total of = 1,184 hours.
Thus, the grand total of grantees for both programs, PRI (including participants) and BeneChoice, is currently 6,610 + 74 + 5 = 6,926. Annual hours are a grand total of 11,898
(Participants) + 5,920 (PRI) + 80 (Bene-Choice), or 17,898 responses.

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A.13 Estimated Cost to Respondents
a) Start-up/capital costs: There are no start-up costs, as ETA provides grantees with a
free, web-based, data collection and reporting system that grantees will use to collect and
maintain participant data, apply edit checks to the data, and generate the quarterly reports.
b) Annual costs: There are no annual costs, as ETA is responsible for the annual
maintenance costs for the free, web-based, data collection and reporting system.

A.14 Estimates of Annualized Costs to Federal Government
The MIS system is fully developed and these costs have been absorbed. The annual costs of
maintaining the system and developing training and technical assistance guides, continues to be
estimated to be $285,000, are borne by ETA.

A.15 Changes in Burden
The change in burden is due to an increase in grantees and the addition of a second grant
program approved by OMB 11/30/2007 (see OMB reference number 200708-1205-0006).

A.16 Tabulation of Publication Plans and Time Schedules for the Project
Grantees will submit narrative progress and MIS performance reports on a quarterly basis to
ETA within 30 days of the end of each quarter. Quarterly report data will be analyzed by ETA
staff and used to evaluate performance outcomes and program effectiveness.
Each year, ETA issues an annual report summarizing program performance based on the
Secretary’s goals. Data contained in the PRI reports may be included in these reports. The data
will also be used to prepare GPRA reports, management and budget reports, and other ad hoc
reports. All reports are available on the internet and accessible to the public.
Product

Submission Date

Quarterly
Narrative
Progress
Report

Within 30 days after the end
of the quarter.

Quarterly
Performance
Report

Within 30 days after the end
of the quarter.

Comments
Quarterly progress reports and MIS data
will be submitted electronically using
ETA’s On-Line Electronic Reporting
System.

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A.17 Approval Not to Display OMB Expiration Date
The expiration date for OMB approval will be displayed. We are not seeking approval to have
this concealed.

A.18 Exceptions to OMB Form 83-I
No exceptions are requested in the “Certification of Paperwork Reduction Act Submissions.”

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL
METHODS
This information collection request does not contain statistical methods.

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