OMB:1205-0275
ETA-9117
SUPPORTING STATEMENT
Part A
The Department of Labor, Employment and Training Administration (ETA), is requesting OMB approval of the extension of the ETA-9117 form. The ETA-9117, Trade Adjustment Assistance (TAA) Program Reserve Funding Request Form is used by State Workforce Agencies (SWAs) to request TAA reserve training funds and job search and relocation allowances under the TAA program.
Background
The administration of the Trade Act of 1974, as amended by the Trade Adjustment Assistance Reform Act of 2002 (Public Law 107-210) and the American Recovery and Reinvestment Act of 2009, is the responsibility of the Secretary of Labor. Through agreements (Governor-Secretary Agreements) established with States, states have served as agents of the Department in making payments to workers adversely affected by trade imports to certain countries. Section 241 of the Act provides that: “The Secretary shall from time to time certify to the Secretary of the Treasury for payment to each cooperating state the sums necessary to enable such State as agents of the United States to make payments provided for by this chapter.”
The statutory training cap for the TAA program is $220 million. In order to maximize the use of these funds for trade-certified individuals, the Department provides funds to cooperating States each year by distributing $165 million in formula base allocations at the beginning of each year. In addition, $55 million is held in reserve for distribution throughout the year to address unforeseen training needs.
Circumstances which make the collection of information necessary.
Enrollment in training is an entitlement for workers adversely affected by imports or shifts of production to certain countries. Thus, the Trade program consists of entitlements for trade readjustment allowances (TRA), job search allowances, relocation allowances and training. Although training becomes an entitlement under the program, the TAA program has a statutory training cap of $220 million. The entitlement nature of the TAA program, plus the statutory limitation on the amount of funds which may be obligated for training requires the Department to institute procedures which ensures that States are funded equitably and that the $220 million training cap is not exceeded.
How, by whom, and for what purpose will the information be used?
ETA uses the information to analyze fund utilization rates (e.g., accrual expenditures, obligations and uncommitted fund balances). Information collected using this form enables the Department to effectively provide financial information to stakeholders such as Congress, OMB, internal and external partners, and the public.
States will use the form to request additional training funds and job search and relocation allowances for trade-certified individuals.
Describe any consideration of information technology to reduce burden.
States use their own automated accounting systems to generate financial data. The majority of State Agencies administering the TAA program still use a uniform automated accounting system formally supported by DOL.
Describe efforts to avoid duplication. Show specifically why any similar information already available cannot be used to satisfy purposes described in 2 above.
The Department is not aware of any duplication of this data collection. ETA’s Office of National Response, Division of Trade Adjustment Assistance is the only program that collects this information.
Small Business Involvement.
This data collection does not involve small businesses.
Consequences on Federal policy if information was collected less frequently.
There are no consequences. However, States submit the ETA- 9117 and the accompanying Standard Form (SF-424)Request for Federal Funds on a case-by-case basis as additional funds are necessary to avoid the interruption of a trade-certified individual’s training plan. The instructions for requesting reserve training funds have been published in Training and Employment Guidance Letters 6-03, 6-04 and 4-05 as Departmental policy. The absence of these forms would make it difficult to effectively evaluate a request for funds and could potentially allow a State(s) to exceed its obligational authority without the Department’s knowledge.
Explain any special circumstances that would cause an information collection to be reported to the agency more often than quarterly.
The only circumstance that would require reporting more frequent than quarterly would arise in cases where a state determines that prior funding is not sufficient to meet the training needs of eligible individuals therefore; making it necessary to submit a subsequent request for TAA reserve funding.
Describe efforts to consult with persons outside the agency on the collection of requested information.
On September 29, 2009, a 60 day Notice seeking comments from the public was published in the Federal Register (Vol. 74, No. 187, p 49893). No comments were received.
Explain any decision to provide payment or gift to respondents, other than reenumeration of contractors or grantees.
No gift or payments will be made to respondents.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulations, or agency policy.
Information collected on the ETA-9117 is public information. The data collected does not contain any information of a confidential nature. Therefore, no assurances are necessary.
Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature being asked.
Provide estimates of the hour burden of the collection of information.
TAA Reporting: A conservative estimate of the states applying annually for additional training funding from the reserve account is 25. A conservative estimate of the time incurred to complete the ETA-9117 is two hours.
25 respondents x 2 hrs. x 1 report = 50 hours
Total hours requested – 50 hours
The annual cost to the State Workforce Agencies is based on an estimate of the total average salary of $26.00 per hour x 2 hours per form submitted equals $52 per form.
Provide an estimate of the total cost burden to respondents resulting from the collection of information. Do not include costs in item 12 or 14.
The States have been collecting this information and supplying it to the national office since fiscal year 1989, therefore no start-up costs are necessary. Also, states collect this information within the agency and do not contract out services.
Provide estimates of annualized costs to the Federal government.
As mentioned in 12 above, the total cost to States would be approximately $13,000,or $26 times 2 hours times 25 reports. The costs of Federal staff reviewing information submitted at the regional and national level, providing reports, and making grant approvals would total one-half staff year at an annual cost of $85,000. This would total approximately $42,500.
Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form 83-I.
There are no changes or adjustments.
16. Address any complex analytical technique which will be used in the publishing of the data collected.
This data is not published and does not involve statistical activities.
17. If seeking approval to not display expiration date for OMB approval of the information being collected, please provide rationale.
The DOL is not seeking to exclude the expiration date from the form.
Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission”.
No exceptions are being requested.
Part B
Collection of Information Employing Statistical Methods
This Collection of Information does not employ statistical means.
| File Type | application/msword |
| File Title | MEMORANDUM FOR: PETER T |
| Author | Louis Harrell |
| Last Modified By | naradzay.bonnie |
| File Modified | 2010-01-06 |
| File Created | 2010-01-06 |