OJC SUPPORTING STATEMENT 1205-0025 Oct 7 2010

SUPPORTING STATEMENT FOR 1205-0025; Job Corps Application Data, Information Collection Request

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The collection of this information is necessary to determine eligibility of applicants to the Job Corps program. The forms in this collection are:

ETA 652, Job Corps Data Sheet

ETA 655, Statement from Court or Other Agency

ETA 682, Child Care Certification

These forms are the initial forms completed for each applicant. They serve as the basic document for determining eligibility for Job Corps. They also provide demographic characteristics for program planning, evaluating and reporting purposes. This activity, previously authorized by Title IV-B of the Job Training Partnership Act and currently authorized under the Title I, Subtitle C of the Workforce Investment Act of 1998, is the major responsibility of the Job Corps admissions counselor.

The ETA 652, Job Corps Data Sheet, is used to obtain information for screening and enrollment purposes to determine eligibility for the Job Corps program in accordance with the Workforce Investment Act. It is prepared by the admissions counselor for each applicant and has no further impact on the public. It is critical to the screening process. It also provides demographic characteristics for program planning and reporting purposes. Data for the form are collected by interview, generally at the admissions counselor’s work site. The information obtained includes age, legal U.S. residency, family income/welfare status, school status, behavior history, parental consent and child care needs of each applicant.

The remainder of the form asks for basic information such as name and address, which are already on the ETA 652. This data continues to be collected electronically.

The ETA 655, Statement from Court or Other Agency, collects essential information for determining the suitability of an applicant to participate in the Job Corps program. It is used to document past behavior problems for all applicants, as well as provide a basis for projecting future behavior. It is collected by the Job Corps admissions counselor who requests the information from proper authorities. If it were not obtained, serious problems could result from enrolling potentially harmful or disruptive individuals in Job Corps, which is a residential program. This could have legal implications for the Federal government. The ETA 682, Child Care Certification, is used to certify an applicant’s arrangements for dependent child(ren) while the applicant is in Job Corps.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Data for the screens are collected via interview by Job Corps admissions counselors, generally at the admissions counselor’s work site. Documentation of behavioral background is obtained from appropriate courts, agencies, and/or institutions. The information gained from these forms is used to determine applicant’s eligibility for the Job Corps program.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and t basis for the decision for adopting this means of collection.

In order to comply with the Government Paperwork Elimination Act of 1998, Job Corps has reduced the paperwork burden by implementing an electronic system of application data collection for use in determining eligibility for the program. Admissions counselors enter data directly from information provided during interviews with applicants. Behavioral information is entered on the ETA 655 from courts and institutions that provide the information. These records are transmitted electronically to the admissions contractor headquarters for quality control as required, to the appropriate Job Corps center to which applicant has been assigned, and to the regional office where appropriate. The database is located at the Job Corps Data Center in Austin, Texas. Further savings in burden are made by having demographic information, such as name and address, automatically printed on all forms where required, after the information is initially entered.

Student records have been consolidated into one database. This has provided a seamless record for each student from application through post-placement follow-up information, and has effectively eliminated much duplication of data.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

Due to the nature of the activity, duplication is minimal. One application must be completed for each person who applies to Job Corps. The forms have no cycle and are used only as the individual situation dictates (e.g., only applicants with dependent children must complete an ETA 682, Child Care Certification). Unless the legislation is changed, the frequency of, the nature of, and the use to which this information is put, will remain unchanged. In terms of duplication of information, once basic information (name and address) is entered in one place, it is automatically entered on each form where appropriate.

5. lf the collection of information impacts small businesses or other small entities (Item 5 of 0MB Form 83-I), describe any methods used to minimize burden.

This collection does not involve small business or other entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

These are basic source documents. No other information is available at the time these documents are prepared. The information must be obtained to determine each applicant’s eligibility to receive the benefits of Job Corps.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by 0MB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

There are no such special circumstances.

8. If applicable, provide a copy and identify the data and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to 0MB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

In accordance with the Paperwork Reduction Act of 1995, the public was given 60 days to review and comment on the Federal Register notice (published in Vol. 75, Number 16, pp 4107 -4108, January 26, 2010). No comments were received.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. Consultation with those who use this form is an ongoing process. Unless the laws are changed, the frequency of, the nature of, and the use to which this information is put, will remain unchanged.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The nature of the program requires that sensitive areas be addressed in order to gather information about each applicant’s eligibility to receive Job Corps benefits. The Job Corps Privacy Act Statement is given to each applicant. It describes how the information will be used, who has access to it, and how it can be released. Some potentially sensitive items are included on the forms such as welfare status, race, annual income, and history of conviction or delinquency against persons or property. All of these, however, are part of the eligibility equation to determine need and suitability for admission to the program, as required by law. The information sought is essential to the well-being of the Job Corps program and is so mandated by legislation. The information is essential to making eligibility decisions on those applicants with known past behavior problems. Further, confidentiality with regard to student social security numbers, student records, including student medical records, is covered in the Job Corps Policy and Requirements Handbook. The law authorizing this program provides for compliance with the Privacy Act in all its aspects. 20 CFR 670.965, Disclosure of Information, provides instructions as to how to handle the confidentiality of the information obtained on each student.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons form whom the information is requested, and any steps to be taken to obtain their consent.

There are no other questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of 0MB Form 83-I.

ETA Form No.	Number of Respondents Current request	Frequency	Average Time Per Respondent	Total Burden Hours	Total Number of Respondents Approved by OMB, 2007 NOA	Total Burden Hours Approved by OMB, 2007 NOA
Job Corps Application ETA 652		1/person	10 minutes
Statement from Court ETA 655		1/person	1 minute
Child Care Certification ETA 682		On occasion	1 minute
Total	92,122		18,424 hours		92,122	16,158 hours

During PY 2009, an estimated 92,122 applicants completed applications for Job Corps. Based on the current minimum hourly wage of $7.25, and at an estimated average of eleven minutes, 30 seconds each to complete the data screens for the three forms, the cost to applicants is calculated at 92,122 x $7.25 per hour x 12 minutes, for a total estimated annual participant cost of $133,576.90.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

During PY 2005, 102,833 applicants completed applications for Job Corps. To estimate burden cost for these respondents, we determined that 45.5% percent or 46,789 of them had ever worked before applying to Job Corps. Based on the minimum hourly wage of $5.15 and a time cost of eleven minutes, 30 seconds each to complete the data screens, for those who had worked before Job Corps, the total burden hours would be 17,139 hours and at $5.15 per hour, the total burden cost would be $39,397 for providing the information needed to complete the data screens.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

•If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records the government, or (4) as part of customary and usual business or private practices.

There are no other costs.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

During PY 2009, 92,122 applicants completed applications for Job Corps. Estimating the annual cost for contractor staff and related cost to be approximately $750,000 and adding $135,577 for the value of applicant time, the total federal cost burden for this ICR as part of all contracts with Job Corps operators would be $885,577.

There are no added federal costs.

15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the 0MB Form 83-I.

There are no changes; however, the hour burden was adjusted upward slightly to account for the fact that the time for filling out ETA-682 was revised from an estimated 30 seconds, or half a minute, to 60 seconds, or a full minute, for a total of 12 minutes for the three forms rather than 11.5 minutes. Thus the total estimated annualized hour burden is now 18,424 hours rather than 16,158 hours.

16. For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

There are no plans to publish.

17. If seeking approval to not display the expiration date for 0MB approval of the information collection, explain the reasons that display would be inappropriate.

Job Corps will make notification of the new expiration date through a Job Corps Directive that is attached.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submission,” of 0MB 83-I.

There are no exceptions.

B. Collection of Information that Employ Statistical Methods

This collection does not employ statistical methods.