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Supporting Statement for Information Collection Approval of the
Extension of the Low Income Home Energy Assistance Program
(LIHEAP) Model Plan
May 7, 2010
A. Justification
1. Circumstances Making the Collection of Information Necessary
The Low Income Home Energy Assistance Program (LIHEAP) statute, U.S.C. 8624, requires that as part of the annual application required for the receipt of Federal funds to administer a LIHEAP program, each grantee must provide specific information in its state plan. Grantees may use any format they wish to submit the information. However, the statute requires HHS to distribute a model plan format to grantees each year.
Under prior guidance, the Chief Executive Officer in States, Tribes or Territories is required to certify in the LIHEAP State Plan that the grantee will uphold all rules, regulations, and policies associated with the LIHEAP program. As cited above, grantees must have in place policies that address waste, fraud and abuse.
Presidential Executive Order 13520, reducing Improper Payments and Eliminating Waste in Federal Programs, issued in November 2009, encourages Federal agencies to take deliberate and immediate action to eliminate fraud and improper payments. As part of the review of programs subsequent to this executive order, HHS has determined that additional information from each administering agency is necessary to assess grantee measures that are in place to prevent, detect or address waste, fraud and abuse in LIHEAP programs.
The Administration for Children and Families is requesting the Office of Management and Budget to authorize emergency processing of its information collection clearance of the LIHEAP Program Integrity Assessment and Plan in order for submission by grantees with their applications for fiscal year 2011 funding.
2. Purpose and Use of the
Information Collection
The
data is reviewed by the Division of Energy Assistance, Office of
Community Services, to determine whether grantees have submitted a
complete application for Federal funds. An application consists of
two parts--certification to sixteen assurances and a plan describing
how several of the assurances will be implemented, along with other
information, as described in section 2605(c) of the statute.
Submission of a complete application is a prerequisite to receiving
Federal funds to administer a LIHEAP program. Most grantees use the
model plan format, which reduces the burden on the grantee, speeds
the HHS review process and makes the faster issuance of grant awards
possible.
3. Use of Information
Technology and Burden Reduction
We
significantly reduced the burden, effective with FY 1998
applications, by developing an abbreviated plan that grantees may use
in two of every three years.
The Division of Energy Assistance makes the LIHEAP Model Plan available to grantees for downloading from the ACF web site.
We have been working closely with the ACF Office of Information Systems to develop an electronic format. The initial effort based on ACF’s current capacity failed to produce a user-friendly product and would have required grantees to purchase software that they would not otherwise need. ACF currently is in the process of developing the capacity to allow our customers to fill out and submit forms electronically. The electronic version will be the same as the paper and website versions.
4. Efforts to Identify
Duplication and Use of Similar Information
There
is no similar source of information used which can be modified for
the purpose of collecting required state plan information for the Low
Income Home Energy Assistance Program from one year to the next.
5. Impact on Small Businesses
or Other Small Entities
This
model plan format does not involve small entities as defined by OMB.
Only states, territories, tribes and tribal organizations are
affected.
6. Consequences of Collecting
the Information Less Frequently
The
information requirements are an annual activity which is required by
law for the receipt of Federal block grant funds. Under the LIHEAP
statute, we must make a model plan available to grantees. It
provides grantees an optional management tool that may alleviate the
burden of preparing additional information to complete plans. This
model encompasses the content of the information statutorily required
for a complete plan. Without this information collection, we would
not be able to issue grants.
7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There is no circumstance
that requires the information to be provided or the model plan format
to be used in a manner inconsistent with the guidelines in
5 CFR 1320.6.
8. Comments in Response to the
Federal Register
Notice and Efforts to Consult Outside the Agency
This
is an emergency request. Notice of the request for OMB approval of
information collection for the LIHEAP application requirements/Model
Plan and the LIHEAP Program Integrity Assessment and Plan will be
published in the Federal
Register and made
available for review and comment. We will send a copy of the Federal
Register notice and
the proposed Model Plan and LIHEAP Program Integrity Assessment and
Plan to all LIHEAP grantees and persons on our "interested
parties" mailing list and requested their comments.
There has been a change in the substance of this collection activity since the activity was last approved to add the LIHEAP Program Integrity Assessment and Plan.
9. Explanation of Any Payment or Gift to Respondents
There is no payment or gift
involved other than awarding funds based on complete plans.
10. Assurance of Confidentiality Provided to Respondents
There is no assurance of
confidentiality that is applicable to this information collection or
Model Plan.
11. Justification for
Sensitive Questions
There
are no sensitive questions contained in the information required or
Model Plan.
12. Estimates of Annualized
Burden Hours and Costs
If
all current grantees choose to apply for funds, there will be
approximately 180 respondents. If the Detailed Model Plan is used,
we estimate that it will take each respondent 1 hour to complete; if
the Abbreviated Model Plan is used, we estimate 20 minutes per
response. The LIHEAP Program Integrity Assessment and Plan will take
an addition hour to complete. This includes the time for reviewing
previous applications, gathering the data needed and reviewing the
completed application, and assessing monitoring procedures. Because
the Model Plan is so simple to use, and has been so well received by
grantees, we expect virtually all respondents to use the model plan
format. The LIHEAP Program Integrity Assessment and Plan will add an
additional 180 hours to the respondent burden due to 1 hour per each
of the 180 respondents. This means that the total respondent burden
is 283 hours. We anticipate that the LIHEAP Program Integrity
Assessment and Plan will also be well received.
The current OMB inventory for this collection is 103 hours. OMB approval for the current information collection expires on September 30, 2011, approval number 0970‑0075.
The breakdown in burden hours is as follows:
ANNUAL BURDEN ESTIMATES
INSTRUMENT |
NUMBER OF RESPONDENTS |
NUMBER OF RESPONSES PER RESPONDENT |
AVERAGE BURDEN HOURS PER RESPONSE
|
TOTAL BURDEN HOURS
|
DETAILED MODEL PLAN |
65 |
1 |
1 |
65 |
ABBREVIATED MODEL PLAN
|
115 |
1 |
.33 (20 MINUTES) |
38 |
LIHEAP Program Integrity Assessment and Plan |
180 |
1 |
1 |
180 |
Estimated Total Annual Burden Hours: 283
If the Detailed Model Plan is used, we estimate that it will take 1 hour to complete. Because the Model Plan is available electronically, and much of the plan only calls for check marks at appropriate places, we expect that the entire task would be performed by a professional staff member at a cost of $20 for one hour's work. The total cost for the 65 respondents we estimate would use the Detailed Model Plan each year would be $1,300 (65 x $20).
If the Abbreviated Model Plan is used, we estimate it will take 20 minutes per response including the time for reviewing previous applications, gathering the data needed and reviewing the completed plan. We estimate the cost, based on an hourly labor cost of $20, to be $759 (.33 x $20 x 115 respondents).
If the LIHEAP Program Integrity Assessment and Plan is used, we estimate that it will take 1 hour to complete. We expect that the entire task would be performed by a professional staff member at a cost of $20 for one hour's work. The total cost for the 180 respondents we estimate would use the LIHEAP Program Integrity Assessment and Plan each year would be $3,600 (180 x $20).
13. Estimates of Other Total
Annual Cost Burden to Respondents and Record Keepers
There
are no additional annual direct costs to respondents as a result of
this information collection.
14. Annualized Cost to the
Federal Government
Based
on our experience in administering the LIHEAP program, we estimate
that it takes an average total of 4 hours for Federal staff to review
each Detailed Model Plan and make any necessary follow-up contacts
with grantees to obtain additional information. We estimate that it
will take an average of 1.5 hours to review each Abbreviated Model
Plan and make any necessary follow-up contacts with grantees.
A GS-13 employee generally reviews each report and a GS 13 may also do second review. A GS-14 or GS-15 employee generally makes final decisions when there are questions about the adequacy of information. At an average salary rate of $30 per hour, assuming 4 hours each for 65 applications and 1.5 hours each for 115 applications, the Federal salary costs each year will be about $12,975 ([4 hours x 65 applications] + [1.5 hours x 115 applications] x $30).
The Division of Energy Assistance projects an annual reproduction cost of $140. This estimate is based on 180 respondents receiving one copy of the Detailed Model Plan and one copy of the Abbreviated Model Plan.
15. Explanation of Program
Changes or Adjustments
A
program change was required by E.O. 13520 mandating the LIHEAP
Program Integrity Assessment and Plan be added to the current
approval. This established the requirement
“LIHEAP Program Integrity Assessment and Plan” to be
submitted by all State LIHEAP grantees. The new LIHEAP Program
Integrity Assessment and Plan must be submitted with each State’s
FY 2011 State Plan. Both the State Plan and the LIHEAP Program
Integrity Assessment Plan must be submitted no later than September
1, 2010. The LIHEAP Program Integrity Assessment Plan must
address key elements of an effective fraud prevention system and a
framework for those key elements will be distributed to all State
grantees via an Action Transmittal. The LIHEAP Program
Integrity Assessment Plan must be submitted by all State grantees
regardless of whether the State grantee is scheduled to submit a
detailed or abbreviated State Plan for FY 2011.”
There were no adjustments.
16. Plans for Tabulation and Publication and Project Time Schedule
The results of the
information collection and Model Plan will not be published.
17. Reason(s) Display of OMB Expiration Date is Inappropriate
The OMB approval number and
expiration date will be clearly displayed on the front page of the
Model Plan and action transmittals relating to application
requirements. The information required in section 1320.8(3) in the
regulation also will be displayed on the front page of the document.
18. Exceptions to Certification for Paperwork Reduction Act Submission
There are no exceptions
necessary for this information collection.
B. Collection of Information
Employing Statistical Methods
This
information collection does not employ statistical methods.
File Type | application/msword |
File Title | SUPPORTING STATEMENT |
Author | Linda Hill |
File Modified | 2010-05-27 |
File Created | 2010-05-27 |