Justification to use emergency procedures

To: ACF Desk Officer, Office of Management and Budget (OMB)

From: Earl S. Johnson, Director, Office of Family Assistance

Re: Emergency Clearance Justification for Collecting ARRA Subsidized Employment Data

Date: August 16, 2010

The Administration for Children and Families (ACF) requests emergency clearance to collect information on the number of individuals in subsidized employment as a result of the TANF Emergency Fund. We initially requested emergency clearance to collect this data and received approval of our data collection form, and we also posted a Federal Register notice on June 8 stating our intent to collect this information and invited comments. As a result of this notice we received comments that yielded improvements to our data collection instrument, and we are therefore submitting a revised data collection form for emergency clearance. The TANF Emergency Fund was authorized under the American Recovery and Reinvestment Act of 2009 (Recovery Act), and this legislation provided up to $5 billion to help States, Territories, and Tribes in fiscal year (FY) 2009 and FY 2010 that have an increase in assistance caseloads or in certain types of expenditures.

Many jurisdictions are implementing subsidized employment programs as a result of the availability of this new funding, and there is substantial interest from the White House, OMB, the Congress, and the media in understanding how this funding has been used. There is also significant public interest in the number of individuals that are being placed in subsidized employment as a result of the Recovery Act. This information will help the agency as well as the public better understand how jurisdictions are using the money they are awarded through the Emergency Fund.

As a result, we are seeking emergency clearance to begin a voluntary data collection to gather information on the number of individuals in subsidized employment funded in whole or in part by the TANF Emergency Fund or that were included in the calculation of a TANF Emergency Fund award. We are requesting emergency clearance as the authorization for this program expires at the end of FY 2010, creating an extremely brief window of opportunity for data collection.

Given this Administration’s commitment to transparency and accountability, it would create public harm if the results of this program were not captured and quantified. The first data collection is due AugustNovember 14, 2010. Failing to collect information on subsidized employment funded through use of the TANF Emergency Fund would prevent the Administration, the Congress, and the public from obtaining meaningful information about the program.

Therefore, this collection of information is needed prior to the time allowed by the use of normal clearance procedures and is essential to the mission of the agency. ACF requests a determination by September 13, 2010 under 5 CFR 1320.13 of the Paperwork Reduction Act regulation.