Justification Part A - Emergency Request OMB 053012

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

Study of the Involvement of Veterans and Military Families in National Service

A. Justification

A1. Need for Information Collection

The 2009 Edward M. Kennedy Serve America Act, which reauthorized the Corporation for National and Community Service (CNCS), directed the agency to expand the participation of veterans and military families in national service. In CNCS’ 2011-2015 Strategic Plan, a key priority for the agency is to increase the involvement of veterans and military families in national service and to improve the quality of CNCS-funded services for these populations. Since the involvement of veterans and military families is a relatively nascent field for national service, CNCS has been developing and expanding its programs and projects and building its knowledge around the most effective and promising models and practices for engaging and serving these important populations.

The proposed information collection is intended to provide CNCS, its programs, and the national service field with critical knowledge about the experiences, successes, and challenges of existing national service programs and projects in engaging and serving veterans and military families. In addition to identifying the particular contributions that national service can make to meeting the needs of these populations, this study will also be used to begin to build an evidence base that documents the effectiveness and impact of national service in this area.

The Serve America Act includes a requirement for CNCS to submit a Congressional report that documents how the strategies undertaken by CNCS have enabled greater participation by veterans, and how existing CNCS programs and activities could be improved to serve veterans and military families [Sec. 196C. (42 U.S.C. 12651k)]. An essential source of information for the report is the proposed information collection, which will involve telephone interviews with organizations that receive CNCS-funding and have proposed substantial and/or strategic efforts to involve veterans and military families as national service participants and/or beneficiaries. During the interviews, these programs and projects will be asked about the history of their national service activities with veterans and military families; the ways in which they involve these populations as national service participants or beneficiaries; effective strategies that they have used to engage these populations; and any evaluation data they have on the effectiveness of their activities.

Initially, the deadline for the Congressional report was April 2012; however, Congress has since allowed an extension for the report and provided a new deadline of October 31, 2012. As Congress has agreed to allow us an extension on the report, we feel that it is incumbent upon us to provide the most accurate and comprehensive report possible by this new deadline. In order to incorporate the findings from the field assessment into the report, CNCS will need to complete the information collection by the summer of 2012, which will not be possible if we are required to undergo the full clearance process. In an effort to be compliant with the Paperwork Reduction Act and with OMB’s information collection policies and procedures, while also fulfilling our obligations to demonstrate good stewardship to Congress and the public, we issued a 60-day notice for public comment, which ended on May 29, 2012 and are submitting the enclosed request under 5 CFR 1320.13 to OMB for emergency processing and approval of information collection activities.

Public harm is reasonably likely to occur if normal clearance procedures are followed. Without an expedited clearance, CNCS will be unable to expand its programs and initiatives to meet the critical needs of transitioning service members and their military families, as dictated by Congress and the President. This important demographic will be negatively impacted by the lack of expanded and effective national service opportunities during this time of increased re-deployment to communities nationwide.

As noted in the Hiring Heroes Act of 2011, passed by the Veterans Affairs Committee, one million veterans are currently unemployed and more than a million are expected to leave the military by 2016. The study of the involvement of veterans and military families in national service is crucial to meeting, in a timely manner, the demands of this emerging population with effectual national service opportunities.

Without the timely implantation of this collection activity, we will miss gathering valuable information that will allow us to serve the largest wave of returning veterans since the Vietnam War. During this critical period, the study will allow CNCS to deploy and expand national service opportunities for veterans and military families in those areas required by the Serve America Act, including coordination of community needs for military families during deployment and reintegration; recruitment of veterans for national service and volunteer opportunities; assistance to veterans in the utilization of education, employment, and other state and federal benefits and services; mentorship of military children; and assistance with the transportation needs of veterans with disabilities, unemployed veterans, older veterans and veterans in rural communities.

In sum, we are requesting emergency approval by [DATE] because a longer review will not allow us to fulfill our obligations to provide effective national serve opportunities and services to meet the critical needs of transitioning service members and their families, and to report to Congress on CNCS activities to increase the involvement of veterans and military families in a timely and accurate manner, as stipulated in the SAA.

A2. Use of Information

The information collected under this request will provide CNCS with a means of identifying effective models and strategies that national service programs and projects have developed for engaging and serving veterans and military families. As part of the project, CNCS aims to gather critical data and information that may be used to inform CNCS’ veterans strategy and identify the unique roles that national service might play in meeting the needs of veterans and military families. The aggregated findings will inform the report to Congress on the involvement of veterans and military families in national service, mandated by the Edward M. Kennedy Serve America Act. In addition, we will use the information to produce a learning document that outlines potential program models and strategies that CNCS programs can use to grow their veterans programs and build evidence of program impact.

 

A3. Minimize Burden: Use of Improved Technology to Reduce Burden

The information will be collected entirely via telephone interviews. All interviews will be scheduled at the convenience of the respondent.

A4. Non-Duplication

There are no other sources of information by which CNCS can meet the purposes described in A2 (above).

 

A5. Minimizing Economic Burden for Small Businesses or Other Small Entities

This collection of information does not impact small businesses. There is no economic burden to any other small entities beyond the cost of staff time to respond to the interview. In order to reduce overall burden to other small entities, we have used a thorough review of application materials submitted under eGrants to limit respondents to those who described explicit plans to engage and/or serve veterans and/or military families.

A6. Consideration of Collection

CNCS will be unable to fulfill its legal obligation to provide effective national serve opportunities and services to meet the critical needs of transitioning service members and their families, and to report to Congress on CNCS activities to increase the involvement of veterans and military families in a timely and accurate manner, as stipulated in the SAA.

A7. Special circumstances that would cause information collection to be collected in the specified ways.

There are no special circumstances that would require the collection of information in any other ways specified.

 

A8. Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice.

The initial 60-day Federal Register notice was published on March 30, 2012 and ended May 29, 2012 (Volume 77, no. 62, pages 19263-19264). A copy is attached. One comment was received with a request to add a question to gather information on best practices for providing training and support that meet the specific needs of veterans who serve as national service participants. CNCS has added a question in response to this comment.

 

A9. Payment to Respondents

There are no payments or gifts to respondent

  

A10. Confidentiality

The information does not require an assurance of confidentiality because no personal information is requested.

A11. Sensitive Questions

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

This is a one-time collection with a maximum of 100 interview respondents. The average amount of time for respondents to complete the interview is estimated at 50 minutes. The total hour burden for the collection is estimated at 83.3 hours.

 

A13. Cost burden to the respondent

There is no annual cost burden to respondents.

 

A14. Cost to Government

The annual cost to the Federal government for the implementation of the study is estimated at $220,000, which includes costs associated with development of the interview protocol, identification of sample respondents, data collection, analysis, creation of database, and reporting.

A15. Reasons for program changes or adjustments

This is a new collection request.

 

A16. Publication of results

Results from the data collection will be used to inform a report to Congress, as stipulated in the Edward M. Kennedy Serve America Act, as well as learning document on promising models and practices for the national service field. 

 

A17. Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

Not applicable.

 

A18. Exceptions to the certification statement

There are no exceptions to the certification statement.

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