SUPPORTING_STATEMENT_VRAP_ICR__Emergency_version final

EMERGENCY SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL for New Information Collection

UNDER THE PAPERWORK REDUCTION ACT OF 1995

SUPPORTING STATEMENT

Veterans Retraining Assistance Program

A. Justification

A.1. Circumstances that make the collection of information necessary.

The information collection is requested to support the required reporting and employment services outreach of the Veterans Retraining Assistance Program (VRAP), described in Section 211 of the VOW to Hire Heroes Act of 2011 (PL 112-56). This provision directs the Department of Veterans Affairs (VA) in cooperation with the Department of Labor (DOL) to pay for up to 12 months of a training program in a high demand occupation for unemployed eligible veterans between the ages of 35 and 60 as determined by DOL and VA. The program is to serve up to 45,000 veterans in fiscal year 2012, which began on July 1, 2012, and up to 54,000 veterans from October 1, 2012, through March 31, 2014.

The VRAP provides the benefit to veterans who fulfill the following eligibility criteria: As of date of application, is at least 35 years old and less than 60; discharged from active duty under conditions other than dishonorable; is unemployed as of date of application; is not eligible to receive other educational assistance from the VA; is not in receipt of compensation for a service-connected disability rated totally disabling by reason of unemployability; was not and is not enrolled in any Federal or state job training program within the previous 180 days; and, the application must be submitted not later than October 1, 2013. DOL is responsible for collecting individual applicant information to verify age, employment status, and status in a Federal or state job training program within the previous 180 days. The veteran confirms eligibility through self-attestation, and the data is being stored with VA. DOL has received OMB approval to collect applicant information, and store it with VA. (OMB Control Number 1205-0491) OMB approved the extension of data collection on October 10, 2012.

VRAP requires DOL to offer employment placement services to veterans participating in the VRAP within 30 days of their completion or termination from the program. Additionally, the VA, in collaboration with DOL, is required to submit a report to Congress by July 1, 2014, on the outcomes of the program. The report must include the total number of eligible veterans who participated in the program, the associate degrees or certificates awarded (or other similar evidence of the completion of the program of education or training), and data related to the employment status of eligible veterans who participated in the program.

To reduce the data collection burden on the states and obtain data related to the employment status and outcomes of eligible veterans who participated in the program, DOL is leveraging the Wagner-Peyser program, which established the Employment Service. The Employment Service utilizes automatic wage records to obtain employment data from the states. The system which captures those records is the Labor Exchange Reporting System (LERS), OMB Control Number 1205-0240.

LERS will provide DOL the following employment data on VRAP participants:

• The Entered Employment Rate (EER)

• The Employment Retention Rate (ERR)

• Average Earnings

• Median Earnings

However, the approach will only capture data pertaining to individuals who formally register with the Employment Service, and DOL must ensure that every veteran was offered employment services even if they were not registered into LERS. Therefore, to ensure that each VRAP participant is offered employment placements services within 30 days of their completion or termination of the program, DOL needs to track the outreach done by the state or local level staff for each participant.

On a weekly basis, the VA has been transmitting a secure participant report to DOL so that employment services can be offered to the participant and program outcomes can be reported after they exit training. After receiving and processing the VA participant report, DOL develops and transmits a report (see the collection instrument, “Sample VRAP File for States”) to each state workforce agency on VRAP participants in that state who terminated or completed VRAP. DOL transmits each state’s file on a weekly basis using a secure File Transfer Protocol (sFTP) site. Each state will be able to access only its file so that it can disseminate the participant information securely to the appropriate American Job Center staff so they can offer employment services to the veteran. The American Job Center staff will then contact the veteran via phone and/or email to offer the employment services

To ensure employment services are being offered and outcomes are being tracked for all participants, ETA proposes to collect quarterly reports from the states on the employment services offered to VRAP participants. The report will be in Microsoft Excel format and will include, among other information, a “unique identifier” field (not personally identifiable information), assigned by ETA and an “Employment Assistance” field which will be blank (see “Sample VRAP File for States”). The “Employment Assistance” field will be completed by the state workforce agency tracking the outreach offered to each VRAP participant. ETA seeks approval from OMB to collect from each state the “unique identifier” field and the “Employment Assistance” field on a quarterly basis, with a 45 day reporting period following each quarter. The collection fields are described in the collection instrument, “Sample States’ VRAP Quarterly Report.” This will ensure that the states will not be transmitting Personally Identifiable Information (PII) to DOL, but will allow for DOL to identify the level of outreach provided to each participant.

As mentioned above, when DOL sends the participant file to the states the “Employment Assistance” field will be blank. When the states send in Quarterly reports as proposed, there will be a numeric value in each “Employment Assistance” field based on the service provided and the directions below:

• A “1” will be entered in the column if the veteran was contacted and did not need employment assistance because they already had a job;

• A “2” will be entered in the column if the veteran was contacted and does not come in to receive employment assistance for any other reason;

• A “3” will be entered in the column if the veteran was non-responsive to the offering of employment assistance; or

• A “4” will be entered in the column if the veteran was either already registered in the state Wagner-Peyser program, or the case manager was able to register the individual after VRAP training completed.

Justification for Seeking Emergency Approval: ETA seeks emergency clearance from OMB for approval to collect VRAP program participant outcome reporting because the VRAP program began on July 1, 2012. DOL needs to be able to track both the provision of employment services to VRAP exiters as well as the employment outcomes of VRAP exiters to ensure compliance with the VOW to Hire Heroes Act of 2011. DOL is leveraging changes to the Labor Exchange Reporting System that were approved by OMB on August 7, 2012 (OMB Control Number 1205-0240) to track employment outcomes of VRAP exiters that enroll in employment services under the Wagner-Peyser program. DOL is also leveraging the participant information collection request, stored with VA, and approved by OMB on October 10, 2012. This information request allows DOL to collect participant information, which it shares with state workforce agencies to provide employment assistance.

However, DOL does not currently have OMB approval to collect information related to outreach and offering of employment services to VRAP exiters. This information collection is required by the VOW to Hire Heroes Act of 2011. Already over 45,000 applications have been received by the VA, and participants are in training. Some training can be short term, and some VRAP participants have already completed or terminated training. This then gives DOL only 30 days, as required in the statute, to be able to attempt to contact the veteran to offer employment services.

DOL will need to collect the information quarterly to measure progress on the provision of employment assistance, and to provide technical assistance. States will submit the quarterly reports through the same sFTP site, set up by DOL to share the VRAP exiter information. Failure to collect these quarterly reports from the states would jeopardize DOL’s ability to ensure participants are offered the employment services they are entitled to under the law and would jeopardize DOL’s ability to report to Congress on the outcomes of the program.

A.2. How, by whom, and for what purpose the information is to be used.

To meet its statutory responsibilities for VRAP under the VOW to Hire Heroes Act of 2011, the Department requests approval to collect quarterly reports from the states on the employment services being offered to VRAP participants. The Department will use the information collected to ensure services are being offered throughout all states and to provide any needed technical assistance. The information will also be incorporated in the required VA and DOL Report to Congress.

A.3. Extent to which collection is automated, reasons for automation, and considerations for reducing impact on burden.

Information technology is being used to reduce the burden. States will be able to submit reports via the fully automated sFTP site they use to receive their participant files.

A.4. Efforts to identify duplication – why similar information already available cannot be used for purpose described in A.2.

These proposed quarterly state reports support a new program requiring DOL to ensure provision of employment services to veterans. DOL is proposing to leverage the existing Wagner-Peyser reporting system to collect performance outcomes on those veterans who receive employment services. This avoids the need to create an entirely new system unique to VRAP, and only requires DOL to ensure that services are being offered to participants. However, additional information is needed about those VRAP participants that elect not to enroll in employment services. These additional reporting requirements will capture more robust information about the VRAP program.

A.5. Efforts to minimize burden on small businesses.

The information collection involves only state workforce agencies, American Job Centers, and individuals (veteran completers or terminators). There is no impact or burden on small businesses.

A.6. Consequences to Federal program if collection not done or done less frequently and any technical or legal obstacles to reducing the burden.

Under the VOW to Hire Heroes Act of 2011 (PL 112-56), DOL is required to provide employment services to all VRAP participants upon completion or termination from the program. DOL seeks this information collection request to verify, through reports back from the states, that employment services are being offered to program participants. If this information is not collected, DOL will be unable to ensure the services are being offered within enough time to provide technical assistance when needed, should the services not be offered. The collection will be done only on a quarterly basis, with a 45-day reporting period following each quarter, and only involve the transmittal of non-personally identifiable information. The entities involved are all accustomed to providing quarterly reports within the time frame described.

A.7. Special circumstances for conducting information collection.

There are no special circumstances that would require the information to be collected or kept in any manner other than those normally required under the Paperwork Reduction Act.

A.8. Summary of public comments.

A sixty day notice was already published in the Federal Register on February 6, 2013 (vol. 78, p 8585 et seq). To date, no comments have been received. DOL will advise OMB if any comments are received.

A.9. Explanation of decision to provide any payment or gift to respondents.

DOL does not provide any payment or gift to respondents.

A.10. Assurance of confidentiality provided to respondents.

ETA is responsible for keeping data private and will maintain the data in accordance with all applicable Federal laws.

A.11. Justification for any sensitive questions.

DOL will collect no sensitive information.

A.12. Estimated hourly burden.

Participant Contact List Dissemination

DOL estimates the time for state agencies to receive and prepare their participant files from DOL to send to the American Job Centers to be 60 minutes per report. There will be a total of 54 states or territories preparing reports 52 times a year (weekly file). This equates to a total of 2,808 reports annually. This equates to 2,808 burden hours.

Record Type	Minutes Per Report	Respondents	# of Annual Reports by respondents	Annual National Burden Hours
Weekly Report	60 (one hour)	54 states and territories	2,808	2,808

Participant Contact

DOL also estimates the time American Job Center staff will need to contact each VRAP participant. DOL estimates that the total amount of time per participant to be 10 minutes. The program is to serve 99,000 participants over a two year period, beginning July 1, 2012 through March 31, 2014. Annualized over three years the amount is 33,000 participants at 10 minutes a participant for a total annualized burden of 5,500 hours per year.

Record Type	Minutes Per Contact	# of Annual Reports	Annual National Burden Hours
Participant Contact	5 per AJP staff intake person; 5 per participant	33,000	5,500 (2,750 attributable to state burden and 2,750 to individual burden)

Final Report Preparation

DOL also estimates the time state agencies need to receive and prepare the participant files they receive back from the American Job Centers on a quarterly basis. DOL estimates that the preparation and submission time to be 90 minutes per report. There will be a total of 54 states or territories preparing reports 4 times a year, which equals a total of 216 responses. 216 responses at 90 minutes a report equals 324 hours per year.

Record Type	Minutes Per Report	Respondents	# of Annual Reports	Annual National Burden Hours
Final Report	90	54	216	324

Total Burden Estimate

DOL estimates a total of 8,632 burden hours annually for the data collection among 33.000 participants, 54 state agencies, and American Job Centers staff.

The annual national burden for the data collection has three components outlined in #12 above. The burden estimate includes the local and state level steps required to collect the information requested. DOL is applying the hourly rate used for the Labor Exchange Reporting System (LERS) revisions (OMB Control No. 1205-0240) to determine the burden hour cost.

Participant Contact List Dissemination

Record Type	Minutes Per Report	# of Annual Reports	Annual National Burden Hours	Applicable Hourly Rate	Annual National Burden Dollars
Weekly Report	60	2,808	2,808	$41.80	$117,374

Participant Contact

Record Type	Minutes Per Contact	# of Annual Reports	Annual National Burden Hours	Applicable Hourly Rate	Annual National Burden Dollars
Participant Contact, AJP staff Participant Contact, Individual	5 5	33,000 33,000	2750 2750	$41.80 $7.25 (federal minimum wage)	$114,950 $19,937.50

Final Report Preparation

Record Type	Minutes Per Report	# of Annual Reports	Annual National Burden Hours	Applicable Hourly Rate	Annual National Burden Dollars
Final Report	90	216	324	$41.80	$13,543

A.13. Estimated cost burden to respondents.

DOL provided $60,000 to each state and territory ($3,180,000 total) to assist in the implementation of the VRAP among other purposes in TEGL 37-11, issued on June 15, 2012.

Each state will need to acquire sFTP software if they currently lack it. However, there are multiple versions available at no cost. States are responsible for disseminating the participant data to the American Job Centers securely and may leverage the existing sFTP software to do so. American Job Centers may have to acquire the same software if they do not have it already, but is available at no cost. Guidance on this process was issued in Training and Employment Guidance Letter (TEGL) 8-12, issued on October 5, 2012.

A.14. Estimated cost burden to the Federal government

The estimated cost to the Federal government is largely based on leveraging an existing secure File Transfer Protocol (sFTP) site to transmit participant reports and to receive quarterly state reports. Those costs, anticipated to be minimal, consist mainly of creating unique state accounts within the sFTP site. Once these costs can be determined, ETA will submit a non-substantive change request to OMB/OIRA.

A.15. Reasons for any program changes reported in Items 13 or 14 of the OMB Form 83-1.

This is a new information collection request.

A.16. Method for publishing results.

In a joint VA and DOL report to Congress 1) the number of participants in the VRAP program, 2) the degrees/certificates/credentials awarded, and 3) the employment status of the participants under the statute, over the life of the program, is due no later than July 1, 2014.

A.17. If seeking approval not to display the expiration date for OMB approval, explain why display would be inappropriate.

DOL will display the OMB approval number on the VRAP participant form when it is disseminated weekly to the state agencies.

A.18. Explanation of each exception in the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions” on OMB Form 83-1.

The Department is not seeking any exception to the certification requirements.

2. Collection of Information Employing Statistical Methods

This information collection request employs no statistical methods.