Supporting Statement A for ICR Rev (11-28-12)

11

SUPPORTING STATEMENT FOR

PAPERWORK REDUCTION ACT SUBMISSIONS

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 Department of Labor’s Veterans’ Employment and Training Service (VETS) administers funds for the multi-year Jobs for Veterans State Grant (JVSG) to each State, the District of Columbia, Puerto Rico and the Virgin Islands on an annual fiscal year basis. These non-competitive, formula-driven grants are codified under Title 38, United States Code, (38 U.S.C.) Section 4102A (b)(5):

“Subject to subsection (c) make available for use in each State by grant or contract such funds as may be necessary to support—(A) disabled veterans’ outreach program specialists appointed under section 4103A (a)(1) of this title, (B) local veterans’ employment representatives assigned under section 4104 (b) of this title, and (C) the reasonable expenses of such specialists and representatives described in subparagraphs (A) and (B), respectively, for training, travel, supplies, and other business expenses…”

VETS provides funds to States in accordance with an allocation formula required by 38 U.S.C. 4102A (c)(2)(B) and as published in regulation at Title 20, Part 1001, Subpart F of the Code of Federal Regulations (CFR). The Assistant Secretary for Veterans’ Employment and Training monitors and supervises the distribution and use of those funds as required by 38 U.S.C. 4102A (b)(6). Additionally, and in accordance with 38 U.S.C. 4107 (b), the Secretary reviews performance and provides an annual report to Congress that includes:

• A characterization of the quality and character of priority of services provided to veterans (38 U.S.C. 4215 and 20 CFR 1010.320, 1010.330);

• Efforts to coordinate with the Veterans Administration in accordance with 38 U.S.C. 4102A (b) (3) and 4109; and

• Incentive fund usage as described in 38 U.S.C. 4112.

VETS is requesting continued approval for the information collection that streamlines the annual funding request process for grantees, reports the use of grantee funds in sufficient detail to allow interim adjustments that ensure all appropriated funding is expended properly, and provides data needed for VETS’ Annual Report to Congress.

The forms and report collect required programmatic and financial data from States requesting and obligating grant funds. The continued use of standardized formats for collecting this information helps to ensure that requested data is provided in a uniform way, reporting burdens are minimized, the impact of collection requirements on respondents are properly assessed, collection instruments are clearly understood by respondents, and the information is easily consolidated for posting in accordance with statutory requirements.

The legislative and/or regulatory justification for each information collection is as follows:

1. Manager’s Report on Services to Veterans: 38 U.S.C. 4104(e) requires a report on employment and training services provided to veterans and eligible persons by each local employment service delivery point or area. This narrative report is provided to the State Director for Veterans' Employment and Training (DVET) each Federal fiscal quarter. It addresses:

• Outreach efforts to employers and other organizations to promote the hiring of veterans and other eligible persons;

• Veterans and other eligible persons enrolled in case management (receiving intensive services) from staff assigned to the local office;

• Outreach efforts to locate and serve veterans and other eligible persons with barriers to employment; and

• Compliance with Priority of Service requirements established at 38 U.S.C. 4215 and 20 CFR, Part 1010.

2. VETS 201 Vocational Rehabilitation and Employment (Chapter 31) Tracking Report: 38 U.S.C. 4102A (b)(3) requires coordination with the Department of Veterans Affairs with respect to other programs, placing particular emphasis on the rehabilitation and training activities carried out under 38 U.S.C, Chapter 31, the Vocational Rehabilitation and Employment (VR&E) program. The Tracking Report (VETS 201) is designed to compile information on disabled veterans jointly served by the VA, VETS and JVSG recipients. All partners agree to share information exclusively to facilitate job development and placement services for participating veterans. It replaces the VR&E information previously reported in the quarterly Manager’s Report on Services to Veterans. The information is collected only with documented consent from veterans in accordance with the Privacy Act of 1974 and other applicable regulations.

3. VETS 401 JVSG Budget Information Summary: In accordance with OMB Circular A-102, “Grants and Cooperative Agreements with State and Local Government,” applicants for non-construction program grants must submit certain detailed budget forecast information as specified by the awarding agency. The awarding agency uses the information provided for the award and general management of the grant. VETS currently uses the OMB-approved (1293-0009) single-page VETS 401, which provides all the budget information needed to accommodate the two JVSG programs and three sub-programs by VETS. Continued approval will allow entry of the forecast costs for all programs funded by the JVSG by Object Class Category and cash needs for each funding source by quarter.

4. VETS 402A/B JVSG Expenditure Detail Report (EDR): Financial reports ensure that the grantee adheres to the budget approved by the awarding agency. VETS collects and compiles the EDR (VETS 402A or B) information to effectively monitor the use of JVSG funds for each separate program purpose in accordance with the regulations at Title 29, Part 97.41 a.3. JVSG recipients use the EDR to detail total expenditures by funding source to supplement the quarterly Federal Financial Report (FFR) which is used to report total grant spending and draw down of funds. To accommodate differences in States’ accounting systems, two separate versions of the self-calculating EDR allow States to report either quarterly (VETS 402A) or cumulative expenditures (VETS 402B) each quarter. The EDR (VETS 402A or B) effectively cross-walks to both the FFR and the JVSG Budget Information Summary (VETS 401) to ensure grantees obligate awarded funding in accordance with their approved budget plan.

Because 39 U.S.C. 4102A (b)(5) stipulates that JVSG funds are made available to staff and support DVOP specialist and LVER positions, VETS requires States to report the amounts expended for Personal Services and Personnel Benefits (the primary costs for staff) and Base Positions Paid for each funding source.

5. VETS 501 JVSG Staffing Directory: Grantees are able to provide information that allows VETS to ensure they have complied with several staffing requirements by submitting a VETS 501. The form was designed to streamline the requirement for certain staffing information and to minimize the reporting burden on grant applicants. The VETS-501 form:

• Satisfies an assurance required by the Drug-Free Workplace Act of 1988, and implemented at 34 CFR Part 85, Section 85.605 and 85.610 by providing the locations where grant-funded staff will be assigned;

• Includes the name and assignment information for all grant funded staff to ensure the grantee is in compliance with 38 U.S.C. 4102A (c)(8)(A), which requires each employee hired by the State to perform the duties of a disable veterans’ outreach program (DVOP) specialist or local veterans’ employment representative (LVER) to satisfactorily complete training provided by the National Veterans’ Employment and Training Services Institute (NVTI) authorized by 38 U.S.C. 4109 during the 18-month period that begins on the date on which the employee is so assigned; and

• Provides information on positions filled by non-veterans to ensure the proper justification is provided as mandated by 38 U.S.C. 4102A (c)(5)(B) that requires grant recipients to notify VETS of and provide rationale for each non-veteran employed as a DVOP specialist or LVER for more than six months.

VETS uses the form to monitor the States use of funds to staff DVOP and LVER positions, track turnover, identify new hires requiring training, and ensure that such staff fulfill their purposes as effectively and productively as possible.

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.

The information collections described in 1. above are a continued collection of information required under the JVSG program. All of the forms are submitted by State Agencies that receive formula funding under the JVSG. With the exception of the narrative Manager’s Report on Services to Veterans, all of the information is provided on the forms submitted for approval. The forms and instructions for the narrative Manager’s Report is made available to the State Agencies electronically and in hard copy and is transmitted via Veterans’ Program Letters (VPLs) - VETS’ policy guidance. All forms will be available for download from the VETS homepage and are used to request and collect staffing, services or financial expenditure information, as described in the paragraphs below.

The VETS 201 replaced the separate outcome reports that the Department of Veterans’ Affairs, the Department of Labor and the respective State Agencies were maintaining for a common set of participants who are served under Chapters 31 and 41 of Title 38, U.S.C. The one-page form captures all information required to be collected and reported by each of the three Federal and State entities to ensure a common set of data is maintained and to ensure, to the greatest extent possible, that the needs of all participants are met and desired results are achieved.

The information collected on the VETS 201 is used to compile information for the Annual Report to Congress and for the three Federal agencies to improve services to the veterans jointly served through each agencies program.

The VETS 401 and VETS 501 are used by State Agencies to request formula funding available through the JVSG. As part of a request for formula funding, they are used by VETS to make informed grant award decisions. The VETS 401 form submitted in this collection has been updated to allow for reporting TAP funding separately. This is a slight change to the form that does not change the burden hours associated with the reporting.

The single-page VETS 401 replaced two, two-page SF 424As previously required. It allows information to be entered for all program categories by Object Class Category and for each quarter on one-side of a page reducing the burden for States and making the form more useful for comparison to actual expenditures reported each quarter during the grant period. VETS uses this information to administer interim adjustments that ensure all appropriated funding is expended properly.

The VETS 501 is a simplified form that streamlines and standardizes the information previously provided by grantees. The form contains the addresses of all locations at which JVSG-funded staff operate to fulfill the requirements of Item #5 in the Certification of Tobacco-free and Drug-free Workspace. It identifies vacant positions the grant applicant plans to fill and indicates which staff will be appointed full-time and which will be appointed half-time for monitoring and internal control of funding. The form also provides a standard format to identify newly appointed (after January 1, 2006) DVOP specialists and LVER staff required to receive specialized training within 18-months of appointment. VETS facilitates coordination with the States, the individual DVOP specialist or LVER staff member, and the contracted trainer to provide the required training. The information is also used to monitor each State’s use of funds to staff DVOP and LVER positions, track turnover, identify new hires, and identify positions filled by non-veterans.

The VETS 402A/B is used by State Agencies to report detailed expenditure information needed to assure VETS the grantee is obligating grant funds in accordance with their approved budget plan. The form allows VETS to track both staff utilization and quarterly spending by relevant cost-category for each of the five JVSG funding sources. Two automated formats were designed to accommodate different State accounting systems which report expenditures on either a quarterly or year-to-date basis. When compared to the Budget Information Summary (VETS-401), it is used by VETS to ensure grantees are spending funds in accordance with their plan and to make timely and informed decision regarding reallocation of funding. The VETS 402A/B forms submitted in this collection have been updated to allow for reporting TAP funding separately. These are slight changes to the form that do not change the burden hours associated with the reporting.

The Manager’s Report on Services to Veterans is used by individual service delivery points or service delivery areas within the State Agency to assure VETS that the approved State Plan is being adhered to at the local level. It is used as a monitoring tool for VETS to evaluate services provided and outcomes that result from those activities.

All of the information collections, past and proposed revisions, have been or will be used to report staff utilization rates, use of funding, and results to Congress annually.

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 the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The Manager’s Report on Services to Veterans is not a form. All of the other information collections are forms that will be made available to grantees electronically as Microsoft Excel documents. Blank forms will be transmitted to the States as attachments to Veterans’ Program Letters and automated copies will be posted on the VETS homepage for download.

Respondents (grantees) will be allowed to submit the Manager’s Report on Services to Veterans in narrative form electronically or in hard copy. The other forms in the information collection may be submitted as follows:

• The VETS 201 – electronically;

• The VETS 401 – electronically or in hard copy for review and uploaded as an attachment to grants.gov;

• The VETS 402 – electronically or in hard copy at the respondent’s discretion; and,

• The VETS 501 – electronically or in hard copy for review and uploaded as an attachment to grants.gov.

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.

The continued information collection modifies current formats to eliminate both duplication and the collection of redundant information. The forms standardize and streamline the methods of collection and ensure that only necessary information is captured and reported in a uniform manner, so that similar data can be easily collated and compared from quarter to quarter and from State to State. A search of the published application forms and Federal reports indicates that these forms and reports do not duplicate any similar information already available.

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

N/A.

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.

The VETS 401 JVSG Budget Information Summary in this data collection must be completed once annually by all grantees and again, if and when additional funds are sought by grantees or the scope, cost or grant conditions change during the fiscal year.

The following reporting forms must be submitted in accordance with guidance and regulations (29 CFR, Part 97) on a quarterly basis. They are: Manager’s Report on Services to Veterans, VETS 201 Vocational Rehabilitation and Employment (Chapter 31) Tracking Report, VETS 402 JVSG Expenditure Detail Report (EDR), and VETS 501 JVSG Staffing Directory.

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 OMB;

• 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.

Grant funds are appropriated by Congress on a fiscal year basis and are requested by grantees once annually, unless requested more frequently through formal grant modification requests. All reports on this funding are required quarterly and submitted electronically. The awarding agency does not impose any record retention requirements on the grantee above and beyond the State’s own requirements.

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 OMB. 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. 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 recordkeeping, 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. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The Department published a Federal Register Notice on September 27, 2012 which appeared in Volume 77, Number 188 Federal Register, dated September 27, 2012 (77 FR 59421-59423), notifying the public of its intent to pursue this information collection (VETS ICR Number 1293-0009). The Department received no responses to the Notice.

The only respondents are JVSG recipients, all of which are State Agencies. The Department has used these information collections for the past three years. No recommendations to change the forms have been received during usage over the past three year period.

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

Outside of an internal State performance-based incentive award program administered by grantees for noteworthy State employees and offices as required at 38 U.S.C. 4112, no payment or gift will be provided by the Federal government to any respondents or to current JVSG grantees.

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

As part of all grant application and reporting processes initiated by the Department which are covered under 29 CFR, Part 97 (Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments- OMB Circular A-102), a “Release of Information” certification is executed by each grantee’s administrator, who is empowered by the Governor to enter into grants and cooperative agreements with the Department.

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 from whom the information is requested, and any steps to be taken to obtain their consent.

No questions of this nature are included in any application or any report form described in this information collection request.

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 OMB 83-I.

• 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.

Form design and imbedded formula calculations were developed expressly to reduce the burden on individual respondents and staff that review application forms and consolidate reports. In order to determine the hour burden for each information collection, VETS field staff tracked the hours it took for three of the smallest and three of the largest States operating all JVSG program categories to complete and submit each of the previously required forms. The burden per respondent is displayed as an average based upon a range of hours determined from past experience of State generated reports for the:

• Manager’s Report on Service to Veterans, respondents can be service delivery points or service delivery areas which could cause the number of respondents to vary between 2,000 to 3,000, dependent upon negotiations between State Directors for Veterans’ Employment and Training and the grantee;

• VR& E Tracking Report, the number of Department of Veterans’ Affairs Regional Offices and eligible individuals served varies greatly by State size and population; there are currently 57 sites that report this information collection;

• JVSG Budget Information Summary, funding for the number of optional programs (Special Initiatives and Incentive Awards Programs) beyond the core DVOP and LVER Program, varies;

• JVSG Expenditure Detail Report, the number of additional approved programs (Special Initiatives and Incentive Awards Programs) reported by each State, beyond the core DVOP and LVER Program, varies; and,

• JVSG Staffing Directory, the number of combined DVOP and LVER staff supportable by formula-based funding, varies from between one (1) staff in Guam to over two hundred (200) in California.

Affected Public: Jobs for Veterans State Grant Applicants/Recipients (54); DVOP specialists and LVER staff (2,000), American Job Center/One-stop/Local Office/Local Area Managers (2,000).

Estimated Number of Respondents:

1. Manager’s Report on Services to Veterans 2,000

2. VETS 201 57

3. VETS 401 54

4. VETS 402A or B 54

5. VETS 501 54

Estimated Average Burden Per Respondent:

1. Manager’s Report on Services to Veterans 2 Hours, Range 1 – 3 Hours

2. VETS 201 2 Hours, Range 1 – 3 Hours

3. VETS 401 1.5 Hours, Range 1 - 2 Hours

4. VETS 402A or B 2 Hours, Range 1 -3 Hours

5. VETS 501 2 Hours, Range 1 -3 Hours

Frequency of Response:

1. Manager’s Report on Services to Veterans Quarterly

2. VETS 201 Quarterly

3. VETS 401 Annually

4. VETS 402A or B Quarterly

5. VETS 501 Quarterly

Estimated Annual Burden:

1. Manager’s Report on Services to Veterans 16,000 Hours

2. VR & E Tracking Report (VETS-201) 456 Hours

3. JVSG Budget Information Summary (VETS-401) 81 Hours

4. JVSG Expenditure Detail Report (VETS-402A/B) 432 Hours

5. JVSG Staff Directory (VETS-501) 432 Hours

Data Collection	Collection Hours Per Response	Number of Respondents	Annual Responses per Respondent	Annual Burden Hours
Manager’s Report	2	2,000	4	16,000
VETS 201	2	57	4	456
VETS 401	1.5	54	1	81
VETS 402	2	54	4	432
VETS 501	2	54	4	432
Total	N/A	2,219	N/A	17,401

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 startup 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 for the government, or (4) as part of customary and usual business or private practices.

Total Annualized Capital/startup costs: $0.

Total Initial Annual Costs: $0.

Respondents will not need to purchase any equipment or special software to respond to this information collection request. Since these data collection requirements apply to state formula grant recipients, administrative resources are provided as part of the grant to off-set staff costs associated with reporting and systems modifications. As such, there is no additional cost to respondents.

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.

Data Collection	Annual Burden Hours	Hourly Rate**	Federal Costs
Manager’s Report	16,000	$49.84	$797,440
VETS 201	456	$49.84	$22,727
VETS 401	81	$49.84	$4,037
VETS 402	432	$49.84	$21,531
VETS 501	432	$49.84	$21,531
	17,401	$49.84	$867,266

**Hourly rate is based on BLSTable 4 dated June 2012, State and local government employer costs per hour worked for total compensation state and local government management, professional, and related workers ($49.84).

The costs for the time taken to apply for these grants, and report quarterly are applied to an indirect cost pool comprised of funds received from various funding sources in the Department of Labor including the JVSG Grant. Therefore, the state bears no burden for the costs to provide these reports and all costs are attributable to the Federal government.

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

The total burden hours for this ICR decreased due to decreasing the number of VETS 201 reports that will be filed (from an estimated 16,000 to 456) and eliminating the VETS 601 report (40).

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.

N/A

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

N/A

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

N/A