NEORHYMIS suppstate 2013 c

Application for Renewal of the National Extranet Optimized Runaway and Homeless Youth

Management Information System (NEORHYMIS) Version 2.1

OMB # 0970-0123

Supporting Statement

Office of Data, Analysis, Research and Evaluation

Administration on Children, Youth and Families

Administration for Children and Families

U.S. Department of Health and Human Services

November 2013

Table of Contents

A. Justification

1. Circumstances Making the Collection of Information Necessary

2. Purpose and Use of the Information Collection

3. Use of Improved Information Technology and Burden Reduction

4. Efforts to Identify Duplication and Use of Similar Information

5. Impact on Small Businesses or Other Small Entities

6. Consequences of Collecting the Information Less Frequently

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

9. Explanation of Any Payment or Gift to Respondents

10. Assurance of Confidentiality Provided to Respondents

11. Justification for Sensitive Questions

12. Estimates of Annualized Burden Hours and Costs

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

14. Annualized Cost to the Federal Government

15. Explanation for Program Changes or Adjustments

16. Plans for Tabulation and Publication and Project Time Schedule

17. Reason(s) Display of OMB Expiration Date is Inappropriate

18. Exceptions to Certification for Paperwork Reduction Act Submissions

B. Statistical Methods (used for collection of information employing statistical methods)

1. Respondent Universe and Sampling Methods

2. Procedures for the Collection of Information

3. Methods to Maximize Response Rates and Deal with Nonresponse

4. Test of Procedures or Methods to be Undertaken

5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

EXHIBIT 1: Legislation 12

EXHIBIT 2: Federal Register Notice 13

A. Justification

1. Circumstances Making the Collection of Information Necessary:

The Runaway and Homeless Youth Act (RHYA), as reauthorized by the Reconnecting Homeless Youth Act of 2008 (P.L.110-378 ) (42 U.S.C. 5601), mandates that the Department of Health and Human Services (HHS) report regularly to Congress on the status of HHS-funded programs serving runaway and homeless youth. Organizations funded under the Runaway and Homeless Youth (RHY) program are required by Section 312 (b) (7, 8, 11 and 12) and Section 322 (a) (9, 12, 13 and 14) of the Statute to meet several data collection and reporting requirements. These requirements include maintenance of client statistical records and submission of annual program reports regarding the characteristics of the youth and families served and the services provided to them. (Attached as Exhibit 1 are the relevant sections of the statute and regulation mandating the collection of information) The October, 2008, reauthorization of the Act maintained the longstanding requirements as described in the legislation.

The Reauthorization also requires that HHS (1) report on promising practices in preventing youth homelessness and (2) evaluate the homelessness prevention and intervention effectiveness of the Transitional Living Program (Part B of the Act). RHYMIS data is central and critical to both mandates. The report was issued in May, 2007. The evaluation is underway through an independent research organization.

The data from the National Extranet Optimized Runaway and Homeless Youth Management Information System (NEO-RHYMIS) support the grantee organizations as they carry out a variety of integrated, ongoing responsibilities and projects.

2. Purpose and Use of the Information Collection:

NEORHYMIS data is used by Federal and grantee staff responsible for planning, funding and implementing projects that assist runaway and homeless youth. Specific organizations include: ACYF Family and Youth Services Bureau along with its Regional outstations; the ACYF Office of Data, Analysis, Research and Evaluation (ODARE); the ACF Office of Planning, Research and Evaluation (OPRE), Basic Center Program (BCP), Transitional Living Program (TLP), and Street Outreach Program (SOP) grantees; academics, HHS research, evaluation and support contractors; and RHY Training and Technical Assistance providers. Additionally, NEORHYMIS is the source for the data contained in the Biannual Report to Congress on the Youth Programs of the Family and Youth Services Bureau (mandated by RHYA) and the ACF Annual Performance Plan and Performance Reports for the President’s Performance Budget. The data is requested from time to time by Congressional staff, officials from State and local levels of government, researchers, and practitioners, within and beyond the RHY community of grantees.

NEORHYMIS data supports several integrated, ongoing responsibilities and projects, including legislative reporting requirements, planning and public policy development for runaway and homeless youth programs, accountability, monitoring, program management, research, and evaluation. The information collected through NEORHYMIS also has a significant role in supporting the requirements and needs of the RHY projects, including reporting requirements, research and evaluation, monitoring, program management, and providing documentation in support of applications for funding.

3. Use of Improved Information Technology and Burden Reduction:

NEORHYMIS utilizes commercially available relational database software (MS Access) that are standard issue on personal computers. NEORHYMIS can operate effectively on a single machine or be accessed in a common database via a local area network (LAN) for grantees using multiple computers. By using NEORHYMIS, grantees have immediate access to the data required to plan, administer, report and evaluate their programs.

Grantee staff are responsible for entering the data into the automated system at each grantee site. NEORHYMIS reads and validates information as it is entered. The grantee can generate various reports for use by local management, administrative and technical staff. Semi-annually, the grantee uses automated functions in NEORHYMIS to download the data onto a diskette and then sends the diskette to FYSB’s contractor, or they may electronically submit the data via email for integration into the national database maintained by the contractor. Personally-identifying information is not shared with FYSB or its contractor.

Prior to FY 2000, RHYMIS reporting requirements were described by grantees as complex and burdensome and response rates were low. The simplification and streamlining incorporated into the currently approved version have dramatically improved the response rate. Over 96% of the FYSB RHY grantees (who number between 600 and 700 in a given year) consistently submit complete reports as required. Another small group includes grantees that may not report in a given period for a valid reason. The response rate has continued unabated every year since the original instrument and design improvements. Many grantees have also stated they find the data not only easier to provide, but useful for their own needs as well. The system requires minimal training due to the simplicity of the product, its help features, and the expert help desk assistance provided by FYSB’s contractor. In addition to live help desk assistance, an online RHYMIS tutorial module was created to provide first line training to grantees and staff members responsible for RHYMIS data entry. This tutorial helps to increase data quality by offering a uniform set of instructions regarding data entry, reporting, system troubleshooting and national data transfer submission..

3. Efforts to Identify Duplication and Use of Similar Information:

There are no other sources of information available to be reported to HHS on runaway and homeless youth and therefore, NEORHYMIS does not duplicate any existing data. In fact, NEORHYMIS is the only uniform collection process that results in accurate, timely and consistent information that can be reported to HHS regarding the number, composition and characteristics of runaway and homeless youth served by the RHY programs as mandated by Congress in the RHY Act.

Currently, there are a variety of youth services information management systems operating at the regional, state, and local levels. These systems are not fully compatible throughout grantee or federal collection efforts and cannot be compiled into one national database. NEORHYMIS is able to accept properly formatted and defined national RHY data from individual systems. The contractor is authorized to assist grantees developing their own proprietary MIS to ensure compatibility with all reporting requirements.

NEORHYMIS addresses the issue of data duplication on a number of levels:

1. NEORHYMIS collects information about programs and youth only once. Only changes in the status of the grantee program or in the status of a youth require new information. NEORHYMIS is designed to allow the grantee to edit and integrate new information with existing information. These edit and integration features minimize data collection, data entry, and reporting burden.

2. Since NEORHYMIS supports the BCP, TLP, and SOP in the same software package, a community agency that receives funding under more than one of these RHY programs will have to complete information on its agency only once.

3. NEORHYMIS is designed to assist the RHY grantees in meeting other reporting requirements and information needs. These include reporting to other funding sources and documenting services for licensing requirements. As noted above, it is easy for a grantee to indicate that a particular caseload record, utilizing all or some of the NEORHYMIS elements, is a “non-FYSB” youth, and NEORHYMIS treats that record as such, and does not include it with the FYSB records during data transfer.

4. HHS and HUD are currently working to collaborate on a shared homeless data collection system to support the US Interagency Council on Homelessness objective to end youth homelessness by 2020. Not only will federal agencies have a more accurate picture of runaway and homeless youth across various programs, but it will also reduce the duplication of services and counts of youth who are receiving them.

5. Impact on Small Businesses or Other Small Entities:

The labor and one-time hardware costs for collecting this information is paid for by the grant to the community-based organizations funded by the RHY Act. The software and technical support is free. The time required for staff to enter the data for the various subset reports is small and organizations will already have collected the data on each youth for many of the data elements. Data need only be entered from existing records. Grantees report that the burden is minimal.

6. Consequences of Collecting the Information Less Frequently:

HHS cannot fulfill its obligation to effectively serve the runaway and homeless youth population in the United States, nor report meaningful and reliable information to Congress about the extent of this problem or the effectiveness of various methodologies designed to provide assistance to this population, without access to timely and accurate information. To be of any value, this information must include specific data elements that are defined in a consistent manner and collected and reported using standard procedures. NEORHYMIS defines the required data and provides required procedures and reports. Grantees currently use the data in justifying applications for grants, not only when they re-compete for FYSB funding, but for other programs serving at risk youth as well.

Since FYSB uses the data as mandated in annual reporting to Congress under GPRA and bi-annual reporting under RHYA, the data must be collected on an annualized basis. Prior to 2000, grantees reported quarterly. The newer versions call for semi-annual reporting, which has reduced the workload on grantees. Semiannual reporting allows for data analysis, quality review and mid-year corrections that might not take place on a timely basis if submissions were less frequent. Grantees are better off entering the data as they obtain it or soon after, to ensure accuracy. They can access NEORHYMIS for data entry, review and editing at any time. The semi-annual submission is a mostly automated process that requires little labor. Most of the users' work in operating NEORHYMIS involves case data entry on an ongoing basis. Aggregating this youth information on less than a semi-annual basis will delay the grantees' ability to benefit from the information contained in the national database, to identify how closely their own clients reflect the national RHY profile or to develop programs that most effectively meet their clients’ needs.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5:

There are no special circumstances regarding the collection of this data. No individually-identifying information enters the report when it is transmitted to Washington for integration in the national database. Youth are tracked using anonymized, system-generated IDs. Standard and mandated security features and confidentiality protections are built in and fully implemented.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside Agency:

On July 15, 2013, we initiated the regular clearance process with a 60 day notice in the Federal Register, (Volume 78 Number 135, Page 42081). A copy of the first Federal Register notice is provided in Exhibit 2.

No changes in content were made since this collection was reapproved in 2010. Grantees continue to provide feedback through the technical support hotline and focus groups sponsored by ACF.

RHY hosts two annual conferences which provide additional opportunities for service provider feedback and discussion. In the past, feedback from such stakeholders have assisted us in identifying system improvements such as allowing grantees to record and track prevention services, successful program completion, youth on waiting lists, and youth who temporarily separate from the program but return for completion.

9. Explanation of Any Payment or Gifts to Respondents: There is no remuneration, of any kind, to NEORHYMIS users. Participation in data collection is mandated for all RHY grantees. The software and support are free.

10. Assurance of Confidentiality Provided to Respondents: NEORHYMIS has built-in, structured security mechanisms that assure the confidentiality of the clients. These mechanisms include:

• Identification Numbers - FYSB assigns unique identification numbers to BCP, TLP, and SOP grantees. The youth identification number is generated by the automated system according to a secure, programmed algorithm. Once a youth is added into the database, only his/her identification number appears on data entry screens and storage files. Individual client files are accessible only to authorized grantee staff.

• Informed Consent - Youth and families are informed about the data collection process, and are asked to sign an informed consent form documenting their awareness and understanding of the data collection process before any data elements are entered into the system. Refusal to participate in the data collection process does not preclude a youth or family from receiving services.

• System Security/User Identification - Access to each data file within NEORHYMIS is limited by the use of an authorized user identification number, password, and other security procedures. The grantee's management controls all access to data. The terms and conditions of their grant requires security and confidentiality protection.

11. Justification for Sensitive Questions:

There are some NEORHYMIS data elements are designed to collect information that may be considered sensitive. This information pertains to the youth and their family's socio-economic status, mental health, alcohol and other drug involvement, legal status, and family and social relationships. It must be noted that, prior to participating in a project, all youth and families are informed that information about them and the services they receive, will be collected, recorded, and submitted anonymously to FYSB for statistical analysis. As stated above, youth and families are assured that all information is strictly confidential and that their identities are protected. Additionally, program participants are required to sign a statement of agreement that acknowledges that this information as well as their rights have been explained to them.

This information is extremely critical for FYSB to ensure the effective delivery of services, use of appropriate interventions and the development of individualized youth and family service plans. It is also essential to assess the attainment of long term programmatic goals and outcomes and for the early identification of trends and problems in the field of RHY.

12. Estimates of Annualized Burden Hours and Costs:

The decrease in burden hours are a result of the formula that is used to calculate burden hours which takes into account the number of agencies funded and the number of your being served.  These numbers fluctuate from year to year based on funding availability and trends in RHY seeking services.  In 2012, both the number of grantees and the number of youth served had decreased from the 2010 count listed in the previous application.  No changes in the data collection instrument were made since re-approval of this collection in FY 2007.

Instrument	Number of Respondents*	Number of Responses per Respondent **	Average Burden Hours per Response	Total Burden Hours
Youth Profile: BCP entrance report (one for each youth)	321	118	0.125	4734.75
Youth Profile: TLP entrance report (one for each youth)	205	19	0.125	486.875
Youth Profile: BCP exit report (one for each youth)	321	118	0.125	4,734.75
Youth Profile: TLP exit report (one for each youth)	205	19	0.125	486.875
Brief Contacts (4 data elements per youth)	526	153	0.05	4023.9
BCP/TLP Turnaways (5data elements per youth)	526	33	0.05	867.9
Street Outreach Report	138	5,660	0.02	15621.6
Data Transfer	664	2	0.50	664.35

Estimated Total Annual Burden Hours: 31,621

* Estimate as of 2012; (the number of funded grantees changes somewhat from year to year)

** Average estimated based on FY 2012 youth entering caseload (FY 2013 finals will not be available until Dec 2013; caseloads change from year to year but not greatly.)

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers:

There is no other cost to the grantees to operate the RHYMIS data system. Additionally, there are no costs for training, ongoing technical support, software or any supporting documentation. Aside from the live help desk, grantees also have access to an online tutorial that provides instructional support for all aspects of RHYMIS data collection.

Task / Item	Annual Number	Annual Cost	Estimated Annual Cost
			0

Estimated total annual personnel cost: $790, 525

(assuming $25/hr for data entry * 31,144 burden hours)

NOTES:

1. Hardware for most agencies has already been acquired. Hardware and Software estimates are annualized over the assumed equipment life. Software is compatible with most PCs. The equivalent contemporary system would probably be far more powerful but a very inexpensive device of relatively modest performance and capacity will suffice.

2. Software and tech support is provided free of cost to grantees.

3. Agencies are required to include these costs for computers and internet for data entry purposes in grant budgets as part of their competitive proposals.

14. Annualized Cost to Federal Government:

Task / Item	Estimated Annual Cost
1.      Technical Assistance hotline (business hours, Monday-Friday)	$242, 299.40
2.      System Improvements	$6, 922.84
3.      Data Analysis and Reporting	$69, 228.44
4.      National Data Transfer: Data Collection and Validation	$325, 373.44
5.      Special Projects	$48, 459.88
6.      Federal Gov’t Staff*	$9,400
7.      Federal Gov’t Travel	$2,000
Total	$703, 684

* GS 13-2 project officer @ .1 FTE

Note: Activities 1 through 5 are provided under a contract with Computer Sciences Corporation (CSC). Costs allocations among tasks 1-5 are approximations.

15. Explanation for Program Changes or Adjustments:

There have been no changes in the program or data collection requirements.  However, there has been an adjustment in the number of burden hours. This is a result of the formula that is used to calculate burden hours which takes into account the number of agencies funded and the number of your being served.  These numbers fluctuate from year to year based on funding availability and trends in RHY seeking services.  In 2012, both the number of grantees and the number of youth served had decreased from the 2010 count listed in the previous application.  No changes in the data collection instrument were made since re-approval of this collection in FY 2007. Grantee estimates on the time needed to enter the BCP or TLP entrance or exit report data for each youth ranged from a few minutes, to five, ten or (rarely) fifteen minutes.  The other reports are very brief.

16. Plans for Tabulation and Publication and Project Time Schedule:

The data collected by NEORHYMIS will be analyzed to determine the characteristics of runaway and homeless youth, their problems, and services provided to them. As exemplified under “Use of Data”, FYSB also will conduct statistical analyses on information about runaway and homeless youth and program activities in order to develop management improvement strategies suggested by statistical trends and patterns.

The data collected through NEORHYMIS will be published by FYSB, as required by Federal law (RHYA), in a report to Congress on the BCP, TLP, and SOP programs. The data will also support FYSB's annual performance plans under the Government Performance and Results Act and appear in Congressional testimony and briefings. Brochures, fact sheets, and other publications periodically produced by FYSB also will include information gathered by NEORHYMIS. These publications will inform potential grantees and the general public about the breadth and scope of the runaway and homeless youth programs, and will support the identification of trends and problems among runaway and homeless youth served in RHY programs. NEORHYMIS data may also appear in reports and evaluations on the prevention of youth homelessness which have been mandated by the authorizing legislation.

https://extranet.acf.hhs.gov/rhymis is a website where anyone can download and request standard and ad hoc reports on the existing data. Functional improvements in this site are planned as funds permit.

Project Time Schedule (Occurs each FY):

Contractor distributes NEORHYMIS Software to new grantees	October FY2013
Live or self-directed online tutorial is made available to new/current grantees	October FY2013 – February FY2014
Contractor Receives, Cleans and Validates 1st Semi Annual Data Transfer (Covering Oct 1 – March 30)	April FY2014
Contractor Receives, Cleans and Validates Data 2nd Semi Annual Data Transfer (Covering April 1 – Sept 30)	October FY2014
FYSB provides FY 14 data to GPRA performance report to Congress	December FY2015

17. Reason(s) Display of OMB Expiration Date is Inappropriate: Not applicable: Dates and notice are displayed on most NEORHYMIS forms and literature.

18. Exceptions to Certification for Paperwork Reduction Act Submissions: This issue is not applicable. There are no exceptions to the certification statement identified on Form OMB 83-I.

2. Statistical Methods:

1. Respondent Universe and Sampling Methods:

This is not applicable as data will not be collected by statistical methods. Instead, each grantee is required to submit data on all FYSB-funded RHY youth on a semi-annual basis.

2. Procedures for the Collection of Information:

Each year, grantees receive the most recent version of the RHYMIS Software program as well as an instruction and definitions manual. Typically, our RHY Technical Assistance Center (RHYTTAC) and RHYMIS support contractor (CSC) collaborates to offer both online self directed as well as live webinar-based tutorial for use of the RHYMIS program. Grantees identify a data entry person to begin entering client data into the RHYMIS system covering the period of October 1 – March 30. Grantees are then required to prepare for the 1^st national semi annual data transfer due by April 15. This information will be downloaded and mailed by disc or submitted online to CSC, Incorporated , the RHYMIS support contractor. At this time, CSC validates the data and forwards a final spreadsheet to FYSB Research and Evaluation Division for analysis and reporting. The previously described steps are again repeated for the 2^nd national semi annual transfer period cover April 1 – September 30, due October 15. A final compilation is submitted by the contractor for use in reporting GPRA and other reports to Congress. Each year the entire process begins again with new grantees.

3. Methods to Maximize Response Rates and Deal with Non Response:

The ease of use and favorable reception from grantees regarding use of the NEORHYMIS data collection has resulted in a 99% response rate. Grantees receive periodic reminders of upcoming transfer dates and in the event that a grantee fails to submit on time, the assigned project officer and or RHYMIS Help Desk will work to assist them in submitting.

4. Test of Procedures or Methods to be Undertaken:

This is non applicable.

5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data:

Our contractors CSC provide quality technical assistance to grantees and are responsible for coordinating the receipt and validation of data. Our principle contact is:

AVI MARGOLIS, Senior Principal

CSC, Incorporated

15245 Shady Grove Road

Rockville, MD 20850

301.921.3033

EXHIBIT 1: Legislative/Regulatory Authority

Sections of legislation and regulations relevant to information collection

For RHY programs

Legislative:

The Runaway and Homeless Youth Act (Title III of the Juvenile Justice and Delinquency Prevention Act of 1974), as Last Amended by the Reconnecting Homeless Youth Act of 2008 (P.L.110-378) October 8, 2008

BASIC CENTER PROGRAM: Section 312 (b) PROVISIONS OF PLAN. In order to qualify for assistance under section 311(a), an applicant shall submit a plan to the Secretary including assurances that the applicant—

...

(7) shall keep adequate statistical records profiling the youth and family members whom it serves (including youth who are not referred to out-of-home shelter services), except that records maintained on individual runaway and homeless youth shall not be disclosed without the consent of the individual youth and parent or legal guardian to anyone other than another agency compiling statistical records or a government agency involved in the disposition of criminal charges against an individual runaway and homeless youth, and reports or other documents based on such statistical records shall not disclose the identity of individual runaway and homeless youth;

...

(8) shall submit annual reports to the Secretary detailing how the center has been able to meet the goals of its plans and reporting the statistical summaries required by paragraph (7);

...

(11) shall supply such other information as the Secretary reasonably deems necessary;

(12) shall submit to the Secretary an annual report that includes, with respect to

the year for which the report is submitted—

(A) information regarding the activities carried out under this part;

(B) the achievements of the project under this part carried out by the applicant; and

(C) statistical summaries describing—

(i) the number and the characteristics of the runaway and homeless

youth, and youth at risk of family separation, who participate in the

project; and

(ii) the services provided to such youth by the project;

...

TRANSITIONAL LIVING PROGRAM

Section 322 (a) ELIGIBILITY

(a) IN GENERAL. To be eligible for assistance under this part, an applicant shall propose to establish, strengthen, or fund a transitional living youth project for homeless youth and shall submit to the Secretary a plan in which such applicant agrees, as part of such project—

...

(9) to submit to the Secretary an annual report that includes information regarding the activities carried out with funds under this part, the achievements of the project under this part carried out by the applicant and statistical summaries describing the number and the characteristics of the homeless youth who participate in such project, and the services provided to such youth by such project, in the year for which the report is submitted;

...

(12) to keep adequate statistical records profiling homeless youth which it serves and not to disclose the identity of individual homeless youth in reports or other documents based on such statistical records;

(13) not to disclose records maintained on individual homeless youth without the informed consent of the individual youth to anyone other than an agency compiling statistical records;

(14) to provide to the Secretary such other information as the Secretary may reasonably require;

Regulatory:

Code of Federal Regulations, 45 CFR, Chapter XIII, Part 1351: Runaway Youth Program, Sub part C, Section 1351.20 (c):

"Grantees will also be required to submit statistical reports profiling the clients served. The statistical reporting requirements are mandated by the Act which states that "runaway youth projects shall keep adequate statistical records profiling the children and parents which it serves..." [FR Doc. 78-32473 Filed 11-27-78;]

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