Supporting Statement 2014

AFCARS SUPPORTING STATEMENT

A. Justification

1. Circumstances Making the Collection of Information Necessary

The Adoption and Foster Care Analysis and Reporting System (AFCARS) is mandated by 42 U.S.C. 679 (http://www.ssa.gov/OP_Home/ssact/title04/0479.htm). The regulation at 45 CFR 1355¹ sets forth the requirements of section 479 of the Social Security Act (42 U.S.C. 679) for the collection of uniform, reliable information on children who are under the responsibility of the State or Tribal title IV-B/IV-E agency for placement, care, and adoption. Effective October 1, 2009, section 479B(b) of the Act authorizes direct Federal funding of Indian Tribes, Tribal organizations, and Tribal consortia that choose to operate a foster care, adoption assistance and, at Tribal option, a kinship guardianship assistance program under title IV-E of the Act. The Federal regulations at 45 CFR 1355.40 were amended as part of an Interim Final Rule published January 6, 2012 to apply the same regulatory requirements for data collection and reporting to a Tribal title IV-E agency as are applied to a State title IV-E agency.

2. Purpose and Use of Information Collection

The AFCARS is the only nationally mandated collection of data on children in foster care and those who have been adopted with involvement by state and tribal child welfare agencies. The Department of Health and Human Services (DHHS) uses the information submitted by child welfare agencies to address policy development and program management issues at state, tribal, and the federal level. The data will enable the Federal government to more effectively direct and manage the national foster care and adoption programs. Specifically, the Department uses the data for:

• the Child Welfare Outcomes Report to Congress;

• the National Standards used for compliance monitoring in the Child and Family Services Reviews;

• drawing samples of case records for various program reviews conducted by ACF;

• allocating Chafee Foster Care Independence Program (CFCIP) funds to States;

• identifying the number of finalized adoptions for which a State may be awarded adoption incentive funds;

• developing short and long-term budget projections;

• trend analyses and short and long-term planning;

• targeting areas for greater or potential technical assistance efforts, for discretionary service grants, for research and evaluation, and for regulatory change; and

• background and justification for policy changes and legislative proposals;

The data will enable policymakers to assess the reasons why children are in foster care and develop remedies to prevent removals when possible. The data will provide information about foster care placements, adoptive parents, length of time in care, delays in termination of parental rights and placement for adoption, and identify geographic areas with special problems.

The data will also be useful for research. The ultimate purpose is to gain a better understanding of the foster care program and to make suggestions and proposals for change to improve the child welfare system.

In addition, the Department uses the data submitted through AFCARS to respond to questions and requests for current data on children in foster care or who have been adopted. These requests may be received from Congress, other Departments, national advocacy organizations, states, tribes and other interested organizations.

3. Use of Improved Information Technology and Burden Reduction

AFCARS data are required to be submitted electronically to the Department on a semi-annual basis (twice a year). FISMA approved software is used that allows for a secure a secure direct mainframe to mainframe or PC to mainframe communication between the title IV-E agencies and the Federal Government.

4. Efforts to Identify Duplication and Use of Similar Information

AFCARS is the only Federal data collection of information on children who have been adopted from the public child welfare system and children in foster care.

5. Impact on Small Businesses or Other Small Entities

This information collection is required of State and Tribal agencies only and does not impact small businesses or other small entities. The Department requires reporting only on those children for whom the title IV-E agency has responsibility for placement and care.

6. Consequences of Collecting the Information Less Frequently

Information must be collected on an on-going basis in order to provide effective trend analysis and other programmatic information for children in foster care and children who have been adopted. As the only nationally mandated child welfare information collection system, AFCARS is the primary source of information. In order to reduce the burden on title IV-agencies, and still gather data on a timely basis, a semi-annual reporting period has been required in the regulation.

If AFCARS were to be submitted on an annual basis, information up to at least 15 months old would have to be used for policy purposes before the next year's data would be available. By contrast, information provided on a semi-annual basis will receive a preliminary analysis within a thirty to sixty day timeframe.

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

There are no special circumstances required in the collection of this information in a manner other than that required by OMB.

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

The 60 day notice was 79, 30850, published 5/29/2014

No comments were received to the first Federal Register Notice.

9. Explanation of Any Payment or Gift to Respondents

No payments, other than Federal financial participation (FFP), will be made to States and Tribes for the maintenance and development of an information system.

10. Assurance of Confidentiality Provided to Respondents

All data on adoption and foster care will be collected with the assurance of confidentiality. The data must be kept confidential as the purpose of its collection is to conduct program and policy analyses and not to track individual children at the national level. The identity of individual children and families will be known to the reporting IV-E agency only. ACF has approved two methods for the creation of an AFCARS record number, encryption or sequential numbering. ACF has assisted IV-E agencies in developing an algorithm to encrypt.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature in the application requirements.

12. Estimates of Annualized Burden Hours and Costs

ANNUAL BURDEN ESTIMATES

Instrument	Number of Respondents	Number of Responses per Respondent	Average Burden Hours per Response	Total Burden Hours
AFCARS	72	2	1786	257, 184

Burden hour estimates are based on the number of children in care at the start of the year, as well as those children who entered and those who exited care during the year.

ANNUAL COST ESTIMATES

Item	Hours	Cost per hour	Total Cost
Annualized cost to respondents for collection of AFCARS	2,581	$30	$77,430

The estimated cost for the collection of information is based on an average caseworker and systems analysts wage.

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

There are no AFCARS only data collection systems. States and Tribes utilize existing computer systems to record and collect information pertaining to the case work associated with children in foster care. The cost of collecting and submitting data to AFCARS for States and Tribes is subsumed under the agency’s expenses for personnel.

14. Annualized Cost to the Federal Government

Item	Hours/Activities	Cost per hour	Annual Total Cost
Operation of AFCARS	10, 400	$50	$601,108
Maintenance Expense			$29,400
AFCARS Reviews	4 site visits	$2,000/review	$8,000
Federal Annual Total			$638,508

The average annual Federal costs associated with overseeing implementation and data analysis is based on nine employees (one grade 14, five grade 13s, and one grade 12). The cost for ACF to conduct periodic monitoring visits in States is based on two Federal Staff conducting the review.

15. Explanation for Program Changes or Adjustments

There has been a decrease in the number of burden hours from 432,720. The number decreased even though tribes are added to the reporting burden: the number of children in foster care per each tribe is small (approximately five to 15) and the number of children in state foster care has decreased.

The burden hours focus on data collection for children in care at the start of the year, those who entered and those children who exited care. There will be variability in the average burden hours over the years and the actual decreases may be nominal.

16. Plans for Tabulation and Publication and Project Time Schedule

There is no timetable or end date for the project, as collection of adoption and foster care data will be ongoing. Tabulation of the data will consist of frequency distributions by State. Statistics generated from the data will include at a minimum the relationship of child demographics and case characteristics to case outcomes: e.g., length of placement. In addition, child demographics, case characteristics, and case outcomes will be tracked over time and by State. Also, ACF is required to submit annual data reports to Congress.

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

The Department is requesting that the OMB number and expiration date not be displayed as there is no form that the IV-E agencies use to submit AFCARS data. All data are submitted electronically. The OMB number is displayed at 45 CFR 1355.40.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification statement.

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

The information collected in AFCARS does not require the use of statistical methods.

1 http://www.ecfr.gov/cgi-bin/text-idx?SID=377070b226510757bacccef682d0cd52&node=se45.4.1355_140&rgn=div8

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