Supporting_Statement_-_Core_Perf_Rpt_Pilot

Office of Strategic Planning and Management

Grants Management and Oversight

SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL
UNDER THE PAPERWORK REDUCTION ACT OF 1995
A. Justification
1. Circumstances Necessitating Data Collection.
This request is for the clearance of data collection and reporting requirements for Core
Performance Reporting. The adoption of Core Performance Reporting for discretionary or
competitively funded grants will enable the U.S. Department of Housing and Urban
Development (HUD) Office of Strategic Planning and Management (OSPM) to collect better
data to track and analyze the performance of the discretionary programs annually. A key
component of the Core Performance Reporting is ensuring the Department’s discretionary
grant awards are clearly focused on outcomes and efforts to continually improve these
outcomes while ensuring comparability of data through the standardization of data element
definitions and data collection requirements. The proposed reporting requirements align
with goals and objectives identified in the Notices of Funding Availability published for the
Department’s discretionary grants. Since HUD has not established performance
benchmarks, the Department will not use data collected to establish accountability,
measure success, or determine selection for award or funding level.
The Department’s first attempt to systematically collect performance information on
discretionary grant programs used a proprietary product called the Logic Model / eLogic
Model. The eLogic Model was intended to collect information on a wide variety of
outcomes, and includes separate performance reports based on unique data definitions and
outcome measures. Each discretionary grant program selected the outcomes and outputs
for which grantees would report without regard for the outcomes being tracked by
programs funding similar activities. For example, in FY2013 nine programs used varying
numbers of the 734 unique performance measures to assess the performance of their
respective discretionary grants. In FY2015 only two programs continued the use of the
eLogic Model.
All programs, except the two currently using the eLogic Model, specify unique reporting
requirements with which grantees must comply. Many programs require annual progress or
performance reports based on each grant’s period of performance. The lack of standardized
data elements and reporting significantly limits the Department’s ability to effectively
analyze grantee data for reporting on the progress of programs to senior Departmental
officials, the Administration, Congress and taxpayers. Additionally, the lack of standardized
data collection and report preparation procedures increases the burden on grantees with
multiple grant awards from HUD.
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The need for a comprehensive and standardized reporting approach is underscored by
reviews conducted by external oversight agencies, including the Department’s Office of the
Inspector General (OIG) and the Government Accountability Office (GAO). These oversight
agencies have questioned the validity and comparability of data reported by the
Department to Congress. To address these issues, the Department is using its statutory and
regulatory authority to redesign and strengthen its various discretionary grant program
performance reports into a single comprehensive framework.
The Secretary’s statutory and regulatory authority to administer housing and urban
development programs include provisions allowing for the requirement of performance
reporting from grantees. This legal authority is codified at 42 USC 3535(r):
“Program evaluation and monitoring
(1) For the programs listed in paragraph (2), amounts appropriated under this subsection
shall be available to the Secretary for evaluating and monitoring of all such programs
(including all aspects of the public housing and section 202 programs) and collecting and
maintaining data for such purposes. The Secretary shall expend amounts made available
under this subsection in accordance with the need and complexity of evaluating and
monitoring each such program and collecting and maintaining data for such purposes.
(2) The programs subject to this subsection shall be the programs authorized under—
(A) titles I [42 U.S.C. 1437 et seq.] and II 1 of the United States Housing Act of 1937;
(B) section 202 of the Housing Act of 1959 [12 U.S.C. 1701q];
(C) section 106 of the Housing and Urban Development Act of 1968 [12 U.S.C. 1701x];
(D) the Fair Housing Act [42 U.S.C. 3601 et seq.];
(E) title I [42 U.S.C. 5301 et seq.] and section 810 1 of the Housing and Community
Development Act of 1974;
(F) section 201 of the Housing and Community Development Amendments of 1978 [12
U.S.C. 1715z–1a];
(G) the Congregate Housing Services Act of 1978 [42 U.S.C. 8001 et seq.];
(H) section 222 of the Housing and Urban-Rural Recovery Act of 1983;
(I) section 3616a of this title;
(J) title IV of the McKinney-Vento Homeless Assistance Act [42 U.S.C. 11360 et seq.]; and
(K) titles II [42 U.S.C. 12721 et seq.], III, and IV and section 811 [42 U.S.C. 8013] of the
Cranston-Gonzalez National Affordable Housing Act.
(3) In conducting evaluations and monitoring pursuant to the authority under this
subsection, and collecting and maintaining data pursuant to the authority under this
subsection, the Secretary shall determine any need for additional staff and funding
relating to evaluating and monitoring the programs under paragraph (2) and collecting
and maintaining data for such purposes.
(4)(A) The Secretary may provide for evaluation and monitoring under this subsection
and collecting and maintaining data for such purposes directly or by grants, contracts, or
interagency agreements. Not more than 50 percent of the amounts made available
under paragraph (1) may be used for grants, contracts, or interagency agreements.
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(B) Any amounts not used for grants, contracts, or interagency agreements under
subparagraph (A) shall be used in a manner that increases and strengthens the ability of
the Department to monitor and evaluate the programs under paragraph (2) and to
collect and maintain data for such purposes through officers and employees of the
Department.
(5) There are authorized to be appropriated to carry out this subsection such sums as
may be necessary for fiscal year 1993 and fiscal year 1994. Such amounts shall remain
available until expended.”
It is also important to note this request for Core Performance Reporting aligns with and
advances the President’s Second Term Management Agenda. The President outlined a
management agenda for his second term that delivers a smarter, more innovative, and
more results-oriented government for citizens. An important component of that effort is
strengthening agencies' abilities to continually improve program performance by applying
existing evidence about what works and using innovation to test new approaches to
program delivery.
2. How, by whom and for what purpose the information is to be used.

Eligible entities receiving discretionary grant funds from HUD are expected to implement
the proposed recordkeeping and reporting requirements with available grant funds. The
proposed reporting requirements will better organize data already being collected and help
standardize the measurement of performance. The Participant Record-level Report (PRL)
and the Capital Investment Record-level Report (CIRL) contain the data elements to be
collected and the purpose for collecting each item, while the Grant Feedback Report (GF) is
a voluntary report for supporting communication.
Information collected and reported will be used by grantees and HUD for the following
purposes:





To continuously improve the quality, effectiveness, and efficiency of programs;
To provide management information for program administration and oversight,
including the monitoring of grant-specific participation, services, capital investments,
and outcomes;
To ensure grantees receive sufficient and timely technical assistance and support.

3. Use of Technology to Reduce Burden.
The Core Performance Reporting will streamline HUD’s collection of data and grantee
preparation of reports by providing an online reporting portal that, initially, will accept data
via extensible markup language (XML) uploads as well as manual data entry. HUD
anticipates deploying data upload via Excel in a later implementation phase. The
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Department will expand its current use of the Grants Center of Excellence at the
Department of Health and Human Services to include the online data collection portal.
Once HUD implements the online data collection portal, grantees will annually upload
Participant Record-level data via XML format or manually enter data. The Department
anticipates launching data upload via Excel in the second year of implementation. The Grant
Feedback form may be submitted via the online data collection portal using manual data
entry.
The majority of current grantees use automated case management and project
management applications to manage program activities. The Department will provide
extensive technical assistance to grantees to assist them in understanding and making
needed changes to existing vendor-developed and home-grown automated case
management and project management data collection and reporting tools.
4. Duplication of Similar Information.
The Participant Record-level report (PRL) and the Capital Investment Record-level report
(CIRL) are the only reports that require data on individual participants and capital
investment projects for discretionary grants, respectively. There will be instances where
limited, identical individual and/or capital investment project information may be collected
by other Program Offices. The use of data export and import functionality will enable
grantees to collect data once and submit required data for the PRL and CIRL reports directly
from their management information systems to HUD.
5. Methods to Minimize Burden on Small Businesses.
No small businesses or entities are impacted. No small businesses are involved as
respondents to this data collection effort.
6. Less Frequent Data Collection.
Both the Department and recipient are mandated by various program-specific legislative
acts, as well as the Government Performance and Results Act, to establish performance
standards and make available reports concerning program operations and expenditures.
The inability to utilize program performance data in order to develop strategies for
continuous improvement could negatively affect system performance, future Congressional
appropriations, and individuals who benefit from services provided through these
programs.
Annual collection of this data is essential to maximize the Department’s ability to provide
appropriate technical assistance to grantees related to compliance with program and

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Federal reporting requirements, program design and implementation, and process
improvement.
Additionally, 42 USC 3535(r)(1) charges the Department with “…evaluating and monitoring
of all such programs (including all aspects of the public housing and section 202 programs)
and collecting and maintaining data for such purposes.” If this proposed collection request
were not approved, the Department would not be able to fulfill its oversight role.
The Department is proposing the frequency of grantee reporting under this collection
request be once annually for the PRL and CIRL. The Department proposes that the Grant
Feedback Report be an optional report that the grantee may submit up to once per year.
Currently, the frequency of reporting is mixed among the discretionary grants, making it
difficult to get a timely and complete picture on grant activities. Presently, there is no
standardized approach to the frequency of reporting. In the last fiscal year, 57% of the
discretionary grant programs required annual reporting, 36% required quarterly reporting
and 7% of the grant programs required real-time reporting. In determining the frequency of
reporting, the Department considered factors such as the size of the grant award, the
duration of the project, the complexity of the grantee operation and the availability of
resources in producing such reports without interrupting normal operation.
If the proposed annual reporting were eliminated for the PRL and CIRL reports and
completed only during the grant closeout process, the Department’s ability to track and
monitor discretionary grants would be severely constrained. There is a tremendous need for
annual reporting so the grantees can track their progress in achieving their stated
performance goals and reporting those results to HUD.
7. Special Circumstances.
These data collection efforts do not involve any special circumstances.
8. Federal Register Notice/Outside Consultation.
In accordance with 5 CFR 1320.6 this information collection soliciting public comments was
announced for 60 days in the Federal Register on September 10, 2015, Volume 80, No. 175,
Page 54577. This information collection soliciting public comments was announced for an
additional 10 days in the Federal Register on November 18, 2015, Volume 80, No. 222, Page
72100.

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There were a total of 43 comments submitted to the 60-Day Federal Register Notice and its
subsequent 10-Day extension. Most of the comments were requests to receive the
accompanying documentation to the notice. All requests were fulfilled. One comment
sought clarity on the terminology of a data element related to “abnormal blood-lead
results”. In response, an additional data element on blood-lead level tests was incorporated
into the Participant Record-level Report. And consequently, the associated core
performance indicator was also revised. Another comment pointed out that one of the core
performance indicators related to attrition could be due to factors outside the control of
the service providers. Hence, that core performance indicator was removed. A few
comments specified the need for additional time in order to respond adequately to the
notice. Ten days were extended to respond to the original notice.
Some concerns were raised on the applicability, reasonableness, and burden from the new
approach. First in regards to applicability, it was explained in response that each program
shall determine which data elements out of the entire inventory listed are applicable to it.
Thus, only a subset of the entire listing of data elements would be collected by grantees.
Furthermore, of those applicable data elements, their collection would only occur in
proportion to the services a recipient receives. Second, in regards to applicability,
reasonableness, and burden, it was explained in response that a one-year proof of concept
pilot will be conducted before any broader implementation is to occur. The pilot will largely
be used to test and evaluate whether the new reporting approach is feasible and practical,
and if the data elements are appropriate. Additionally, it was explained that an online data
collection and reporting tool will be made available to grantees that will be tested in the
pilot. Its purpose will be to allow grantees with existing electronic systems to do a simple
data file upload when reporting. The online data collection and reporting tool will also
accommodate grantees without an electronic system by allowing them to input their data
directly into the tool. All aspects of the methodology will be evaluated during and after the
conclusion of the pilot. Throughout the pilot and broader implementation, technical
assistance and guidance will be provided to grantees.
In accordance with 5 CFR 1320.6 this information collection soliciting public comments was
announced for 30 days in the Federal Register on April 26, 2016, Volume 81, No. 80, Page
24631.
There were a total of 29 comments submitted to the 30-Day Federal Register Notice. All of
the comments were requests to receive the accompanying documentation to the notice. All
requests were fulfilled.
9. Payment/Gift to Respondents.
The Department does not provide remuneration to grantees.

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10. Confidentiality.
The Privacy Act (5 USC 552a) provides the statutory authority for confidentiality. The
Department is responsible for protecting the confidentiality of record-level or individual
record data and will maintain the data in accordance with all applicable Federal laws, with
particular emphasis upon compliance with the provisions of the Privacy Act and the
Freedom of Information Act (FOIA). The FOIA provides that any person has a right,
enforceable in court, to obtain access to federal agency records, except to the extent that
these records are protected from public disclosure.
Please note the record-based data submitted by grantees and maintained by the
Department will not contain any personally identifying information identified by the
National Institute of Standards and Technology (NIST) as clearly distinguishing individual
identity (e.g., names, Social Security Numbers, birth dates, physical addresses, et cetera).
Each grantee will submit records to the Department each year, but it will submit these
records using unique individual identifiers developed and known only by the grantee. The
unique identifiers will not contain any personally identifiable information. The optional
Grant Feedback Report will not contain any protected personal information.
At a later date, the Department intends to annually publish public-use data files constructed
from the record-level reports submitted by grantees. In order to further ensure nondisclosure of individual identity and characteristics and to limit the dissemination of data of
unacceptable quality, census tract geographic area information will be redacted or removed
from the public-use data and publicly available analytical products. If the data for a grant
has 25 or fewer individuals served during a fiscal year as reported in the record-level
reports, then the results for the demographic data elements for the 25 or fewer individuals
will also be redacted or removed from the public-use data file and publicly available
analytical products.
11. Sensitive Questions.
Potentially private or sensitive demographic information to be reported under this request
are already required by authorizing legislation to be collected and documented for eligibility
determination purposes in order for individuals receive Department-funded services and
products. This collection request does not include questions of a sensitive nature for
grantees, sub-grantees and participating individuals.
12. Burden Estimate (Total Hours and Wages).
The burden for the requested collection is limited to the amount of information to be
collected that is not already being collected by grantees as part of their customary and
usual burden to run the program (e.g., data already being collected for eligibility
determination purposes). Thus the burden reflects the information collected solely to
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comply with the requested reporting requirements applicable to roughly 2,000
discretionary grantees. The estimate also does not include the burden associated with
collecting and reporting information required to meet Equal Employment Opportunity
requirements, which are covered under a separate estimate.
Please refer to Table 1 for annual burden estimates for the requested reporting approach.
Table 1 outlines the costs for the one-year pilot (also referred to as the proof of concept
pilot project).
A proof of concept pilot project is an opportunity to demonstrate with a small group of
grantees in a controlled manner the value of collecting and reporting record-level data and
feedback information to the Federal-level to track and manage grantee performance while
also identifying and exploring the technical and operational risks involved in a nation-wide
deployment. The proof of concept pilot project will take place for approximately one year to
test the design idea and related assumptions associated with the report submissions.
The data collection burden calculation uses a minutes per record estimate. The PRL and
CIRL minutes per record estimate are derived from the count of data elements that are
required for the record type, as well as the relative burden of collecting that data. The Grant
Feedback Report estimate is derived from the number of items to be addressed by the
grantee.

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Table 1
Annual Burden Estimate for the Requested Reporting Approach
Initial Year or Proof of Concept Pilot Project

Type of
Record
Participant
Record-level
(data export to
HUD reporting
system)

Number of Submission
Respondents Frequency

Hourly
Rate1

Average
No. of
Minutes

Estimated
Annual
Burden
Hours

Estimated
Annual
Burden
Dollars

5

15,375.00

218,171.00

20,500.00

$290,895.00

7.00

$99.00

1,500
grantees2

1

$14.19

Participant
Record-level
(direct data
entry)

500
grantees2

1

$14.19

Capital
Investment
Record-level

7
grantees3

1

$14.19

Grant
Feedback

200
grantees

1

$14.19

30

100.00

$1,419.00

Total

/////

/////

$14.19

/////

35,982.00

$510,585.00

Per Record

20
Per Record

15
Per Record

1 The

hourly rate of $14.19 is the average wage for office and administrative support occupations as reported in the May 2014
Occupational Employment and Wages produced by the U.S. Department of Labor, Bureau of Labor Statistics.
2 There are an estimated 246,000 individuals to be served by the 2,000 grantees.
3 There are an estimated 28 project-level records for the 7 grantees.

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13. Capital Costs.
There are no capital costs for respondents beyond customary or usual business practices or
that are not otherwise required to achieve regulatory compliance.
14. Cost to the Federal Government.
Since the Department is utilizing a shared service offered by HHS, HUD is not incurring any
capital costs.
15. Program or Burden Changes.
The current approach (the use of the eLogic Models) does not provide a useful, reliable and
accurate picture of the results and impacts of Department’s discretionary investments. The
Government Accountability Office (GAO) issued this conclusion in a 2013 report: Rental
Housing Assistance: HUD Data on Self-Sufficiency Programs Should Be Improved (GAO-13581: Published: Jul 9, 2013). The Department also conducted an internal study of the utility
of the eLogic Models and found:





Due to its highly flexible nature, the eLogic Models lack uniformity or standardization in
the definitions and uses of data elements, including outcome and impact indicators,
preventing the Department from comparing similar grants;
Impossible to aggregate discretionary grantee outcomes to determine the overall
outcomes and impacts associated with these investments;
Extremely difficult to nearly impossible to validate the accuracy of outcome and impact
data reported by grantees to the Department; and
The depth and complexity of the eLogic Models resulted in confusion among grantees,
with many discretionary grantees failing to submit complete periodic performance
summaries or failing to submit performance summaries at all.

In 2013, the Department’s Deputy Secretary announced the phasing out of the use of the
eLogic Models for reporting and directed staff to develop and implement a standardized
reporting and performance measurement approach for discretionary grants.
The shift from the current OMB-approved reporting approach to the proposed approach will
result in an increase in the estimated annual burden hours, largely due to the proposed
collection of standardized individual record data on capital investment projects and program
participants or direct beneficiaries of Department-funded services and products. The
collection and analysis of “case-level” data instead of aggregate data on individual
participants and projects is considered to be a gold standard approach to describing,
explaining and predicting program outcomes. Program results can be aggregated at many
different levels using this approach. A major advantage of collecting and analyzing recordlevel data over the conventional aggregate data approach is that it allows detailed
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participant-level and project-level exploration of program effectiveness in relation to
individual/project characteristics and the services and products (including capital
investments) individuals received during participation.
Table 2 details the burden hour estimate for the current OMB-approved data collection and
reporting approach based on 11,000 grantee respondents. Please note the burden hour
estimates in Table 2 include the Continuum of Care and Choice Neighborhood grants, while
the burden hour estimates in Table 1 do not include these two types of grants as the pilot will
be limited in size. The estimated annual number of burden hours for the current approach is
109,175 or the equivalent of $1,637.625 ($149 per grantee) in estimated costs. The estimated
annual burden hours for the proposed pilot detailed in Table 1 is 35,982 hours or an
estimated cost of $510,585 ($749 per grantee).
Table 2
“eLogic Model” Grant Performance Report Standard Burden Estimate
Current OMB Approved Reporting Requirement

Number of
Respondents

Frequency of
Responses

Number of
Responses

Estimated
Average
Response Time

Estimated
Annual Burden
Hours

6,540 existing
grantees

1

6,540

4.50 hours

29,430.00

60 new
grantees

1

60

5.75 hours

345.00

4,360 existing
grantees

4

17,440

4.50 hours

78,480.00

40 new
grantees

4

160

5.75 hours

920.00

Total

/////

24,200

/////

109,175.00

Note: Respondent cost was computed to be $1,637.625 annually and assumes the average hourly rate was $15. The
respondent cost was calculated using the following formula: ($15 an hour)*(109,175 annual burden hours).

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16. Publication and Tabulation Dates.
There are no plans to publish information at this time.
17. Expiration Date.
The OMB expiration date will be displayed on all data collection instruments. No exceptions
are requested.
18. Certification Statement.
No exceptions are requested in the “Certification of Paperwork Reduction Act Submissions.”

B. Collection of Information Employing Statistical Methods
This information collection request does not contain statistical methods.

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