ORR-3 and ORR-4
THE SUPPORTING STATEMENT
Approval of the ORR-3 Placement Report and ORR-4 Outcomes Report
Justification
Circumstances Making the Collection of Information Necessary
The Refugee Act of 1980, Pub. L. No. 96-212, 8 U.S.C. 1522, amended the Immigration and Nationality Act to create a domestic refugee resettlement program that provides assistance and services to refugees resettling in the United States. With the enactment of this legislation, the Office of Refugee Resettlement (ORR) issued a series of regulations at 45 CFR Part 400 to establish comprehensive requirements for a State-administered refugee resettlement program including child welfare services to unaccompanied refugee minors (URMs). Originally, the program provided services for refugee youth arriving from overseas unaccompanied by a parent or adult relative. Over the years Congress passed laws making other special populations already in the United States eligible for the URM program.
The URM program currently operates in 15 States and provides the same range of child welfare benefits and services available to other foster children in those States as well as services required by ORR regulation. URM benefits and services are provided in accordance with State Title IV-B and IV-E child and family service plans, Federal and State regulations, and ORR policy guidance. Participants in the URM program are placed with licensed providers by the State or local government agencies based on the provider’s licensed capacity and the minor’s specific needs.
The Director of ORR is required by the Refugee Act of 1980 to prepare and maintain a list of unaccompanied children who have entered the United States; the names and last known residence of their parents (if living) at the time of arrival; and the children's location, status, and progress. Additionally, the Act (8 Pub. L. No. 96-212, U.S.C. 1523) requires ORR to submit a report to the Congress each year which summarizes the location and status of unaccompanied refugee children admitted to the United States. ORR regulations at 45 CFR 400.120 describe specific URM program reporting requirements (ORR-3 and ORR-4) prescribed by the Director.
Information submitted as part of the current ORR-3 and ORR-4 report forms is similar to the information that State agencies collect on children placed under their supervision and care, such as child and family information, appropriateness of the placement, family reunification, legal status, services necessary to attain the placement goals, and periodic review of the child's progress in attaining case plan goals.
Purpose and Use of the Information Collection
ORR uses information collected to determine a minor’s eligibility for the URM program, to facilitate placement in the program, to track progress of minors in the program, and to allow for effective program monitoring. Information gathered through ORR-4 also contributes to ORR’s tracking of URM cases and their outcomes.
ORR uses data from these reports as follows:
Program Eligibility: Cases with questionable eligibility are flagged for further investigation. Such cases include children whose parents have arrived or who are independently living in the United States, children above State‑allowed age limits for foster care, and similar discrepancies.
Monitoring: Reports on placement locations and status changes (including establishment of legal responsibility for the child) enable ORR to monitor State programs based on numbers and characteristics of the caseload of each State, reconciling numbers of children reported with financial claims for their support.
Planning and Budgeting: Data related to caseloads and projected program terminations, particularly those children about to reach the age of majority are correlated to permit long‑range program planning and budgeting. For example, Item 5, "Estimated Date of Emancipation," in Form ORR‑3 together with State Department estimates of anticipated new arrivals of unaccompanied refugee minors permits ORR, States, and national resettlement agencies to project caseloads several years into the future. Such information assists both in projecting budgets and in assisting national resettlement agencies in placing new arrivals with cost‑effective agencies with refugee expertise.
Family Reunification: The information on Forms ORR‑3 and ORR‑4 enables ORR to meet its statutory obligation to maintain a national, central registry of all unaccompanied refugee minors which could thereby assist parents and other relatives in locating their children anywhere in the United States for purposes of family reunification. No other registry of unaccompanied minor placement exists.
The data from Form ORR‑4 (Outcomes Report) permit ORR to develop aggregate data by agency on client progress and achievements. This permits comparisons of program quality among provider agencies and States, and, when correlated with program cost data, permits identification of qualitative cost-effectiveness among States and agencies. This strategy remains important as the number of admissions has increased and many of the current providers have rapidly expanded their capacity to serve increased numbers of minors.
Use of Improved Information Technology and Burden Reduction
Currently, the ORR-3 and ORR-4 reports are submitted via a web-based data collection system (internet Refugee Arrivals Data System) whereby grantees and requestors submit the information online. This has helped:
Simplify information collection and the process of review by States
Ensure that information reaches ORR quicker
Centrally manage the data collection process
Standardize data entry and increase accuracy
Improve ORR’s ability to analyze data along several parameters to assess program quality
Enhance quality control
Efforts to Identify Duplication and Use of Similar Information
The Children’s Bureau via the National Youth in Transition Database (NYTD) requires States to report on the characteristics of and services provided to youth participating in Independent Living programs authorized by the Chafee Foster Care Independence Program (CFCIP) of 1999 (Pub. L. No. 106-169) and subsequent enhancements. Because many URM youth are in private agency custody (rather than State or county), a significant percentage of URM youth are not subject to these reporting requirements despite their receiving services similar to those provided to other youth. It follows that aggregate NYTD data are inadequate in presenting outcomes-related information for URM youth and do not permit ORR to meet its legislative requirements.
Impact on Small Businesses or Other Small Entities
Not applicable.
Consequences of Collecting the Information Less Frequently
Current regulations at 45 CFR 400.120 outline the reporting requirements for child welfare services.
The State must submit the Unaccompanied Refugee Minors Placement Report (ORR‑3) within:
30 days of the date of a youth's placement in the State;
60 days of the date of a change of status in which the youth's placement is transferred or legal responsibility of any kind for the minor is established or transferred; and
60 days of the date of termination in which the youth is emancipated or reunited with a parent or other (relative or non-relative) adult with custody.
The State must submit the current Unaccompanied Refugee Minors Progress Report (ORR‑4) on each youth annually, beginning approximately 12 months from the date of the initial placement report by the State.
To require either of these reports less frequently would both undermine their purpose and violate legislative and regulatory requirements.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
No special circumstances are involved. This information collection is consistent with all OMB guidelines specified in 5 CFR 1320.5. The Unaccompanied Refugee Minors (URM) database as a part of the internet Refugee Arrivals Data System (iRADS) and is a Privacy Act System of Records.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
The 60-day Federal Register Notice was published on Friday, April 1, 2016, Volume 81, Number 63, page 18857. ORR forwarded a link to the Federal Register Notice to all URM State Refugee Coordinators, URM provider agencies and two national voluntary agencies.
ORR received responses to this notice from URM service provider agency Catholic Charities Community Services in Arizona, Michigan’s State Refugee Coordinator’s office, and URM service provider agency Catholic Community Services of Utah.
Specific Comments and ORR responses:
Comment: The time limit for filling out the forms is too restrictive, and needs to expand to give case managers more flexible time considering their workload.
Response: The time allowances for report submission, as described in preceding paragraphs, we established in 1986 and took account of transmission methods of the time (triplicate hard copy forms sent via the mail). The ability to transmit reports instantly via the iRADS Web-based database has reduced transmission time and thus increased the time available for collection and entry of data. ORR is not convinced of a need to increase the time allowance. In addition, the current time allowances are regulatory requirements, and thus cannot easily be changed.
ORR understands that this comment may pertain to the amount of time before the screen times out due to inactivity, as opposed to the time allowance for report submission. ORR will include more detailed instruction regarding the time out limit, including a suggested frequency for saving one’s work.
Comment: Each form should show the fiscal year on top and there needs to be a catch up period for late forms after the close of the fiscal year.
Response: Each submission allows for a date of action to be entered. This date indicates the fiscal year the action took place. Therefore, there is no need to have the fiscal year at the top of the report form.
Per reporting regulation there is a 30 day catch up period for ORR-3 Initial Placement reports and a 60 day catch up period for ORR-3 Change of Status reports. The ORR-4 Outcomes report is meant to gather information on the youth’s progress and outcomes each year while in the URM program and subsequent years after leaving the program. Allowing for a catch-up period for this type of report would undermine its purpose and violate legislative and regulatory requirements.
Comment: The database needs to be equipped so that once you enter the information, it does not get changed. For example: the Baseline ORR-4 form changes to Follow-up if you check that the client has participated. The form is prepared after the client has had an intake.
Response: ORR understands that this comment may also refer to the functionality of the database, as opposed to the text of the form itself. ORR recognizes that the placement of the referenced data element has caused some confusion, and will enhance the instructions accordingly.
Comment: The person who reviews the forms and rejects them, needs to give clear and concise feedback with the reasons the form is rejected and how to re-submit.
Response: ORR plans to give further instruction for the State Agency to review and include detailed comments when denying the form and sending back for revisions. This instruction will be included in the both the ORR-3 and ORR-4 instructions.
Comment: The education section of the report form has caused confusion regarding the choices given with regards to what grade number corresponds to the options listed on the form, particularly with the options “secondary” and “college bound”.
Response: ORR has decided to include a breakdown of corresponding grade levels in numeric form, in parentheses, on the ORR-4 instructions under Section III. ORR will also define “college bound” clearly in the ORR-4 instructions.
Comment: The placement/cost data should be removed from the ORR-3 and placed onto the ORR-4 report form.
Response: After review and consideration of the comment to remove the placement/cost data collection element from the ORR-3, ORR has decided to leave the data collection element as-is on the ORR-3. Per the Refugee Act of 1980, the Director is required to maintain a list of unaccompanied children’s locations, status, and progress. The ORR-3 is submitted within 60 days of a change in a minor’s placement or status, whereas the ORR-4 is only submitted annually. ORR is not convinced that an annual collection of placement data would be sufficient to meet the statutory requirement to maintain a central record of such data.
Comment: The estimated hours for the ORR-3 reports is significantly too low. The average number of hours when taken into consideration the completion and review by all parties within the service provider agency and state is much higher.
Response: The burden estimate represents an average of all ORR-3 reports. In many cases an ORR-3 change of status report involves a minimal investment in time due to auto population of data. ORR understands that processing times may vary by location based on caseload, as well as in response to procedures chosen by URM provider agencies and States for filling out, reviewing, approving, and submitting the reports to ORR.
In moving the ORR-3 and ORR-4 reports to iRADS, ORR took several measures to reduce redundancy, and thus the time spent on data entry. For example, several parts of each form have auto-populated fields which reduce the need to enter information multiple times. In addition, certain sections of the forms are not required, based on age and/or the type of form that is selected for submission.
Comment: More specific educational outcomes, including high school graduation should be included on the ORR-3 (or elsewhere- ORR-6, ORR-4).
Response: Specific educational outcomes are already collected in the ORR-4 Section III (d) and Section VI #13.
Comment: MI collects all of the same information that the ORR-3 requires on their own forms and in their own format. Caseworkers, as a result are duplicating efforts for the state and the feds. It is recommended that some of the information collected as part of the ORR-3 reports be contained in the Trimester ORR-6 Schedule D.
Response: ORR recognizes that there are varying levels of reporting taking place at the URM provider, State, and Federal level. However, ORR does not have access to data reported within the State context. In addition, the ORR-6 trimester report has a different purpose. The ORR-3 and ORR-4 reports collect case-specific data while the ORR-6 report collects programmatic data. The ORR-3 fulfills the reporting requirements set out in 45 CFR 400.120 while also maintaining the list of unaccompanied children required under the Refugee Act of 1980.
Explanation of Any Payment or Gift to Respondents
Not applicable.
Assurance of Confidentiality Provided to Respondents
The internet Refugee Arrivals Data System (iRADS), which now includes the URM program database, is a Privacy Act System of Records. The Privacy Act System of Records Notice was initially published in the SSA Privacy Act: Notices of Systems of Records in 1985 (No. 09-60-0216). A system of Records Notice for iRADS under 09-80-0325 was published on July 18, 2016.
Justification for Sensitive Questions
Not applicable.
a. Estimates of Annualized Burden Hours and Costs (State Agencies)
Annual Burden Estimates |
||||
Instrument |
# of Respondents |
# of responses per Respondent |
Average burden hours per Response |
Total burden hours |
ORR-3 (Unaccompanied Refugee Minors Placement Report) |
15 |
178 |
0.25 (15 Minutes) |
667.50 |
ORR-4 (Unaccompanied Refugee Minors Outcomes Report) |
15 |
127 |
0.50 (30 minutes) |
952.50 |
Estimated Total Annual Burden Hours for State Agencies: 1,620
b. Estimates of Annualized Burden Hours and Costs (URM Provider Agencies)
Annual Burden Estimates |
||||
Instrument |
# of Respondents |
# of responses per Respondent |
Average burden hours per Response |
Total burden hours |
ORR-3 (Unaccompanied Refugee Minors Placement Report) |
22 |
121.36 |
0.50 (30 minutes) |
1,334.96 |
ORR-4 (Unaccompanied Refugee Minors Outcomes Report) |
22 |
86.59 |
1.00 (1 hour) |
1,904.98 |
Estimated Total Annual Burden Hours for URM Provider Agencies: 3,239.94
c. Estimates of Annualized Burden Hours and Costs (Youth Participants)
Annual Burden Estimates |
||||
Instrument |
# of Respondents |
# of responses per Respondent |
Average burden hours per Response |
Total burden hours |
ORR-4 (Unaccompanied Refugee Minors Outcomes Report) |
1,200* |
1 |
0.50 (30 minutes) |
600 |
Estimated Total Annual Burden Hours for Youth Participants: 600
*This represents the estimated number of URM youth participants ages 17 and older who are expected to participate in the completion of the ORR-4 report by the URM Providers.
Aggregate cost estimates for collecting information are provided here:
Unaccompanied Refugee Minors Placement Report (Form ORR‑3)
ORR estimates the total annualized cost to be $42,051.66 (667.50 state staff hours at $21 per hour + 1,334.96 URM provider staff hours at $21 per hour).
Unaccompanied Refugee Minors Outcomes Report (Form ORR‑4)
ORR estimates the total annualized cost to be $60,007.08 (952.50 state staff hours at $21 per hour + 1904.98 URM provider staff hours at $21 per hour).
The annualized cost burden for ORR-3 and ORR-4 reports on state agencies and URM provider agencies is $102,058.74. The costs associated with ORR-3 and ORR-4 reports are included in the program budget for URM program. The cost of administration of the Unaccompanied Refugee Minors program is reimbursed 100 percent by the Federal government.
Cost of youth participation in the ORR-4 reporting has been calculated separately as it is not included in the budgets for URM programs. These costs are estimated at the federal minimum wage rate of $7.25/hour x 600 burden hours to equal $4,350. When added to the total annualized cost burden on state agencies and URM provider agencies, the total annualized cost burden is $106,408.74.
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There is no other cost burden associated with this information collection other than the above-mentioned estimated burden and cost in section 12.
Annualized Cost to the Federal Government
There is no additional cost to federal government.
Explanation for Program Changes or Adjustments
The revisions we propose are based upon comments received from State Refugee Coordinators, URM service provider agencies, and ORR’s own analysis with the overall objective of increasing validity of the forms.
ORR estimates an overall increased collection burden due to a larger caseload for URM services, reflecting a 137% increase in number of responses for the ORR-3 and a 6.7% increase in the number of responses for the ORR-4. In addition, the estimated average burden hours for the ORR-3 report have increased (from 15 minutes to 45 minutes) due to the consideration of the URM provider agencies’ time in completing the reports. While the estimated average burden hours for the ORR-4 report have remained the same (1 hour 30 minutes), the average burden hours now reflect both the State agencies’ time and URM provider agencies’ time. The estimated total annual burden hours decreased from 2,958.75 to 1,620 hours for the state agencies as a result of ORR considering the burden for URM provider agencies; however, there is an overall increase to the annualized burden estimate as it now reflects the addition of the URM provider agencies and youth participants. After consultation with OMB and the Office of General Counsel, ORR was advised to add the URM Provider Agencies (Section 12.b.) and Youth Participants (Section 12.c.) in to the burden estimate due to their participation in the data collection.
Although the collection forms have not undergone formal changes, this program change estimate primarily refers to the updates made to the instructions, which in turn require time to review. Estimated costs to the federal government reflect an increase commensurate with that for burden hours.
Plans for Tabulation and Publication and Project Time Schedule
Not applicable.
Reason(s) Display of OMB Expiration Date is Inappropriate
Not applicable; expiration date will be displayed.
Exceptions to Certification for Paperwork Reduction Act Submissions
No exceptions.
Not applicable. No statistical methods employed.
| File Type | application/msword |
| File Title | THE SUPPORTING STATEMENT |
| Author | sdavis |
| Last Modified By | SYSTEM |
| File Modified | 2017-12-27 |
| File Created | 2017-12-27 |