Supporting Statement TRIBAL PRA renewal 11082016 update

Supporting Statement TRIBAL PRA renewal 11082016 update.docx

Tribal Child Support Direct Funding Regulation - Final

OMB: 0970-0218

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SUPPORTING STATEMENT FOR THE TRIBAL CHILD SUPPORT ENFORCEMENT DIRECT FUNDING REQUESTS

COLLECTION NUMBER 0970-0218



Specific Instructions


  1. Justification


  1. Circumstances Making the Collection of Information Necessary

The final rule within 45 CFR part 309 contains a regulatory reporting requirement that in order to receive funding for a Tribal IV-D program a Tribe or Tribal organization must submit a plan describing how the Tribe or Tribal organization meets or plans to meet the objectives of section 455(f) of the Social Security Act, including establishing paternity, establishing, modifying, and enforcing support orders, and locating noncustodial parents. The plan is required for all Tribes requesting funding; however, once a Tribe has met the requirements to operate a comprehensive program, a new plan is not required annually unless a Tribe makes changes to its title IV-D program. Tribes and Tribal organizations must respond if they wish to operate a fully funded program. This paperwork collection activity is set to expire in December, 2016.


  1. Purpose and Use of the Information Collection

The information collected is necessary to enable OCSE to determine whether an applicant Tribe or Tribal organization meets the requirements to receive direct funding to operate a child support enforcement program under 455(f) of the Social Security Act and implementing regulations at 45 CFR part 309. The Tribal Plan gives each Tribe a method for developing a statement to be submitted to OCSE for approval describing the nature and scope of its program and giving assurances that the program will be administered in conformity with the requirements in title IV-D of the Act and the implementing regulations at 45 CFR part 309. The Tribal plan is analogous to a Tribe having a contract with OCSE in that it outlines the activities the Tribe will perform as required by law in consideration for receiving Federal funds to meet the costs of these activities. In this sense, the Tribal plan is the basis for making Federal funding available to the Tribal IV-D agencies in the costs of operating the Child Support Enforcement program.


  1. Use of Improved Information Technology and Burden Reduction

Funding for automated systems is available for Tribal IV-D programs that meet eligibility requirements of regulations at 45 CFR part 310, however not all Tribes receive funding for automated systems. Many Tribes have office automation and are capable of tracking this required information using office automation.


  1. Efforts to Identify Duplication and Use of Similar Information

The collection of information requirements contained in this form does not duplicate any other reporting or recordkeeping requirements. In complying with those regulations that require information collection, agencies are specifically directed to use and build upon existing information, whenever it exists. It is the intent of these regulations that duplicity of efforts be avoided, and that information collection occurs only when information is not available from another source.


  1. Impact on Small Businesses or Other Small Entities

The collection of information requirements does not involve small businesses or entities.


  1. Consequences of Collecting the Information Less Frequently

The Tribal IV-D agencies will submit new plans to OCSE on a one-time only basis. In addition, the Tribal IV-D programs will periodically amend their plans to reflect any material change in Tribal laws, organization, policy, IV-D agency operation, or new Federal requirements. These amendments must be approved by OCSE prior to implementation.


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

The collection of information does not involve any special circumstances.


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

The 60 day notice was published in the Federal Register on May 13, 2016, volume 81, page 29865. Three comments were received and did not apply to the direct funding request.


  1. Explanation of Any Payment or Gift to Respondents

No payment or gift is provided to respondents, other than remuneration of contractors or grantees.


  1. Assurance of Confidentiality Provided to Respondents

We do not assure confidentiality of the information collected.


  1. Justification for Sensitive Questions

The required information collection does not involve asking questions of a sensitive nature.


  1. Estimates of Annualized Burden Hours and Costs

We estimate that preparing and submitting a new Tribal Plan to OCSE will impose a total annual burden of 960 hours, while preparing and submitting an amendment to the Tribal Plan will impose a total annual burden of 7,560 hours. The combined total annual burden of this collection is 8,520 hours. This is not a new collection activity; it is an approval of an existing tool (0970-0218).


Respondents’ Hour Burden


The estimate of burden hours to respondents is based on the following assumptions:

  • The 65 respondents include Tribes or Tribal organizations submitting the 45 CFR 309 Plan to receive direct funding, and any Tribal IV-D agency which makes a change to its already approved plan.

Instrument

Number of Respondents

Number of Responses Per Respondent

Average Burden Hours Per Response

Total

Burden

Hours

45 CFR 309

Amended Plan

63


1

120

7,560

45 CFR 309

New Plan

2

1

480

960

Total




600 hours

8,520 hours

Total Burden Hours: 8,520 hours


Respondents’ Annual Burden Cost


The annualized costs to the Tribes or Tribal organizations for the hour burdens are based on an average wage rate of $25 per hour for Tribal grant writers who prepare and submit plans and changes to already approved plans. Eight-thousand five-hundred twenty hours multiplied by $25 per hour equals a total annual cost to the Tribes or Tribal organizations of $213,000.


  1. Estimates of other Total Annual Cost Burden to Respondents and Record Keepers

There are no direct monetary costs to respondents other than their time to participate in the program.


  1. Annualized Cost to the Federal Government

The annualized costs to the Federal Government for the hour burdens are based on an average wage rate of $41 per hour for Federal employees (grades 12 – 15) who review submitted Tribal plans from respondents. Estimates regarding the hours spent processing each Tribal submission (4 hours average per Tribal Plan for new plan submissions and plan amendments) was determined by employees’ experiences in reviewing Tribal plans. Eight Federal employees review each Tribal submission. Eight Federal employees multiplied by 4 hours, multiplied by $41 per hour, multiplied by 65 responses, equals a total cost to the Federal Government of $85,280.


  1. Explanation for Program Changes or Adjustments

Upon closer review of the previously submitted respondents’ burden hour estimate we overestimated the hours per response as each response would have been the submission of a new tribal plan. A more accurate estimate is that two new Tribes per year submit new plans while the remainder of the responses are amendments requiring less time to complete and submit. In the prior submission we only reported the 45 CFR 309 plan in the respondents’ hour burden estimate table, we are now reporting both the 45 CFR 309 new plans and 45 CFR 309 amended plans in the table to reflect the new estimate. The charts for annualized federal costs were removed as they did not pertain to this specific information collection.


  1. Plans for Tabulation and Publication and Project Time Schedule

Not applicable


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

Not applicable

  1. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification statement.


  1. Statistical Methods

The information collection requirements outlined in this report do not employ the use of statistical methods.








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