THE SUPPORTING STATEMENT
A. Justification
Circumstances Making the Collection of Information Necessary
The Developmental Disabilities and Bill of Rights Act, 42 U.S.C. 15044, requires each Protection and Advocacy for Developmental Disabilities program (PADD) to annually report on “the activities, accomplishments, and expenditures of the system during the preceding fiscal year, including a description of the system’s goals, the extent to which the goals were achieved, barriers to their achievement, the process used to obtain public input, the nature of such input, and how such input was used.” In order to comply with this requirement, each PADD annually prepares a Program Performance Report (PPR) (0987-0027) that describes the activities and accomplishments of the system during the preceding fiscal year and a Statement of Goals and Priorities (SGP) (0985-0034) for each coming fiscal year.
Up to this point, P&As have used separate forms for submitting the PPR (0985-0027) and the SGP (0985-0034). The Department is proposing that the two reports be combined by creating the Protection and Advocacy Annual Program Performance Report and Statement of Goals and Priorities form (PPR/SPG). By combining the forms, we will reduce the burden on grantees because they will only have to submit one report. The combined form will also allow federal reviewers to analyze patterns more readily between goals, priority setting, and program performance.
These are ongoing data collections. It represents revisions with changes of two existing Information Collection Requests.
Purpose and Use of the Information Collection
The annual program performance report (PPR) and SGP is reviewed by federal staff for compliance and outcomes. Information in the PPRs and SGPs is analyzed to create a national profile of programmatic compliance, outcomes, and goals and priorities for P&A Systems for tracking accomplishments against goals and to formulate areas of technical assistance related to compliance with Federal requirements. Information collected in the unified report will inform AIDD of trends in P&A advocacy, facilitate collaboration with other federally-funded entities, and identify best practices for the efficient use of federal funds.
Additionally, the information is used to provide a national perspective on where the program is going (prospective view), and to provide a gauge for program accomplishments against program objectives for purposes of identifying continuing challenges and formulating technical assistance and management support provided to P&A systems. Finally, the form’s prospective information is compared for interpretation purposes with the corresponding performance data and outcomes that are reported to Congress, as required by the Government Performance and Results Act of 1993 (GPRA).
AIDD plans to make the data from these reports available on the internet to the general public.
Use of Improved Information Technology and Burden Reduction
The report will be submitted electronically. A major consequence of the electronic submission of the PPR/SGP is enhanced ability to review the PPRs/SGPs and to manage the data in them.
Efforts to Identify Duplication and Use of Similar Information
A careful review of the SGP and the PPR was conducted to avoid any duplication between the two reports that are submitted by the P&As. No duplication was found. Note that the SGP is prospective, showing intentions of the P&A in the coming year, while parallel reporting in the PPR is retrospective, showing how the P&As actually performed in comparison to the prior year plan.
Note that the PADD is the only P&A program that works specifically with individuals who have developmental disabilities. In addition, no other federal program providing protection and advocacy for individuals with non-developmental disabilities requires an SGP, and hence there is no duplication between the prospective reporting for this program with such reporting for any other similar program.
Impact on Small Businesses or Other Small Entities
The information collected does not involve, nor result in assignment of burden to any small business or other small entity. It is collected from 57 State systems designated by the governor of each State.
Consequences of Collecting the Information Less Frequently
The collection of data less frequently than that prescribed by the requirements of the Act and by the regulations (annually), would violate the statute and regulation. Less frequent collection would also prevent the Department from meeting its obligations under GPRA. Further, it would deny the Department the opportunity to have a year to year understanding of the P&A planning process in each State for purposes of providing technical assistance. In addition, the annual reports provide ongoing data on the performance of the P&As in terms of the requirements of the Act and performance outcomes.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances governing the collection of data that are inconsistent with the established guidelines pursuant to 5 CFR 1320.5.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
A 60-day comment period was provided. The solicitation of comments for the proposed information collection was published in the Federal Register, Vol. 81, No. 163 (Tuesday, August 23, 2016). No comments were received during the 60 days or anytime thereafter. A 30 day notice was published in the Federal Register, Vol. 82, No. 10 (Tuesday, January 17, 2017).
Issues of the scope, content, availability of data, format, and clarity of instructions for the combined PPR/SGP have been discussed with all of the P&A systems through focus groups, work groups, and in conferences organized on behalf of Administration on Intellectual and Developmental Disabilities by the National Disability Rights Network (NDRN). The format is based on the efforts of these focus groups, work groups, and conferences. This form streamlines the data collection of the PPR and SGP by collecting data on more quantifiable measures to support the qualitative data that the P&As have consistently provided. For example, for the first time, P&As will report the number of clients who had successful outcomes, broken down into 10 measurements in section 3A of the form. An example of the measures is below.
1. People with disabilities who are provided with appropriate community based services resulting in community integration and independence.
2. People with disabilities who accessed benefits.
3. People with disabilities who live in a healthier, safer or otherwise improved environment.
This form also eliminates the need for grantees to reenter goals and priorities which remain the same from year to year, reducing the burden on grantees. The current OMB approval for this collection included no terms or conditions.
Explanation of Any Payment or Gift to Respondents
No payments or gifts to respondents are planned.
Assurance of Confidentiality Provided to Respondents
There are no data collected that requires confidentiality, and hence no assurance of confidentiality is required. All data is aggregated by the States, and no individual data is provided to the Federal Government.
Justification for Sensitive Questions
No data is collected from States that is of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
The following table summarizes the burden hour estimate for this information collection:
No. of States |
No. of Responses Per State |
Average Burden Hours Per State |
Total Hours |
57 |
1 |
75 |
4275 |
The estimates of annual burden to the States vary very greatly in accordance with the size, program complexity, and technological capacity of the States. Consultations with selected States indicated that the range of times would vary. The current estimate of annual burden is from 5 to 20 eight-hour days, with the most common figure of about nine eight -hour days. Hence, a mode of9.2 such days (75 hours) is being used in these calculations.
Consequently, the estimated burden hours are 2,508 hours (57x44).
The annualized cost of the hour burden, expressed in dollars is:
Average Cost/Hour |
Average Burden Hours/State |
Average Annual Cost/State |
Total Annual Cost |
$62.20 |
75 |
$4,665.00 |
$265,905 |
This estimated average cost per hour includes a base average hourly salary cost of $31.10 plus 100% of salary for fringe benefits and overhead.. This figure comes from national survey data published by the Bureau of Labor Statistics in 2016 for the job classification 11-9151, Social and Community Service Managers. Fifty of the 57 grantees completing the form are nonprofit organizations providing legal services. Most of the staff completing the forms are Executive Directors or Program Directors.
|
|
|
|
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There is no annual cost burden or startup cost to respondents resulting from the collection of information for the PPR/SGP.
Annualized Cost to the Federal Government
This computation is based on an estimated $60 per hour for the efforts of a Program Specialist; this estimated hourly rate includes a base average salary of $30 plus 100% for fringe benefits and overhead.
Program specialists will devote an estimated 300 hours each year to organize and review the Program Performance Reports and to generate analyses of the information therein for the uses described in section 2.
Total Estimated Federal Costs: $18,000
Explanation for Program Changes or Adjustments
The combination of the two reports will simplify reporting, and the questions are very similar in the data collections for each of the individual reports. The new measures ask grantees to quantify the number of people impacted in their work, which was data previously reported in narrative form. Examples of the new measures are below:
1. People with disabilities who are provided with appropriate community-based services resulting in community integration and independence.
2. People with disabilities who accessed benefits.
3. People with disabilities who live in a healthier, safer or otherwise improved environment.
The grantees will report on more (new) measures, but the requirement to enter repetitive information on two forms (PPR and SGP) is removed. Additionally, the measures have been designed so that they can be automatically tabulated by the grantees’ case-tracking software. ACL’s technical assistance provider will provide assistance to grantees in setting up automatic tallying in their existing systems. As such, we are predicting a 17% reduction in burden, based on the reduction in the need to enter duplicative data and combination of two forms into one. Now, data will only be entered once into one form. This form also eliminates the need for grantees to reenter goals and priorities that remain the same from year to year, reducing the burden on grantees.
Plans for Tabulation and Publication and Project Time Schedule
The PPRs are prepared by the P&A systems and submitted to the Department by January 1 of each year. Program personnel check the PPRs for completeness and consistency, and prepare program reviews and summaries of the information for use in technical assistance formulation, and for program management studies. Program personnel aggregate the data, do national analyses (sum, average, etc.), and other management analyses. The information obtained is used by AoD to develop program priorities and to formulate technical assistance.
Legislation and regulation mandate the information collected within the PPR becomes a public document. AIDD plans to make the data from these reports available on the internet to the general public.
The small amount of quantitative data is summed to show national totals for reports. Analysis and reporting of the data includes pie-charts and bar-charts. Textual data is stored in electronic databases for access by word-searches and to search for commonalties among States with regard to researching activities of evolving interest. Reporting on this data will be on an annual basis.
Additionally, prospective information contained in the SGP provides an informative backdrop to outcome performance measures based on the data in the Annual PPRs submitted a year later. The performance data reported to Congress under GPRA is analyzed in light of the prospective information in the SGP.
Expiration Date
The OMB expiration date will be displayed on all data collection instruments.
Exceptions to Certification for Paperwork Reduction Act Submissions
Not applicable.
B. Statistical Methods (used for collection of information employing statistical methods)
This information collection does not employ statistical methods.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | PA-SGP-09-Supp |
| Author | ACF |
| File Modified | 0000-00-00 |
| File Created | 2021-01-23 |