Emergency Clearance Request

Department of
Veterans Affairs

Memorandum

Date: October 22, 2018
From: Executive Director, Homeless Program Office (10NC1)
Subj: Request for Office of Management Review and Consideration for Emergency
Clearance for Case Management Services Program
To:

Neomi Rao, Administrator, Office of Information and Regulatory Affairs (OIRA)

CC:

Stephanie Tatham, VA Desk Officer

1. The purpose of this memorandum is for the Department of Veterans Affairs (VA) to
request emergency clearance of an information collection under the Paperwork
Reduction Act pursuant to 38 CFR 61.90. The title of this information collection is
Grant for Case Management Services Program.
2. Section 712 of the Veterans Health Care and Benefits Improvement Act of 2016
(Public Law 114-315) states that the “Secretary shall carry out a program under which
the Secretary shall provide case management services to improve the retention of
housing by veterans who were previously homeless and transitioning to permanent
housing and veterans at risk of becoming homeless.” On June 5, 2018, VA published
an interim final rule at 83 FR 25915 to amend its regulation to implement the new case
management program.
3. Information collection associated with this interim final rule will be used by the Veteran
Health Administration (VHA) Homeless Program Office officials in VA Central Office to
determine eligibility to receive grant, apply the criteria to rate and rank each grant
application. To obtain information necessary to ensure the Federal funds are awarded
to applicants who are financially stable and who will conduct the program for which the
grant award was made.
4. The information collection for this grant is essential to the mission of the agency and
will serve as a key component in the Federal government’s efforts to end
homelessness among Veterans. To accomplish the goal of ending Veteran
homelessness VA must ensure that once formerly homeless Veterans are housed,
they have the ongoing supports to maintain this housing. Housing retention is the
intent of the statue that authorizes the case management grant. The quick approval of
the information collection is essential to expedite the publication of a Notice of Funding
Availability (NOFA), the grant selection, award process, and ultimately the
implementation of this new service for Veterans.
5. Per 5 CFR 1320.13(a)(2), an executive agency may request an emergency processing
of information collection, when the agency cannot reasonably comply with the normal

Page 2.
Subj: Request for Office of Management Review and Consideration for Emergency
Clearance for Case Management Services Program
clearance procedures under that part because: public harm is reasonably likely to
result if normal clearance procedures are followed; an unanticipated event has
occurred; or the use of normal clearance procedures is reasonably likely to prevent or
disrupt the collection of information or is reasonably likely to cause a statutory or court
ordered deadline to be missed.
6. In this case, the use of normal clearance procedures is reasonably likely to prevent or
disrupt collection of information and is reasonably likely to cause a statutory deadline
to be missed. Public Law 114-315 requires a report to congress by June 1, 2020,
regarding an assessment of the case management grant. The VA plans to offer a
NOFA this fiscal year, which will not be able to be executed without the information
collection. The process of publishing a NOFA, processing a grant round and awarding
grants take several months. Without the emergency approval for information collection
the statutory deadline requirement for reporting on the case management grant will
likely be missed.
7. In addition to not meeting the statutory deadlines of Public Law 114-315, delays in the
implementation of the case management grants increases the risk of returning to
homelessness for those Veterans who do not have access to this supportive service.
8. VA requests emergency processing of this information collection no later than
November 22, 2018. VA has taken steps to consult with other VHA Homeless
Program Offices, and field staff in an advisory role to minimize the burden of data
collection, while ensuring an effective grant selection and responsible case
management service for Veterans.
9. Any questions may be addressed to, Mr. Jeffery L. Quarles, MRC, LICDC, National
Director GDP Program, VHA via phone at (813) 979-3570, or by email at
[email protected].
10. Thank you for your consideration in this matter.

Monica Diaz, MBA, BA, L-NHA, C-RCFE
Executive Director,
Veterans Health Administration (10NC1)