2018OMB_SupportingStatement_2018-05-15

Supporting Statements for the

Paperwork Reduction Act Submission

Agency: Office of Justice Programs, Office for Victims of Crime

Title: OVC TTAC Trafficking Information Management System (TIMS)

A. JUSTIFICATION

1. Necessity of Information Collection

The Office for Victims of Crime (OVC) is a Federal agency within the Office of Justice Programs, U.S. Department of Justice. This is a request for a revision of the OVC TTAC Trafficking Information Management System (TIMS) covered under collection 1121-0336 to serve the information needs of OVC TTAC under the Office of Justice Program contract.

Congress formally established OVC in 1988 through an amendment to the 1984 Victims of Crime Act (VOCA) to provide leadership and funding on behalf of crime victims. It is further authorized to provide training for diverse professionals who work with victims, develop and disseminate publications, support projects to enhance victims’ rights and services, and educate the public about victim issues. The mission of OVC is to enhance the nation’s capacity to assist crime victims and to provide leadership in changing attitudes, policies, and practices to promote justice and healing for victims of crime. As one part of its mission, OVC is committed to provide victims of crime with access to comprehensive, quality services. One of the ways it does this is through the OVC Training and Technical Assistance Center (OVC TTAC).

OVC TTAC was created in 1998 to serve as a central access point for OVC's training and technical assistance (TTA) resources and to funnel resources to local, state, tribal, and federal agencies to strengthen their capacity to serve victims. As part of this effort, OVC TTAC provides specialized training and technical assistance to OVC Services to Victims of Human Trafficking grantees (OVC Anti-Human Trafficking Grantees). OVC has funded more than 70 service agencies since 2003 to provide services to victims of human trafficking.

OVC Anti-Human Trafficking Grantees must report on specific grant performance measures biannually. These performance measures require OVC Anti-Human Trafficking Grantees to maintain detailed client demographics and records of training and technical assistance activities conducted through OVC grant funds. One of the resources OVC TTAC developed to support these grantees is TIMS, which allows grantees to easily collect and report on their grant performance measures and for OVC to receive standardized data reports for performance monitoring.

There are two different types of OVC Services to Victims of Human Trafficking Grants, each with a unique set of required performance measurements:

OVC Services to Victims of Human Trafficking Grantees

• The number of new foreign national trafficking victims served for the first time during the reporting period.

• The number of new domestic trafficking victims served for the first time during the reporting period.

• The total number of trafficking victims served during the reporting period. (This includes new clients and existing clients served during the reporting period.)

• The number of service units provided.

• The number of collaborative partners (both key and informal) serving trafficking victims.

• The number of service professionals trained.

OVC Enhanced Collaborative Model To Combat Human Trafficking Grantees

• The number of new foreign national trafficking victims served for the first time during the reporting period.

• The number of new domestic trafficking victims served for the first time during the reporting period.

• The total number of trafficking victims served during the reporting period. (This includes new clients and existing clients served during the reporting period.)

• The number of service units provided.

• The number of collaborative partners (both key and informal) serving trafficking victims.

• The number of service professionals trained.

TIMS was designed specifically to capture data on these performance measurements, reducing the burden for grantees by simplifying and standardizing the required reporting process. To report data on these required grant performance measurements, OVC Anti-Human Trafficking Grantees submit to OVC reports created through TIMS Online at the end of the bi-annual reporting periods (January 1– June 30 and July 1– December 31). Some organizations receive multiple OVC grants and must report performance measurements separately per grant. Without TIMS, each OVC Grantee would need to develop its own system for tracking and reporting the above performance measurements.

2. Needs and Uses

Per OMB approval in 2015, OVC has mandated the use of TIMS, ensuring that performance measurement data used by OVC in performance monitoring are consistent. Mandating TIMS has ensured that future OVC Anti-Human Trafficking Grantees consistently utilize the database from the onset of their grant, allowing for increased quality of data.

The performance measurement data will be provided to Congress via the annual Attorney General’s Report to Congress and Assessment of U.S. Government Activities to Combat Trafficking in Persons as required by the Trafficking Victims Protection Act of 2000, as amended. The data will also be used for individual grant reporting by tracking grantee performance in meeting the goals and objectives of the program. To track grantee performance, OVC will analyze the consistent and quality data provided through TIMS. This information will also allow OVC to most accurately consider future applications for additional funding that are submitted by existing grantees.

OVC uses information captured in TIMS to measure the quality and comprehensiveness of direct services to victims, and the level of support provided to build community capacity through training, public awareness and outreach. Performance measures data allow OVC to better assess trends in services, which in turn will lead to funding opportunities that best reflect the needs of the community. OVC looks at the performance measures collectively to obtain a full picture of grantee activities and performance, and to identify challenges and inform future technical assistance opportunities.

Fields of information and reports generated in TIMS allow OVC Anti-Human Trafficking Grantees to capture and detail their required OVC grant performance measurements, removing the need to independently develop mechanisms to track and report this information. Required fields of information are kept to a minimum and used only when necessary to obtain performance measurement data. Grantees enter basic demographic information on the clients they have served. TIMS does not contain personal identifier information (PII). Grantees will utilize and access TIMS via a regular Web browser through a secured username and password.

1. Efforts to Minimize Burden

TIMS reduces the burden for OVC Anti-Human Trafficking Grantees by providing them with a free Web-based tool with which to enter data and provide reports on required grant information so that they do not need to develop or purchase individual tracking systems. Office of Justice Program (OJP) Grantees must already report financial and programmatic information online via OJP’s Grants Management System. The TIMS online version is more user-friendly and simplifies the steps needed for OVC to access the data entered. The grantees are no longer required to complete a multi-step process to export their data, as was necessary under the PC-based version of TIMS. In addition, changes, updates and enhancements can be made to TIMS without disrupting grantee use, and without requiring a new roll-out of the database, as was required under the previous PC-based version of TIMS. OVC TTAC can also provide “live time” assistance for trouble-shooting with TIMS, which will eliminate the need for grantees to explain the problem in detail and OVC TTAC responding by re-creating the problem to understand and address it for the grantees. TIMS reduces the burden for grantees by helping OVC Anti-Human Trafficking Grantees to easily meet their mandated reporting requirements.

TIMS provides a safe and secure platform for storing programmatic information, removing the burden from grantees to maintain this information on their individual computers or networks, and it reduces the paper burden for the OVC Anti-Human Trafficking grantees by providing them with an online system.

3. Efforts to Identify Duplication

The information to be collected is only for the purposes of OVC grant monitoring and is not available elsewhere.

3. Methods to Minimize Burden on Small Businesses

Most OVC Anti-Human Trafficking Grantees are small nonprofit agencies. TIMS is a case management tool as well as a performance measurement tool. Smaller organizations that do not already have a systematic way of tracking client data can do so in TIMS, thereby providing small agencies with a useful resource that tracks project data regardless of funding source.

3. Consequences of Less Frequent Collection

TIMS creates a standardized system for OVC Anti-Human Trafficking Grantees to report on their required programmatic performance measurements. Grantees are required to provide this information biannually for OVC to review the grant initiative and improve support services being provided to victims of human trafficking. Less frequent collection of this information would impede OVC’s ability to review and continually enhance the grant program.

3. Special Circumstances Influencing Collection

While respondents are required to collect needed performance measurements, respondents are not required to prepare a written response in fewer than 30 days.

3. Public Comment and Consultation

A 60- and 30-day notice will be published in the Federal Register to solicit public comments in accordance with the Paperwork Reduction Act requirements. If we receive comments, those comments will be summarized and actions taken by OVC TTAC described herein.

3. Payment or Gift to Respondents

OVC Anti-Human Trafficking Grantees must report specific performance measurements to OVC as a stipulation of the grant. TIMS is a tool by which this requirement is simplified because grantees can store case information in a tool designed to generate reports based on required OVC performance measurements. Grantees receive no payments or gifts for their use of TIMS.

3. Assurance of Confidentiality

Collection of all information in TIMS is in accordance with the Privacy Act of 1974. Any release of information will conform to the stipulations of the Privacy Act. No personally-identifiable client/victim information is requested in the database, and victims are not directly impacted since they are not involved with the data collection and reporting. Only those who are required to review and process data submissions will have access to the data, and they will sign statements of confidentiality.

3. Justification for Sensitive Questions

Sensitive questions are not asked of victims or clients, and victims are not directly impacted since they are not involved with the data collection and reporting.

3. Estimate of Hour Burden

OVC Anti-Human Trafficking Grantees incur a minimum hour burden when utilizing TIMS. Approximately 60 OVC Anti-Human Trafficking Grantees will utilize TIMS Online per six-month reporting period, which is a total of 120 annual responses. It is estimated that Grantees will spend one hour to seven hours (on average 4 hours), depending on client case load per reporting period, entering this data into TIMS. There are two reporting periods per year.

Number of Respondents (annually): 60

Number of Online Respondents (annually): 60 (100%)

Frequency of Response (annually): Twice

Average Burden Hours Per Response: 4 hours

Estimated Total Annual Burden Hours: 480 hours

Information recorded in TIMS by OVC Anti-Human Trafficking Grantees is obtained through customary and usual business practices as Grantees are already required to maintain detailed information on their clients. TIMS allows users to input this information into the online database to produce automated grant performance reports, thus saving the grantee time. OVC provides proactive training on the use of TIMS, as well as ongoing technical assistance, which again reduces the hour burden and simplifies the process for Grantees.

3. Estimate of Cost Burden

OVC Anti-Human Trafficking Grantees incur a minimal cost burden when utilizing TIMS. Grantees are already required to maintain detailed information on their clients, and TIMS allows users to input this information into the online database to produce grant performance reports, minimizing the need to maintain separate records on grant performance measures.

To use the system, organizations need to have access to a computer with Internet access. OVC grant funds allow organizations to purchase computers and to pay for administrative costs such as Internet connections; therefore, TIMS users do not incur additional costs.

3. Estimated Annualized Cost to Federal Government

OVC’s Training and Technical Assistance Center has responsibility for the maintenance of TIMS. The annualized cost to the Federal Government for maintaining TIMS, providing training and technical assistance on the use of TIMS, analyzing data contained in TIMS, and producing bi-annual reports does not exceed $300,000.

3. Reasons for Program Changes

This information collection request is a request for a renewal of OVC TTAC TIMS covered under collection 1121-0336.

3. Plans for Publication

OVC intends to publish an annual aggregate report from data generated by TIMS. The report would provide stakeholders with demographic data about clients served by the OVC Initiative.

3. Expiration Date Approval

OVC will display the OMB control number and expiration date.

3. Exceptions to Certification Statement

There are no exceptions to Item 19 of OMB form 83-I.

OMB Submission – OVC TTAC Trafficking Information Management System (TIMS) Page 7