PRA supporting statement for AV application 4.18.19_Final

PRA supporting statement for AV application 4.18.19_Final.doc

State Access and Visitation Grant Application

OMB: 0970-0482

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State Access and Visitation Grant Application




OMB Information Collection Request

0970 - 0482




Supporting Statement Part A - Justification

April 2019















Submitted By:

Office of Child Support Enforcement

Administration for Children and Families

U.S. Department of Health and Human Services












SUPPORTING STATEMENT A – JUSTIFICATION



  1. Circumstances Making the Collection of Information Necessary


The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) created the “Grants to States for Access and Visitation” program (AV grant program). Funding for the program began in FY 1997 with a capped, annual entitlement of $10 million. The statutory goal of the program is to provide funds to states that will enable them to provide services for the purpose of increasing noncustodial parent (NCP) access to and visitation with their children. State governors decide which state entity will be responsible for implementing the AV grant program and the state determines who will be served, what services will be provided, and whether the services will be statewide or in local jurisdictions. The statute specifies certain activities which may be funded, including: voluntary and mandatory mediation, counseling, education, the development of parenting plans, supervised visitation, and the development of guidelines for visitation and alternative custody arrangements. Even though OCSE manages this program, the funding for the AV grant is separate from funding for federal and state administration of the Child Support program.


Section 469B(e)(3) of the Social Security Act (Pub.L.104-193) requires that each state receiving an Access and Visitation (AV) grant award monitor, evaluate and report on such programs in accordance with regulations (45 CFR Part 303). The AV Grant Program Terms and Conditions Addendum references administration of the grant program in accordance with an approved state application. Additionally, the Catalog of Federal Domestic Assistance, states that there is an application requirement for Grants to States for Access and Visitation Programs (93.597). The application process assists OCSE in complying with this requirement and is reflective of a greater emphasis on program efficiency, coordination of services, and increased attention to family safety.


We respectfully request OMB to extend the approval, without any changes, to the existing AV Grant Application (Attachment A). The application compiles information on actions and decisions related to program priorities, program administration, and program safeguards made by grantees in fulfilling their statutory responsibilities in using grant funds to increase noncustodial parent access to and visitation with their children. As such, completion of the application requires minimum burden for grantees with one application submitted in a 3 year cycle. However, the grantee is required to provide updated information to OCSE if a grantee planned to make substantive programmatic or administrative changes during the three-year period covered by the application.







  1. Purpose and Use of the Information Collection


The application collects information on how grantees plan to: spend grant funds, monitor service delivery, and implement safety protocols to ensure client and staff safety. OCSE is then able to review states’ Access and Visitation services for the purpose of ensuring compliance with federal regulation and to provide enhanced targeted technical assistance as indicated. Also, because the application focuses on inquiry related to program efficiency, coordination of services, and attention to family safety, this information is useful to states as they engage in strategic planning and continuous process improvement as it relates to providing access and visitation services.



  1. Use of Improved Information Technology and Burden Reduction


The application is submitted electronically via e-mail to OCSE’s AV program manager. This form of submission reduces the burden on grantees by relying on one of the most commonly used electronic processes in the workplace. There will be no requirement to submit any paper forms via mail. OCSE considered using a web-based portal system for submission but determined it would not provide any additional benefits over e-mail and the costs would be much higher than e-mail (which has no additional administrative costs).



  1. Efforts to Identify Duplication and Use of Similar Information


The information collected through the application is not otherwise collected by OCSE or available elsewhere. OCSE collects actual statewide data on the operations of Access and Visitation program services on an annual basis through the Survey (OMB Control Number 0970-0204), whereas this application collects descriptive program information including type of service delivery, overall administrative structure, safeguards, contracting information, projected costs, and monitoring, reporting and evaluation related issues. There is no overlap or duplication in information collections between the AV application instrument and the Survey.



  1. Impact on Small Businesses or Other Small Entities


Not applicable.


  1. Consequences of Collecting the Information Less Frequently


The proposed application will only need to be submitted once every three years unless programmatic changes are made. If programmatic changes are made, grantees will only need to submit information on what those changes are. This schedule reduces the burden on AV grantees while ensuring OCSE is able to fulfill and adhere to the statutory and regulatory mandates governing the AV grant program. It is important that the application be submitted every three years so that OCSE is able to monitor the grant properly and provide quality technical assistance to states.



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


Not applicable.



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


In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on January 31, 2019, Volume 84, Number 21, page 743, and provided a sixty-day period for public comment. During the notice and comment period, no substantive comments were received.



  1. Explanation of Any Payment or Gift to Respondents


Not applicable.



  1. Assurance of Confidentiality Provided to Respondents


Not applicable.



  1. Justification for Sensitive Questions


Not applicable.



  1. Estimates of Annualized Burden Hours and Costs


Information Collection Title

Total Number of Respondents

Total Number of Responses Per Respondent

Average Burden Hours Per Response

Total Burden Hours

Average Hourly Wage

Total Annual Cost

Child Access and Visitation Grant Application Form

54



1

10

540

$38.80

$20,952

The job code is 21-1093 and wage data from May 2018 is $19.40 per hour. Therefore to account for fringe benefits and overhead the rate is multiplied by two which is $38.80. https://www.bls.gov/oes/current/oes211093.htm

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


There are no other costs to respondents and record keepers.



  1. Annualized Cost to the Federal Government

The review of the applications will be conducted by OCSE staff members @ 54 hours (one hour per application) x hourly salary (averaging $54) = $990. Review occurs every three years.



  1. Explanation for Program Changes or Adjustments


There are no changes to the information collection since the last OMB approval.



  1. Plans for Tabulation and Publication and Project Time Schedule


The annual report summarizes and quantitatively describes features of the OMB approved collection of information, i.e. Survey instrument (OMB Control Number 0970-0204), through the use of descriptive information.



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


Not applicable



  1. Exceptions to Certification for Paperwork Reduction Act Submissions


No exceptions are necessary for this information collection.





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