ombrocisSTOP2020supportstatement

Supporting Statement for Paperwork Reduction Act Submission
Annual Progress Report for STOP Violence Against Women Formula Grant
Program
A. Justification
1.

Statutorily-Mandated Need for Information

The primary goal of the STOP (Services*Training*Officers*Prosecutors) Violence
Against Women Formula Grant Program (STOP Formula Grant Program) is to develop and
strengthen the criminal justice system's response to violence against women and to support and
enhance services for victims. The STOP Formula Grant Program was authorized through the
Violence Against Women Act (VAWA) of 1994 and reauthorized and amended by the VAWA
of 2000, by the VAWA of 2005 and by the VAWA of 2013. Grant awards are made to state
governments and administered through a STOP State Administrator. Each state and territory
must allocate OVW grant funds to law enforcement, prosecution, courts, and victim services
within the statutory parameters. Eligible applicants for the STOP Formula Grant Program include
any state within the United States, the District of Columbia, the Commonwealth of Puerto Rico,
the Virgin Islands, American Samoa, Guam, and the Commonwealth of the Northern Mariana
Islands.
Currently, there are different statutory and regulatory reporting requirements that affect
STOP Formula Grant Program grantees. VAWA 2000 required all VAWA grantees, including
STOP Formula Grant Program grantees, to report on the effectiveness of their programs to the
Attorney General who, in turn, must report to Congress every two years. Section 1003 of
VAWA 2000 states that
(a) REPORT BY GRANT RECIPIENTS.- The Attorney General or Secretary of
Health and Human Services, as applicable, shall require grantees under any
program authorized or reauthorized by this division or an amendment made by
this division to report on the effectiveness of the activities carried out with
amounts made available to carry out that program, including number of persons
served, if applicable, numbers of persons seeking services who could not be
served and such other information as the Attorney General or Secretary may
prescribe.
(b) REPORT TO CONGRESS.- The Attorney General or Secretary of
Health and Human Services, as applicable, shall report biennially to the
Committees on the Judiciary of the House of Representatives and the
Senate on the grant programs described in subsection (a), including the
information contained in any report under that subsection.
34 U.S.C. 10238.
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The Department of Justice regulations provide that states and local and Indian tribal
governments receiving federal grants must submit periodic performance reports that include a
comparison of actual accomplishments to the objectives established and the reasons for slippage
if the objectives were not met. 28 CFR 66.40 1
OVW must also comply with the Government Performance and Results Act of 1993
(GPRA) (Pub. L. 103-62) which was enacted to increase Congressional and Administrative focus
on the results from government programs and activities. To meet its GPRA reporting obligations
and elicit more meaningful information about grantee performance, OVW has recently developed
performance measures, including output measures, regarding which the STOP Formula Grant
Program grantees must report on an annual basis.
2.

Use of Information

OVW uses data from the information collection 2 in different ways. OVW will review each
annual progress report to ensure statutory compliance and to ensure that the goals and objectives
set forth in applications for funding and award documents are met.
The STOP Formula Grant Program subgrantees collect information that addresses the
following grant-funded activities (different sections on the reporting form): staff, statutory
purpose areas, informational materials, and victim services. Narrative questions at the end of
these different sections enable subgrantees to give more detailed qualitative information about
their grant-funded activities. In addition, subgrantees must answer narrative questions on the
most significant areas of remaining need with regard to improving services to victims/survivors
of sexual assault, increasing victims/survivors safety, and enhancing community response
(including offender accountability or sex offenders), what has federal funding allowed the
grantee to do that grantee could not do prior to receiving funding, additional information about
the STOP Formula Grant program subgrant and/or the effectiveness of the subgrant and any
additional information about the data submitted.
In addition to the proposed information collection, OVW will continue to use a number of
other techniques to review the activities of the STOP state administrators and of subgrantees.
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In addition, VAWA requires that “[U]pon completion of the grant period..., a State or
Indian tribe shall file a performance report with the Attorney General explaining the activities
carried out, which report shall include an assessment of the effectiveness of those activities in
achieving the purposes of this part. 34 U.S.C. 10446(h).
2

Under a cooperative agreement between OVW and the University of Southern Maine’s
Muskie School of Public Service, data collected from OVW grantees on all of OVW’s progress
report forms is transmitted to the Muskie School for analysis. For the analysis of the data,
standard descriptive statistics (frequency, sum, percentage, mean, etc.) are used to describe the
characteristics of the grantees and report basic findings. All analyses are conducted in SPSS 13.0.
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These may include OVW staff attendance at site visits, grant-funded training and technical
assistance events, and ongoing consultation with OVW staff.
OVW will aggregate data from all subgrantees progress reports to assess the performance of
the STOP Formula Grant Program as a whole and to respond to Congressional, Department of
Justice, and other inquiries about how these funds are being used. In addition, information
collected from grantees will support the following OVW GPRA measures:
Number of victims receiving requested services;
Number of advocates funded:
Number of protection orders issued;
Number of policies developed/revised;
Number of victims requesting services who received them;
Number of grant funded multi-disciplinary training events that have occurred; and
Number of professionals trained to respond to domestic violence, dating violence, sexual assault,
and stalking.
Information collected from STOP state administrators and subgrantees will enable OVW to
respond to statutory requirements to report on the effectiveness of grant-funded activities. OVW
has submitted the 2016 Biennial Report to Congress on the STOP Grant program, which includes
information about how funds were expended and an assessment of the effectiveness of funded
programs. This report is based on data submitted by grantees reflecting STOP awards made and
STOP-funded activities during the calendar year 2013 and 2014.
The data that OVW collects on the annual progress reporting forms is currently not used in
connection with an evaluation of the STOP Formula Grant Program. OVW is currently exploring
the development of a multi-layered evaluation agenda for its grant programs.
The data that OVW collects on the annual progress reporting forms is currently not used in
connection with an evaluation of the STOP Formula Grant Program. OVW is currently exploring
the development of a multi-layered evaluation agenda for its grant programs.
3.

Use of Information Technology

The collection of information will involve the use of automated, electronic, mechanical or
other technological collection techniques or other forms of information technology. STOP
administrators are required to submit annual progress reports through the Grants Management
System (GMS).
4.

Duplication of Information Request

There is no other mechanism by which OVW collects information about grant funded
activities including number of victims served, victims seeking services who could not be served,
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or persons trained.
5.

Impact on Small Entities

There is no impact on small entities as the collection of this type of information is
routinely kept by most STOP administrators and subgrantees receiving funds under the STOP
Formula Program.
6.

Consequences to Federal Programs or Policy

Through the VAWA, Congress has mandated that STOP administrators and subgrantees
report to the Attorney General on the effectiveness of their activities funded under VAWA. If
OVW was not able to collect the information necessary to complete these reports on behalf of the
Attorney General, not only would it be failing to meet statutorily required reporting mandates,
but also the existence of this important and necessary formula grant program could be
jeopardized. The STOP Formula Grant Program supports important programs that provide
critical training to address violence against women, provide victims services, and support
coordinated community responses to such crimes. The STOP Formula Grant Program promotes
a coordinated, multi-disciplinary approach to improving the criminal justice system’s response to
violence against women and supports partnerships among law enforcement, prosecution, courts,
and victim advocacy organizations to enhance victim safety and to increase offender
accountability.
7.

Special Circumstances

There are no special circumstances as identified in the specific instructions for a
supporting statement for Paperwork Reduction Act Submissions.
8.

Federal Register Publication

OVW has consulted with persons outside the agency who have advised that the data
proposed to be collected is available, the annual collection of such data is not burdensome, the
form is clear, and that the information is routinely kept by most grantees receiving funds under
the STOP Formula Grant Program. OVW has solicited public comment on this form in
accordance with the requirements of the Paperwork Reduction Act. A 60 day notice was
published in the Federal Register on February 24, 2020 (Federal Register, Volume 85, page
10477) and a 30-day was notice was published in the Federal Register on April 22, 2020 (Federal
Register, Volume 85, page 122445). OVW did not receive any public comments.
9.

Payment or Gift to Respondents
There will no payment or gift to respondents.
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10.

Confidentiality

Although this information is needed for a public report to Congress, it will not involve
any personal information about victims that could identify them as specific individuals.
However, anecdotal, non-identifying information about the effectiveness of individual programs
may be included in the report. There is no assurance to confidentiality.
11.

Specific Questions

The annual progress report will not contain any questions of a personal, sensitive nature
such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly
considered private.
12.
13.

Hour Burden of the Collection of Information

The data collection tool will be completed by 56 STOP State Administrators (from 50
states, the District of Columbia and five territories and commonwealths (Guam, Puerto Rico,
American Samoa, Virgin Islands, Northern Mariana Islands) and their approximately 2500
subgrantees 3. There will be 2,556 annual responses and it is estimated that it will take State
STOP Administrators and subgrantees no more than 1 hour to complete the annual progress
report form. Thus, the annual reporting and recordkeeping hour burden is 2,556. State STOP
Administrators are informed about the reporting requirements during the grant solicitation
process and during the grant award process.
OVW is seeking basic information that is routinely kept by the subgrantees in the normal
course of their operations. Thus, the requirement that grantees complete this progress report
within a period of less than 30 days after receipt of it is not overly burdensome. OVW estimates
that it will take approximately 1 hour for a subgrantee to complete the form. OVW developed
this estimate based on the fact that information of this nature is already kept by subgrantees
receiving funds under the STOP Formula Grant Program and that the subgrantees have been
apprized of these reporting requirements. The progress report is divided into sections that pertain
to the different types of activities that subgrantees may engage in, i.e. training, product
development, victim services. Grantees will only have to complete the sections of the form that
relate to their specific activities.
13.

Cost Burden of the Collection of Information

OVW does not believe that there is any annual cost burden on respondents or
recordkeepers resulting from the collection of this information.
3 Each year the number of STOP subgrantees changes. The number 2,500 is based on the number of reports that
OVW has received in the past from STOP subgrantees.

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14.

Annualized Costs to the Federal Government

The annualized costs to the Federal Government resulting from the OVW staff review of
the progress reports submitted by grantees are estimated to be $143,356.
15.

Program Changes or Adjustments

There are no program changes or adjustments for the estimates identified in Section 13
and in Section 14. This is a information collection that is necessary for OVW and its STOP
administrators and STOP Formula Grant Program subgrantees to comply with the statutory
reporting requirements and the Government Performance and Results Act of 1993 (Pub. L. 10362).
16.

Published Results of Information Collections

There will be no complex analytical techniques used in connection with the publication of
information collected under the request. Information will be gathered once a year at the end of
the reporting periods. OVW is statutorily required to submit a report on the effectiveness of all
grant-funded activities on a biennial basis.
17.

Display of the Expiration Date of OMB Approval

OVW will display the Expiration Date of OMB Approval in the upper right hand corner
of the Progress Report.
18.

Exception to the Certification Statement

OVW is not seeking any exception to the certification statement identified in Item 19,
Certification for Paperwork Reduction Act Submissions, of OMB Form 83-I.

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