0061_CARES_Act_CIL_PPR_Non_Material_Change_SS

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Centers for Independent Living Program Performance Report

OMB Number: 0985-0061

1. Justification

1. Circumstances Making the Collection of Information Necessary

In compliance with 44 U.S.C. § 3507, the Administration for Community Living (ACL) has submitted the following proposed non-substantive collection of information to OMB for review and approval to collect data under the approved Center for Independent Living (CIL) Program Performance Report. The Office of Independent Living Programs (OILP) must update the currently approved Centers for Independent Living (CIL) Program Performance Report (PPR) 0985-0061 to highlight any CARES Act reporting requirements.

The Rehabilitation Act Title VII, Subchapter C of 1973 (The Act) requires three Independent Living program reports: (1) State Plan for Independent Living, (2) Independent Living Services (ILS) Program Performance Report (PPR), and (3) Centers for Independent Living (CILs) PPR. This request is for the CIL PPR submitted annually by every CIL that receives funding. The CIL PPR serves as the main way for CILs to fulfill the requirement to “[submit] an approvable annual performance report demonstrating that the Center meets the indicators of minimum compliance.” 29 U.S.C. § 725(c)(8) (2015); 45 CFR § 1329.21(a)(2).

The CARES Act requires ACL to report monthly to “the Office of Management and Budget, the Bureau of Fiscal Service in the Department of the Treasury, the [Pandemic Response Accountability Committee], and the appropriate congressional committees on any obligation or expenditure of large”—meaning more than $150,000—“covered funds, including . . . awards.” The CARES Act requires ACL grantees that receive CARES Act funding to report quarterly, to ACL and to the Pandemic Response Accountability Committee, “the total amount of large covered funds that the grantee received from ACL; the amount of large covered funds received that were expended or obligated for each project or activity; a detailed list of all projects or activities for which large covered funds were expended or obligated, including the name of the project or activity; a description . . .; and the estimated number of jobs created or retained by the project or activity, where applicable; and detailed information on any subcontracts or Subgrants. . .” Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, H.R. 748 § 15011(a–b), 116th Cong. (2020).

ACL must update the CIL to include guidance and an updated instrument, which highlights data elements required by different CIL grantees to report CARES Act related data. A non-substantive change to the CIL PPR will provide additional instructions and a form for CILs to enter data specific to the CARES Act funded services with an emphasis on COVID-19 related services defined in the CARES Act. Funded data requires CILs that receive funds to report activities that assist individuals with disabilities with needs resulting from the impact of the COVID-19 pandemic.

2. Purpose and Use of the Information Collection

The CIL PPR collects data to assess grantees’ compliance with Title VII of the Act, 45 CFR part 1329 of the Code of Federal Regulations, applicable provisions of the HHS Regulations under 45 CFR part and the CARES Act. Based on ACL’s assessments of PPRs, it provides technical assistance, further assesses compliance, grants and denies continuations, and terminates grants. CIL PPRs are necessary forms of compliance assessment because PPRs alert ACL about grantees that need further assessment.

The PPR is also used by ACL to design CIL and Statewide Independent Living Council training and technical assistance programs authorized by section 721 of the Act. See 29 U.S.C. § 721(b)(1) (2015); see 45 CFR § 1329.24. Under the CARES Act, ACL has created a supplemental CARES Act CIL PPR instrument and instructions that will collect any COVID-19 related service data.

3. Use of Improved Information Technology and Burden Reduction

Grantees electronically submit reports through ACL Reporting because it standardizes answers in a way that is easy to understand, search, remotely access, and store. The questions are phrased and formatted to minimize burden and channel information collected into categories that consistently inform ACL. CIL PPRs are all in the same easy-to-understand and easy-to-compare format, which also inform ACL’s training and technical assistance programs.

4. Efforts to Identify Duplication and Use of Similar Information

The data that is necessary for the purpose described in Item 2, above, is not available through other data collection.

5. Impact on Small Businesses or Other Small Entities

Not applicable.

6. Consequences of Collecting the Information Less Frequently

The Rehab Act, as amended, requires ACL to annually grant or deny continuations of Subchapter C funding to CILs. The CARES Act is a two-year grant to Part C funded CILs. Collecting the pertinent information less than annually would not allow ACL to appropriately grant or deny continuations.

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

None of the listed provisions applies to this information collection.

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

This justification provides non-substantive changes to the currently approved 0985-0061. In 2019 during clearance of this information collection ACL published both a 60-and 30-day Federal Register Notice.

External Consultation

ACL is not seeking external input because this version of the CARES Act CIL PPR does not contain substantive changes from the previous version. These non-substantive changes will allow ACL to collect data where CARES Act CIL funding was used.

9. Explanation of Any Payment or Gift to Respondents

Not applicable.

10. Assurance of Confidentiality Provided to Respondents

The Department provides no assurance of confidentiality. The CIL PPR does not collect personally identifiable information.

11. Justification for Sensitive Questions

Not Applicable.

12. Estimates of Annualized Burden Hours and Costs

ACL estimates the burden of this collection of information as follows: Three-hundred fifty-three CILs will each complete CIL PPRs annually, and it will take an estimated forty-six hours per CIL per PPR. The 353 CILs will take an estimated 16,238 hours to complete CIL PPRs.

Respondent/Data collection activity	Number of respondents	Responses per respondent	Hours per response	Total Annual burden hours
CILs	353	1	46	16,238

The calculation is based on the median salary for social workers, which, according to the Bureau of Labor Statistics, is $23.07 per hour. Multiplying the total response time—16,238 hours—by this median hourly salary results in $285,029.90. Multiplying this total amount of salary costs by two—to account for benefits and overhead—results in $570,059.80.

Respondent/Data collection activity	Total Annual Burden Hours	Average Cost Per Hour	Total Cost
CILs	16,238	$46.14	$749,221.32

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

No additional capital or other costs are incurred by respondents other than those specified in this question.

14. Annualized Cost to the Federal Government

Each report takes approximately 2.5 hours to review and approve, and there are 353 reports, so ACL will spend approximately 882.5 hours reviewing these reports. ACL staff members who will review these reports will be GS-11s, GS-12, and GS-13s; all of whom work in Washington, DC. The median salary of a reviewer is estimated as $44.28 per hour, which is the salary of a GS-12, step 5 in the Washington, DC area. This median hourly salary multiplied by the 882.5-hour estimate of the total review time is $39,077.10. Multiplying this $39,077.10 by two—to account for salaries and benefits—results in an estimated total cost of the review of $78,154.20.

15. Explanation for Program Changes or Adjustments

ACL has estimated a (30%) adjustment increase range calculated into the burden estimate and any Federal Cost to Government. These estimates are based on the CARES ACT respondent and or reporting frequency adjustments.

16. Plans for Tabulation and Publication and Project Time Schedule

Data will be made available to the public upon request.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The OMB expiration date will be displayed.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

There are no exceptions to the certification statement.

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