ACL Request for OMB Emergency Clearance Memo

DEPARTMENT OF HEALTH & HUMAN SERVICES Administration for Community Living Washington, D.C. 20201

To: Julie Wise

Office of Information and Regulatory Affairs

Through: Tomakie Washington

Administration for Community Living

From: Stephanie Whittier Eliason

Team Lead

Office of Elder Justice and Adult Protective Services

Administration on Aging/Administration for Community Living

Date: July 2, 2020

Subject: Emergency Clearance Request for the Study on the Impact of COVID-19 on Adult Protective Service Programs

The Administration for Community Living (ACL) requests emergency clearance approval to collect data for a study on the impact of COVID-19 on Adult Protective Service (APS) Programs (OMB 0985-New). ACL seeks approval from OMB under the Paperwork Reduction Act (PRA) section 1320.13(i)(iii); due to an unanticipated event the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of this vital time-sensitive information.

Due to the recent COVID-19, pandemic ACL requests OMB emergency approval to collect data using an online survey. This study’s collection of information is essential to the mission of ACL, as the unanticipated COVID-19 pandemic has caused changes in APS policy and practice in several areas; including, but not limited to, a reduction of in-person interactions with clients. This study needs to occur now during the COVID-19 pandemic to explore both challenges and successes and with the goal of developing a resource of information to assist APS programs in responding to ongoing and future outbreaks or similar emergencies. For this reason, ACL cannot reasonably comply with the normal PRA clearance procedures and requests a waiver of public comment to expedite online distribution of the data collection activity on July 20, 2020. ACL has prepared the supporting statement parts A and B as well as relevant study approvals for submittal via ROCIS on OMB approval to review under emergency clause 1320.13.

This is a one-time usage survey with 36 questions; ACL estimates 20-minutes per respondent to complete. We estimate a maximum of 50 respondents for a total burden increase of 16.5 burden hours. ACL has taken steps to consult with five APS State offices most affected by COVID-19 to discuss the relevancy and feasibility of the data collection during these times as well as data collection strategies and methods to minimize burden. Four APS state directors reviewed the study for readability, accuracy, and ease.

Please provide your informal response to this request by Tuesday July 7, 2020. With approval to use an emergency clearance, ACL will submit the ICR via ROCIS and requests your review, comment and approval by Friday July 17, 2020. This will allow ACL to post the study on July 20.

Thank you for your review of this emergency clearance request, if you have any questions or comments please contact Tomakie Washington, [email protected] and [email protected].

Cc: Rasheed D. Williams

Deputy Administrator for Management and Budget

Administration for Community Living (ACL)

U.S. Department of Health & Human Services