COMM_OMB_SupportingStmt_HHR_Final CLEAN

Low Income Home Energy Assistance Program (LIHEAP) Annual Report on Households Assisted

OMB Information Collection Request

0970 - 0060

Supporting Statement Part A - Justification

April 2020

Submitted By:

Office of Community Services

Administration for Children and Families

U.S. Department of Health and Human Services

SUPPORTING STATEMENT A – JUSTIFICATION

Summary

1. Circumstances Making the Collection of Information Necessary

The Low Income Home Energy Assistance Program (LIHEAP) block grant (42 U.S.C. 8621) was established under Title XXVI of the Omnibus Budget Reconciliation Act of 1981, Public Law 97-35. The Office of Community Services (OCS) within the Department of Health and Human Services' (DHHS) Administration for Children and Families (ACF) administers LIHEAP at the Federal level.

The LIHEAP statute requires the collection of data on the number of households assisted, their income levels, and vulnerability group, by type of LIHEAP assistance, for inclusion in the Secretary’s annual LIHEAP Report to Congress. The data are collected through the LIHEAP Household Report, which consists of the following: (1) a Long Format for state grantees, the District of Columbia, and selected territory grantees, and (2) a Short Format for tribal grantees and selected territory grantees.

The LIHEAP Household Report is an annual data collection effort conducted by the U.S. Office of Community Services (OCS) to collect information from LIHEAP grantees to meet statutory requirements and program objectives. ACF is currently requesting non-substantive changes to the LIHEAP Household Report to meet statutory requirements related to the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) stimulus funding and potential other supplemental funding from Congress.

2. Purpose and Use of the Information Collection

The statutory purpose and use of the information collection includes the following:

• LIHEAP grantees are required to report the estimated or final data contained in the previously approved LIHEAP Household Report as part of their annual application for LIHEAP funds, as required by Section 2605(c)(1)(G) of the Act (42 U.S.C. 8624). If reporting estimated data, the grantee is required to submit a final Household Report no later than December 31st.

• OCS prepares the data on assisted households for inclusion in the Department's annual LIHEAP Report to Congress, as required by Section 2610(a)(4) and (5) and section 2610(b) of the Act (42 U.S.C. 8629). The data are used for Congressional oversight and in response to Congressional and White House queries on case load statistics and demographic characteristics of LIHEAP households.

• Finally, the data on heating assisted households containing at least one member who is elderly or a young child are used in calculating LIHEAP recipiency targeting performance measures, under the Government Performance and Results Act (GPRA) of 1993 (31 U.S.C. 1101) and the President’s annual Congressional Justification.

• To provide separate tracking and reporting of the CARES Act LIHEAP funding that Congress appropriated on March 27, 2020. Separate reporting is a requirement of the terms and conditions of the grant awards for this supplemental funding.

3. Use of Improved Information Technology and Burden Reduction

All grantees reports are submitted through the Administration of Children and Families’ On-Line Data Collection System (OLDC). Instructions for completing the form are built into the form itself, through hyperlinks.

4. Efforts to Identify Duplication and Use of Similar Information

Household income levels and presence of elderly, disabled, or young children can be estimated at the national and regional levels for the households receiving heating assistance from two national household surveys–the Annual Social and Economic Supplement (ASEC) to the Current Population Survey (conducted by the U.S. Bureau of the Census) and the Residential Energy Consumption Survey (conducted by the U.S. Energy Information Administration). However, national household surveys do not provide reliable State-level data on any type of LIHEAP assistance, or data in a timely manner to comply with LIHEAP statutory reporting requirements. Also, these surveys underestimate the number of households receiving heating assistance due to underreporting and sampling error. There is no other similar information collection that can be modified to provide the data.

5. Impact on Small Businesses or Other Small Entities

No small business entities are involved in the data collection.

6. Consequences of Collecting the Information Less Frequently

The deadline for LIHEAP grantees to submit their block grant applications/plans for the following fiscal year is September 1st of the current fiscal year. Part of the block grant application requires the annual fiscal year data that are reported in the LIHEAP Household Report. Consequently, grantees would be unable to comply with statutory requirements in section 2605(c)(1)(D of the LIHEAP statute (42 U.S.C. 8624(c)(1)(G) and 8629(a)(4), (a)(5), (b), and (c)) if the data were collected less frequently.

Without the grantees’ annual reporting of the LIHEAP household data, HHS would be unable to complete its annual LIHEAP Report to Congress, as required by section 2610(b) of the LIHEAP statute (42 U.S.C. 8629).

There would be no way for OCS to track annual LIHEAP performance output.

Finally, OCS also would be unable to obtain data that are necessary in calculating LIHEAP recipiency targeting and outcome developmental performance measures that are included in the President’s annual Congressional Justification.

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

There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5.

8. 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 August 17, 2018, Volume 83, Number 41075, pages 41075-41076, and provided a sixty-day period for public comment. We did not receive comments.

9. Explanation of Any Payment or Gift to Respondents

No payment or gifts to respondents are involved.

10. Assurance of Confidentiality Provided to Respondents

Confidentiality is not an issue as only aggregated household data are collected.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature that are commonly considered private.

12. Estimates of Annualized Burden Hours and Costs

Estimates of the hour burden of the collection of information are based on the number of LIHEAP grantees (50 States, the District of Columbia, 148 Indian Tribes/Tribal Organizations, and five Insular Areas) completing the information collection annually.

The response burden on respondents varies based on the following:

• The LIHEAP Household Report – Long Format for the 50 States, the District of Columbia, and selected territory grantees (average burden per response of 43 hours).

• The LIHEAP Household Report – Short Format for the 148 Indian Tribes/Tribal Organizations and selected territory grantees (average burden per response of 2 hours).

Annual Burden Estimates for LIHEAP Household Report

Instrument	Number of Respondents	Number of Responses Per Respondent	Average Hour Burden Per Response	Total Burden Hours
Long Format	56	1	43	2,408
Short Format	148	1	2	296
Total Annual Burden Hours				2,704

The variance in burden is due to the Department waiving most of the reporting requirements for small LIHEAP grantees, given the small grant amounts involved and the overall difficulty in obtaining reliable demographic data from small grantees. In reducing the burden on small LIHEAP grantees, all Indian Tribes and Tribal Organizations and selected territory grantees will continue to be exempted from most of the reporting requirements. These grantees report only on the number of households assisted by type of LIHEAP assistance through the LIHEAP Household Report–Short Format.

The annual costs for respondents for each format of the LIHEAP Household Report are estimated as follows:

• For the LIHEAP Household Report–Long Format, OCS estimates that the total annual respondent cost to be $84,000.

Staff	Number of respondents	Average # hours per respondent	Average $ per hour	Total cost
Reporting	56	29	$44	$71,456
Recordkeeping	56	14	$16	$12,544
Total Cost				$84,000

• For the LIHEAP Household Report–Short Format, OCS estimates the total annual respondent cost to be $8,880.

Staff	Number of respondents	Average # hours per respondent	Average $ per hour	Total Cost
Reporting	148	1	$44	$6,512
Recordkeeping	148	1	$16	$2,368
Total Cost				$8,880

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

Respondents will not incur any additional costs.

14. Annualized Cost to the Federal Government

Cost Item	Hours	Salary (per hour)	Total
GS-13: (a) update LIHEAP Household Report and instructions to reflect the current Federal Fiscal Year (b) prepare an Action Transmittal reminding grantees of the reporting requirement, (c) oversee the work of the contractor.	375	$75.1	$28,162.50
Contractor Cost: (a) oversee the collection effort and prepare statistical tables (b) prepare tables with footnotes for final publication in the Report to Congress.	176	$83.79	$14,747.04
Total			$42,909.54

15. Explanation for Program Changes or Adjustments

The Department of Health and Human Services (DHHS) changed the LIHEAP Household Report form for FY 2020 and FY 2021. These changes require grantees to report the number of households assisted by non-CARES-Act funds separate from new households assisted by CARES-Act funds provided by the CARES Act (Title VIII of Division B of P. L. 116-136) from those provided by the other FY 2020 appropriations acts. These changes separate LIHEAP funding and benefits provided by the following:

1. LIHEAP’s regular FY 2020 appropriations acts, including the Continuing Resolution (i.e., the Continuing Appropriations Act, 2020, and Health Extenders Act of 2019 | P. L. 116-59);

2. LIHEAP’s supplemental FY 2020 appropriations acts, including the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) (P. L. 116-136) and any subsequent such acts.

ACF proposes to increase the total burden hours for this request to accommodate the additional reporting requirements (4 additional hours for CARES Act-related reporting on the Long Format and 2 additional hours for CARES Act-related reporting on the Short Format). ACF also proposes to decrease the number of respondents for the Short Format from 160 to 148 due to a recent reassessment of reporting grantees.

16. Plans for Tabulation and Publication and Project Time Schedule

The results of the information collection are published in the Department's annual LIHEAP Report to Congress. State-level data are prepared as tables in Part III of the LIHEAP Report to Congress. The aggregation of State-level data also is reported in Part III of the LIHEAP Report to Congress. Complex analytical techniques will not be used as national totals, percentages, and percent distributions will be tabulated only. Selected results of the information collection also are published as part of the Department’s annual Congressional Justification.

The LIHEAP Household Report needs to be available before the end of each fiscal year to allow grantees time to submit their completed reports as part of their application for LIHEAP funds for the following fiscal year in accordance with 45 CFR 96.10. This regulation establishes September 1st as the deadline for State, Tribal, and Insular Area grantees to submit their block grant applications/plans for the following fiscal year. The projected time schedule for the annual LIHEAP Household Report is shown below.

Activity	Weeks following Octoberber 1st Submission Deadline
LIHEAP Household Reports (household data can be estimated so as not to delay issuance of new grant awards) reviewed for completeness as part of the LIHEAP grant application process	2
Final (non-estimated) household data inputted and edited	15
Final household data checked and edited for consistency with benefit data from the LIHEAP Performance Data Form – Module I (Grantee Survey), previous fiscal year LIHEAP Household Reports, the LIHEAP Carryover and Reallotment reports, and LIHEAP state plans.	25
Draft of statistical tables for inclusion in annual LIHEAP Report to Congress – text and appendices	34
Final statistical tables for inclusion in annual LIHEAP Report to Congress	40
Publication of annual LIHEAP Report to Congress**	--

**Publication is dependent upon the Department’s clearance process of the annual LIHEAP Report to Congress.

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

The expiration date for OMB approval of the information collection will be displayed on the report forms and instructions.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions indicated to the certifications required by 5 CFR 1320.9.