0043 FInal Supporting Statement

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

Independent Living Services Program Performance Report

OMB Number: 0985-0043

1. Justification

1. Circumstances Making the Collection of Information Necessary

In compliance with 44 U.S.C. § 3507, ACL has submitted the following proposed collection of information to OMB for review and clearance. The Independent Living Services (ILS) program provides financial assistance, through formula grants, to states, the District of Columbia, Puerto Rico, American Samoa, the Commonwealth of the Northern Mariana Islands, Guam, and the US Virgin Islands for expanding, and improving the provision of, IL services. The Designated State Entity (DSE) is the agency that, on behalf of the state, receives, accounts for, and disburses funds received under Part B of the Rehabilitation Act of 1973, as amended. Funds are also made available for the provision of training and technical assistance to Statewide Independent Living Councils (SILCs). The Act requires three IL program reports: (1) State Plan for Independent Living (SPIL), (2) ILS Program Performance Report (PPR), and (3) Center for Independent Living (CIL) PPR. This request is for the ILS PPR, which is submitted annually by the SILC and DSE in every state that receives Part B funds. The ILS PPRs are used by ACL to assess grantees’ compliance with title VII of the Act, with 45 CFR part 1329 of the Code of Federal Regulations, and with applicable provisions of the HHS Regulations at 45 CFR part 75. The ILS PPR serves as the primary basis for ACL monitoring activities in fulfillment of its responsibilities under sections 706 and 722 of the Act. The PPR is also used by ACL to design CIL and SILC training and technical assistance programs authorized by section 721 of the Act.

This request is for the ILS PPR, submitted annually by the SILC and DSE in every state that receives Part B funds. The ILS PPR serves as the primary way for DSEs to fulfill their requirement to “submit . . . reports with respect to . . . records” of “the amount and disposition of . . . financial assistance” from ACL and the costs of projects that financial assistance from ACL pays for. 29 U.S.C. § 704(m)(4); 45 CFR 1329.6(b).

This collection of information is an extension without change.

2. Purpose and Use of the Information Collection

The ILS PPRs are used by ACL to assess grantees’ compliance with Title VII of the Act, with 45 CFR part 1329 of the Code of Federal Regulations, and with applicable provisions of the HHS Regulations at 45 CFR part 75. ACL assessments of the PPRs provides technical assistance, further assesses compliance, grants and denies continuations, and terminates grants. ILS PPRs are necessary forms of compliance assessment.

In addition, ILS PPRs alert ACL about what grantees need further assessment. The PPR is also used by ACL to design CIL and SILC training and technical assistance programs authorized by section 721 of the Act. See 29 U.S.C. § 721(b)(1); see 45 CFR 1329.24. The data is also used to meet the requirements of GPRAMA regarding performance measures. See 31 U.S.C. § 1116.

3. Use of Improved Information Technology and Burden Reduction

All ILS PPRs are submitted according to ACL requirements. The questions are phrased in ways that minimize the time and effort that answering requires and in ways that channel answers into categories that conveniently tell ACL what it needs to know. (These forms are all in the same easy-to-understand and easy-to-compare format.)

4. Efforts to Identify Duplication and Use of Similar Information

The data is necessary for the purpose described in Item 2 above and is not available through other data collections.

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 annually determine DSEs have made substantial progress and are, therefore, eligible for continuation awards. Collecting the pertinent information less than annually would not allow ACL to determine grant funding and deny continuations as statutorily required. See 29 U.S.C. § 711(a) (1) (A) (“for each fiscal year . . . , the Administrator shall make an allotment to each state”).

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

Explain any special circumstances that would cause an information collection to be conducted in a manner requiring respondents to:

• report information to the agency more often than quarterly;

• prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• submit more than an original and two copies of any document;

• retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• design a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• use a statistical data classification that has not been reviewed and approved by OMB;

• include a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

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

A 60-day notice published in the Federal Register in vol. 85, No. 243 pages 81924–81925 on December 17, 2020. There were no public comments received. A 30-day notice published in the Federal Register in vol. 86, No. xxx pages xxxx on [ACL PRA Office Inserts]

External Consultation

ACL did not seek external input for this extension without change of the ILS PPR. There are no substantive changes from the previous version. ACL intends to determine any substantive changes during this next collection period.

9. Explanation of Any Payment or Gift to Respondents

Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.

Not Applicable.

10. Assurance of Confidentiality Provided to Respondents

The Department provides no assurances of confidentiality.

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: Fifty-six jurisdictions—specifically, the fifty states, Puerto Rico, the District of Columbia, and the outlying areas—will each complete ILS PPRs annually, and it will take an estimated thirty-five hours per jurisdiction per ILS PPR. Each jurisdiction’s SILC and DSE will collaborate to complete the ILS PPR.

The fifty-six jurisdictions combined will take an estimated 1,960 hours per year to complete ILS PPRs. This burden estimate is based on what DSEs and SILCs have told the Office of Independent Living Programs (OILP) about how long filling out ILS PPRs took in previous reporting years.

Respondent/Data collection activity	Number of respondents	Responses per respondent	Hours per response	Total Annual burden hours
SILCs and DSEs	56	1	35	1,960

The calculation is based on the median salary for social workers, which, according to the Bureau of Labor Statistics, is $24.26 per hour. Multiplying the total response time—1,960 hours—by this median hourly salary results in $47,549.60. Multiplying this $47,549.60 by two—to account for benefits and overhead costs—results in $95,099.20.

Respondent/Data collection activity	Total Annual Burden Hours	Average Cost Per Hour	Total Cost
ILS PPR	1,960	$24.26	$95,099.20

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 two hours to review and approve, and there are 56 reports, so ACL will spend approximately 112 hours reviewing these reports. ACL staff members who will review these reports will be GS-11s, GS-12s, and GS-13s; all will work in Washington, DC. The median salary of a reviewer is estimated as $47.35 per hour, which is the salary of GS-12, step 5 in the Washington, DC area. This median hourly salary multiplied by the 112-hour estimate of the total review time is $5,303.20. Multiplying this $5,303.20 by two—to account for salaries and benefits—results in an estimated total cost of the review of $10,606.40.

15. Explanation for Program Changes or Adjustments

This is an extension without change; there are no program changes or adjustments.

16. Plans for Tabulation and Publication and Project Time Schedule

The data will be available on ACL.gov and more details 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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