Low Income Household Water Assistance Program (LIHWAP) Plan
OMB Information Collection Request
0970 - NEW
Supporting Statement Part A - Justification
June 2021
Submitted By:
Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
SUPPORTING STATEMENT A – JUSTIFICATION
Summary
This information collection request (ICR) consists of instructions for Low Income Household Water Assistance Program (LIHWAP) grantees regarding the required information they must submit to the Office of Community Services (OCS) to receive funding under LIHWAP. LIHWAP is a new program in response to the COVID-19 pandemic and which Congress established temporarily via the Consolidated Appropriations Act, 2021 (Public Law No: 116-260) signed on December 27, 2020. The Consolidated Appropriation Act included instructions for the Administration for Children and Families (ACF) to carry out grants to assist low-income households, particularly those with the lowest incomes, that pay a high proportion of household income for drinking water and wastewater services, by providing funds to owners or operators of public water systems or treatment works to reduce arrearages of and rates charged to such households for such services. The program received additional stimulus funding through the American Rescue Plan Act, 2021 (Public Law No: 117-2) signed on March 11, 2021 with similar instructions.
Consistent with the Paperwork Reduction Act of 1995, and the Office of Management and Budget (OMB) procedures, ACF requests approval for emergency processing for the LIHWAP Plan. The LIHWAP Plan is necessary for the program to meet its statutory obligations (Consolidated Appropriations Act, 2021; Public Law No: 116-260 and the American Rescue Plan Act, 2021; Public Law No: 117-2) which includes COVID-19 pandemic related emergency relief for individuals and families. The Department requests emergency OMB approval pursuant to 5 CFR 1320.13 in order for OCS to receive necessary information to provide LIHWAP grantees with funding in an effort to ensure households receive benefits as soon as possible to avoid disruption of services and to maintain continuity in accessing safe drinking water and wastewater services.
An extension request, including the appropriate 60- and 30-day comment periods will be submitted to OMB prior to the expiration of the 6-month emergency approval period.
Circumstances Making the Collection of Information Necessary
This request is for a new collection to gather grantee program design and implementation information related to the Low Income Household Water Assistance Program.
The Consolidated Appropriations Act, 2021 (Public Law No: 116-260) signed on December 27, 2020, included $638,000,000 in funding with instructions for the Administration for Children and Families (ACF) within the U.S. Department of Health and Human Services (HHS) to carry out grants to assist low-income households, particularly those with the lowest incomes, that pay a high proportion of household income for drinking water and wastewater services, by providing funds to owners or operators of public water systems or treatment works to reduce arrearages of and rates charged to such households for such services. As a result, ACF is planning a new program, the Low Income Household Water Assistance Program (LIHWAP).
Congress appropriated an additional $500 million in stimulus funding for the program in the American Rescue Plan Act (Public Law No: 117-2) signed on March 11, 2021.
The Office of Community Services (OCS) will administer LIHWAP funds through the Division of Energy Assistance (DEA). Eligible entities include States, territories, and tribes that received a Low Income Household Energy Assistance program grant award for FY2021.
LIHWAP grantees have the flexibility to design certain policies and procedures related to the implementation of their LIHWAP programs in order to target the specific needs of their service population. Many of these policies and procedures must be reported to and approved by OCS prior to grantees making payments to operators of public water systems or treatment works on behalf of eligible households. The LIHWAP Plan is an important step in maintaining program integrity. Grantees must report on program design and be approved prior to making payments on behalf of eligible households.
OCS is requesting emergency approval of the LIHWAP Plan to expedite receipt and approval of grantee LIHWAP Plans in response to the emergency nature of this program. The intent is for eligible household to receive benefits as soon as possible to avoid disruption of services and to maintain continuity in accessing safe drinking water and wastewater services. The administration must award funding in May and is targeting a release date of May 27, 2021. ACF intends to make the Plan available to LIHWAP grantees concurrent to the launch of the funding because the May launch only gives grantees access to 15% of the funding to use for administrative costs to start-up the program. Grantees must submit the Plan in order for ACF to review and release the remainder of the grant to grantees to begin issuing benefit payments. Grantees will need to obtain public input on their Plans prior to submission to ACF—a process that is required under the similar Low Income Home Energy Assistance Program (LIHEAP).
Purpose and Use of the Information Collection
The LIHWAP Plan will provide OCS with information related to each grantee’s program design, including eligibility, benefit amounts, outreach, fiscal monitoring, etc. OCS will use information received to identify recipients, methods and categories for grantee expenditures, as well as to assess the effectiveness of grantee planning and compliance to terms and conditions for the LIHWAP. OCS will review and approve LIHWAP Plans prior to allowing access to grant funds beyond the administrative cap.
Use of Improved Information Technology and Burden Reduction
The LIHWAP Plan may be collected through the Online Data Collection (OLDC) platform.
Efforts to Identify Duplication and Use of Similar Information
The LIHWAP Plan will not duplicate any other work by ACF. LIHWAP is a new program and this will be the only instrument for collecting information related to grantee LIHWAP program planning, design and implementation.
Impact on Small Businesses or Other Small Entities
This data collection does not impact small business or other small entities.
Consequences of Collecting the Information Less Frequently
LIHWAP grantees will submit the LIHWAP plan once. They are required to submit the information prior to making payments to water utility providers on behalf of low income households. This information is critical for understanding how grantee programs will be administered and for assessing compliance with LIHWAP terms and conditions. OCS will review and approve LIHWAP Plans prior to allowing access to grant funds beyond the administrative cap. Grantees must submit a revised Plan during the project period if they make significant changes to their program. Collection of revised Plans will be included in an extension request, which will be submitted to OMB for review and approval within the next 6 months.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances for proposed data collection effort.
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 published on May 26, 2021 (86 FR 28362) and alerted the public to a request for emergency approval for six months of data collection. The Notice directed comments to be submitted through RegInfo.gov, but due to unforeseen delays, the request was not submitted to OMB concurrently and was not on RegInfo.gov at the time of publication of the Notice. You may now submit comments in one of the following ways:
Email comments to: [email protected]. Please include the title of the information collection (Low Income Household Water Assistance Program (LIHWAP) Plan) with your comments.
Submit comments on RegInfo.gov:
Go to the url: www.reginfo.gov/public/do/PRAMain
Click on "Currently under 30-day Review - Open for Public Comments"
Find this collection: Low Income Household Water Assistance Program (LIHWAP) Plan
Select “Comment” and submit your comment
OCS solicited comments in the form of the LIHWAP survey (approved under OMB #0970-0531), which was available on the LIWHAP webpage from Monday, April 19 – Tuesday April 27, 2021. These comments were due prior to submission of this information collection request and have been addressed. See Attachment A: Comments and OCS Responses.
Explanation of Any Payment or Gift to Respondents
No payment or gift will be provided to respondents.
Assurance of Confidentiality Provided to Respondents
No assurance of confidentiality will be provided to respondents. No personal identifiers will be collected. IRB review is not required for data reporting.
Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
Information Collection Title |
Total Number of Respondents |
Total Number of Responses Per Respondent |
Average Burden Hours Per Response |
Annual Burden Hours |
Average Hourly Wage |
Total Annual Cost |
LIHWAP Plan |
206 |
1 |
8 |
1648 |
$72.46 |
$119,414.08 |
The LIHWAP survey (OMB #0970-0531), which was available on the LIWHAP webpage from Monday, April 19 – Tuesday April 27, 2021, included a question to gather grantee feedback on the burden hours to complete the LIHWAP Plan. Grantees were given access to a draft of the LIHWAP plan to inform their response. Survey responses were as follows:
38% estimated 8-12 hours,
30% estimated 4-8 hours,
19% estimated 4 hours or less, and
13% estimated 12 hours or more.
Based on these responses, OCS identified 8 hours to be the most frequently indicated number burden hours needed to complete the LIHWAP Plan.
The estimated annual cost is based upon the average hourly salary for social and community service managers, job code 11-9151 based on May 2020 Occupational Employment Statistics from the Bureau of Labor and Statistics. The mean hourly wage is $36.23 per hour. The mean wage was multiplied by two to calculate wage plus fringe benefits and overhead.
https://www.bls.gov/oes/current/oes119151.htm
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There are no additional costs to respondents.
Annualized Cost to the Federal Government
Annual costs to the federal government for this collection are estimated based on an average total of 4 hours for federal staff to review each LIHWAP Plan and to make any necessary follow-up contacts with grantees to obtain additional information.
A GS-13 employee generally reviews each report and a GS 13 may also do second review. A GS-14 or GS-15 employee generally makes final decisions when there are questions about the adequacy of information. At an average salary rate of $30 per hour, assuming 4 hours each for 210 applications the federal salary costs each year will be about $34,650.
Explanation for Program Changes or Adjustments
This is a new information collection.
Plans for Tabulation and Publication and Project Time Schedule
It is anticipated that aggregated data will be provided in the program’s report to Congress, as well as possible shared on the public LIHWAP web site. There are no specific deadlines for this tabulation and publication. ACF anticipates that the data will be compiled by the end of FY 2021 and can be available for dissemination after that point. Key tabulations are likely to include information such as: whether subgrantees will be used for application intake, the benefit amount range, program operation dates, and key eligibility criteria (such as income cutoff and whether categorical eligibility is available). These data will cover the project period through FY 2023. No advanced or complex analytical techniques are anticipated.
Reason(s) Display of OMB Expiration Date is Inappropriate
The expiration date for OMB approval will be displayed.
Exceptions to Certification for Paperwork Reduction Act Submissions
No exceptions to the certification statement are necessary.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Christopher, Lauren (ACF) |
| File Modified | 0000-00-00 |
| File Created | 2021-06-11 |