NonSub Change Memo - ARPA Reporting Column

To: Jordan Cohen

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Susan Golonka

Office of Family Assistance

Administration for Children and Families (ACF)

Date: March 19, 2021

Subject: NonSubstantive Change Request – Temporary Assistance for Needy Families (TANF) ACF-196R Financial Report for States (OMB #0970-0446)

This memo requests approval of nonsubstantive changes to the approved information collection: Temporary Assistance for Needy Families (TANF) ACF-196R Financial Report for States (OMB #0970-0446; Expiration date 2/29/2024).

Background

On March 11, 2021 the American Rescue Plan Act of 2021, (ARPA), P.L. 117-2, was signed into law. The ARPA provided $1 Billion of Pandemic Emergency Assistance funding to the Temporary Assistance for Needy Families program. At this time, ACF is seeking approval for non-substantive changes to the form and form completion instructions to grantees to appropriately report and categorize ARPA funding to the Office of Family Assistance.

Currently, State TANF grantees submit quarterly ACF-196R Financial Reports. The frequency of reporting will remain the same with additional capabilities for ARPA expenditures, since there is no financial reporting mechanism for ARPA funds at this time. The general uses of the information collected through the ACF-196R remain the same.

Overview of Requested Changes

Updates were made to the previously approved ACF-196R form to include reporting capabilities on ARPA funds made available by appropriations for Pandemic Emergency Assistance Fund (P.L.117-2). This update entails re-categorizing an available reporting column on the ACF-196R from American Recovery and Reinvestment Act of 2009 (ARRA) funding to ARPA funding. Information requested on ARRA funding is outdated and no longer needed on the form.

Updates were made to the previously approved 196R instructions add descriptive language in the accompanying reporting instructions concerning requirements and allowable uses of ARPA funds.

We consider the above changes to be nonsubstantive in nature while providing improved simplicity for users of the ACF-196R.

Time Sensitivities

As previously noted, State TANF grantees already submit the current ACF-196R Financial Report on a quarterly basis and this frequency will remain intact after incorporating these non-substantive updates to allow for ARPA funding.

The next ACF-196R Financial Report, quarter-end March 30, 2021, has a due date of May 14, 2021. Approval as soon as possible will facilitate timely reporting of these pandemic emergency funds, clear communication of awarding amounts and will facilitate efficient stewardship of the funds and ensure they are expended for the emergency purposes they are intended. Therefore, a prompt approval is desired.