IMLS G2S Five-Year Evaluation Part A 20220911

Part A. Justification: Guidelines for IMLS Grants to States Five-Year Evaluation  (3137-0090)

1. Necessity of the Information Collection

The Institute of Museum and Library Services (IMLS) requests an approval of a renewal of the three-year clearance for the agency’s information collection requests for the Guidelines for IMLS Grants to States Five-Year Evaluation under the Paperwork Reduction Act (PRA).

Each State Library Administrative Agency (SLAA) is required, under 20 U.S.C. § 9101 et seq. (in particular 20 U.S.C. § 9134, attached at the end of this document), to submit a plan that details library services goals for a five-year period, along with associated certifications. IMLS authorizing legislation (20 U.S.C. § 9134) directs SLAAs to “independently evaluate, and report to the Director regarding, the activities assisted under this subchapter, prior to the end of the Five-Year Plan.” This evaluation provides SLAAs an opportunity to measure progress toward meeting the goals set forth in their approved Five-Year Plans, along with a framework to synthesize information across all state reports to facilitate telling a national story.

These guidelines were approved by the Office of Management and Budget (OMB) in 2019 and received a 4-month extension of the 6/30/2022 expiration date in the spring of 2022. They are being submitted with minor updates intended to increase efficiencies of the data collection itself and minimize confusion around reporting requirements. These changes are based on feedback from SLAAs and their independent evaluators received during the most recent evaluation-reporting submissions.

2. Purposes and Uses of the Data

The evaluation guidelines specify a consistent set of retrospective, process, and methodology questions to be used by independent evaluators engaged by the SLAAs. These questions solicit information about progress in meeting Five-Year Plan goals, reaching specific beneficiary groups, and documenting any modifications made to the plan. Evaluators have flexibility in their data collection methods, but many use document review (particularly annually reported data from IMLS-funded projects carried out under the approved Five-Year Plan), interviews, surveys, and focus groups to answer the questions.

Data from the Five-Year Evaluation help SLAAs measure progress in meeting the targets set in their approved Five-Year Plan, reflect on the recent federal investment in library services, and fine-tune their approach when they submit a new Five-Year Plan to IMLS later that year. In particular, many SLAAs use findings from the Five-Year Evaluation as part of the needs assessment in the statutorily required Five-Year Plan to help make effective resource allocation decisions going forward. The Five-Year Evaluation data are also used for IMLS program planning and compliance with the Government Performance and Results Act (GPRA)/Annual Performance Report (APR) and other reporting to OMB and Congress.

The data allow IMLS to synthesize information across states in telling a national story about the use of federal funds for library services and operations. They enable IMLS and its state partners to better understand the effectiveness of the Grants to States program, to improve accountability of taxpayer dollars spending, and to identify promising practices for broader implementation across the library sector. An analysis of the evaluations covering the 2018-2022 cycle was presented by IMLS staff at the June 2022 conference of SLAAs and is available at https://imls.gov/sites/default/files/2022-06/2018-2022-fiveyearevaluations-analysis-reflections.pdf.

3. Use of Information Technology

IMLS is committed to the use of information technology for improving the efficiency and effectiveness of its programs while reducing burden on SLAA grantees. As narrative documents authored by independent evaluators, Five-Year Evaluations are generally born-digital and received through a designated IMLS email address. Once accepted, each SLAA’s Five-Year Evaluation is rendered 508 compliant and posted as PDFs to the IMLS website (https://imls.gov/grants/grants-state/five-year-evaluations).

4. Efforts to Identify Duplication

The retrospective, process, and methodology questions of the Five-Year Evaluation Guidelines are distinct from any other IMLS data collection and are not duplicated by states or other federal agencies. IMLS checks in with each SLAA about its Five-Year Plan progress as part of a site visit that occurs once every five years, but those impressions come from the SLAA itself rather than an independent evaluator. SLAAs prepare and submit federally required annual performance and financial reports detailing their progress toward meeting the goals of the Five-Year Plan at the individual project and annual funding levels, but only the Five-Year Evaluation by an independent evaluator synthesizes project data over multiple years to generate a comprehensive picture of Five-Year Plan goal achievement.

5. Method Used to Minimize Burden on Small Businesses

Not applicable.

5. Consequences of Less Frequent Data Collection

These collections of information are essential to IMLS in meeting its statutory mission under 20 U.S.C. § 9101 et seq. (in particular 20 U.S.C. § 9134). The information collected, as directed by the Five-Year Evaluation Guidelines, is necessary to support IMLS in demonstrating prudent investment of federal funds in library services across the U.S. and its territories, monitoring the progress of Five-Year Plan achievement by the SLAAs, and meeting its APR reporting requirements. The information is collected only once per five-year cycle to evaluate the Five-Year Plan retrospectively. Less frequent data collection would lessen the value of independent review and would eliminate the important basis for continuous learning about investments and iterative development as new Five-Year Plans are created and submitted.

5. Special Circumstances

Not applicable.

5. Consultations Outside the Agency

The 60-Day Notice requesting comment for this collection was published in the Federal Register June 10, 2022 (87 FR 35575). The agency has taken into consideration the one comment that was received under this notice. The 30-Day Notice was published in the Federal Register on September 15, 2022 (87 FR 56714).

Grants to States program staff and Office of Research and Evaluation staff received informal feedback from SLAAs and independent evaluators during the most recent Five-Year Evaluation process and made minor adjustments to the guidelines. IMLS hosted a conference kick-off session for SLAAs in 2021 followed by eight monthly Community of Practice sessions in 2021 and 2022 to help new SLAA staff and evaluators better navigate the evaluation guidelines and process and to solicit feedback. IMLS staff also consult informally with the SLAA community throughout the year, including regular meetings with professional staff and the chief executive officers of SLAAs. These include informal Zoom calls to help SLAA representatives connect with each other, participation in state-hosted forums to share experiences, lessons learned, and recommendations on how to plan for the evaluation reporting. Question-and-answer sessions in these meetings can surface points of confusion that the SLAAs experience during their evaluations. IMLS staff considered this feedback as they made incremental enhancements to evaluation guidelines that are documented in this package.

5. Payments or Gifts to Respondents

No payments or gifts are provided to any of the respondents.

5. Assurance of Confidentiality

Independent evaluators follow best practices to aggregate and anonymize responses from surveys, interviews, and focus groups that are included in the Five-Year Evaluation. IMLS will review evaluations before accepting and publishing them and will also ask evaluators to address confidentiality concerns before final submission, as needed. Personal information collected through this information collection will be subject to privacy protections to the extent permitted by law.

5. Justification for Sensitive Questions

There are no questions of a sensitive nature.

5. Estimate of Hour Burden to Respondents

The affected public for this data collection are the State Library Administrative Agencies (SLAAs), which number 59 respondents. The estimated average burden per overall response to the Five-Year Evaluation Guidelines is 90 hours once every five years. The total estimated burden is 5,310 hours. When annualized over five years, this translates to 12 respondents per year, 18 hours per year, and 1,062 hours per year.

5. Estimate of Cost Burden to Respondents

The total estimated cost burden to respondents is $163,866.60. When annualized over five years, this translates to $32,773.32 per year.

5. Estimate of Costs to Federal Government

The total estimated annual cost burden for this effort to the Federal Government is $10,287.24. When annualized over five years, this translates to $2,057.45 per year. Costs consist of IMLS staff time calculated at $43.59 per hour x 236 hours over five years or 47.2 hours per year.

5. Explanation of Change in Burden

The total burden estimate increased slightly due to an increase in the median hourly wage reported for librarians in March 2022.

5. Statistical Usage

This is a non-statistical administrative collection.

5. Request to Not Display Expiration Date

The OMB Control Number and expiration date will be displayed.

5. Exception to Certification Statement

Not applicable.

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