NonSub Change - Add AHP to SOT PPR Materials

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To:	Jordan Cohen
	Office of Information and Regulatory Affairs (OIRA)
	Office of Management and Budget (OMB)

From:	Xiayun Tan 
	Office of Refugee Resettlement (ORR)
	Administration for Children and Families (ACF)

Date:	October 20, 2021

Subject:	NonSubstantive Change Request – Three Generic Performance Progress Reports Approved Under OMB #0970-0490)


This memo requests approval of nonsubstantive changes to the following approved information collections under the ACF Generic for Performance Progress Reports (OMB #0970-0490):
1. Preferred Communities Program Data Points
2. Ethnic Community Self-Help (ECSH) Program Data Indicators
3. Survivors of Torture Program Data Points

Background
The House and Senate passed the continuing resolution (CR) in late September 2021. For the Office of Refugee Resettlement (ORR), the CR authorizes the eligibility of Afghan Humanitarian Parolee (AHP) to receive services and benefits to the same extent as refugees. Current OMB approved Performance Progress Report (PPR) forms for the Preferred Community Program, Ethnic Community Self-Help (ECSH) Program, and the Survivors of Torture Program have already been collecting eligible immigration status or category of individual. There is no existing option available to accurately capture the newly authorized AHP population. ORR is requesting to add the AHP option to the existing OMB approved forms. 

Overview of Requested Changes
ORR is requesting to make the following nonsubstantive changes:

    1. Preferred Communities Program Data Points: This form is submitted by grantees semi-annually as well as annually to gather uniform program performance data from each grantee, allowing aggregation at the program level to calculate outputs and client outcomes. Grantees also provide some key demographic information of the clients served. Under the sections of “01: Totals – ICM Clients Served” and “03: Totals – Remote and Underserved Areas Clients only”, ORR requests to add “Afghan Humanitarian Parolee” as an option under the existing “Category of ORR eligibility”. Under the same sections, original “Survivors of Trafficking” was revised to “Victims of Human Trafficking”, which is a more accurate term and is consistent with ORR Policy Letter 16-01


    2. ECSH Program Data Indicators: The ECSH Data Indicators is used to collect information on grantees’ performance on a semi-annual basis. The data is used to help ORR assess the progress of the ECSH Program in terms of three main objectives1. Under the existing section “6. Number of Clients Served According to Status”, ORR requests to replace the original “Other status eligible for ORR services” option with a list of individual eligible immigration status or category (including the newly authorized “Afghan Humanitarian Parolee” population) for more accurate reporting. The instructions have been updated to reflect the following changes to improve accuracy and clarity:
        a. Inclusion of Afghan Humanitarian Parolees and other existing eligible populations in the form, to improve accuracy; 
        b. Update from “4. Number of New Enrollments this Reporting Period” to “4. Number of New Enrollments” to be more concise; 
        c. Update from “5. Number of Refugee Served” to “5. Number of Clients Served”, which is a more accurate term; 
        d. Update from “1 and 0” to “yes and no” to indicate whether services were provided to client and trainings were provided to staff (section #7 and #10), to minimize data reporting error; and 
        e. Deletion of “Cumulative Budget Period” fields to stay consistent with the semi-annual reporting requirements and to minimize confusion among grantees. . Cumulative information could be aggregated by ORR Program Officer, if needed.


    3. Survivors of Torture Program Data Points: The Survivors of Torture (SOT) Program Data Points form collects annual demographic and outcome data, as required, from SOT grantees. ORR requests to add “Afghan Humanitarian Parolee” as an option under the existing sections: “8. Immigration category/status at intake”. The User Guide has been updated to reflect the inclusion and the definition of Afghan Humanitarian Parolees, to improve clarity of instructions. 


Time Sensitivities 
Afghan humanitarian parolees became newly eligible for applicable ORR benefits and services starting October 1, 2021, following the passage of the CR.  Without a timely approval on adding this newly authorized eligibility type and immigration status/category for the hereinbefore forms, ORR is unable to ensure accurate data collection and reporting on services provided to the Afghan humanitarian parolees.