ICR Supporting Statement - COVID-19 Mandatory Reporting_final 6.5.23

ICR Supporting Statement - COVID-19 Mandatory Reporting_final 6.5.23.docx

Mandatory Reporting of COVID-19 Performance Indicators

OMB: 0412-0621

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SUPPORTING STATEMENT – Part A

REQUEST FOR APPROVAL UNDER THE PAPERWORK REDUCTION ACT AND 5 CFR 1320

OMB 0412-0621


Collection Title: COVID-19 Performance Monitoring



PART A. JUSTIFICATION


  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The U.S. COVID-19 Global Response and Recovery GRRF (GRRF), the USG’s strategy to address the COVID-19 pandemic, consists of five objectives designed to manage the immediate global health crisis and mitigate the second-order impacts of the pandemic. The USAID Implementation Plan for the U.S. COVID-19 Global Response and Recovery Framework (Implementation Plan) operationalizes and further elaborates on the Agency’s role in this whole-of-government effort. The Global Health COVID-19 Monitoring, Evaluation and Learning (MEL) Plan outlines USAID’s efforts to monitor its COVID-19 programming and includes a set of performance indicators that track implementing partner results. Tracking these performance metrics on a regular basis allows USAID to engage in responsive, data-driven decision-making; plan strategically and allocate resources effectively; and adapt interventions as the situation continuously evolves.



  1. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

COVID-19 performance monitoring data is used by a number of stakeholders involved in the pandemic response. The COVID-19 Response Team (CRT), the principal actor coordinating USAID’s response efforts, uses performance data to monitor program implementation, make course corrections or direct technical assistance as needed, and ensure the overall COVID response is progressing as expected, even as global attention to the pandemic response wanes.

Washington-based operating units (OUs), including Regional and Technical Bureaus, utilize performance management data for strategic planning, evidence-based decision-making, and to promote learning and accountability. Field-based OUs, with analytical support from Regional and Technical Bureaus, also use output-level data to track activity progress and make adjustments as needed in their respective substantive and geographic programming areas.


  1. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The majority of USAID Implementing Partners submit their performance monitoring data electronically into an Agency data management system. This method of reporting reduces the burden on Mission staff and provides streamlined reporting for IPs. The DIS also offers the potential for future functional improvements, such as bulk data upload, streamlined data quality checks, and cross-country analyses. USAID has developed a COVID-19 module in the DIS with standard COVID-19 global indicators that cover the breadth of the Agency’s COVID-19 response and has made it available to partners to submit performance data. The alternative to using the DIS is for IPs to submit data via email which may lead to formatting errors and the need for additional corrections due to the lack of data validation checks that are available in the DIS.


  1. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.


USAID IPs are currently collecting and reporting on the COVID-19 global health performance indicators (under a six-month emergency ICR approval) but were otherwise reporting on a voluntary basis. The information collected from IPs will be used as described in item 2, above, and does not entail any duplication.

The U.S. Government's Global COVID-19 response plan in the aforementioned GRRF and Implementation Plan requires that a distinct set of indicators be tracked and reported on at regular intervals, including quarterly reporting for key adaptive management outputs. USAID initially asked IPs to voluntarily report those indicators and has made significant efforts to encourage submission. However, voluntary reporting rates have demonstrated that reaching reporting levels sufficient for adaptive management, strategic decision-making, and accountability requires the mandatory reporting requested in this ICR. Similar information is not being collected elsewhere and therefore cannot be shared or modified to fulfill this requirement.




  1. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Most of the Implementing Partners (IPs) that would be involved in the information collection are not small businesses or entities. To reduce the overall burden on IPs, the collection described herein will take place on the reporting schedule specified in each IP’s award, thus minimizing the burden of off-cycle or more a frequent reporting tempo. USAID IPs are largely already reporting on these indicators, and will receive guidance and support as needed from Missions in order to meet the reporting requirements. This includes summary guidance from Technical Bureaus on the frequency, level of disaggregation, and reporting schedule for required indicators.



  1. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Given the still-evolving nature of the pandemic and USAID’s response, if collection occurs less frequently than specified in partner awards, field-based Missions and Washington OU’s would not have the data necessary to adequately assess the progress of COVID activities or make necessary course corrections, negatively affecting their planning and decision-making capabilities. If the performance data were not collected at all, it would hobble the Agency’s ability to engage in accountable programming; provide proper oversight for significant resources; and undermine efforts to facilitate operational tracking, evaluation and continuous learning.



  1. Explain any special circumstances for the information collection.

No special circumstances are anticipated.



  1. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

On March 21, 2023, a 60-Day Federal Register Notice was published at 88 FR 16938 [page 16938 (1 page)]. No comments were received. On June 5 2023, a 30-day Federal Register Notice was published at 88 FR 36526 [page 36526 (1 page)].



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


N/A


  1. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a Systems of Records Notice (SORN) or Privacy Impact Assessment (PIA), those should be cited and described here.

No personally identifiable information is included in the information collection. The monitoring data are a collection of performance indicators which are reported in aggregate by USAID implementing partners. The data include basic disaggregates, such as sex of respondents.


  1. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.


N/A



  1. Provide estimates of the hour burden of the collection of information.



Category of Respondent

# Of Respondents

# Of Responses Per Year

Participation Time

Burden

Hours (annual)

USAID Implementing Partners of Affected Awards

46

4

83

15,318



  1. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).


The burden estimate includes only the hour burden of information collection as specified above (12). No capital/start-up costs are anticipated for respondents or record-keepers, nor are operation and maintenance costs or purchase of services expected.


  1. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. If there will be no costs beyond the normal labor costs for staff, state that here.


There will be no cost beyond normal labor cost.



  1. Explain the reasons for any program changes or adjustments reported on the burden worksheet.


N/A



  1. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The results of the data collection will not be made available to the public as performance monitoring data is intended for internal use. However, aggregated or summarized versions of the performance monitoring data are featured in public communications designed to showcase USAID’s progress in the COVID-19 crisis.


  1. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


N/A


  1. Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.” (See Pg. 2 of the OMB 83-I form)

The request does not meet the criteria (i) It uses effective and efficient statistical survey methodology, as the collection instrument is not a survey and this is not applicable.



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