TVAP Summary of Proposed Changes

Summary of Proposed Changes: Information Collection, TVAP (OMB No. 0970-0467)

Trafficking Victims Assistance Program (TVAP) Performance Indicators

The Trafficking Victim Assistance Program (TVAP) is inclusive of four distinct programs: the Trafficking Victim Assistance Program (TVAP), Aspire: Child Trafficking Victim Assistance Demonstration Program, Victims of Human Trafficking Services and Outreach Program – Pacific Region Demonstration Program (VHT-SO Pacific Program), and Lighthouse: Services, Outreach, and Awareness for Labor Trafficking (Lighthouse) Demonstration Program. The performance indicators described below are applicable to all four TVAP programs. TVAP award recipients must provide the following program performance indicator data to OTIP on a quarterly and annual basis, as indicated.

Victim Assistance – Client Characteristics and Program Entry (QUARTERLY)

Original Data Element	Proposed Change	Justification
Grant Recipient	Eliminate	OTIP’s new online case management system will automatically populate this information.
Type of Intake	Eliminate	This data element was used to track clients as they cycled in and out of services. OTIP’s new case management system includes functionality to track individual clients through their service delivery/continuum of care, rendering this data element unnecessary.
Intake Date	Keep	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Was client matched to a service provider within 48 hours of referral?	Eliminate	This requirement was removed from the notice of funding opportunity; data element is no longer relevant. OTIP suggests removing this data element.
Referral Date	Keep	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Referral Source	Keep with one modification to field values (Removed: Look Beneath the Surface Grantee)	OTIP’s LBS program sunset in 2019, therefore this referral source category is no longer relevant.
Does the client have family members receiving services from the grant recipient?	Keep	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Relationship to Victim	Eliminate	To reduce burden and the risk of victim identification, OTIP suggests removing this data element. This level of specificity is not required for OTIP’s monitoring purposes.
Service Eligibility Status	Keep (renamed Grant Eligibility Status to bring the data element into alignment with the field within ATIMS)	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Date of Birth	Eliminate	To reduce burden and the risk of victim identification, OTIP suggests removing this data element. Age will be retained. Specific date of birth is not needed.
Age	Keep	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Gender Identity	Keep with modifications to field values; add: Client uses a different term: [free text], Unknown, Prefer not to answer	TVAP grantees are expected to effectively serve all victims of all forms of trafficking in a person-centered, culturally appropriate, and trauma-informed manner, including individuals belonging to groups that have been historically underserved, marginalized, or subject to discrimination or systemic disadvantage, in order to increase identification of and support for individuals from these groups. OTIP suggests retaining this data element to better understand the populations at risk of human trafficking, inform program development, assess the unmet needs of these populations, and respond to the National Action Plan to Combat Human Trafficking and recommendations made by honorable members of the U.S. Advisory Council on Human Trafficking. Modified field value options correspond with the proposed sexual orientation and gender identity measures proposed in NASEM’s 2022 report.
Does the client identify as LGBTQ2S+?	Keep (changed LGBTQ2S+ to 2SLGBTQIA+ for consistency with the notice of funding opportunity (NOFO))	TVAP grantees are expected to effectively serve all victims of all forms of trafficking in a person-centered, culturally appropriate, and trauma-informed manner, including individuals belonging to groups that have been historically underserved, marginalized, or subject to discrimination or systemic disadvantage, in order to increase identification of and support for individuals from these groups. OTIP suggests retaining this data element to better understand the populations at risk of human trafficking, inform program development, assess the unmet needs of these populations, and respond to the National Action Plan to Combat Human Trafficking and recommendations made by honorable members of the U.S. Advisory Council on Human Trafficking. OTIP does not need to know the specific sexual orientation of clients served, therefore, this question deviates from the proposed measure in the NASEM 2022 report.
Does the victim have a disability?	Keep	Originally, OTIP proposed removing this data element to reduce burden and the risk of victim identification. However, this data element was added back after internal consultation with OTIP project officers who determined this information was needed to understand client demographics/service needs and to monitor grant recipients’ efforts to serve underserved/marginalized populations.
Country of Origin	Keep (renamed from Location of Origin)	This piece of information enables OTIP and the grant recipient to confirm eligibility and informs monitoring activities. OTIP suggests retaining this information.
Living Situation at Intake	Keep (renamed from Current Living Situation)	OTIP suggests retaining this data element to assess the needs of clients at intake, inform program evaluation and development efforts, and guide policy discussions with federal partners such as the Department of Housing and Urban Development.
If client is a minor are they enrolled in school?	Keep	OTIP suggests retaining this data element to ensure that minors enrolled in the TVAP Aspire program are receiving all of the benefits and services to which they are entitled.
Services Requested/Needed (At Intake)	Eliminate	To reduce burden, OTIP suggests removing this data element. Rather than collect information on services requested/needed at intake, OTIP proposes collecting on services rendered at the end of the reporting year.
Services Requested/Needed (At Intake)	Eliminate	To reduce burden, OTIP suggests removing this data element. Rather than collect information on benefits requested/needed at intake, OTIP proposes collecting on benefits issued at the end of the reporting year.
Location of Services	Keep with modifications; change from County/Parish, State/Territory, Tribal Land/Reservation to only State/Territory; add: Remote option	To reduce burden, OTIP suggests modifying this data element to require only the state/territory where services are to be rendered. The FY23 notice of funding opportunity provides that grant recipients may provide remote case management services. OTIP proposes adding “Remote” as a field value.
Type of Trafficking	Keep (moved up on the form to encourage data entry, higher quality data)	OTIP requires this information in order to be responsive to various federal reporting requirements, including the annual Attorneys General Report. OTIP suggests retaining this data element.
Relationship to Trafficker	Eliminate	To reduce reporting burden, OTIP suggests removing this data element.
County or Parish, State or Territory, and Country of Trafficking Incident	Keep with modifications; change from County/Parish, State/Territory, Tribal Land/Reservation to only State/Territory and Country of Trafficking Incident (moved up on the form to encourage data entry, higher quality data)	OTIP has added in language to clarify that this data element is voluntary and that the information is not required for enrollment in the program as well as highlighting the ability for the grantee to mark unknown when the information is not provided. To reduce burden, OTIP suggests modifying this data element to require only the state/territory and country where the trafficking incident occurred, where known/provided.
Exploitation Industry/Venue	Keep with modifications to certain corresponding field values; Add: • Auto-Mechanic/Auto-Shop/Car Repair  • Carpentry/Woodworking  • Cobbling • Commercial Sex • Garment/Textiles • Herding Livestock/Animal Husbandry • Other (specify) • Personal Sexual Servitude • Production of Child Sexual Abuse Material (CSAM) • Traveling Sales Crew • Waste Management/Recycling • Not Reported Modify: • Illicit Massage/Health/Beauty to Illicit Massage/Health • Stripping/Exotic Dancing to Stripping/Dancing Remove: • Cartel/Gang • Pornography/Remote Interactive Sexual Acts • Prostitution/Outdoor Solicitation •Prostitution/Residential	OTIP has added in language to clarify that this data element is voluntary and that the information is not required for enrollment in the program as well as highlighting the ability for the grantee to mark unknown when the information is not provided. OTIP suggests retaining this data element to inform victim identification efforts, development of its revised Look Beneath the Surface Awareness Campaign materials, and other prevention efforts led by the office.

Victim Assistance – Client Case Closure (QUARTERLY)

Original Data Element	Proposed Change	Justification
Case Closure Date	Keep	OTIP suggests retaining this data element to assess client outcomes, inform program evaluation and development, and guide policy discussions with federal partners.
Reason for Case Closing	Keep	This indicator informs monitoring activities and program evaluation. OTIP suggests retaining this information.
Employment Status upon Case Closing	Eliminate	To reduce burden, OTIP suggests removing this data element.
Living Situation upon Case Closing	Keep	OTIP suggests retaining this data element to assess client outcomes, inform program evaluation and development, and guide policy discussions with federal partners.
Did the client obtain Continued Presence or T-Visa?	Keep	OTIP suggests adding in the data element to track program outcomes.
Did the client obtain HHS Certification or Eligibility?	Keep	OTIP suggests adding in the data element to track program outcomes.
Did the client receive a referral for continued case management services?	Keep	OTIP suggests adding in the data element to track program outcomes.

Victim Assistance – Barriers to Service Delivery (QUARTERLY)

Original Data Element	Proposed Change	Justification
Barriers to Service Delivery Encountered	Keep	OTIP suggests retaining this data element to assess client outcomes, program performance, inform program evaluation and development, and guide policy discussions with federal partners
Number of Monitoring Visits Conducted	Eliminate	To reduce burden, OTIP suggests removing this data element. Monitoring activities, specifically site visits and desk audits are tracked separately from the program performance indicator data.
Number of Desk Audits Conducted	Eliminate	To reduce burden, OTIP suggests removing this data element. Monitoring activities, specifically site visits and desk audits are tracked separately from the program performance indicator data.
Number of Subrecipients that Provided Services	Eliminate	To reduce burden and reporting redundancy with the Subrecipient Enrollment Form, OTIP suggests removing this data element.
Number of Clients Who Received Remote Case Management	Eliminate	To reduce burden and reporting redundancy with the Subrecipient Enrollment Form, OTIP suggests removing this data element.

Client Service Use and Delivery (ANNUAL)

Original Data Element	Proposed Change	Justification
Services Received	Keep with modifications to field values: Dental Health removed and replaced with Healthcare Add: • Peer-to-Peer Support/Mentoring	OTIP suggests retaining the data element to assess whether clients receive the services and benefits they need, ensure the compliance of grantees in providing comprehensive case management, inform program evaluation and development, and guide policy development.
Benefits Received	Keep with additional program specific field values; Add: • ORR Unaccompanied Children (UC) Program  • ORR Unaccompanied Refugee Minors  (URM) Program	OTIP suggests retaining the data element to assess whether clients receive the services and benefits they need, ensure the compliance of grantees in providing comprehensive case management, inform program evaluation and development, and guide policy development.
Did the client apply for HHS Certification or Eligibility?	Eliminate	This question was duplicative (asked on the Client Case Closure Form). To reduce duplication and burden, OTIP proposes eliminating this question from the Client Service Use and Delivery Form. Grant recipients should report this information at the time a client’s case is closed, if known.
Did the client receive HHS Certification or Eligibility?	Eliminate	This question was duplicative (asked on the Client Case Closure Form). To reduce duplication and burden, OTIP proposes eliminating this question from the Client Service Use and Delivery Form. Grant recipients should report this information at the time a client’s case is closed, if known.

Victim Outreach [NEW] (QUARTERLY)

The revised FY23 TVAP programs require outreach activities to be conducted by grant recipients. Accordingly, Outreach indicators modeled after those in use for the Domestic Victims of Human Trafficking – Services and Outreach program (OMB No. 0970-0542) are proposed.

New Data Element	Response Options	Justification
Outreach Activities Conducted	(number)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Outreach Settings	• Agricultural Settings • Casinos • Commercial Establishments • Consulates • Court-Based Settings • Day Labor Settings • Detention Settings • Digital: Social Media • Digital: Other • Education Settings • Factories • Health Care Settings • Homeless Encampments • Hotel/Hospitality Settings • Massage Parlors • Shelter Settings • Strip Clubs • Youth Care Settings • Other (specify)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities. This information may also inform the development of revised public awareness and screening materials under OTIP’s revised Look Beneath the Surface Campaign, and other prevention activities.
Target Population(s)	Keep with modification: data element to change from open text to a list with structured field values: • 2SLGBTQIA+ Populations • Alaska Native/Indigenous Populations • Asian American/Pacific Islander Populations • Black Populations • Boys and Men • Direct Care Workers • Hispanic or Latino Populations • People with Disabilities • People who Live in Rural Communities • Religious Minority Populations • Runaway Homeless Youth Populations	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities. This information may also inform the development of revised public awareness and screening materials under OTIP’s revised Look Beneath the Surface Campaign, and other prevention activities.
Number of Victims Identified	(number)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Screening Tool	Eliminate	Screening Tool(s) used removed based on consultation with existing grant recipients regarding the difficulty of collecting this information in practice and based on OTIP’s review of historical PPR submissions. OTIP is able to monitor the recipient’s progress toward screening and identification activities through other proxy measures.

Training (QUARTERLY)

No changes proposed.

Original Data Element	Proposed Change	Justification
Total Trainings	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities, including providing content and audience-specific training opportunities for relevant stakeholders.
Training Topic	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities, including providing content and audience-specific training opportunities for relevant stakeholders.
Training Audience	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities, including providing content and audience-specific training opportunities for relevant stakeholders.

Subrecipient Enrollment (QUARTERLY)

Original Data Element	Proposed Change	Justification
Name of Subrecipient Organization	Keep (renamed from Name of Organization)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. Data element was renamed for clarity.
Location of Subrecipient Organization	Keep (renamed from Location of Organization)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. Data element was renamed for clarity.
Type of Subrecipient Organization	Keep (renamed from Type of Organization)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. Data element was renamed for clarity.
Subrecipient Service Sites	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. This data will enable OTIP to identify potential service coverage gaps.
Goal of Partnership	Eliminate	Screening Tool(s) used removed based on consultation with existing grant recipients regarding the difficulty of collecting this information in practice and based on OTIP’s review of historical PPR submissions. OTIP is able to monitor the recipient’s progress toward screening and identification activities through other proxy measures.
Type of Partnership	Eliminate	Screening Tool(s) used removed based on consultation with existing grant recipients regarding the difficulty of collecting this information in practice and based on OTIP’s review of historical PPR submissions. OTIP is able to monitor the recipient’s progress toward screening and identification activities through other proxy measures.
Services Provided by Subrecipient (In-House)	Keep with modification: Services Provided by Subrecipient (In-House) Services Provided by Subrecipient through Referral collapsed into one data element with the same field values.	Service(s) Provided by the Subrecipient (In-House) and (Through Referral) collapsed into one category, Services Provided by Subrecipient, which should be sufficient for OTIP’s grant monitoring purposes and less burdensome for the grant recipients’ to report. This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. This data will enable OTIP to identify potential service coverage gaps.
Services Provided by Subrecipient through Referral	Eliminate	Service(s) Provided by the Subrecipient (In-House) and (Through Referral) collapsed into one category, Services Provided by Subrecipient, which should be sufficient for OTIP’s grant monitoring purposes and less burdensome for the grant recipients’ to report. This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. This data will enable OTIP to identify potential service coverage gaps.
Enrollment Date	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. This data will enable OTIP to identify potential service coverage gaps.
Exit Date	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities as the prime recipient, or through subrecipients. This data will enable OTIP to identify potential service coverage gaps.

Categories of Assistance (ANNUAL)

No changes proposed.

Original Data Element	Proposed Change	Justification
Total number of clients who received services under each category of assistance	Keep (renamed from Name of Organization)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Total dollars spent on each category of assistance	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Percentage of recipient’s budget spent on each category of assistance	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Total grant recipient budget for project	Keep	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.
Categories of Assistance	Keep (with modification): Advocacy changed to Victim Advocacy Case Management added Clothing collapsed into Basic Necessities Dental Health (removed) Education (added 'Assistance') Employment and Job Skills (removed 'and Job Skills' and added 'Assistance') Food collapsed into Basic Necessities Housing/Shelter (added 'Services') Legal (added 'Advocacy and Services') Medical Care/Physical Health changed to Healthcare Mental/Behavioral Health (added 'Services') Personal Care Items collapsed into Basic Necessities Safety Planning (added 'Services') Vision Care (removed)	This data element will enable OTIP to monitor grant recipient overall performance and to assess the extent to which grant recipients are meeting required program activities.

4