SSA_2900-NEW_Veterans Child Care Assistance Program (VCAP)_VA Forms 10-380 10-381 10-382_rev Oct 2024

SUPPORTING STATEMENT A

Veterans Child Care Assistance Program (VCAP)

VA Forms: 10-380, 10-381, 10-382
OMB Control Number: 2900-NEW

Summary:

• This is a new collection and all burden hours are considered a program increase.

• This collection consists of three new VA Forms.

• Two comments were received on the 60-day FRN.

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

The Veterans Child Care Assistance Program (VCAP) was established via Public Law 116-315, Section 5107a, Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020. Section 5107a provided permanent authority in 38 United States Code Section 1709C for VA to provide child care assistance to certain veterans receiving health care at VA medical facilities by January 1, 2026.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

The Department of Veterans Affairs (VA) intends to collect information from veterans in order to establish eligibility and intent to utilize the VCAP. Information will include veteran name, social security number, address, phone numbers, emergency contact information as well as various details on the child(ren) who will receive child care services. Currently, VA does not capture or maintain information on children of veterans, or those under their care. In order to protect the safety of the children and VA, appropriate information must be obtained for those being cared for on VA premises including emergency contact information for someone other than the veteran. VA facilities with onsite drop-in child care centers will be able to access the current VA systems to verify veteran name and SSN for eligibility but must maintain their contact information and the child’s information for use in the child care setting for emergency and safety precautions. This information will also be used for auditing and validation purposes in the reimbursement system for those veterans submitting claims for financial reimbursement of child care expenses. This is necessary to pay claims as well as monitor and prevent fraudulent claims.

VA Child Care Enrollment Form (10-380): The respondent population is composed of veteran individuals who are in need of drop-in child care services at VA medical facilities across the nation. This child care assistance is provided solely for the time period of the veteran’s health care appointment.

VA Child Care Appointment Certification Form (10-381): The respondent population is composed of veteran individuals who are in need of child care assistance (drop-in child care or reimbursement for child care expenses) while attending certain medical appointments at VA medical facilities. This veteran individual will use this form to attest that they are attending an eligible appointment and have an eligible veteran-child relationship for the purpose of establishing eligibility for child care assistance.

VA Child Care Reimbursement Claim Form (10-382): The respondent population is composed of veteran individuals who request reimbursement for the cost of child care at licensed non-VA child care facilities across the nation. Reimbursement for child care services is limited to the time required for the veteran’s health care appointment and travel to/from the eligible child care provider.

3. 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 VCAP is working through VA Office of Information and Technology (OIT) to create automated systems for the enrollment, scheduling, and reimbursement claim processes to the maximum extent possible. It is our intent to make each step of this process as simple and automated as possible for both veterans and the entire VA organization, at the individual facility and VA Central Office levels.

4. 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.

The VCAP has identified the Beneficiary Travel System (BTSSS) as a similar IT system that could be duplicated for the VCAP reimbursement system. Though the technological components can be duplicated, the data sets will not be the same as the reimbursements are for different types of expenses. VCAP will be able to utilize the veteran’s payment information established in BTSSS, therefore eliminating the need to duplicate that information.

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

The information collected will directly impact the child care provider who is awarded the contract to provide child care at each individual facility. The childcare service contract will likely be awarded to a minority small business owner. However, regardless of the company that contracts with VA, the burden will be limited to the process of obtaining access to VA systems as a contractor. A computer workstation will be provided to each site establishing a drop-in VA child care center for use by the contractor. Every effort has been made to minimize the burden on small businesses by keeping questions simple and to an absolute minimum.

6. Describe the consequences 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.

Of first importance, the information collected is required to ensure veteran eligibility, as not all veterans may be eligible. To ensure implementation in accordance with the authorizing statute, we must be able to verify the veteran-child relationship consistent with the eligibility criteria established in forthcoming regulations. Second, the legislation further limits child care assistance to only certain types of health care appointments, which will also be established in forthcoming regulations. The statutory criteria for eligible appointments is broad, thus requiring VA to establish the criteria within regulation. The proposed regulations outline specific types of appointments and provide authority for the veteran to self-certify that the appointment is an eligible appointment under the proposed regulations. This veteran attestation must be documented in order to provide proper oversight for the VCAP. Third, child care is a new program for VA, thus requiring a very detailed and proactive approach to policy and operational development. Failure of any type in those three areas could place the VA and the U.S. Government at risk.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.

Information must be collected upon enrollment for drop-in child care and then validated at each use of drop-in child care assistance thereafter. The validation effort may be simplified but must occur to ensure the safety of the child is maintained. Recognizing the ever-changing status of family relationships, VA cannot assume the information will remain unchanged from one child care encounter to the next. Additionally, reimbursement claims are date-specific and require a receipt as proof of payment, therefore these collection points are a one-time data point. The veteran must submit a new receipt for each claim unless multiple dates/payments are reflected on the receipt. Reimbursement claims must be submitted within 30 days of the service date, so it is possible to have multiple dates of service on a single receipt.

8.a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’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 sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

A 60-Day Federal Register Notice (FRN) for the collection published on Tuesday, August 6, 2024. The 60-Day FRN citation is 89 FRN 64044.

Two comments were received during the 60-Day Comment Period regarding determining eligibility for VCAP services. The VHA program office (PO) responded that information collected on the forms is used to determine eligibility for childcare. VA did not make changes to the collection as a result of the comments, and the agency response is included as a supplementary document in the ICR in ROCIS.

A 30-Day Federal Register Notice for the collection published on Wednesday, October 16, 2024. The 30-Day FRN citation is 89 FRN 83551.

b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.

Outside consultation is conducted with the public through the 60- and 30-day Federal Register notices.

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

No payment or gift is provided to respondents.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Assurances of privacy are contained in 38 U.S.C. 5701 and 7332. Respondents are informed that the information collected will become part of the Consolidated Health Record that complies with the Privacy Act of 1974. These forms are part of the system of records identified as 24VA19 “Patient Medical Record – VA” as set forth in the Compilation of Privacy Act Issuances via online GPO access at http://www.gpoaccess.gov/privacyact/index.html.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include 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.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

Total Annual Burden: 215,639 hours.

Total Annual Responses: 4,174,528.

a. The number of respondents, frequency of responses, annual hour burden, and explanation for each form is reported as follows:

VA Form	No. of respondents	x No. of responses	x No. of minutes	÷ by 60 =	Number of Burden Hours
10-380 VA Child Care Enrollment Form	281,600	1 = 281,600	15		70,400
10-381 VA Child Care Appointment Certification Form	290,528	13 = 3,776,864	2		125,895
10-382 VA Child Care Reimbursement Claim Form	8,928	13 = 116,064	10		19,344
TOTALS	581,056	4,174,528			215,639 hrs

VA Child Care Enrollment Form (10-380): Estimate 281,600 veterans would use drop-in child care @ 1 form per Veteran = 281,600 x 15 / 60 = 70,400.

VA Child Care Appointment Certification Form (10-381): Estimate 281,600 veterans would use drop-in child care; estimate 8,928 veterans would use reimbursement (see methodology in the following paragraph); average 13 child care encounters per veteran with a separate form for each visit = (281,600 + 8,928) x 13 x 2 / 60 = 125,895.47 (rounded to 125,895).

VA Child Care Reimbursement Claim Form (10-382): Estimate 310,000 veterans will need child care assistance and 48% will prefer reimbursement with only 6% using licensed child care; average 13 visits per veteran with a separate claim each visit = 310,000 x 0.48 x 0.06 x 13 x 10 / 60 = 19,344.

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13.

See chart in subparagraph 12a above.

c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

VA cannot make assumptions about the population of respondents because of the variability of factors, such as the educational background and wage potential of respondents.  Therefore, VHA used general wage data to estimate the respondents’ costs associated with completing the information collection.

The Bureau of Labor Statistics (BLS) gathers information on full-time wage and salary workers.  According to the latest available BLS data, the mean hourly wage is $31.48 based on the BLS wage code – “00-0000 All Occupations.”  This information was taken from the following website: https://www.bls.gov/oes/current/oes_nat.htm

Legally, respondents may not pay a person or business for assistance in completing the information collection. Therefore, there are no expected overhead costs for completing the information collection. VHA estimates the total cost to all respondents to be $6,788,315.72 (215,639 burden hours x $31.48 per hour).

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

a. There are no capital, start-up, operation, or maintenance costs.

b. Cost estimates are not expected to vary widely. The only cost is that for the time of the respondent.

c. There is no anticipated recordkeeping burden beyond that which is considered usual and customary.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The estimated annual cost of these three forms to the Federal Government: $5,067,071.

See table below:

VA Form Number	# of Forms	Processed by GS- equivalent	$/Hour	# Min to Process	Cost to VA
10-380 VA Child Care Enrollment Form	281,600	12	$32.73*	5	$768,064
10-381 VA Child Care Appointment Certification Form	3,776,864	12	$32.73*	2	$4,120,559
10-382 VA Child Care Reimbursement Claim Form	116,064	7	$18.45*	5	$178,448
TOTAL COST					$5,067,071

*Used Step 1 from GS Pay Table, Base Locality

15. Explain the reason for any burden hour changes or adjustments reported in items 13 or 14.

This is a new collection, and all burden hours are considered a program increase.

16. 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.

VA does not intend to publish this data.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

VA seeks to minimize the cost to itself for collecting, processing, and using the information by not displaying the expiration date. VA seeks an exemption that waives the displaying of the expiration date on this VA Form. The VA Form may be reproduced by the respondents and VA medical facilities from the internet and then stocked. Requiring an expiration date would result in unnecessary waste of existing stock of the forms. The inclusion of the expiration date would place an unnecessary burden on the respondent (since they would find it necessary to obtain a newer version, while VA would have accepted the old one).

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

There are no exceptions.

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