For
annual reporting burden estimates, Tribal administrators believe
the ACF estimate of 25 burden hours should at least be doubled;
the reflection and organizing required of multiple staff members
is time consuming and more likely to fall around 50 hours than
25.
Where
possible, eliminate duplication among all reporting obligations.
While
technical assistance is appreciated, the annual reporting
requirement for information about TA feels burdensome and
unnecessary. Administrators report feeling the need to provide
lengthy information in order to show their support of TA, which
is a time consuming process.
Administrators
request that they receive information on what will be asked of
them for end of the year reporting at the beginning of the year,
allowing them to track that information throughout the year and
making final reporting easier.
Reconsidering
monthly phone calls regarding annual reporting, if information
has already been shared and reflected on.
Administrators
are curious about automated reporting opportunities but do
believe that, as no program has the same measurements, such
efforts seem easier said than done; all Tribal programs have a
different story to tell, and this may get lost in automation.
However, an automated system that details what prior information
regarding a specific reporting question has already been
submitted would be very welcome as an option for reducing
administrative burden.
Tribal
administrators also would appreciate detailed, timely feedback on
their annual reports. As programs spend, according to their
estimates, around 50 combined hours on this requirement, feedback
on how the information provided is being used and by whom would
be meaningful to programs and staff.
|
ACF
appreciates ASTHVI's feedback on the proposed revisions to an
approved information collection: Tribal Maternal, Infant, and
Early Childhood Home Visiting (MIECHV) program Guidance for
Submitting Annual Reports. Regarding the estimated number of
burden hours, ACF used a 25-hour estimate in the previous
guidance (i.e., Guidance for Submitting an Annual Report to the
Secretary), but ACF agrees that this underestimated the actual
burden hours for the last annual report. As a result, significant
changes have been made, including a thorough review of the
previous annual report to identify areas of duplication and
streamline the annual report to reflect the 25-hour estimate more
accurately. Further details about these changes are also provided
below.
As
requested, ACF worked diligently to reduce duplication (including
eliminating the semi-annual Program Progress Report requirement).
A significant change in the annual report was the streamlining of
requirements, resulting in a 10-page reduction for the annual
report guidance from 14 pages to 4.
Section
6, technical assistance, is designed to evaluate whether grant
recipients’ TA needs are met and, if not, what additional
support would be helpful. ACF values the feedback of all
recipients, whether their TA needs are met or not. To reduce
unnecessary burden, ACF has modified the TA reporting section to
allow recipients to respond "yes" if their TA needs are
met and "no" if they do not have any recommendations on
improving TA support. However, ACF also wants to provide other
recipients with unmet TA needs the opportunity to express those
needs and share ideas for how ACF can fulfill them. It is
therefore at the discretion of the grant recipient how much
information they wish to include in response to this section.
ACF
recognizes that early communication is crucial in preparing
recipients for their reporting obligations and reducing the
burden of collecting information from grant recipients. At the
start of each grant year, ACF provides recipients with a document
laying out their reporting requirements for the coming year (at
minimum). ACF communicates in the NOFO that after the first year
of the grant, grant recipients are required to submit a detailed
annual report to the Secretary. As grant recipients approach
their second year of reporting, ACF will seek ways to integrate
the annual report with the other reporting requirements specified
in their Implementation Plan Guidance, making it easier for all
administrators to track the information throughout the year and
simplify final reporting.
Tribal
MIECHV recipients have the opportunity to discuss their annual
reports during the grant recipient performance review call each
February. Before the call, Federal Project Officers (FPOs)
carefully evaluate the annual reports to ensure an effective
discussion. Each February, FPOs hold a call with recipients to
review their performance, including the annual report and other
reporting requirements for Tribal MIECHV. It's important to note
that the annual report (as well as other end of year reports) is
only discussed during the February call and not during any other
monthly calls.
ACF
is grateful for the idea of automated reporting and agrees that
it is a complex task, given the unique narratives of each Tribal
program. Nevertheless, ACF is committed to reducing duplicative
reporting and is actively working to understand the program's
existing data needs through a comprehensive process. This
involves reviewing existing data sources and documentation. In
line with this, ACF will consider automation-led approaches where
suitable to address reporting inquiries that have already been
raised.
The
deadline for submitting annual reports is December 31st. Grant
recipients receive feedback on their reports (including the
annual report and the demographic and service utilization and
performance measurement reports) in February following this
submission, only a month later. This allows FPOs to review each
report thoroughly in preparation for providing detailed feedback
in February. ACF deeply appreciates the hard work and dedication
put into completing these reports. The annual report aims to
collect detailed, contextualized information that cannot be found
in other Tribal MIECHV reporting. The annual reports provide
unique insights, including qualitative information about program
implementation, success stories, testimonials, and
recommendations for improving ACF's support to grant recipients.
The information recipients provide will help inform individual
support and technical assistance and shape future policy
decisions. We at ACF are truly grateful for the amazing
contributions of our grant recipients. Their support is essential
in ensuring the continued success of the Tribal MIECHV Program.
|