Objective Work Plan and On-going Progress Report
OMB Information Collection Request
0970 - 0452
Supporting Statement Part A - Justification
January 2025
Type of Request: Revision
Submitted By:
Administration for Native Americans
Administration for Children and Families
U.S. Department of Health and Human Services
Circumstances Making the Collection of Information Necessary
The Objective Work Plan (OWP) information collection is conducted in accordance with 42 USC of the Native American Programs Act of 1972, as amended. This collection is necessary to evaluate applications for financial assistance and determine the relative merits of the projects for which such assistance is requested, as set forth in Sec. 806 [42 USC 2991d-1](a)(1).
The Ongoing Progress Report (OPR) information collection is conducted in accordance with Sec. 811 [42 USC 2992] of the Native American Programs Act and will allow the Administration for Children and Families (ACF) Administration for Native American (ANA) to report quantifiable results across all program areas. It also provides grantees with parameters for reporting their progress and helps ANA better monitor and determine the effectiveness of their projects.
This request includes revisions to the currently approved OPR and a request for an extension for the OPR and the OWP; there are no changes proposed to the OWP. ANA would like to coordinate the review and approval of the OWP/OPR and the Project Outcomes Assessment Survey (POAS) (OMB #0970-0379) information collection to align expiration dates in the future. ANA is currently revising the POAS in accordance with Executive Order (E.O.) 14112 (Reforming Federal Funding and Support for Tribal Nations To Better Embrace Our Trust Responsibilities and Promote the Next Era of Tribal Self-Determination) so took the opportunity to review and make updates, as needed, to the materials under this OMB number and is now submitting the updated materials in coordination with a revision request for OMB #: 0970-0379.
Purpose and Use of the Information Collection
The OPR is submitted to ANA on a semi-annual basis and provides grantees with a set format by which they report on their performance indicators, progress achieved, and training and technical assistance needs. This standardized format allows ANA to monitor grantee progress, identify grantees that may need training and/or technical assistance, and report quantifiable results to Congress. The changes proposed to the OPR are to ensure the report aligns with other ANA information collections, improve the clarity of request, and to streamline. The updates do not change the intended purpose or use of the OPR information collection.
The information collected in the OWP is used by ANA to determine if an applicant has a viable implementation plan from which to carry out a proposed project. Applicants are required to complete this as part of their funding application package. The OWP is a planning and implementation tool which requires applicants to map out their goals, objectives, activities, resources, and time frames for their projects. It is used on the front end during the panel review process, and by ANA program specialists throughout the grant period to compare projected objectives and activities against actual accomplishments in order to gauge grantees' progress. There are no changes proposed to the OWP.
Use of Improved Information Technology and Burden Reduction
Applicants are able to electronically submit the OWP through www.grants.gov. The OPR is an online form which grantees can complete electronically and submit in the GrantSolutions system, a Grants Management Center of Excellence managed by ACF.
Efforts to Identify Duplication and Use of Similar Information
ANA has reviewed information collection instruments and has determined that there are no existing forms that can be used to meet ANA’s data collection needs.
Impact on Small Businesses or Other Small Entities
The information being requested has been held to the absolute minimum required for the intended use.
Consequences of Collecting the Information Less Frequently
Failure to collect this information would violate the legislative mandate of the Native American Programs Act of 1974 as amended. The OWP is required one-time only (at time of application), and the OPR is only required to be collected on a semi-annual basis in order to effectively monitor ANA projects. Completing the OPR is a reporting requirement as a term and condition of an ANA grant award.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances.
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on November 13, 2024, (89 FR 89645) and provided a sixty-day period for public comment. During the notice and comment period. We did not receive comments.
Explanation of Any Payment or Gift to Respondents
No payments or gifts have been or will be provided to any respondents.
Assurance of Confidentiality Provided to Respondents
Information being requested in the OWP and OPR is not considered confidential. Therefore, no additional safeguards are considered necessary beyond those that are customarily applied to routine government information. In rare cases, grantees may insert or attach information to their OPRs, such as community meeting attendance lists that include contact information. ANA will take reasonable precautions to keep information contained in the OPR private to the extent permitted by law. The OWP and OPR are "housed" electronically on the ACF GrantSolutions system.
Justification for Sensitive Questions
This is not applicable. No information of a sensitive nature is requested in the OWP or OPR.
Estimates of Annualized Burden Hours and Costs
Estimated Burden Hours
ANA collects the OWP from grant applicants, including Tribal governments, Native American nonprofit organizations, and Tribal Colleges and Universities. Based on experience to date, the estimated time to complete the OWP is 3 hours. The total burden is 900 hours (300 applicants x 1 response x 3 hours per response). This amount is divided by three to provide an average annual estimate (300 hours).
ANA collects the OPR from grant Recipients twice per year. The estimated time to complete OPR is one hour. Based on experience to date, the estimated time to complete the OPR is 1 hours per response. The total burden on an annual basis is 400 hours (200 respondents x 2 response x 1 hour per response).
Estimated Cost to Respondents
We estimated the total cost by using the Bureau of Labor Statistics wage data for Social and Human Services Assistants (job code 21-1093). The mean hourly wage from May 2023 is $21.27 per hours. To account for fringe benefits and overhead the rate was multiplied by two which is $42.54. The estimate of annualized cost to respondents for hour burden (inclusive of fringe and overhead) is $42.54. https://www.bls.gov/oes/current/oes211093.htm
Information Collection Title |
Total Number of Respondents |
Total Number of Responses Per Respondent (over 3 years) |
Average Burden Hours Per Response |
Total Burden Hours |
Annual Burden Hours |
Average Hourly Wage |
Total Annual Cost |
OWP |
300 |
1 |
3 |
900 |
300 |
$42.54 |
$12,762 |
OPR |
200 |
6 |
1 |
1,200 |
400 |
$42.54 |
$17,016 |
Estimated Annual Burden and Cost Totals: |
1,300 |
|
$29,778 |
||||
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There are no additional costs to respondents or record keepers.
Annualized Cost to the Federal Government
The annual cost burden to the federal government is approximately $13,400 to collect and analyze data.
Explanation for Program Changes or Adjustments
ANA proposes the following changes to the OPR:
Page 1, line 5. ANA added “Federal Financial Report” for clarity in reference to the SF425.
Section A
ANA eliminated questions A.1 and A.2 as they are confusing to recipients and ANA does not utilize the data gathered.
Item 3. Clarified the instructions and streamlined the activity status options.
Section B
Item 3. Deleted and moved to Item 1. Reworded to specifically ask if there was a Key Personnel Change (Authorized Official (AOR) and Project Director/Principal Investigator (PIPD). And renumbered accordingly.
Item 3. Employment Tables. Added a section to indicate whether the position was vacant.
Section C
Item 2. Added instruction pointing grant recipients to ANA TTA Centers if necessary.
Items 3-4. Deleted
Section D
Added instruction for Project staff to work with their accounting/financial staff.
Items 3-9. Deleted
Item 10. Reworded for clarity and further specificity.
Section F
Removed the work “Impact” in four places. ANA no longer uses the term Impact as in this instance.
Removed Three-Year Post Project Target. ANA no longer tracks this data.
Section I
Item 2. Deleted.
Section J
Item 1. Added 1.d. Did you count volunteers as part of your non-federal share?
Item 2. Reworded for clarity. Eliminated the percentages as multiple choice options and added a simplified Yes/NO/NA and a space to explain why the recipient might not have achieved the participation they anticipated.
Plans for Tabulation and Publication and Project Time Schedule
The OWP form will be made available on Grants.gov and the ACF Grants webpage. OPR’s will be tabulated and the aggregate data shared with Congress and other stakeholders on an annual basis.
Reason(s) Display of OMB Expiration Date is Inappropriate
This is not applicable.
Exceptions to Certification for Paperwork Reduction Act Submissions
This is not applicable.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Jones, Molly (ACF) |
| File Modified | 0000-00-00 |
| File Created | 2025-01-19 |