Supporting Statement A NYTD 2025 w. data 3.21.25 cln

Supporting Statement A NYTD 2025 w. data 3.21.25 cln.docx

National Youth in Transition Database (NYTD) and Youth Outcomes Survey

OMB: 0970-0340

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National Youth in Transition Database (NYTD) and Youth Outcomes Survey



OMB Information Collection Request

0970 - 0340




Supporting Statement Part A - Justification

March 2025

Type of Request: Revision














Submitted By:

Children’s Bureau

Administration for Children and Families

U.S. Department of Health and Human Services








  1. Circumstances Making the Collection of Information Necessary

The John H. Chafee Foster Care Program for Successful Transition to Adulthood (42 U.S.C. 677, as amended by Pub. L. 115–123, the Family First Prevention Services Act within Division E, Title VII of the Bipartisan Budget Act of 2018) requires State child welfare agencies to collect and report to the Administration for Children and Families (ACF) data on the characteristics of youth receiving independent living services and information regarding their outcomes.


The regulation implementing the National Youth in Transition Database (NYTD), listed in 45 CFR 1356.80, contains standard data collection and reporting requirements for States to meet the law’s requirements. ACF uses the information collected under the regulation to track independent living services, assess the collective outcomes of youth, and assess performance with regard to those outcomes, consistent with the law’s mandate. There are two information collection instruments associated with this request: the Data File and the Youth Outcome Survey. ACF is requesting a three-year extension of these two collection instruments. There are no changes requested to the forms.



  1. Purpose and Use of the Information Collection

For NYTD, states report information about certain youth both in and out of foster care and the services that are traditionally offered to young adults in preparation for emancipation. States use the information to improve their independent living programs to assist youth transition to independence. ACF uses this information to track independent living services, to assess the collective outcomes of youth, and to evaluate state performance with regard to those outcomes consistent with the law’s mandate. The Fostering Connections to Success and Increasing Adoptions Act of 2008 (P.L. 110-351) allowed states to opt to extend title IV-E foster care assistance to youth ages 18 to 21. Consequently, NYTD data are also used to assess the impact of extending foster care supports to youth over age 18. Finally, we make available our raw NYTD data sets to researchers for analysis in our National Data Archive on Child Abuse and Neglect (NDACAN) and through the Cornell University.



  1. Use of Improved Information Technology and Burden Reduction

States submit the NYTD Data File to directly to the NYTD Portal in an electronic format. In previous years, states submitted the NYTD Data File to ACF via ACFTitan, however the NYTD Portal was upgraded in August 2024 to directly accept NYTD Data Files to the benefit of the government, in both efficiency and cost savings. We decided to use Extensible Markup Language (XML) for file transmission consistent with the E-Government Act of 2002 (Public Law 107-347) based, in part, on public responses we received during the NYTD rule-making process. ACF released its final technical specifications for the transmission of NYTD data files in NYTD Technical Bulletin #1. ACF also released a technical bulletin that provides guidance on the new NYTD Data File upload process in Technical Update #1: Uploading Your Files to the NYTD Application. For the NYTD Youth Outcome Survey, many states have opted to collect these data using web-based technologies designed to ease the burden related to collecting and reporting outcomes data on young people. We believe that web-based technologies have great potential to assist states in locating and engaging youth and young adults in the NYTD Youth Outcome Survey in an efficient and cost-effective way. While we have not required a specific method that states must use to collect the survey data or track youth that leave foster care, we continue to provide technical assistance and other guidance to states on appropriate and allowable methods for locating youth and administering the survey using technology.



  1. Efforts to Identify Duplication and Use of Similar Information

Congress specifically mandated that we collect data on independent living services and youth outcomes. Prior to our rulemaking, we analyzed the sources and reporting instruments already in use in the collection of independent living services information and concluded that the type of data in the NYTD is not collected elsewhere. Specifically, we examined both federal and non-federal data sources such as:

  • Federal data collection systems such as the Adoption and Foster Care Analysis and Reporting System (AFCARS; OMB #: 0970-0422), and the Runaway and Homeless Youth Management Information System (RHYMIS; OMB #: 0970-0573);

  • State, county, and local governments with integrated and/or complementary data systems such as Statewide Child Welfare Information Systems (SACWIS); and

  • Data collection efforts of non-governmental organizations such as Casey Family Programs, United Way, Lutheran Social Services, Catholic Social Services, Child Welfare League of America, and Public/Private Ventures.


AFCARS collects data on youth who are in foster care or who were adopted under the auspices of state child welfare agencies. Many youth that will be reported by states to NYTD are also going to be reported to AFCARS. However, youth receiving independent living services may not be in foster care. And NYTD provides the opportunity to capture and report longitudinal outcomes data about youth who were served by our child welfare programs, whether in care or not. In fact, most youth in the follow-up population will not be in foster care at ages 19 and 21. So the ability to maintain relationships that motivate youth to participate in the follow up is a unique and important aspect of the NYTD data collection effort. Finally, there are separate and different authorizing statutes and penalty structures for NYTD and AFCARS that do not lend themselves to combining the databases.



  1. Impact on Small Businesses or Other Small Entities

This information collection is required of state agencies only and does not impact small businesses or other small entities.

  1. Consequences of Collecting the Information Less Frequently

This data collection is mandated by law; therefore we would be out of compliance with the statutory requirements if we did not collect independent living service and youth outcome information. In the regulation, we require that states submit NYTD data to ACF every six months, which is the same reporting frequency as AFCARS. We believe that any less frequent reporting may increase the risk of states reporting inaccurate or missing data. Further, we chose a semi-annual reporting period to preserve our ability to analyze NYTD data along with AFCARS data for the same youth. The six-month report period for AFCARS is integral to a number of ACF priorities and legislative requirements.



  1. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances required in the collection of this information in a manner other than that required by OMB.



  1. 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 December 30, 2024 (89 FR 106491) and provided a sixty-day period for public comment. During the notice and comment period, we did not receive comments.


To further aid our state users, we host a NYTD Help Desk where technical specialists are available to assist with NYTD data collection related issues. We also partner with youth engagement specialists who are able to help states implement youth engagement strategies that improve youth participation. Additionally, we are also able to provide direct and onsite guidance during NYTD Reviews and subsequently during performance improvement plan implementation. It is our goal to continue to strengthen our technical assistance efforts to support states in their work with transition aged youth.



  1. Explanation of Any Payment or Gift to Respondents

No payments, other than Chafee Program funds and federal financial participation for the maintenance and development of child welfare information systems are made to states for NYTD data collection efforts. States are permitted and encouraged to use Chafee funds to provide small tokens of appreciation to youth to encourage participation in the NYTD Youth Outcome Survey.



  1. Assurance of Confidentiality Provided to Respondents

The NYTD regulation requires states to use an encrypted personal identification number so the identity of the individual youth remains private to anyone other than the state. The encrypted ID must be a 12-character identifier that cannot be linked to the young person except at the agency or local level. We also encourage states to implement an informed consent protocol that assures survey participants that the state will ensure that their personal data is secure.


  1. Justification for Sensitive Questions

Congress specifically required in law that states collect outcome information on issues of a sensitive nature including rates of non-marital childbirth, incarceration, and high-risk behaviors. Therefore, we require states to pose questions in the youth survey that ask about these areas of a youth’s life. The survey is voluntary and, as noted in Item #10, we expect states to obtain youth or parental consent, as appropriate.



  1. Estimates of Annualized Burden Hours and Costs

This information collection will be comprised of:

  1. Data File: The state’s submission to ACF of two (2) semi-annual data files that contain information on all data elements regarding youth services, demographics, characteristics and outcomes; and,

  2. Youth Outcome Survey. A survey composed of 22 questions on youth outcomes (that correspond with 22 data elements in the first instrument) to be completed by youth in the baseline (17-year-olds in foster care) and follow-up populations (19- and 21-year-old youth who participated in the survey at age 17).


Annual Burden Hour Estimates for the NYTD, FY 2025– FY 2027

The following are burden hour estimates for FY 2025, FY 2026, and FY 2027. Please note that the average annualized burden estimates (covering all three years of this information collection request) are detailed in the table labeled “Annualized burden estimates for the NYTD for the 3-year period corresponding to this ICR, FY 2025 – FY 2027” on page 9 of this document. Pursuant to the NYTD regulation, states submit two semi-annual data files (the Data File) that contain information for each youth in the reporting populations on all data elements regarding independent living services and youth demographics, characteristics, and outcomes. The following burden hour estimates include the estimated time states will spend collecting and reporting information contained in the semi-annual data files. Additionally, burden hours are reported for the estimated time youth will spend participating in the NYTD survey (Youth Outcome Survey).


Burden Estimates - FY 2025

Instruments (subcomponents)

Number of respondents

Number of responses per respondent

Average burden per response (hrs)

Total burden hours (hrs)

1. Data File

52

2

1,238

128,752

Services

Outcomes

Tracking

1,000

104,000

65

6,760

173

17,992

2. Youth Outcome Survey

9,000

1

0.5

4,500

TOTAL burden for both collections

133,252


  1. FY 2025: With regard to the Data File, we estimate that there will be a total annual burden of 1,238 hours per State per report period to collect and submit information on (a) services and (b) outcomes and (c) for tracking purposes, to maintain contact with youth for follow-up surveys.

(a) We have estimated the same 1,000-hour burden per State per report period associated with collecting and reporting youth independent living services, demographics and characteristics information.

(b) In FY 2025, States will collect outcomes information on the Cohort 5 follow-up population of 19-year-olds. The age 19 follow-up population is a subset of the NYTD baseline population as it includes only youth who participated timely in the survey at age 17. Pursuant to the NYTD regulation, some States may also opt to collect outcomes information on a sample of 19-year-olds instead of the complete follow-up population. For these reasons, our estimate for the age 19 follow-up population is approximately 4,500 youth nationally (or 87 per State) per report period (totaling 9,000 youth annually). We are estimating 45 minutes (0.75 hours) for States to explain the purpose of the survey to these youth and to record the outcomes information that will be reported in the data file. This results in a burden estimate of 65 hours per State per report period (130 hours annually).

(c) In addition, we are estimating tracking burden during this year as we expect most 19-year-olds to have exited foster care. Similar to the 19-year-old population in prior cohorts, we expect most of them will have exited foster care. We are estimating States making up to 12 contacts in FY 2025 to locate and engage a 19-year-old youth in the NYTD survey. Estimating 10 minutes per contact, we anticipate 2 burden hours for tracking the estimated 4,500 19-year-old youth semi-annually in FY 2025, or 173 burden hours per State per report period (346 hours annually).


With regard to the Youth Outcome Survey instrument, we are estimating 0.5 burden hours for each of the 9,000 youth to listen to the State’s survey instructions and to provide responses to the survey questions, resulting in a total of 4,500 burden hours.





Burden Estimates - FY 2026

Instruments (subcomponents)

Number of respondents

Number of responses per respondent

Average burden per response (hrs)

Total burden hours (hrs)

1. Data File

52

2

1,187

123,448

Services

Outcomes

Tracking

1,000

104,000

144

14,976

43

4,472

2. Youth Outcome Survey

20,000

1

0. 5

10,000

TOTAL burden for both collections

133,148


  1. FY 2026: With regard to the Data File, we estimate that there will be a total annual burden of 1,187 hours per State per report period to collect and submit information on (a) services and (b) outcomes and (c) for tracking purposes, to maintain contact with youth for follow-up surveys.

(a) We have estimated the same 1,000-hour burden per State associated with collecting and reporting youth independent living services, demographics and characteristics information.

( b ) In FY 2026, States will begin surveying a new cohort of youth starting with outcomes data collection for another baseline population of 17-year-olds in foster care (Cohort 6). We are estimating 20,000 youth will be in the FY 2026 baseline population, and States will take approximately 45 minutes (0.75 hours) to explain the purpose of the survey to these youth and to record the outcomes information that will be reported in the data file. We estimate that there will be on average 192 17-year-old youth in foster care per State per report period, resulting in approximately 144 burden hours (288 hours annually) to record this information.

( c) We are estimating tracking burden during FY 2026 for the Cohort 5 21-year-old follow-up population to be surveyed in FY 2027 as we expect States to maintain contact with the estimated 9,000 youth between follow-up survey rounds (youth who were surveyed at age 19 in FY 2025 and are age 20 in FY 2026). In this intervening year between survey rounds, we estimate that States will make three contacts in FY 2026 to maintain a current address and contact information for tracking each State’s follow-up population. Estimating 10 minutes per contact, we anticipate 0.5 burden hours for tracking 173 20-year-old youth in FY 2026, or 43 burden hours per State per report period (87 hours annually). We are not estimating tracking burden during this year for the baseline population as we expect States to know the whereabouts of the 17-years-olds still in foster care.


With regard to the Youth Outcome Survey instrument, we are estimating that it will take the estimated 20,000 youth nationwide approximately 30 minutes (0.5 hours) to complete the survey, resulting in a total of 10,000 burden hours.





Burden Estimates - FY 2027

Instruments (subcomponents)

Number of respondents

Number of responses per respondent

Average burden per response (hrs)

Total burden hours (hrs)

1. Data File

52

2

1,281

133,224

Services

Outcomes

Tracking

1,000

104,000

65

6,760

216

22,464

2. Youth Outcome Survey

9,000

1

0.5

4,500

TOTAL burden for both collections

137,724

3) FY 2027: With regard to the Data File, we estimate that there will be a total annual burden of 1,281 hours per State per report period to collect and submit information on (a) services and (b) outcomes and (c) for tracking purposes, to maintain contact with youth for follow-up surveys.

(a) We estimate approximately 104,000 youth will receive services semi-annually (2,000 youth per State). Each State will expend on average 30 minutes (.5 hour) to collect the services, demographics, and characteristics information from those youth, resulting in an hour burden of 1,000 per State per report period.

(b) In FY 2027, States also will collect outcomes information on the Cohort 5 follow-up population of 21-year-olds. The same number of youths who were eligible to participate in the survey at age 19 are eligible to participate in the survey at age 21. As such, we are estimating that States will collect outcomes information from 4,500 youth nationally (or 173 per State) per report period (totaling 9,000 youth annually). We are estimating 45 minutes (0.75 hours) for States to explain the purpose of the survey to these youth and to record the outcomes information that will be reported in the data file. This results in a burden estimate of 65 hours per State per report period (130 hours annually).

(c) In addition, we are estimating tracking burden during this year as we expect, as seen similarly in prior cohorts, the majority of 21-year-olds in Cohort 5 will have exited foster care. We are estimating States making up to 12 contacts in FY 2027 to locate and engage 21-year-old youth in the NYTD survey. Estimating 10 minutes per contact, we anticipate 2 burden hours for tracking 4,500 21-year-old youth semi-annually or 173 burden hours per State per report period (346 hours annually). Similarly, we are estimating tracking burden during FY 2027 for Cohort 6 youth (surveyed in FY 2026 at age 17 and currently age 18 in FY 2027) as we expect States to maintain contact with this population between survey rounds. We expect States to maintain contact information for the estimated 9,000 youth who will be eligible to participate in the survey in FY 2027. In this intervening year between survey rounds, we estimate that States will make three contacts in FY 2024 to maintain a current address and contact information for such youth. Estimating 10 minutes per contact, we anticipate 0.5 burden hours for tracking 18-year-old youth in FY 2027 or 43 burden hours per State per report period (87 hours annually).


With regard to the Youth Outcome Survey instrument, we are estimating 0.5 burden hours for each of the 9,000 youth to listen to the State’s survey instructions and to provide responses to the survey questions, resulting in a total of 4,500 burden hours.


Annualized burden estimates for the 3-year period corresponding to this ICR: FY 2025 – 2027

Instruments (subcomponents)

Number of respondents

Number of responses per respondent

Average burden per response (hrs)

Total burden hours (hrs)

1. Data File

52

2

3706

(1,235 average)

134, 809

2. Youth Outcome Survey

12,667 average (38,000 Total)

1

0.5

6,333

TOTAL annualized burden estimate for both collections

141,142


Annualized Cost Estimates for the NYTD, FY 2025 - 2027

Using $33.08 per hour as an approximation for social worker hourly wages (Bureau of Labor Statistics, 2023) the costs associated with gathering the Youth Outcome Survey information and preparing and submitting the NYTD Data File would be $257,227 per state annualized over a 3-year period ((134,809 annual burden hours per response x 2 responses per year  x  $33.08 hourly wage)/52).  We are not estimating any costs to the youth who participate voluntarily in the NYTD Youth Outcome Survey.


Annualized cost estimates for NYTD

Instruments (subcomponents)

Total cost

1. Data File

$257,277

FY 2025-27

$257,277

2. Youth Outcome Survey

$0

FY 2025-2027

$0



Estimated Cost to Respondents

The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for 21-1029 Social Workers, and wage data from May 2023, which is $33.08 per hour.


Information Collection Title

Total Number of Respondents

Total Number of Responses Per Respondent

Average Burden Hours Per Response

Annual Burden Hours

Average Hourly Wage

Total Annual Cost


State Data File

52

2

3706

134,809

$33.08

$4,459,482


Youth Outcomes Survey

38,000 total; 12,667 annual avg

1

0.5

6333

$0

$0


Estimated Annual Burden and Cost Totals: 141,142

-

$4,459.482






  1. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

We expect that on average business process costs, travel and training, process development, information technology (IT) operational and maintenance costs will be approximately $250,000 per state per year. Because many of these costs can be matched at 50% Federal financial participation for a state that has a Comprehensive Child welfare Information System. (CCWIS, formerly SACWIS), we are estimating a cost burden of $125,000 per state per year (or $62,500 for each of the two responses per year). We do not expect that reporting for NYTD will require the purchase of additional hardware or other capital equipment. For IT system changes, the main costs are in software development and/or modification. We characterize these costs as minor, but we are aware of the impact the cost of implementation has on states. During the rule-making process, we received comments from states regarding anticipated start-up and annual costs that indicated our estimates are accurate. We are not estimating any other cost burden associated with the Youth Outcome Survey instrument because we are not estimating any costs to respondent youth and because costs associated with a State collecting survey data is captured as part of other IT system development costs in the Data File instrument (as shown below*).


Estimates of other total annual cost burden for reporting.


We recognize that the reporting and record keeping burden is disproportionately higher for small states because they need to develop the same functionality as large states regardless of the number of youths reported. State costs are not affected by the number of youths in the reporting population or the number of reporting periods. We also recognize that county-administered states may face more challenges in implementation but see no need to change our cost burden estimates. Each state will have different costs depending on their populations of youth and the changes required in their information systems and business procedures to meet the requirements in the regulation.



  1. Annualized Cost to the Federal Government

A federal NYTD system was developed and implemented in 2011 to receive, process and store NYTD data submitted by states. This system has since been modernized to support our state users in meeting their regulatory requirement to collect and report data and to increase federal staff capacity to manage the collection process. Currently, it is estimated to cost the federal government $2 million dollars annually, to fully staff and operate the entire NYTD enterprise system. These costs are associated with hosting NYTD on an AWS cloud-based platform and maintaining system related security protocols, such as the Authorization to Operate and Zero Trust Score Cards. Federal cost to the government is the contract is calculated by using the current estimated contract award amount per year.




  1. Explanation for Program Changes or Adjustments

We are not proposing any material changes to the collection instruments, instructions, or to the uses of the information collection currently approved by OMB. However, we are making minor adjustments to the burden hours to reflect the use of historic data to arrive at a more accurate depiction of effort.



  1. Plans for Tabulation and Publication and Project Time Schedule

We make annual NYTD data reports available on the Children’s Bureau website at https://acf.gov/cb/data-research/data-and-statistics-nytd. We generally issue these reports in October following the fiscal year that is the subject of the data brief. The purpose for this lag time is to allow states the option to resubmit corrected/updated data from the prior year as allowed in 45 CFR 1356.85(e)(1). NYTD data sets also are publicly available to researchers at our National Archive on Child Abuse and Neglect (NDACAN) at https://www.ndacan.acf.hhs.gov/datasets/datasets-list-nytd.cfm.



  1. Reason(s) Display of OMB Expiration Date is Inappropriate

As in prior information collection requests, we are requesting that the OMB number and expiration date not be displayed for the NYTD Data File as these files will be transmitted electronically to ACF. (Please note that we do currently post the OMB number and expiration date on the web portal states use to submit the NYTD file). We also request that the OMB number and expiration date not be displayed on the NYTD Youth Outcome Survey. While we chose to regulate the survey questions and response options in the Youth Outcome Survey, there is no specified form or format in which states must administer the survey to youth.



  1. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification statement.





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