OPRE OMB Clearance Manual

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Resource Guides for
Discretionary Grant Programs within the Office of Refugee Resettlement’s (ORR’s) Division of Refugee Services (DRS)


Formative Data Collections for Program Support

0970 – 0531


Supporting Statement
Part A - Justification
March 2023

Submitted By:
Office of Refugee Resettlement (ORR)
Administration for Children and Families 
U.S. Department of Health and Human Services

4th Floor, Mary E. Switzer Building
330 C Street, SW
Washington, D.C. 20201



A1. Necessity for the Data Collection
The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services (HHS) seeks approval for the collection of data and feedback, from recipients of discretionary grant program funds within ORR’s DRS, to improve the quality of training and technical assistance (T/TA) delivery provided to recipient organizations nationwide. Moreover, the collected data and feedback would serve to facilitate the implementation of approved grant activities, as stipulated within corresponding Notices of Funding Opportunities (NOFOs), and it would also streamline internal processes, reduce administrative burdens, and consolidate resources for circulation amongst recipient networks. 

Background 
As stipulated by the NOFOs for each DRS discretionary grant program, recipient organizations must create and maintain certain documents, such as intake and enrollment forms, T/TA logs, policies and procedures documents, business plans, etc., for reporting and monitoring purposes, identifying organizational T/TA needs, ensuring the ORR-eligibility of served clients, and verifying programmatic progress.

While standardization of these forms would prove challenging, particularly due to the regional and population-specific needs of ORR-eligible populations, many of their elements are similar across programs, and samples or templates of these documents could be shared with new and existing recipient organizations to prevent duplicative efforts, improve existing data collection methods, increase programmatic performance within the guise of ACF/HHS’s information collecting requirements, and reduce the administrative burden on recipient organizations. 

Additionally, to improve programmatic efficacy and relevance to served populations, recipient organizations are encouraged to share information about best practices with one another at their respective annual workshops, which are required grant activities. However, recipient organizations have also indicated the usefulness of this information and have often requested additional guidance to enhance the efficacy of their programs. 

As a result of the aforementioned factors, DRS' Program Officers (POs) are proposing a voluntary, one-time per project cycle gathering of templates, forms, and best practices to create resource guides for circulation amongst recipient organizations within DRS' discretionary grant programs, as doing so would ultimately increase the efficacy of the administration of Federal funds in serving newly arrived, ORR-eligible populations across the United States.

Legal or Administrative Requirements that Necessitate the Collection 
There are no legal or administrative requirements that necessitate the collection. ACF is undertaking the collection at the discretion of the agency.


A2. Purpose of Survey and Data Collection Procedures
Overview of Purpose and Use

This proposed information collection meets the following goals of ACF’s generic clearance for formative data collections for program support (0970-0531): 
    • Delivery of training or technical assistance (TA) and/or workflows related to program implementation or the development or refinement of program and grantee processes. This could include the development and refinement of recordkeeping or data gathering systems.
    • Planning for provision of programmatic or evaluation-related T/TA.
    • Obtaining feedback about processes and/or practices to inform ACF program development or support.
    • Requesting information about resources, programs, or other ACF services or related activities to provide consolidated public sources of information for those using or interested in ACF funded services, or those interested in systems, programs, or research related to ACF. 

Processes for Information Collection 
If approved, DRS' POs would disburse a brief questionnaire, containing four broad questions to encourage the sharing of relevant, program-related information and resources, via email and request the voluntary, one-time per project period participation of discretionary grant recipient organizations. Respondents would receive a disclaimer about the intended use(s) and circulation method(s) of the gathered data, and they would be informed that the sharing of PII is prohibited. Responses would be sent back to the POs via email, and if requested, the recipient organizations’ identities will be kept private.

A3. Improved Information Technology to Reduce Burden
If approved, the questionnaires would be sent to recipient organizations via email, and then they would be returned to the respective POs via email as well. 


A4. Efforts to Identify Duplication
The referenced templates and best practices are not always shared or received through required reports and/or Non-Completing Continuation (NCC) submissions. As a result, the proposed questionnaire, along with any sample templates that may be forwarded, would provide critical information that could improve the efficacy of DRS' discretionary grant programs.

A5. Involvement of Small Organizations
Responses are voluntary and unnecessary burden on recipient organizations is not anticipated.

A6. Consequences of Less Frequent Data Collection
If approved, this would be a voluntary, once-per-project period data collection. This frequency would allow ORR to periodically update the guides with information that is current and relevant to recipient organizations.

A7. Special Circumstances
There are no special circumstances for the proposed data collection efforts.


A8. Federal Register Notice and Consultation
Federal Register Notice and Comments
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 request to extend approval of the umbrella generic with minor changes. The notice was published on January 28, 2022, (87 FR 4603), and provided a sixty-day period for public comment. ACF did not receive any comments on the first notice. A second notice was published, allowing a thirty-day period for public comment, in conjunction with submission of the request to OMB. ACF did not receive any comments on the second notice.

Consultation with Outside Experts
No consultations have taken place outside of the project team.


A9. Tokens of Appreciation for Respondents
No tokens of appreciation for respondents are proposed for this information collection.

A10. Privacy of Respondents
Information collected will be kept private to the extent permitted by law. Respondents will be informed of all planned uses of data, that their participation is voluntary, and that their information will be kept private if they do not give consent for their information to be shared or attributed to them. Additionally, no PII will be collected or shared.

A11. Sensitive Questions
There are no sensitive questions in this data collection.

A12. Estimation of Information Collection Burden
Burden Estimates
The estimated burden in responding to the questionnaire is 40 minutes. The burden was calculated by estimating the length of time it would take to answer four, short answer questions and identify resources to share with the respective DRS PO. More specifically, the four questions can be answered with a short narrative response, and we anticipate a program or program manager/coordinator to complete the questionnaire.

Cost Estimates
The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for [11-9151] and median wage data from May 2021, which is $35.58 per hour. To account for fringe benefits and overhead the rate was multiplied by two which is $71.16.  
https://www.bls.gov/oes/current/oes_stru.htm 

Instrument
Total Number of Respondents
Total Number of Responses Per Respondent
Average Burden Hours Per Response
Total
Burden Hours
Average Hourly Wage
Total Annual Cost
Questionnaire 
171
1
.667
114
$71.16
$8,112.24


A13. Cost Burden to Respondents or Record Keepers
There are no additional costs to respondents.


A14. Estimate of Cost to the Federal Government
The total cost for the data collection activities under this current request will be approximately two hours of staff time, or $44.75 at the GS13 level, for seven discretionary grant programs, which would equal $626.57.  


A15. Change in Burden
This is for an individual information collection under the umbrella formative generic clearance for program support (0970-0531).


A16. Plan and Time Schedule for Information Collection, Tabulation and Publication
Over the next 12 months, ORR will send these questionnaires to past and current grantees, review information collected, and develop program guides, which will be shared with current and future program recipients.

A17. Reasons Not to Display OMB Expiration Date
All instruments will display the expiration date for OMB approval.


A18. Exceptions to Certification for Paperwork Reduction Act Submissions
No exceptions are necessary for this information collection.	

Attachments
Instrument 1: ORR Program Guide Development Questionnaire
Appendix A: Outreach Email