Instructions for writing Supporting Statement A

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Supporting Statement A

Delta States Rural Development Network Grant Program,
OMB Control No. 0915-0386

Terms of Clearance: None 

A.	Justification
    1. Circumstances Making the Collection of Information Necessary
The Health Resources and Services Administration (HRSA)’s Federal Office of Rural Health Policy (FORHP) is requesting OMB approval to collect grantee level performance data for the Delta States Rural Development Network Grant Program (Delta). This program is authorized by the Public Health Service Act, Section 330A(f) (42 U.S.C. 254c(f)). The Delta Program supports projects that demonstrate evidence based and/or promising approaches around cardiovascular disease, diabetes, acute ischemic stroke, or obesity in order to improve health status in rural communities throughout the Delta Region. Key features of Delta Program-supported projects are collaboration, adoption of an evidence-based approach, demonstration of health outcomes, program replicability, and sustainability. 
HRSA currently collects information from Delta Program award recipients using an OMB-approved set of performance measures. These measures last received OMB review and approval under OMB Number 0915-0386 and have a current expiration date of July 31, 2026.
HRSA seeks to revise that approved collection. The changes are a result of keeping the instrument relevant and responsive to the Delta Program’s needs. The main revisions to the current collection are displaying race and ethnicity as two separate questions and updating the total burden hours.
    2. Purpose and Use of Information Collection
The purpose of the data collection is for HRSA to assess Delta Program awardees' progress in meeting the program goals, and how well each awardee meets their community needs. Additionally, HRSA will be able to monitor and assess the impact of the Delta Program and ensure funds are effectively used to provide services that meet the target population's needs. Delta awardees will submit annual performance reports to HRSA through this data collection. These performance measures may be used for the report to Congress required under 42 U.S.C. 254c(i).
The Delta performance measures will cover the following topic areas: A) access to care; B) population demographics; C) sustainability; D) health promotion/disease management; E) mental/behavioral health; F) oral health; G) childhood obesity and H) clinical measures.
If the Delta Program cannot collect this information, HRSA and FORHP would not be able to do the following:
    • comprehensively and adequately monitor grantee progression of grant goals and activities related to improving and expanding delivery of health care services in rural communities throughout the Delta region;
    • understand how grant funds are impacting access to care or being utilized to serve the grantee’s target population as described in their application; and
    • measure the success and impact of the Delta Program’s overall objectives.
    3. Use of Improved Information Technology and Burden Reduction
This information collection is fully (100 percent) electronic. HRSA will be using a web-based secured platform to house the data collection instrument as well as allowing Delta awardees to electronically submit their data to HRSA.
    4. Efforts to Identify Duplication and Use of Similar Information
There are no other information/data collections currently available for the Delta program.
    5. Impact on Small Businesses or Other Small Entities
This data collection will not have a significant impact on small business entities. The information being requested by Delta awardees has been held to the minimum required for the intended use of the data.
    6. Consequences of Collecting the Information Less Frequently
Delta awardees will respond to this data collection annually during their project period. HRSA needs this information annually in order to:
    • comprehensively and adequately monitor grantee progression of grant goals and activities related to improving and expanding delivery of health care services in rural communities throughout the Delta region;
    • understand how grant funds are impacting access to care or being utilized to serve the grantee’s target population as described in their application; and
    • measure the success and impact of the Delta Program’s overall objectives.
There are no legal obstacles to reduce the burden.
    7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
The request fully complies with the regulation.
    8. Comments in Response to the Federal Register Notice/Outside Consultation
Section 8A:
A 60-day notice published in the Federal Register on March 18, 2026, vol. 91, No. 52; pp. 13041 - 13042.  There were no public comments.
A 30-day notice published in the Federal Register on June 12, 2026, vol. 91, No. 113; pp. 35692 - 35693.  
Section 8B:
HRSA consulted with four current Delta awardees in 2026 to assess the burden of this data collection.
    9. Explanation of any Payment/Gift to Respondents
Respondents will not receive any payments or gifts.
    10. Assurance of Confidentiality Provided to Respondents
No Personally Identifiable Information (PII) is collected under this OMB control number; all data is organizational-level data. Data will be kept private to the extent allowed by law.
    11. Justification for Sensitive Questions
HRSA will be collecting race/ethnicity data at an aggregate level. The purpose is to ensure that Delta grant projects funded with federal dollars are meeting the needs of the population served. 
    12. Estimates of Annualized Hour and Cost Burden  
12A.        Estimated Annualized Burden Hours

The number of respondents is based on the number of current Delta awardees. The number of responses per respondent is one because Delta grantees will submit the data once a year. The estimated average burden hours per response was determined by consulting four current Delta grantees. They were asked to estimate how much time it would take to review the instructions; processing and maintaining information; training personnel to be able to collect the information; search existing data sources, gather and maintain the data needed, and complete and review the collection of information. An average of the four estimates were calculated to determine the average burden response.
12B.  
Estimated Annualized Burden Costs
Type of
Respondent

Total Burden
Hours

Hourly
Wage Rate (x2)

Total Respondent Costs

Project Director
873 
$98.38
$85,885.74
Total
873
$98.38
$85,885.74
To estimate the hourly wage for a Project Director, HRSA used the most recent data from the Bureau of Labor Statistics.  The chosen occupation is Project Management Specialists (SOC Code 13-1082), as this category most accurately reflects the coordination of budgets, schedules, and staffing that is typical of grant project directors.   
    • Source:  Overview of BLS Wage Data by Area and Occupation: U.S. Bureau of Labor Statistics 
    • Median Hourly Wage: $49.19 
    • Locality Adjustment: The Median hourly rate is used as opposed to adjusting for locality, since award recipients are spread across the country. 
    • Overhead/Benefits:  Wage has been doubled to account for overhead costs.  
    13. Estimates of other Total Annual Cost Burden to Respondents or Recordkeepers/Capital Costs
Other than their time, there is no cost to respondents.
    14. Annualized Cost to Federal Government
The data collection platform is maintained through an information technology (IT) contract at the HRSA level. The initial build-out cost attributable to the Delta program is estimated at $37,260. In subsequent years, costs are projected at $37,260 annually to support ongoing maintenance and system enhancements.
The estimated annual cost for Federal staff to perform data analysis, reporting, program monitoring, and recipient support cost of $6,302.16 per year. This cost is estimated as 72 hours of staff time per year at a GS-13, Step 1 salary level, estimated hourly wage of $58.35 (locality pay is based in the Washington-Baltimore-Arlington area) plus 50% for benefits and fringe ([$58.35 per hour + $29.18 fringe per hour] x 72 hours = $6,302.16).
The Delta program is a multi-year program. Data collection will happen annually for up to three years. The total cost to the Federal Government for this project over a three-year period is $130,686.48 with an average annual cost of $43,562.16.
    15. Explanation for Program Changes or Adjustments
HRSA seeks to revise the currently OMB approved collection. The only substantive change to the collection is modifying how HRSA displays race and ethnicity measures in the data collection platform by making it display as two separate questions for current Delta Program recipients. 
Additionally, the estimated total burden hours have increased to 873 hours, compared to the currently approved 24 burden hours, to reflect the time required for current Delta Program awardees to complete data collection-related training for their internal staff as well as staff within their network partnerships. There are several additional contributing factors to the increase in estimated total burden. These grantee organizations vary in data collection and reporting capacity as well as vary in the number of network organizations they must coordinate with to report this data to HRSA. Furthermore, the grantee organization and its network organizations may not share the same data collection systems/platforms. As a result, this increase in total burden accounts for the time that Delta Program awardees will need to compile and review data quality from its network organizations prior to submitting the data to HRSA.
    16. Plans for Tabulation, Publication, and Project Time Schedule

FORHP does not plan to release a publicly available dataset using this data. Releasing this data would have privacy implications and negatively impact the communities served. FORHP will not publish this data to provide sufficient protection and assurance of full confidentiality to respondents and participants. Aggregate data is also used to assess the progress and success of this program. The information is accessible to the grantees as the data relates to them. 

This is a recurring data collection that program recipients report once a year. We are requesting clearance of this information collection for the next three years. The next reporting period is scheduled for Summer 2026.
 
This information collection will not use statistical methods such as sampling, imputation, or other statistical estimation techniques.
    17. Reason(s) Display of OMB Expiration Date is Inappropriate
The OMB number and Expiration date will be displayed on every page of every form/instrument.
    18. Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification.