Supporting Statement A

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	Guidance for the Tribal Temporary Assitance for Needy Families (TANF) Program


OMB Information Collection Request
0970 – 0157


Supporting Statement Part A - Justification

July 2026


Type of Request:  Revision











Submitted By:
Office of Family Assistance 
Administration for Children and Families 
U.S. Department of Health and Human Services







    1. Circumstances Making the Collection of Information Necessary 
42 U.S.C. 612 (section 412 of the Social Security Act) requires each Indian tribe that elects to administer and operate a TANF program to submit a Tribal Family Assistance Plan (TFAP).  The TFAP is a mandatory statement submitted to the Secretary by the Indian tribe, which consists of an outline of how the Indian tribe's TANF program will be administered and operated.  It is necessary for the Secretary to determine whether the TFAP is approvable and to determine that the Indian tribe is eligible to receive a TANF assistance grant.  It is also made available to the public.  Requirements for the content of the TFAP can be found in the Code of Federal Regulations at 45 CFR 286.70.

The Guidance has been revised for clarity, utilizing plain language edits, and to ensure that only necessary information is included. 

    2. Purpose and Use of the Information Collection 
The information has been used and will continue to be used to assist Tribes in obtaining approval of their TFAPs so that they can operate a TANF program and serve their populations.  Because Tribes have great flexibility in designing their TANF programs, the TFAP establishes what those flexibilities are, sets the allowable uses of the grant, establishes work participations rates, and provides the measures for each program’s success.  The plan elements are mimicked in the annual reports, which inform the Annual Report to Congress.

    3. Use of Improved Information Technology and Burden Reduction 
An Indian tribe may prepare the TFAP in Microsoft Word or other Word processing software.  Tribes are required to submit TFAPs via the Online Data Collection system (OLDC). Interim drafts may be submitted via email to reduce the submittal burden. Reviewer comments are also provided to the tribe via email.  

    4. Efforts to Identify Duplication and Use of Similar Information 
No similar or duplicate information is available.

    5. Impact on Small Businesses or Other Small Entities 
This collection of information does not impact small businesses or other small entities.  

    6. Consequences of Collecting the Information Less Frequently 
The Indian tribes will only be required to respond to this information collection once every three years. Without this information, TFAPs cannot be approved and therefore, Tribes would be unable to operate TANF programs and serve their populations.

    7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5 
This collection of information does not involve any special circumstances.

    8. 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), the Administrations for Children and Families (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 May 14, 2026 (91 FR 27351) and provided a sixty-day period for public comment.  We received one comment. OFA appreciates the comments, but has not made any changes to the information collection as a result because they were broadly related to the Tribal TANF program and not specific to the information collection. 

    9. Explanation of Any Payment or Gift to Respondents 
No payments and/or gifts will be given to respondents.

    10. Assurance of Confidentiality Provided to Respondents 
This data collection does not constitute a Privacy Act System of Records and no assurance of confidentiality is needed.

    11. Justification for Sensitive Questions 
This data collection does not contain any questions of a sensitive nature.

    12. Estimates of Annualized Burden Hours and Costs 

Information Collection Title
Total Number of Respondents
Annual Number of Responses Per Respondent
Average Burden Hours Per Response
Annual Burden Hours
Average Hourly Wage
Total Annual Cost
Guidance for Tribal Temporary Assistance for Needy Families
77
1/3
45.6
1,170.4
$43.86
$51,333.74

Estimated Burden Hours
The Respondents are continuing Tribal TANF Programs or those who are applying to become Tribal TANF programs. The number of respondents has increased, to reflect current grant recipient numbers. As TFAPs come up for renewal every three years, approximately one third of programs renew their TFAP every year. The guidance has been edited for clarity and to ensure the only necessary guidance is included, reducing the estimated time per response from 68 hours to 45.6 hours.  This reduction was established using artificial intelligence to evaluate time savings expected based on the significantly shorter length and greater clarity of Guidance reducing reading time and simplifying and easing the burden needed to thereby respond.

Estimated Cost to Respondents
The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for Social and Human Services Assistants [21-1093] and wage data from May 2025 which is $21.93 per hour (mean hourly wage). To account for fringe benefits and overhead the rate was multiplied by two, which is $43.86.  https://www.bls.gov/ooh/community-and-social-service/social-and-human-service-assistants.htm   

    13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers 
There are no other costs to respondents.

    14. Annualized Cost to the Federal Government 
We estimate total annual cost to the federal government to be $132,282.72. This includes the costs of information collection, mailing list compilation and maintenance, mailing, editing, analysis, negotiation, publication of results, technical assistance, and monitoring (approximately 1062 hours). Estimated cost is based on an estimated average hourly federal salary of $62.28 per hour (per OPM salary table for GS 11 and up, including base and locality pay), multiplied by 2 to include fringe benefits, or $124.56.   

    15. Explanation for Program Changes or Adjustments 
The Guidance has been edited to be plain language, which has significantly shortened the length of the document, while making the Guidance clearer.  As a result, the estimated time per response has been reduced, as described in section A12. Burden estimates also reflect an increase in the number of agencies, to reflect the current number of grant recipients. 

    16. Plans for Tabulation and Publication and Project Time Schedule 
Much of the information is published in the TANF Annual Report to Congress, which is also posted on the ACF Website.

    17. Reason(s) Display of OMB Expiration Date is Inappropriate 
Not applicable.

    18. Exceptions to Certification for Paperwork Reduction Act Submissions
Not applicable.