NonSub Change Request - October 2026

Status: Original and derived artifacts are available for this document.

Download: docx | pdf | html

To:	Kelsi Feltz
Office of Information and Regulatory Affairs (OIRA)
Office of Management and Budget (OMB)

From:	Jessica Hale
Office of Community Services
Administration for Children and Families (ACF)

Date:	October 23, 2026

Subject:	NonSubstantive Change Request – Medical-Legal Partnerships Semi-Annual Quantitative Report (OMB# 0970-0490)


This memo requests approval of nonsubstantive changes to the Medical-Legal Partnerships Semi-Annual Quantitative Report, which is approved under the Administration for Children and Families Generic for Program-Specific Performance Progress Reports, OMB #0970-0490.

Background
The Office of Community Services uses the Medical-Legal Partnerships Semi-Annual Quantitative Report, or MLP SAR, to collect quantitative performance information from the eight Medical-Legal Partnerships Plus grant recipients. The report supplements narrative reporting on project progress by collecting information on service delivery, including referral and intake activity, cases managed and legal matters addressed, partnerships supporting service delivery, and events carried out with grant funds. The report also includes information from grant recipient administrative data on client characteristics and case outcomes to support program monitoring, technical assistance, and learning about the demonstration program. 

This summer, OCS invited current MLP+ grant recipients to apply for supplemental funding to extend their projects through September 2027. In that invitation, OCS noted that grant recipients should provide characteristics and outcomes data where available to support more robust reporting during the extension period. All eight current grant recipients applied for and received supplements.

OCS circulated a proposed revised version of the MLP SAR and met with the eight grant recipients to discuss the feasibility of the proposed approach. The revised form reflects grant recipient feedback, including clarifications to the Direct Services and Legal Services tabs, revisions to the Social Service Referrals tab to acknowledge limitations in reporting service-type-level referral counts, and revised language and accounting for the Outcomes tab. During this process, OCS also learned that some grant recipients may be able to provide more complete information if they request administrative data from partners. As a result, OCS updated the submission template to include time for partner organizations to provide information as needed to support grant recipient reporting. OCS circulated a newly revised draft to grant recipients and did not receive further requests for revision or clarification.

Overview of Requested Changes
OCS proposes nonsubstantive revisions to the MLP SAR to improve clarity, feasibility, and consistency of reporting across the eight MLP+ grant recipients. These changes include:

    1. Clarifying Direct Services reporting instructions.
The Direct Services tab has been revised to clarify that grant recipients should generally report the minimum number of known counts, use the Notes columns to document reporting challenges, and report the number of individuals not receiving services using a consistent definition and formula.

    2. Clarifying Legal Services case definitions.
The Legal Services tab has been revised to provide definitions for recording and reporting cases, so grant recipients can report these items consistently across projects.

    3. Revising the Social Service Referrals tab to better align with available administrative data.
The Social Service Referrals tab has been revised to acknowledge that some grant recipients may not be able to provide counts by specific service type. The revised tab makes service type column optional, allowing grant recipients to instead describe service types associated with a referral category in the Notes column.

    4. Revising the Outcomes tab to improve feasibility and consistency.
The Outcomes tab has been revised to better align with grant recipient recording of case outcomes by simplifying the successful/partially successful breakdown to simply report whether a specific objective is achieved for a case, the number of cases that achieved an objective in that category, and the total number of cases in that category for which the outcome of the case is known. Additionally, the discussion with grant recipients yielded a request for an additional optional column to track objectives for cases only receiving brief services so that grant recipients could report on all cases during the extension period, not just cases receiving extended services. 

    5. Revising the Characteristics tab to support reporting where data are available.
The Characteristics tab has been revised to request information for focal clients in MLP+ cases closing during the reporting period. The revised instructions clarify that if administrative data do not support reporting the requested information, grant recipients should use the “Unknown” categories and Notes columns as needed. This change supports more complete reporting while acknowledging variation in grant recipient data systems.

    6. Updating burden estimates to account for partner-provided administrative data.
The submission template has been updated to reflect that, in some cases, grant recipients may ask partners to provide administrative data for some data elements to supplement grant recipient data. The estimated burden for grant recipients remains 8 hours per response, with 8 grant recipients reporting twice per year, for 128 annual burden hours. The revised submission template adds an estimated 1 hour per response for partner organizations, with 8 respondents reporting twice per year, for 16 additional annual burden hours. The total annual burden estimate is therefore 144 hours.

These revisions do not change the purpose of the information collection, the semi-annual reporting frequency, or the core respondent group of eight MLP+ grant recipients. The information will continue to be used for program improvement, accountability, program management, support, oversight, identifying technical assistance needs, and informing refinements to program activities and supports. No personally identifiable information will be collected, and all information will continue to be reported in aggregate at the grant recipient level.

OCS believes these revisions are nonsubstantive because they clarify reporting instructions, improve alignment with available administrative data, and support more consistent and complete reporting across grant recipients without changing the fundamental purpose or scope of the collection.

Timing Sensitivities
Although the next MLP SAR submission is not due until April 30, OCS hopes to roll out the revised form and instructions to grant recipients in a timely manner near the start of the next reporting period on October 1. Providing the updated materials early will give grant recipients and, where applicable, partner organizations adequate time to adjust recordkeeping practices, coordinate administrative data-sharing processes, and track information consistently throughout the reporting period.