PPR Supporting Statement – Attachment 5
SF-PPR Comments Received and Resolved
Row # |
Agency Comment |
Source |
Commenter |
Resolution |
1 |
This is to request that a "supplemental" cover page be added to the SF-PPR as an optional form so that we can include additional questions about the grantee organization and its staff in the Performance report. Some of these should include standard formats and objects such as "Person Name", "Address", "Phone Number", "Email addresses". These are included on some of our existing OMB-cleared performance reports and we use this as a way to update grantee organization and staff contact information. Some examples of those types of additional fields are listed below:
Organization’s Fax number Website Address Toll-free Phone Toll-free TTY Number Executive Director Name Program Director/Coordinator Name President of Board of Directors (BoD) Name, Address, Phone, Fax number, E-mail Chair of Advisory Council Name and Address Satellite Office(s) (SOs) Contact Name and Address Contractor Name, Address, Phone, Fax, Email Person to contact regarding report: Name and Phone
Please allow 20 to 30 additional lines on the supplemental cover page for information about the grantee organization and staff contact information that does not directly relate to the performance of the grant project. |
HHS ACF |
J. Dionne |
Agree.
SF-PPR Continuation page added for additional information relating to the grantee organization or grant project. |
2 |
The Health Resources and Services Agency (HRSA), an operating component under the U.S. Department of Health and Human Services, has the following comments on the proposed SF-PPR, Performance Progress Report: GLOBAL A major concern is whether the use of this form would be mandated for all agency programs. The consensus at HRSA is that it should not be mandated. Various agency programs have established performance measurement reporting requirements with which grantees must comply with as the reporting requirements are mandated in statute. In some cases the data is collected using electronic data reporting systems. These systems collect data not necessarily captured by the proposed reporting forms, nor in the same format. |
HHS HRSA |
C. Bish |
These formats are proposed for government-wide use. At this time, they are not required. The current clearance is for voluntary participation in pilots, electronic or other.
If used, the only required form is the cover page. All other forms/formats (A through F) are optional. SS-PPR-A through E are formats that are intended to accommodate agency-specific or program-specific questions and information collection needs.
|
3 |
In other cases, some of the requested data proposed for collection in the new forms would be duplicative of the information already being collected. These systems have been developed at great cost and provide the grantees with a uniform and expedient means of conveying the information electronically to the agency, while at the same time satisfying Congressional mandates and other agency and Departmental reporting requirements. |
|
|
These formats are not intended to immediately replace existing collections. They are intended, however, to begin to propose standard formats for collection of same and similar information as we move toward full electronic collection and as existing collections undergo future clearances. |
4 |
In addition, once data is inputted and transmitted to the agency using these systems, the current reporting systems enable programs ready access to the data and the ability to run various reports based on querying capabilities that were developed to address specific audience needs.
HRSA believes that if the form is mandated, it will be burdensome on the grantee and duplicative in many cases as HRSA would still need the data provided by the other more established and specifically tailored reporting systems/requirements. Additionally, some information is already reported back to the agencies which incrementally fund grants when the grantee reports on its progress in its non-competing continuation applications or it competing renewal applications. In some cases, requiring this form in addition to other required reporting would increase a grantee’s administrative expenses which for some programs are legislatively capped. |
HHS HRSA |
C. Bish |
Information from these collections can go into existing or future electronic databases and be used in existing (or future) reports and queries.
Over time, this could replace existing collections and relieve grantees of some burden by providing standard electronic instruments and collection mechanism across Federal agencies and programs.
Data on an electronic SF-PPR form could easily be pre-populated on a continuing grant report from existing databases using pre-award or award information. |
5 |
Additionally, it should be noted that the requested information in the proposed forms would be inadequate for use in some programs to assess a grantee’s progress and determine if continued funding was warranted. Also, it is unlikely that the proposed requested data will satisfy or crosswalk with some programs’ specific project measures and goals specific to the actual grant, program specific measures and goals which address core measures and goals that meet the Department and Agency goals. |
HHS HRSA |
C. Bish |
As stated above, agency-specific and program-specific requirement and questions can be supported in one or more formats A through E. |
6 |
HRSA does not believe that the proposed forms and electronic submission of data through Grants.gov would permit the type of data access and reporting capacities that agencies need to report on program performance measures or other grantee information that are required in some instances. |
HHS HRSA |
C. Bish |
The initial electronic pilots are intended to be done in conjunction with GMLoB consortia efforts, not specifically Grants.gov. Post-award reporting does need ties with back-office databases for pre-population and validation.
|
7 |
HRSA has concerns similar to those posed with the combined financial reporting form pertinent to the quarterly reporting requirements based on the calendar year versus the actual quarterly cycle established by the award issuance date which may not coincide with calendar quarters. Mandating reporting on such a basis will be problematic both for the grantee and the awarding agency. HRSA sees no meaningful benefit to be gained from this requirement. |
HHS HRSA |
C. Bish |
At this point there is no policy for timing and usage of these report formats in association with the clearance for voluntary electronic pilots.
Reporting based on calendar quarters is proposed for the SF-FFR and SF-PPR forms/formats. Separately comments will be solicited before policy is established, but not for this pilot. For pilot collections agencies will specify their reporting frequency and due dates. |
8 |
Of particular concern is the proposal for form PPR-E requiring reporting of expenditures on the basis of activities. HRSA believes this would require very careful scrutiny by OMB to determine whether the benefit of such reporting warrants the added cost to the grantee for identifying and aggregating financial information in that manner unless there is already a pre-existing requirement for the grantee to do so. |
HHS HRSA |
C. Bish |
An agency would only use SF-PPR-E when they already have OMB-clearance to collect cost by activity.
Forms and formats A through F are optional collections. |
9 |
HRSA believes the forms, if approved, should be optional only and directed towards use by programs which do not have any satisfactory reporting process/requirements in place to capture the range of information covered by the various reporting under the PPR format. |
HHS HRSA |
C. Bish |
We agree that most of these collection forms/formats are optional. In the proposed policy, if adopted, the only required form is the cover page.
If adopted, the other forms and formats are intended to be utilized with existing and future OMB clearances. That can include agency-specific and program-specific question and data but only in formats A through F. |
10 |
SPECIFIC: If the forms ultimately are approved for agency use and/or become a requirement the following comments and suggestions are provided:
|
HHS HRSA |
C. Bish |
We agree. Agency-specific and program-specific instructions should be available and should be made electronic. |
11 |
|
HHS HRSA |
C. Bish |
Currently there is no OMB policy regarding research performance reporting. There is a separate draft set of questions (that could fit into these formats) for research reporting.
Since there is no specific definition of research, these forms could be used by an agency as an option |
12 |
|
HHS HRSA |
C. Bish |
These are intended to be used electronically. |
13 |
|
HHS HRSA |
C. Bish |
Same as answer #8. Not required.
If agency has OMB-cleared need to collect activity based budget AND collects the same information at time of application, then electronic mechanisms can pre-populate that information as a starting point. |
14 |
|
HHS HRSA |
C. Bish |
Correct. Form E allows this projection. Form D could also be used for some levels of projection if additional columns are needed. |
15 |
|
HHS HRSA |
C. Bish |
Agencies may provide additional instructions instead of or in addition to the instructions written. |
16 |
|
HHS HRSA |
C. Bish |
Both are not intended to be used at the same time unless they fit current collection formats. |
17 |
|
HHS HRSA |
C. Bish |
These are intended to be used electronically with pre-population capabilities. |
18 |
|
HHS HRSA |
C. Bish |
We have added a supplemental page to the cover page to allow types of questions such as the check box asking a question. |
19 |
|
HHS HRSA |
C. Bish |
All agency-specific or program-specific questions will still need to seek OMB clearance and provide burden hours. The intent, however, is that when the SF-PPR is adopted along with revised policy, those agency-specific clearances would be expedited if using the standard forms and formats. |
20 |
|
HHS HRSA |
C. Bish |
Yes, drop down customization can be provided as part of electronic implementation. Yes, clearance would be required (see answer #19) |
21 |
|
HHS HRSA |
C. Bish |
The abstract is on the cover page as a “narrative”, and can be attached. This would not require additional OMB clearance unless the specifications for the narrative became too extensive, restrictive or burdensome. |
22 |
|
HHS HRSA |
C. Bish |
The intent is to require collection for all grants except those in special exempt categories that might need to be protected by the privacy act or national security interests. The policy is not part of this current clearance. |
23 |
|
HHS HRSA |
C. Bish |
The policy is not part of this clearance, however, the intent is that small dollar amount grants would not be required unilaterally to report, but that an agency could still have the option to impose such a requirement. |
24 |
|
HHS HRSA |
C. Bish |
The intent in this regard is for the awarding agency to make the determination of what is required to be submitted and what is optional. |
25 |
Other Comments/Concerns
|
HHS HRSA |
C. Bish |
Not clear what network information is required for reporting by a grantee or grant project. Federal identifiers are provided and might be possibly used for this purpose. |
26 |
|
HHS HRSA |
C. Bish |
SF-PPR-A, SF-PPR-B, and SF-PPR-C are not intended to all be used at the same time. They can be considered subsets of one another with A being middle, B being the most simple and C being the most complex. They would only be used if an agency had a need to collect different types of information in varying degrees of complexity. |
27 |
|
HHS HRSA |
C. Bish |
SF-PPR-D is provided so that information can be collected in a tabular fashion where there may be a relationship between values in the same row and column. It is also provided for collections where a large amount of comparative data is needed. |
28 |
|
HHS HRSA |
C. Bish |
The intent of these instruments is to be implemented electronically. If filed and maintained electronically and reporting data requested is consistent over reporting periods, then database reports or data validation business rules can be installed to note where monies over different reporting periods have been moved or exceed certain noted business thresholds. |
29 |
|
HHS HRSA |
C. Bish |
Use of the SF-PPR-F is optional.
SF-PPR-F would only be used if an agency wished to include grantee input into their P.A.R.T. response. The Yes/No answers were developed so that the information could be aggregated. The explanation was included so that if there was non-compliance or problem performance, it could be noted, and could serve as a checklist during site reviews. In general, we find grantees to be truthful. In fact, this should be perceived as an opportunity to solicit assistance from the awarding office if, in fact, there are any problems. |
30 |
In response to the Federal Register document #07-1676, Proposed Information Collection Activity entitled, “Performance Progress Reports”, the Substance Abuse and Mental Health Services Administration (SAMHSA) would like to make the following comments:
|
HHS SAMHSA |
S. Griffith |
These formats are proposed for government-wide use. At this time, they are not required. The current clearance is for voluntary participation in pilots, electronic or other.
If used, the only required form is the cover page. All other forms/formats (A through F) are optional. SS-PPR-A through E are formats that are intended to accommodate agency-specific or program-specific questions and information collection needs. |
31 |
|
HHS SAMHSA |
S. Griffith |
We agree that individual case-data, or client-data, should not be considered to be performance/progress reporting. However, when client-level or case-level data is reported in aggregate or as summary data, it should be done using whatever PPR format is most appropriate.
Thank you for noting that this needs to be included in any policy guidance. |
32 |
|
HHS SAMHSA |
S. Griffith |
This clearance is for initial voluntary electronic pilots only. If the proposed forms and accompanying policy is adopted for government-wide usage and standardization, the intent is to phase out other cleared collections over time and to standardize new OMB-cleared performance and progress reporting instruments and programmatic surveys by having agencies use the SF-PPR formats. |
33 |
|
HHS SAMHSA |
S. Griffith |
We disagree, that in the future there may be value in collecting some aggregated common data across agencies and programs. |
34 |
|
HHS SAMHSA |
S. Griffith |
Use of the SF-PPR-F is optional.
SF-PPR-F would only be used if an agency wished to include grantee input into their P.A.R.T. response. The Yes/No answers were developed so that the information could be aggregated. The explanation was included so that if there was non-compliance or problem performance, it could be noted, and could serve as a checklist during site reviews.
The half hour is intended to only be the time to fill the SF-PPR-F. The data collection effort is not included in this estimate and should be part of normal grant operations.
|
35 |
SAMHSA appreciates the opportunity to comment on the proposed data collection activity. If there are questions about these comments, please contact Ms. Suzanne Fialkoff in SAMHSA’s Office of Policy, Planning and Budget. |
HHS SAMHSA |
S. Griffith |
No response needed. |
File Type | application/msword |
Author | fhenry |
Last Modified By | elizabethP |
File Modified | 2007-08-21 |
File Created | 2007-08-21 |