1205-0392: SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL
UNDER THE PAPERWORK REDUCTION ACT OF 1995
TABLE OF CONTENTS
SECTION PAGE
A. JUSTIFICATION 2
A.1 Circumstances Necessitating Data Collection 2
A.2 How, by Whom, and For What Purpose the Information is to be Used 3
A.3 Use of Technology to Reduce Burden 3
A.4 Efforts to Identify Duplication 4
A.5 Methods to Minimize Burden on Small Businesses 4
A.6 Consequences of Less Frequent Data Collection 4
A.7 Special Circumstances for Data Collection 4
A.8 Federal Register Notice and Consultation Outside the Agency 4
A.9 Payment of Gifts to Respondents 4
A.10 Confidentiality Assurances 4
A.11 Additional Justification for Sensitive Questions 5
A.12 Estimates of the Burden of Data Collection 5
A.13 Estimated Cost to Respondents 5
A.14 Estimates of Annualized Costs to Federal Government 6
A.15 Changes in Burden 6
A.16 Tabulation of Publication Plans and Time Schedules for the Project 6
A.17 Approval Not to Display OMB Expiration Date 6
A.18 Exceptions to OMB Form 83-I 6
B. Collection of Information Employing Statistical Methods 6
This is a justification for the Department of Labor, Employment and Training Administration’s (ETA) request to extend the existing reporting and recordkeeping requirements for the Trade Adjustment Assistance (TAA) program. This reporting structure features standardized data collection for TAA program participants based on a core set of participant and performance information. This standardized individual record, formally called the Trade Act Participant Report (TAPR), includes information on demographic characteristics, types of services received, and common measures of outcomes defined consistently across state programs.
The accuracy, reliability, and comparability of program reports submitted by states using Federal funds are fundamental elements of good public administration and necessary tools for maintaining and demonstrating system integrity. The use of a standard set of data elements, definitions, and specifications at all levels of the workforce system helps improve the quality of performance information that is received by the Department. The common performance measures are an integral part of ETA’s performance accountability system, and ETA will continue to collect from grantees the data on program activities, participants, and outcomes that are necessary for program management and to convey full and accurate information on the performance of workforce programs to policymakers and stakeholders.
In 2001, the President announced a Management Agenda to improve the management and performance of the Federal government. Budget and performance integration, one of the five government-wide goals, emphasizes program effectiveness. As part of the President’s Management Agenda, the Office of Management and Budget (OMB) and other Federal agencies developed a set of common performance measures to be applied to certain federally-funded employment and training programs with similar strategic goals.
The implementation of common performance measures across Federal job training and employment programs will enhance the government’s ability to assess the effectiveness and impact of the workforce investment system, including the performance of the system in serving individuals facing significant barriers to employment. Multiple sets of performance measures have burdened states and grantees as they are required to report performance outcomes based on varying definitions and methodologies. By minimizing the different reporting and performance requirements, common performance measures can facilitate the integration of service delivery and break down barriers to cooperation among programs.
The common measures are an integral component of the TAA performance accountability system. The value of common measures is the ability to describe in a similar manner the core purposes of the workforce system - how many people found jobs; did people stay employed; and did earnings increase. Standardizing the definitions of the outcomes across programs simplifies reporting, and provides a greater ability to compare and manage results.
ETA’s statutory and regulatory authority to administer job training and employment programs includes provisions allowing for the requirement of performance reporting from states and grantees. The Trade Adjustment Assistance Reform Act of 2002 (P.L. 107-210), as amended by PL No. 110-329, the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, and PL No. 110-161, the Consolidated Appropriations Act, 2008, indicates that each state agency must furnish to the Secretary such information and reports and conduct such studies as the Secretary determines are necessary or appropriate for carrying out the purposes of the Act (20 CFR 617.57 and 617.61).
Attachment A contains a list of the individual data elements collected in the TAPR and the purpose for collecting each item. Information collected and reported is used by State Workforce Agencies (SWAs) and Federal agencies for the following purposes:
To provide program and performance information to stakeholders including participants, businesses, taxpayers, Congress, and others;
To continuously improve the quality, effectiveness, and efficiency of job training and employment programs; and
To provide management information for use in Federal program administration and oversight, including grant-specific participation, service, and outcome summaries. Selected demographic information will also be used by grantees to demonstrate compliance with equal opportunity provisions in the law, and to prepare and maintain state management reports.
To measure compliance with the Government Performance and Results Act (GPRA) and to assess the program using the Administration’s Performance Assessment Rating Tool (PART).
In addition, information obtained through the TAPR is used at the national level during budget and allocation hearings, for DOL compliance with GPRA and other legislative requirements, and during legislative reauthorization proceedings.
To comply with the Government Paperwork Elimination Act, ETA streamlined the collection of program participant data and performance reports to the extent feasible by providing uniform data elements and data definitions to states, and through the use of technology. All TAPR reports are submitted to ETA via the Internet. States and local areas decide the best technology for collecting individual case management data, given their unique circumstances and resource availability. States collect, retain, and report all information electronically.
The use of UI wage records as the primary source of data on wages and employment-related outcomes has resulted in decreased burden hours for many states who administer TAA programs. ETA works with the states to access and exchange UI wage records among the states. ETA is also planning to upgrade existing reporting software for states that will import participant data, check for data errors and out of parameter records, and produce the TAPR in both printable and electronic data transfer formats.
The TAPR is the only report on TAA participants that requires data on individual participants. Except where individuals are registered in other programs, and outcomes are reported for them under those programs, there is no duplication of data. Where participants are reported on under other programs, for example the Workforce Investment Act (WIA) dislocated worker program, standardized data elements such as demographic information, services, and common outcome measures may be easily copied and transferred for use in the TAPR.
No small businesses or entities are impacted.
States and grantees are required to submit TAPR records to ETA electronically, and to upload aggregate performance outcomes information into ETA’s Enterprise Business Support System (EBSS). If states do not comply with these requirements, the funding for these programs would be compromised to the detriment of the individuals that benefit from services provided through these programs. ETA’s responsibility for reporting, oversight, and monitoring will be severely hampered because there is no other vehicle for judging program performance and participant outcomes for TAA and NAFTA-TAA. The agency will also be unable to fulfill its responsibilities under GPRA and will be unable to submit required information to OMB for completion of the PART.
These data collection efforts do not involve any special circumstances. The proposed reporting system is consistent with the guidelines in 5 CFR 1320.5.
A Pre-clearance Notice was published in the Federal Register on August 1, 2008 (Vol. 73, No. 149, Pages 45076 thru 45077). No comments were received.
There are no payments to respondents other than the formula funds and incentive funds provided for in the authorizing statutes.
ETA is responsible for protecting the confidentiality of the TAPR data and will maintain the data in accordance with all applicable Federal laws, with particular emphasis upon compliance with the provisions of the Privacy and Freedom of Information Acts. TAPR data does not contain any individually identifying information. States submit records on individuals, but they submit them under an individual identifier, which must not include the individual’s social security number.
There are no sensitive questions included in the proposed data collection. Individual records, which contain wage record information, may be submitted using a unique personal identifier or pseudo-social security number.
The annual national burden for states for TAA reporting is comprised of two parts: 1) the burden of collecting participant data, and 2) the burden of preparing the TAPR submission.
The data collection burden considers the amount of information collected and reported on the TAPR that would not have to be collected by the states as part of their customary and usual burden to run the program. Thus the burden reflects the information collected solely to comply with the Federal reporting requirements.
TAA Burden |
Hrs. Per TAPR Record |
Annual National Participants |
Annual TAPR Burden Hours |
Applicable Hourly Rate |
Annual TAPR Burden Dollars |
Data Collection |
0.3 |
30,000 |
9,000 |
$39.17 |
$352,530 |
Hourly rates used to calculate cost depend upon the type of organization administering the program. For state-run programs the hourly rate is the average hourly earnings for employees in state Unemployment Insurance (UI) agencies in FY 2009 (as used for FY 2009 UI budget purposes).
The burden for preparing the TAPR submission is based on the assumption that each of the 50 states will prepare a quarterly TAPR submission, for a total of 200 reports per year. (It is possible that one or more state agencies will have no terminees during a quarter and therefore will not be required to submit a report.) States require an average of 2.5 hours to prepare each quarterly TAPR submission.
TAA Burden |
Hrs. Per TAPR Submission |
States Submitting Per Quarter |
Annual TAPR Burden Hours |
Applicable Hourly Rate |
Annual TAPR Burden Dollars |
TAPR Submission |
2.5 |
50 |
500 |
$39.17 |
$19,585 |
The current TAPR requirements have been in operation for several years and states have the necessary technology and data collection mechanisms in place to meet these approved reporting requirements. Therefore, the Department is not reporting any start-up/capital costs or annual operating costs as a part of this information collection request. The costs to maintain and disclose these data are covered by the states' existing grant funds.
ETA collects and stores the data in house, through its Office of Performance and Technology. Since the current TAPR has been in place for several years and the mechanism for collecting and storing the data remains the same, the cost to the Federal government is minimal. It is estimated that staff spend 5 hours per quarter monitoring the data and providing technical assistance for a total of 20 hours per year. Using an average hourly staff rate of $39.17, the estimated annual cost to the Federal government is $783.
There are no changes in burden requested. The respondent cost, inadvertently reported in the previous submission as $308,000, has been removed from ROCIS (as an adjustment) in this submission. The states incur no data collection costs, including the cost to purchase and maintain the necessary computer equipment, because these costs are covered by grant funds.
Collection and storage of the TAPR and publication of the reports is handled internally by ETA. TAPR reports for each quarter are due within forty-five (45) days of the end of the quarter. Reports are compiled every quarter and for every fiscal year. Data is published as part of the Department of Labor’s annual report.
Product |
Submission Date |
Publishing Date |
TAPR |
Within 45 days following the end of each calendar quarter |
ETA uses this information to prepare reports for GPRA, budget and performance management purposes on a quarterly and annual basis. |
The expiration date for OMB approval will be displayed. We are not seeking approval to have this concealed.
No exceptions are requested in the “Certification of Paperwork Reduction Act Submissions.”
This information collection request does not contain statistical methods.
| File Type | application/msword |
| File Title | NOTE: (1) PLEASE |
| Author | Earline Teasley |
| Last Modified By | Amy Hobby |
| File Modified | 2008-11-10 |
| File Created | 2008-11-05 |