Supporting Statement

THE SUPPORTING STATEMENT FOR THE ADMINISTRATION FOR NATIVE AMERICANS PROJECT IMPACT ASSESSMENT SURVEY

A. Justification

1. Circumstances Making the Collection of Information Necessary

The information collected by the Project Impact Assessment Survey (PIAS) is needed for two main reasons: 1) to collect crucial information required to report on the Administration for Native Americans' (ANA) established Government Performance and Results Act (GPRA) measures, and 2) to properly abide by ANA's congressionally-mandated statute (42 United States Code 2991 et seq.) found under the section titled ‘Evaluation’ in the Native American Programs Act of 1974, as amended, which states that ANA will evaluate projects assisted through ANA grant dollars “including evaluations that describe and measure the impact of such projects, their effectiveness in achieving stated goals, their impact on related programs, and their structure and mechanisms for delivery of services.” The information collected with this survey will fulfill ANA's statutory requirement.

The Native American Programs Act of 1974 additionally states under the section titled ‘Evaluation’ that, “the projects assisted under this title shall be evaluated in accordance with this section not less frequently than at 3-year intervals.” ANA will therefore asses one-third of its grant portfolio each year to meet the assigned mandate. This mandate eliminates the need to use sampling methods as all ANA projects will be evaluated over a three-year period.

2. Purpose and Use of the Information Collection

The information collected in the PIAS will be used by ANA to report quantifiable results to Congress on the impact of grantees’ projects and effectiveness in achieving their planned project goals. The consequences of not collecting project information would result in ANA violating their congressionally-mandated statute.

The information collected in the PIAS will also serve as a valuable performance and planning tool for ANA. The analysis of information collected will provide an opportunity to review and make changes to ANA’s internal policies and procedures in an effort to better support and serve its grantees. Information collected on grantee best practices will be made available to all ANA grantees and will serve as a resource guide for implementing effective and efficient projects.

3. Use of Improved Information Technology and Burden Reduction

In order for ANA to obtain standardized and accurate data, the PIAS will be completed on-site with the grantee. The on-site process will allow ANA to verify planned project deliverables and will also ensure a respondent rate of 100%. The PIAS has been developed in personal document format (PDF), which will allow ANA to easily extract data and perform subsequent analysis.

4. Efforts to Identify Duplication and Use of Similar Information

ANA has reviewed existing information collection instruments and has determined that there are no existing forms which can be used to meet ANA’s data collection needs.

5. Impact on Small Businesses or Other Small Entities

The information being requested has been held to the absolute minimum required for the intended use.

6. Consequences of Collecting the Information Less Frequently

Collecting the information less frequently would violate the legislative mandate of the Native American Programs Act of 1974 as amended. Reducing the frequency of the PIAS would also hinder ANA’s efforts to accurately report on its annual GPRA measures.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances requiring these collections to be conducted in any manner described in Item #7 of the OMB Supporting Statement Instructions and Guidance.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

The First Federal Register Notice was published on December 11, 2009, p.65777. A scanned copy of the notice can be found on page 5 of this document.

No public comments were received in response to this notice.

9. Explanation of Any Payment or Gift to Respondents

No payments or gifts will be provided to any respondents.

10. Assurance of Confidentiality Provided to Respondents

Information being requested in the Project Impact Assessment Survey (PIAS) is not considered confidential, therefore no additional safeguards are considered necessary beyond that customarily applied to routine government information. Grantees do provide contact information in the PIAS, and ANA will take reasonable precautions to keep the information private to the extent permitted by law. The PIAS will be housed electronically on the ANA shared drive and will be prudently maintained by ANA.

11. Justification for Sensitive Questions

This is not applicable. No information of a sensitive nature is requested in the Project Impact Assessment Survey.

12. Estimates of Annualized Burden Hours and Costs

Annual Burden Estimates
Instrument	Number of Respondents	Number of Responses per Respondent	Avg. Burden Hours per Response	Total Burden Hours
ANA Project Impact Assessment Survey	85	1	6	510
Estimated Total Burden Hours:				510

The estimated reporting burden for each respondent includes the time spent on-site with ANA staff to complete the PIAS.

Annual Cost Estimates
Type of Respondent	Form Name	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
Project Director	PIAS - Sections 1,2,3,4,5,6,8	5	$24.00	$120.00
Finance Director	PIAS - Section 7	1	$24.00	$24.00
Estimated Total Burden Costs:				$144.00

The estimated annual cost burden is based on an average salary of $50,000 per annum for each position specified. During the on-site evaluations, ANA expects to discuss project results with community beneficiaries as well, but this will be on a strictly voluntary basis.

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

The estimated annualized capital cost burden to respondents or record keepers resulting from the collection of information is expected to be zero.

14. Annualized Cost to the Federal Government

The estimated annualized cost to the government to collect this information is expected to be $60,000. This amount is the total estimated travel costs for ANA staff to conduct the evaluation and complete the PIAS with 85 grantees at the site of their projects.

15. Explanation for Program Changes or Adjustments

This is not applicable, as this is a new project.

16. Plans for Tabulation and Publication and Project Time Schedule

All ANA grants have a standardized completion date of September 29^th. The PIAS information collection process will commence three months prior to this date and terminate within three months after this date. ANA staff will analyze the information thereafter, and author a comprehensive report to be sent to Congress, thereby fulfilling the congressional mandate that ANA “shall publish the results of evaluative research and summaries of evaluations of program and project impact and effectiveness not later than ninety days after the completion thereof. The Commissioner shall submit to the appropriate committees of the Congress copies of all such research studies and evaluation summaries.” ANA will submit this report to Congress on an annual basis.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

This is not applicable.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

This is not applicable.

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