FINAL_LRP_Supporting_Statement_5-11-12 OCIO

FINAL_LRP_Supporting_Statement_5-11-12 OCIO.docx

Indian Health Service Loan Repayment Program

OMB: 0917-0014

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Supporting Statement for the

Indian Health Service Loan Repayment Program

Information Collection 0917-0014,

Authorized Under 25 U.S.C. § 1616a,

P.L. 94-437 § 108



Background


The Indian Health Service (IHS) Loan Repayment Program (LRP) identifies health professionals with pre‑existing financial obligations for education expenses that meet program criteria and who are qualified and willing to serve at, often remote, IHS health care facilities. Under the program, eligible health professionals sign a contract through which the IHS agrees to repay part or all of their indebtedness for professional training education. In exchange, the health professionals agree to serve for a specified period of time in IHS health care facilities.


A. Justification


1. Need and Legal Basis


This program is necessary to augment the critically low health professional staff at IHS health care facilities. Any health professional wishing to have their health education loans repaid, may apply to the IHS LRP. A two-year contract obligation is signed by both parties, and the individual agrees to work at an IHS location and provide health services to American Indian and Alaska Native individuals. The proposed information collection is a revision of the currently approved information collection, 0917-0014, “Indian Health Service Loan Repayment Program.” The paper application was made available online and is now electronically fillable and fileable; applicants can complete and submit the application on line. The online IHS LRP Information Booklet contains the instructions and the application formats, and the information will be stored in a database.


This information is authorized to be collected by Section 108 of Public Law (Pub. L.) 94‑437, the Indian Health Care Improvement Act, as amended (See Attachment 1).


  1. Information Users


The previously approved LRP application is now available in an on-line format. This information collection enables the applicant the use of electronic information technology in order to complete and submit the application, with the option to print and mail the application to the program. The technology also provides the IHS with the capability to store the information in a database.


The information collected from individuals is analyzed by the LRP staff, and a score is given to each applicant. This score will determine which applicants will be awarded each fiscal year. The administrative scoring system assigns a score to the geographic-location according to vacancy-rates for that fiscal year and also considers whether the location is in an isolated area. When an applicant accepts employment at a location, they in turn “pick-up” the score of that location. Once scores are assigned to the applicants, loan repayment is awarded to those with scores above 70.


The awardees then sign 2-year contracts obligating them to work at their locations, and in return the Agency pays their tuition loans.


This request for information collection has been approved in previous years, since 1988.


  1. Improved Information Technology:


The IHS LRP Application is now available to complete and submit in an electronic on-line format.


  1. Duplication of Similar Information


Duplication is not an issue. There is no similar information available which can be used or modified to meet the information needs of this program. The information requested on the IHS LRP application is specific to the applicant and unique to this program. Applicants who live in remote areas or do not have access to the internet may still submit the application via mail or other method.


5. Small Businesses


This information will not involve the collection of information from small businesses.


6. Less Frequent Collection


If the information were collected less frequently, the ability of the IHS LRP to identify and select qualified health professional applicants to fill priority health professional vacancies as needed at IHS health care facilities would be harmed. The information collection must be completed every fiscal year, once a year.


7. Special Circumstances


This information collection will be consistent with the guidelines in 5 C.F.R. 1320.5(d)(2).



8. Federal Register Notice/Outside Consultation


A 60-day Federal Register Notice (77 FR 11558) was published on February 27, 2012. (See Attachment 1). No public comments were received.


OUTSIDE CONSULTATION: The program surveyed the following non-agency individuals to obtain constructive feedback to improve the application, improve efficiency, and minimize the collection burden. The comments on the clarity and ease of completion of the forms were positive. There were no suggestions for improvement nor any major problems identified. The consultations took place in 2010. The following are the names, titles, phone numbers, and e-mail addresses of those consulted.


W. Lyndon Lamb, D.P.M. L. Stewart Anderson, M.D.

Podiatrist Physician

50125 State Hwy 82 P.O. Box 538

Talihina, OK 74521 Shiprock, NM 87420

(918) 349-7026 (817) 658-8205

wllamb@choctawnationhealth.com Lee.Anderson@ihs.gov


Darrell Acheson, PharmD Douglas Nolan, D.O. Ms. Deborah Farrell

Pharmacist Osteopathic Medicine Nursing

2325 Glacier St. P.O. Box 745 P.O. Box 328

Anchorage, AK 99508 Park Hill, OK 74451 Tuba City, AZ 86045

(907) 729-1994 (918) 207-5012 (928) 283-2628

dracheson@anmc.org Douglas.Nolan@ihs.hhs.gov Debi.Farrell@TCHealth.org


In addition, the following IHS LRP Review Committee members reviewed and verified the estimated burden response for this information collection:


Mr. Eugene Robinson Ms. Regena Dale

801 Thompson Ave. Ste. 120 Phoenix Office

Rockville, MD 20857 Phoenix, AZ 85004

(301) 443-1561 (602) 364-5258

Eugene.Robinson@ihs.hhs.gov Regena.Dale@ihs.hhs.gov


Mr. Michael Berryhill Mr. Carmen Clelland

Health Professions Chief Executive Officer

12300 Twinbrook Winslow Indian Health Center

Rockville, MD 20857 500 N. Indiana Ave.

(301) 443-2443 Winslow, AZ 86047

Michael.Berryhill@ihs.hhs.gov (928) 289-6287

Carmen.Clelland@ihs.hhs.gov



9. Payment/Gift to Respondents


The respondents of this information collection will not receive any payments or gifts for providing the information.


10. Confidentiality


The information collected through the IHS LRP application process is maintained in accordance with the Health and Human Services Privacy Act Records System Notice 09‑17‑0002, “Indian Health Service Scholarship and Loan Repayment Program.” The Privacy Act notification statement will be contained in the LRP Information and Application Booklet. Applicants will be assured that their records will be maintained in accordance with the provisions of the Privacy Act.


11. Sensitive Questions


There are no questions of a sensitive nature solicited in this information collection. Respondents are requested to voluntarily provide their Social Security Number (SSN) and informed that if awarded an IHS loan repayment, under the Debt Collection Act, the SSN must be provided, otherwise their application will be considered incomplete.



12. Burden Estimate (Total Hours & Wages and Costs


12A. Estimated Burden Hours



Estimated Burden Hours


Data

Collection Instrument


Estimated

No. of Respondents


Responses per Respondent


Average Burden Hour per Response*


Total Annual Burden Hrs


LRP Application


510


1


1.5 hours


765



Total


510


1


1.5 hours


765



Annual Information Collection Costs to Respondents:


There is no costs to respondents, other than their time to voluntarily complete the IHS LRP application process.



12B. Estimate of annualized costs to respondents for the hour burdens for collections of information.


Type of Respondent

Total Burden Hours

Hourly Wage Rate

Total Respondent Cost


Health Care Professional


765


$32


$24,480



Total


765


$32


$24,480



This information collection will not require the purchase of any capital equipment or start-up costs; and places no additional computer or record keeping requirements upon the respondents. Therefore, the estimated total annual cost burden to respondents or record keepers for capital and start-up costs components (annualized over the expected useful life) for this information collection is zero. This process is now available in an electronic on-line format. This information collection is part of the respondents’ customary and usual business practices, and therefore is not included in the estimate.


The estimated total cost burden to respondents or record keepers for operation and maintenance, and purchase of services components for this information collection is zero. The information collection will not create costs associated with generating, maintaining, and disclosing or providing the information.

13. Capital Costs (Maintenance of Capital Costs)


The cost estimate is reflected into two components.


a) The total capital and start-up costs components which is not an issue due to the use of all existing hardware and software.


b) The total operation and maintenance associated with generating, maintaining, and disclosing information again is not an issue due to in-house, existing staff and equipment and software. The expected useful life of capital is infinite.


Cost to Federal Government


The annual cost to the Federal government for this information collection is the cost of maintaining capital associated with this information collection which is based on the annual printing and mailing of the applications (per applicant’s request); and the staff time to perform the initial screening of each application and a thorough review and analysis of each of the remaining applications. Cost estimate is also based on information technology (IT) consultant’s fees and services. The estimated annual cost to the Federal government is as follows:



ITEM COST


Estimated annual capital cost: $75,250


15. Program or Burden Changes


This is a request for an extension. Although, there was a change in the mechanism to apply and submit the application on line, vs. submitting the application via mail, there are no program changes or adjustments in burden hours.


16. Publication and Tabulation Dates


Information collected and tabulated is used by the IHS LRP for internal program planning, management and evaluation purposes. There are no plans for publication of this information.


17. Expiration Date


The OMB approval number and expiration date will be displayed on the information collection.


18. Certification Statement


There are no exceptions to the certification.


















B. Collections of Information Employing Statistical Methods


Statistical methods are not used in this collection.


The Agency has determined that the need to use statistical methods during this collection of information at this time of the process, will not reduce the burden of applicants, nor will it improve the accuracy of the results. Once actual Loan Repayment awards are made, however, the Program and the Agency report those statistics and relevant data to Congress.


    1. Respondent Universe and Sampling Methods

    2. Procedures for the Collection of Information

    3. Methods to Maximize Response Rates and Deal with Nonresponse

    4. Tests of Procedures or Methods to be Undertaken

    5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

Attachment 1


Authorizing Legislation for the Indian Health Service

Loan Repayment Program

9


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