OFA OMB Supporting Statement5.22.12

Department of Health and Human Services

Administration for Child and Families

Office of Family Assistance

Data Collection Request for Grantee Performance Measurement Data

Office of Management and Budget

Clearance Revision Package Supporting Statement and Data Collection Instruments

May 2012

Table of Contents

A. Justification 1

A1. Circumstances making the collection of information necessary 1

A2. Purpose and use of information collection 2

A3. Use of improved information technology and burden reduction 2

A4. Efforts to identify duplication and use of similar information 2

A5. Impact on small businesses or other small entities 3

A6. Consequences of collecting the information less frequently 3

A7. Special circumstances relating to the guidelines of 5 CFR 1320.5 4

A8. Comments in response to the Federal Register notice and efforts to consult outside the agency 4

A9. Explanation of any payment or gift to respondents 4

A10. Assurance of confidentiality provided to respondents 4

A11. Justification for sensitive questions 4

A12. Estimates of annualized burden hours and costs 4

A13. Estimates of other total annual cost burden to respondents and record keepers 5

A14. Annualized cost to the federal government 5

A15. Explanation of program changes or adjustments 6

A16. Plans for tabulations and publication and project time schedule 6

A17. Reason(s) display of OMB expiration date is inappropriate 6

A18. Exceptions to certification for Paperwork Reduction Act Submission 6

B. Collection of Information Employing Statistical Methods 7

List of Appendices 8

1. Justification

A1. Circumstances making the collection of information necessary

The information to be collected is information on the performance (outputs and outcomes) of Community-Centered Healthy Marriage, Pathways to Responsible Fatherhood and the Community-Centered Responsible Fatherhood Ex-Prisoner Reentry Pilot Project funded by the Office of Family Assistance (OFA). These grants were authorized under Sec. 811 (b) Healthy Marriage Promotion and Promoting Responsible Fatherhood Grants of the Claims Resolution Act of 2010, Pub. L. No. 111-291, 124 Stat.3064 (Dec. 8. 2010). A copy of the legislative authority is included as Appendix A.

The information collection is necessary for OFA and the Administration for Children and Families (ACF) to ensure the accountability and performance of these grants programs. The grant solicitations issued by the Administration for Children and Families require the grantees to participate in data collection. Specifically, the grant announcements state, “[a]ll grantees will participate fully in quantitative or monitoring activities that capture measurable indicators and outcomes. ACF will require a consistent measuring system across all funded programs.”

The Community-Centered Healthy Marriage grants announcement and the Claims Resolution Act funds grantees in several priority areas to conduct one or more of the following activities:

• Public advertising campaigns on the value of marriage and the skills needed to increase marital stability and health.

• Education in high schools on the value of marriage, relationship skills, and budgeting.

• Marriage education, marriage skills, and relationship skills programs that may include parenting skills, financial management, and job and career advancement.

• Premarital education and marriage skills training for engaged couples and for couples or individuals interested in marriage.

• Marriage enhancement and marriage skills training programs for married couples.

• Divorce reduction programs that teach relationship skills.

• Marriage mentoring programs that use married couples as role models and mentors in at-risk communities.

• Programs to reduce the disincentives to marriage in means-tested aid programs, if offered in conjunction with any activity described above.

The Pathways to Responsible Fatherhood grant announcement and the Claims Resolution Act funds grantees to conduct one or more of the following activities:

• Activities to promote marriage or sustain marriage

• Activities to promote responsible parenting

• Activities to foster economic stability

The Community-Centered Responsible Fatherhood Ex-Prisoner Reentry Pilot Project announcement and the Claims Resolution Act funds grantees to provide one or more of the following activities to formerly incarcerated parents:

• Activities to promote marriage or sustain marriage

• Activities to promote responsible parenting

• Activities to foster economic stability

A2. Purpose and use of information collection

The purpose of the information collection is to allow OFA and ACF to carry out their responsibilities for program accountability. The collected information will be used by OFA to assist Federal Project Officers (FPOs) to monitor and manage the performance of grantees on the outputs and the short- and intermediate-term outcomes of the grant program. The data will also be aggregated to assess the overall performance of the grant program, and support management and budget decisions regarding the grant program.

A3. Use of improved information technology and burden reduction

Grantees will report the data twice yearly using the ACF’s Online Data Collection (OLDC). Online Data Collection will reduce grantees’ reporting burden by providing a convenient and simple method for submitting data electronically. Grantees will only be able to view and report on the allowable/authorized activities which they are funded to conduct, reducing the burden for grantees of determining what forms to complete. The questions are broad enough to allow grantees to report on the data requested, despite the extensive variety of activities being conducted by the grantees. Grantees are expected to report data for activities they conduct and collect data on. Hard copies of the data forms, date entry instructions, and glossaries being incorporated into OLDC for the information collection are included in Attachments B-F.

A4. Efforts to identify duplication and use of similar information

We examined several potential data sources, both internal and external to the grant program and found none of the data sources to be suitable for providing OFA with performance metrics on the grant program.

Grantees are currently providing some information on program activities in their semi-annual reports to OFA. However, the information collected for the performance measurements will obtain information on program performance that is not provided in the semi-annual reports. Specifically, this information request will provide data about the discrete number of people enrolled and completed, the demographic information and the positive changes experienced by individuals attributed to program participation.

We also considered that grantees are conducting individual evaluations of their programs. The methods and instruments grantees are designing to gather data for evaluation purposes are tailored to each program and the methodology and outcome measures vary greatly across grantees. The performance measures were developed to create a consistent set of measures that can be aggregated up to the program level and be broad enough to apply to the variety of activities grantees are conducting. Grantees can use information collected for their evaluations, but the performance measures will not duplicate existing evaluation efforts. Grantees will be encouraged to include the performance measures in their local evaluations.

In addition to the individual grantee’s evaluations, there are two HHS-sponsored national level evaluations of Healthy Marriage, Responsible Fatherhood and Fatherhood Reentry grants being conducted¹. There is little overlap between grantees participating in any of the national evaluations and those being funded through the Healthy Marriage and Responsible Fatherhood grant programs. The national level evaluations are narrowly focused on specific program models and cannot be used to monitor and determine the performance of these OFA grantees. Collecting performance data from the Healthy Marriage, Responsible Fatherhood and Fatherhood Reentry grantees will complement and contribute to knowledge in the field about Healthy Marriage and Responsible Fatherhood programs and will not duplicate information.

We also considered State or national level data on marriage and divorce rates as benchmark performance measures to reflect the intermediate-term goals of the grant program of increasing healthy marriages and decreasing divorce rates, on the way to the long-term goal of increasing family and child well-being. However, due to the small geographic regions that the grants operate in and the multitude of other factors that can affect marriage and divorce rates, these measures were deemed inappropriate benchmarks. Collecting data from grantees is the most reasonable and appropriate way to determine program performance.

A5. Impact on small businesses or other small entities

Information being requested has been held to the minimum information necessary to construct performance measures for the Healthy Marriage, Responsible Fatherhood and Fatherhood Reentry grants. It is anticipated that these requirements will have no impact on small businesses or other entities. The grantees submit all of their reports to OFA electronically, therefore they will not be required to purchase computers or incur other capital costs for providing the required information using the ACF’s OLDC. The time required for the average entity to respond is estimated at 1.6 hours per year. This amount of time should not impose substantial burdens on these entities.

A6. Consequences of collecting the information less frequently

Grantees are required to provide information semi-annually. This frequency of reporting is needed to obtain information needed for timely grant monitoring and assessment of the development of the grant programs.

A7. Special circumstances relating to the guidelines of 5 CFR 1320.5

None. The information collection does not involve any special circumstances relating to the guidelines of 5 CFR 1320.5.

A8. Comments in response to the Federal Register notice and efforts to consult outside the agency

No comments were received in response to the Federal Register Notice published on March 12, 2012 (pages 14527 and 14528).

OFA consulted with the ICF International (Dr. Mary Hyde – 703-225-2299), the contracted Technical Assistance (TA) provider. ICF International provided input on revising the new revised performance measures, method of data collection and the feasibility of the grantees providing the data based on their experience as the technical assistance providers for Healthy Marriage and Responsible Fatherhood Demonstration grant.

A9. Explanation of any payment or gift to respondents

None. There are no gifts or payments for respondents.

A10. Assurance of confidentiality provided to respondents

Respondents are grantees; they are reporting on grant outputs and outcomes during the reporting period. Information on the performance of individual grantees will be used by FPOs in monitoring and managing the grants. Grantee information will be aggregated to the program level (or other intermediate level, such as program grantees working in particular grant areas) to provide information on the performance of the grant program.

Respondents are told that the information they provide will be available to their FPO and to OFA, and that for public reporting, the information will be presented in aggregate form rather than for individual grantees.

A11. Justification for sensitive questions

No sensitive questions are asked. Grantees are only asked to provide information on changes in participants’ knowledge and skills for marriage and parenting (e.g., conflict resolution, communication), attitudes about the importance of marriage and fatherhood, or similar changes and demographic information.

A12. Estimates of annualized burden hours and costs

Data will be collected from all 61 Community-Centered Healthy Marriage, 53 Pathways to Responsible Fatherhood and 4 Community-Centered Responsible Fatherhood Ex-Prisoner Reentry grantees in the OFA program. We estimate it will take on average approximately 1.6 hours per year per grantee to respond to this information request. Based on an estimated average hourly salary of $40 per hour (including fringe benefits, overhead, etc), the total annual cost for the 118 grantees is estimated to be $7,552 ($40 x 1.6 x 118). Table 1 shows the burden estimate.

Table 1: Annual Burden Estimates

Instrument	Number of respondents	Number of responses per respondent	Average burden hours per response	Total annual burden hours
Performance measure reporting form (for private sector affected public)	103	2	0.8	165
Performance measure reporting form (for State, local, and tribal government affected public)	15	2	0.8	24
Estimated Total Annual Burden Hours	…..	…..	…..	189

A13. Estimates of other total annual cost burden to respondents and record keepers

For this information collection the respondents will not have to invest in any new technologies or data collection resources for the purpose of producing and providing this information. Therefore, no additional cost burden applies.

A14. Annualized cost to the federal government

We estimate total annual Federal burden to be 297 hours for an estimated annual cost of $24,679.

Table 2: Annualized Cost to the Federal Government

	Development		Monitoring		Total Cost
	Hours	Avg. Salary	Hours	Avg. Salary
Total – All Federal staff	130	83	762	83	$74,036
Average Annual Cost					$24,679

Note: Federal burden estimate includes costs for development and monitoring for years 1 through 3 of the grants. Average salary is calculated as a weighted average of the loaded hourly rates of GS-15 and GS-14 Step 2 managers, GS-13 step 2 and GS-12 Step 2 Federal Project Officers.

A15. Explanation of program changes or adjustments

The current OMB estimates the total annual burden as 342 hours; however, the proposed OMB inventory estimates a reduction of 153 hours. Therefore, the proposed total annual reporting burden is 189 hours. The net decrease in the burden is a result of the reduction of the number grantees from 214 to 118.

The program changes include the addition of questions to data collection forms, the deletion of questions from data collection forms and the addition of a new instrument. These changes were made to streamline the data collection process and to collect information that is relevant for monitoring and managing the performance of grantees.

The following is a description of the each of the program change:

• Healthy Marriage: OLDC Report Questions/Information for OFA HMRF Grantees to Enter into OLDC System – The following are the proposed changes: the deletion of questions, and the addition of new questions and demographic information.

• Responsible Fatherhood: OLDC Report Questions/Information for OFA HMRF Grantees to Enter into OLDC System – The following are the proposed changes: the deletion of questions, and the addition of new questions and demographic information.

• Responsible Fatherhood Reentry: OLDC Report Questions/Information for OFA HMRF Grantees to Enter into OLDC System – This is a proposed new data collection instrument for the Responsible Fatherhood Reentry grantees. The Responsible Fatherhood Reentry data collection instrument is adapted from Responsible Fatherhood data collection instrument with additional questions to gather information relevant to ensure the accountability and performance of the grants programs.

A16. Plans for tabulations and publication and project time schedule

Performance measurement data will be tabulated (descriptive statistics such as frequencies and percentages) twice a year. The information will be used by FPOs to provide feedback to and monitor the performance of individual grantees. The aggregate data will be used by OFA for program monitoring and management and to create efficiency measures for the grant program. The aggregate data may be used as part of a Congressional report or briefing or other products to report on the Community-Centered Healthy Marriage, Responsible Fatherhood and Fatherhood Reentry grant programs.

Project Timeline

OFA will have one data collection for year one and then on a semi-annual basis for two years and any additional years of funding the grant program receives. The following table maps out the timeline for the first round of data collection and analysis.

Table 3: Project Timeline

Activity	Approximate Time Frame
Training sessions on reporting	2-7 weeks post OMB approval
First round of data reporting	September – October, 2012
Data approvals	October, 2012
Data analysis preliminary	November – December, 2012
Data analysis final and report	December – January, 2012

A17. Reason(s) display of OMB expiration date is inappropriate

Not applicable. OMB expiration date will be displayed.

A18. Exceptions to certification for Paperwork Reduction Act Submission

None. No exceptions to certification.

2. Collection of Information Employing Statistical Methods

Data will be reported by all grantees thus no statistical sampling or other statistical methods will be used.

List of Appendices

• Appendix A - Copy of the legislative authority

• Appendix B – Healthy Marriage Data Collection Instruments

• Appendix C – Responsible Fatherhood Data Collection Instruments

• Appendix D – Responsible Fatherhood Reentry Data Collection Instruments

• Appendix E – Data Entry Instructions

• Appendix F – Glossary: Healthy Marriage

• Appendix G – Glossary: Responsible Fatherhood

• Appendix H – Glossary: Responsible Fatherhood Reentry

1 The two evaluations are the Parents and Children Together (PACT) study project sponsored by the Administration of Children and Families’ Office of Planning, Research and Evaluation (OPRE) and conducted by Mathematica Policy Research, Inc., and the Ex-Prisoner Reentry Strategies Study project sponsored by the Administration of Children and Families’ Office of Planning, Research and Evaluation (OPRE) and conducted by The Urban Institute.