The Supporting Statement
A. Justification
Circumstances Making the Collection of Information Necessary
Sections 471 and 477(b)(2) under title IV-E of the Social Security Act (the Act) authorize collection of information through the Title IV-E plan. The Title IV-E Plan information collection is approved under OMB control number 0980-0141.
A compilation of the Social Security Act containing title IV-E Sections 471 and 477, 45 CFR 1355 and 1356, ACYF-CB-PI-10-11, ACYF-CB-PI-09-08 and ACYF-CB-PI-11-09 are posted on the Children’s Bureau website at http://www.acf.hhs.gov/programs/cb/laws_policies/index.htm#laws.
Purpose and Use of the Information Collection
Each public child welfare agency (Title IV-E Agency) requesting Federal funding under the Act for foster care, independent living services, adoption assistance and (optional) guardianship assistance program is required to submit a IV-E plan. Title IV-E Agencies include state and territorial public child welfare agencies and those tribes, tribal organizations and tribal consortia (hereafter referred to as tribes) who elect to operate a IV-E program. The plan is used by a the Title IV-E Agency to describe the nature and scope of the agency’s programs; document program compliance; and provide assurances the programs will be administered in conformity with specific requirements stipulated in title IV-E. The plan must include all applicable statutory/Code, regulatory, or policy references and citation for each Federal requirement as well as supporting documentation. The Federal government has used the plan to evaluate and monitor State program implementation; identify practice and systemic issues; target areas for potential or enhanced technical assistance; and support monitoring reviews.
Use of Improved Information Technology and Burden Reduction
Title IV-E Agencies complete an electronic version of the title IV-E plan pre-print that can be accessed through the Children’s Bureau website which may be submitted electronically or on a compact disc to the Children’s Bureau. A Title IV-E Agency may use the pre-print plan format issued by the Children’s Bureau or a different format, on the condition that the format used includes all of the title IV-E state plan requirements of the law.
Electronic submission of IV-E plans has resulted in significantly reducing paperwork for a Title IV-E Agency.
Efforts to Identify Duplication and Use of Similar Information
This information collection does not duplicate information collected for other purposes or from other data sources. Through extensive contacts with organizations and individuals in the public and private sectors, program staff is certain there is no similar information available.
5. Impact on Small Businesses or Other Small Entities
This information collection does not impact small businesses or other small entities. Only Agencies are required to collect and report this information.
6. Consequences of Collecting the Information Less Frequently.
A Title IV-E Agency cannot receive Federal reimbursement for allocable program activities if the information collection is not conducted or is conducted in a manner contrary to Federal provisions. The IV-E plan is required by Federal statute. Legislative change is the only means to reduce or eliminate this burden.
Once the initial IV-E plan has been submitted by the Title IV-E Agency and approved by the Department, the plan remains in effect until an amendment is required due to a significant and pertinent change in the plan information. Requiring a Title IV-E Agency to submit the plan only when necessary rather than during regular intervals has substantially reduced the reporting burden on agencies. Experience has demonstrated that on average a plan is submitted by a Title IV-E Agency once every four years.
7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances that require the collection of the requested information in a manner other than that required by OMB.
8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
The Department of Health and Human Services, Administration for Children and Families (ACF) published a notice in the Federal Register, according to the requirements in 5 CFR 1320.8 (d), on June 28, 2012 (Volume 77, Page Number 38637), The ACF received one comment.
The public comment was in reference to information in the IV-E plan that appeared to be duplicative and that previously approved policies, laws, etc. should not have to be resubmitted every time there is a required plan amendment due to new legislation. ACF is in agreement with the statement and provides pages for Title IV-E Agencies to complete for new requirements. ACF periodically provides an entire pre-print incorporating changes to date for the agency to use although only those pages where requirements have changed are required for re-submission. The option to have a compiled clean copy of the pre-print allows for ease of use for all.
Annually, ACF meets with Title IV-E Agency representatives responsible for foster care, adoption and guardianship services. These meetings discuss innovations in the field and allow ACF to provide a forum for discussing critical child welfare issues. These experts expressed no concerns regarding the collection of information in the Title IV-E plan.
9. Explanation of Any Payment or Gift to Respondents
No gift or payment will be provided to any respondents other than reimbursement for legitimate financial claims under this program.
10. Assurance of Confidentiality Provided to Respondents
Title IV-E plans are public documents. The plans do not contain identifying, personal information on individuals and must be made available for public review. The plans must include assurances of compliance with section 471(a)(8) of the Act, which provides for safeguarding the use and disclosure of information on applicants and recipients of services.
Justification for Sensitive Questions
There are no questions or other information of a sensitive nature in this information collection.
12. Estimates of Annualized Burden Hours and Costs.
ANNUAL BURDEN ESTIMATES
Instru-ment |
Number of Respondents |
Number of Responses per Respondents |
Average Burden Hours Per Response |
Total Burden Hours |
Title IV-E State Plan |
17 |
1 |
16 |
272 |
Estimated Total Annual Burden Hours: 272
An initial IV-E plan is submitted by an Agency for approval to participate in the title IV-E program. Plan amendments are submitted whenever necessary to reflect changes in Federal statute or regulation, or, material changes in state, territorial or tribal law/Code, policy or program operation. The ACF’s experience is that an Agency will amend a plan once every four years and that about one-fourth of agencies will amend their plans annually. In addition Tribal agencies are electing to participate and submit Title IV-E Plans (see #15 below). It is estimated that it will take approximately 16 hours to abstract, assemble and transmit necessary information. The basis for the estimate of burden is prior experience and informal reports from the Agencies.
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
There is no additional cost burden to a Title IV-E Agency associated with generating, maintaining, disclosing or providing the information. Any costs incurred are related to the use of existing resources in the agency. Title IV-E plan preparation and maintenance are considered standard operating procedures necessary for efficient and proper performance of the agency; therefore, associated costs may be claimed for Federal reimbursement at the 50 percent administrative rate.
14. Annualized Cost to the Federal Government
There are no additional costs to the Federal government resulting from this collection of information. Any costs incurred are associated with the use of existing resources in ACF.
15. Explanation for Program Changes or Adjustments
The Social Security Act was amended to allow for two optional program changes. Section 479B of the Act provides for an Indian tribe, tribal organization or tribal consortium (Tribe) to operate a title IV-E program in the same manner as a State with minimal exceptions. The Tribe must have an approved Title IV-E Plan. The Act also provided for a guardianship assistance program for Title IV-E agencies who elect the option (471)(a)(28)). Title IV-E Agencies electing this option must have an approved Title IV-E Plan. These program changes did not change burden.
However, there is an adjustment due to an error in the last submission which reduces the hourly burden from 528 hours to 272 hours and the number of responses from 33 to 17.
16. Plans for Tabulation and Publication and Project Time Schedule
The ACF does not plan to publish the information collected.
17. Reason(s) Display of OMB Expiration date is Inappropriate
The OMB control number and expiration date are displayed on the front page of the pre-print format issued by ACF.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification statement.
B. Statistical Methods (used for collection of information employing statistical methods)
Respondent Universe and Sampling Methods
Procedures for the Collection of Information
Methods to Maximize Response Rates and Deal with Nonresponse
Test of Procedures or Methods to be Undertaken
Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data
The information that must be submitted in the IV-E plan collection does not require the use of statistical methods.
| File Type | application/msword |
| Author | ACF |
| File Modified | 2012-10-15 |
| File Created | 2012-10-15 |