Supporting Statement ACF-204 - 10.24.19_final

Instructions for Annual Report on State Maintenance-of-Effort Programs: Form ACF-204

OMB Information Collection Request

0970 - 0248

Supporting Statement Part A - Justification

October 2019

Submitted By:

Office of Family Assistance

Administration for Children and Families

U.S. Department of Health and Human Services

THE SUPPORTING STATEMENT A - JUSTIFICATION

1. Justification

1. Circumstances Making the Collection of Information Necessary

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) amended the Social Security Act and imposed certain data collection requirements including section 411(b)(3) (data collection and reporting), which requires the annual reporting of the characteristics of programs funded by PRWORA. These requirements are also discussed in Part 265 of the Temporary Assistance for Needy Families Program (TANF) final rule that was published on April 12, 1999. The requirement remains unchanged under the Deficit Reduction Act of 2006 and the TANF Reauthorization Interim Final Rule.

Authority: 42 U.S.C. 611.f

2. Purpose and Use of the Information Collection

These data will also provide us with the necessary information to carry out our other financial management and oversight responsibilities. Other analyses will include, but not necessarily be limited to, analyses of the impacts of various TANF provisions and descriptions of the characteristics of the populations served. We publish these findings in the TANF Annual Report to Congress.

3. Use of Improved Information Technology and Burden Reduction

It is mandatory that States submit this report as an electronic file via e-mail so States do not have to produce “clearance packages” in hard copy form. The electronic submission also saves on paper and mailing expenses.

4. Efforts to Identify Duplication and Use of Similar Information

There are no TANF-specific data available that are similar to what we collect with this information collection.

5. Impact on Small Businesses or Other Small Entities

This collection of information does not impact small businesses or other small entities. It will affect only states and territories and has been held to the absolute minimum required for the intended uses.

6. Consequences of Collecting the Information Less Frequently

The statute mandates the annual collection of the Annual Report on State MOE Programs.

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

This collection of information does not involve any special circumstances and will not result in a system of records. The data relate to program characteristics only.

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

In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on January 31, 2019, Volume 84, Number 21, page 742, and provided a sixty-day period for public comment. We received no comments in response to the notice.

9. Explanation of Any Payment or Gift to Respondents

This data collection does not involve any payment or gift to respondents other than remuneration of grantees.

10. Assurance of Confidentiality Provided to Respondents

This information collection does not collect information that requires assurances of confidentiality. This data collection does not constitute a Privacy Act System of Records.

11. Justification for Sensitive Questions

This data collection does not contain any questions of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

Instrument or Requirement	No. of Respondents	Yearly Submittals	Average Burden Hours per Response	Total Annual Burden Hours
Annual Report on State MOE Programs – ACF-204 §265.9(b)-(c)6	54	1	118	6,372

Estimated Total Annual Burden Hours: 6,372

We have estimated the burden hours for each information collection activity as though they applied to all jurisdictions for ease of discussion and public review.

We estimate the annualized cost of the hour burden to be $354,156. According to Bureau of Labor Statistics data from May 2018 (https://www.bls.gov/oes/current/naics4_999200.htm), the mean hourly wage for state government employees is $27.79. Multiplying this by two (to account for fringe benefits and overhead) results in an average hourly cost of $55.58. The estimate of annualized cost to respondents for hour burden is thus $55.58 times 6,372 or $354,156.

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

There are no other costs to respondents and record keepers.

14. Annualized Cost to the Federal Government

We estimate total annual federal burden to be 243 hours. This includes the costs of information collection, development, printing forms, e-mail list compilation and maintenance, e-mailing, editing, calculations, analysis, evaluation, publication of results, technical assistance, and monitoring. According to Bureau of Labor Statistics data from May 2018 (https://www.bls.gov/oes/current/999101.htm), the mean hourly wage for federal government employees is $36.93. Multiplying this by two (to account for fringe benefits and overhead) results in an average hourly cost of $73.86. The total estimated annual Federal cost is thus $73.86 times 243 or $17,948.

15. Explanation for Program Changes or Adjustments

This request is for a reinstatement of the information collection under OMB #0970-0248. There are no program changes.

16. Plans for Tabulation and Publication and Project Time Schedule

We analyze and compile these data at the end of each fiscal year after the states have transmitted the data to us. These data will also provide us with the necessary information to carry out our other financial management and oversight responsibilities. Other analyses will include, but not necessarily be limited to, analyses of the impacts of various TANF provisions and descriptions of the characteristics of the populations served. We publish these findings in the TANF Annual Report to Congress.

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

Not applicable

18. Exceptions to Certification for Paperwork Reduction Act Submissions

Not applicable

B. Statistical Methods (used for collection of information employing statistical methods)

Not applicable

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