Health Resources and Services Administration
Supporting Statement
Ryan White HIV/AIDS Program (RWHAP) Parts A and B Unobligated Balances and Rebate Addendum Tables
OMB Control No. 0906-XXXX
New
Terms of Clearance: “None”.
A. Justification
Circumstances Making the Collection of Information Necessary
This is a request for OMB approval (new) for the Health Resources and Services Administration’s (HRSA’s) Ryan White HIV/AIDS Program Parts A and B Unobligated Balances and Rebate Addendum Tables.
HRSA’s Ryan White HIV/AIDS Program (RWHAP) funds and coordinates with cities, states and territories, and local clinics/community-based organizations to deliver efficient and effective HIV care, treatment, and support to low-income people with HIV. Nearly two-thirds of RWHAP clients (patients) live at or below 100 percent of the Federal poverty level and approximately three-quarters of RWHAP clients are racial and ethnic minorities. Since 1990, the RWHAP has developed a comprehensive system of HIV service providers who deliver high quality direct health care and support services to over half a million people with HIV—more than 50 percent of all people with HIV in the United States.
Grant recipients funded under Parts A, B, C, and D of the RWHAP (codified under Title XXVI of the Public Health Service Act) are required to report financial data to HRSA at the beginning (Allocations Report) and at the end of each grant budget period (Expenditures Report) using the Electronic Handbooks. HAB RWHAP’s Parts A and B collect Unobligated Balances (UOB) of federal funds by subprogram from their grant recipients. The exact amount of UOBs must be reported on the final Federal Financial Report (FFR), due annually on July 30 after the end of the budget period, in accordance with the Reporting Requirements listed on the Notice of Award (NoA). In addition, RWHAP Part B recipients must report anticipated UOB on the interim FFR, due 150 days after receipt of their final award. The interim FFR is submitted to assess recipient compliance with the requirement to obligate 75% of the Part B award within 120 days. HRSA HAB added the Unobligated Balance of Federal Funds by Subprogram Table to both the interim and final FFRs.
The RWHAP legislation also requires that rebates collected on ADAP medication purchases must be used for the statutorily permitted purposes under the RWHAP Part B Program. For any ADAP receiving rebates on medication purchases, the RWHAP legislation has a specific exemption from the UOB penalties provision that applies when a recipient is unable to expend grant funds because rebates must be spent first. If a recipient would otherwise incur a penalty, that recipient may request that the amount of the UOB balance be reduced by the amount of obligated rebates, and that such amount be carried forward to the next budget period without penalty. Such request should accompany the final FFR and final carryover request due July 30, and no later than August 30. RWHAP Part B recipients that fail to report rebates, fail to request a UOB balance reduction due to expenditure of rebates, and have an UOB of five percent (5%) or greater, are subject to the full UOB penalty.
To assess compliance with reporting requirements and process requests for reductions in UOB amounts used to determine the RWHAP Part B 5% obligation penalty, a Ryan White Rebate Funding table was added to the interim and final FFRs as an addendum.
Purpose and Use of Information Collection
These UOB tables and drug rebates are essential for allowing HRSA to ensure that RWHAP recipients are meeting the goal of accountability to the Congress, clients, advocacy groups, and the general public. Information provided by the FFR SF-425 and in the UOB tables are critical for HRSA, states and territories, and local grantees, and individual providers to evaluate the effectiveness of these programs.
Each program Part uses the UOB financial information to determine formula funding for the HRSA HAB RWHAP. The UOB tables are used to determine statutory penalties associated with non-compliance with the RWHAP Part B 75% obligation requirement and the RWHAP Parts A and B 5% UOB penalty. For a subsequent fiscal year, these penalties can result in reductions to recipient formula award amounts, changes in recipient eligibility to apply for supplemental funding opportunities, and changes in the total amount of supplemental funding available for award. In addition, the UOB tables provide amounts available for carryover. Since RWHAP Parts A and B awards include multiple subprogram categories with different requirements, UOB approved for carry over must be de-obligated and re-obligated to the same subprogram.
Use of Improved Information Technology and Burden Reduction
The UOBs and Rebate Addendum data for RWHAP Part A and Part B recipients have been collected through a separate document when grant recipients submit their annual Federal Financial Report (FFR SF-425). Recipients submitted these financial data in a non-electronic form and uploaded them as attachments as a part of their FFR-425 submissions.
At this time, HRSA HAB initiated the collection of the FFR SF-425 and the UOB through the Electronic Handbooks (EHBs) instead of collecting it separately within each of the individual OPDIVs. The financial information was collected in the same location to streamline the process for the grant recipients. The data tables are available in the EHBs below the FFR SF-425 control number and the Paperwork Burden Statement. The FFR-425 would be consolidated within the Payment Management System, or PMS. HAB is streamlining the UOB data reporting and collection processes by moving the UOB tables into the FFR-425 in an electronic format.
This automated process modification will decrease administrative burden, increase transparency and improve the quality of data submitted to HAB.
Use of information technology varies greatly among grant recipients, though most grant recipients have now established data systems that are capable of producing the required reports with minimal effort.
Efforts to Identify Duplication and Use of Similar Information
Data of the type required to evaluate or monitor each of the Ryan White HIV/AIDS Program Parts are not available elsewhere. Recipients report financial data to HRSA at the beginning (Allocations Report) and at the end of each grant budget period (Expenditures Report) using the Electronic Handbooks (OMB control #0915-0318). HAB RWHAP’s Parts A and B collect Unobligated Balances (UOB) of federal funds by subprogram from their grant recipients. The exact amount of UOBs must be reported on the final Federal Financial Report (FFR), due annually on July 30 after the end of the budget period.
Impact on Small Businesses or Other Small Entities
This information collection does not include small entities. The information being requested or required has been held to the minimum required for the intended use.
Consequences of Collecting the Information Less Frequently
HRSA HAB’s RWHAP Part A and Part B recipients report these financial data once each year. Since annual reporting of the UOBs and Rebate addendum data are used to determine statutory penalties associated with non-compliance with the RWHAP Part B 75% obligation requirement and the RWHAP Parts A and B 5% UOB penalty, less frequent reporting would impact HRSA HAB’s ability to accurately determine recipient formula award amounts, changes in recipient eligibility to apply for supplemental funding opportunities, and changes in the total amount of supplemental funding available for award.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
The request fully complies with the regulation.
Comments in Response to the Federal Register Notice/Outside Consultation
Section 8A:
A 60-day Federal Register Notice was published in the Federal Register on July 19, 2019 (Vol. 84, No. 139, pp. 34903-34904). See attached for a copy of the notice. There were no public comments.
Section 8B:
In 2019, input on burden and the impact of the moving the reporting into an electronic format on the burden was provided by the following eight recipient representatives outside of the agency. There were four grant recipients representing Part A and four representing Part B.
Ketlen Alsbrook – Part A
NEWARK CITY HEALTH AND HUMAN SERVICES
(973) 733-4402
Judy Hung/Karen Martin – Part A
HARRIS COUNTY HEALTH DEPARTMENT
(713) 439-6041
Katie Cobb – Part A
BOSTON PUBLIC HEALTH COMMISSION
(206) 898-1929
Marcee Kerr – Part A
SEATTLE-KING COUNTY PUBLIC HEALTH DEPARTMENT
(206) 263-2022
Ricardo Fernandez/Nicole Vandrovec – Part B
ARIZONA DEPARTMENT OF PUBLIC HEALTH SERVICES
(602) 364-3638
Tracey Hunt/Sharon Linzy – Part B
FLORIDA DEPARTMENT OF HEALTH
(850) 901-6708
Annette Rockwell – Part B
MASSACHUSSETS DEPARTMENT OF PUBLIC HEALTH
(617) 624-5762
DeAnna P. Kreidler – Part B
OREGON STATE DEPARTMENT OF HUMAN SERVICES
(503) 569-5708
Explanation of any Payment/Gift to Respondents
Respondents will not receive any payments or gifts.
Assurance of Confidentiality Provided to Respondents
The UOB and Rebate Addendum financial data does not require any information that could identify individual clients. Aggregate data on the amount of funding authorized, unexpended carryover and balances for Part A and Part B recipients, an aggregate amounts of rebates allotted, unexpended and expended will be collected. No personally identifiable information will be collected.
Justification for Sensitive Questions
There are no questions of a sensitive nature.
Estimates of Annualized Hour and Cost Burden
The estimated average annualized hour burden is 56.5 hours per year. Burden estimates are reported by burden to Part A and Part B grant recipient respondents, as seen in Table 1 (Estimates of Average Annualized Hour Burden to Respondents).
12A. Estimated Annualized Burden Hours
Type of Respondent
|
No. of Respondents |
No. Responses per Respondent |
Total Responses |
Average Burden per Response (in hours) |
Total Burden Hours |
Part A UOB Table |
52 |
1 |
52 |
0.5 |
26.0 |
Part B UOB Table |
59 |
1 |
59 |
0.5 |
29.5
|
Total |
111 |
|
111 |
|
55.5
|
12B.
Estimated Annualized Burden Costs
Type of Respondent
|
Total Burden Hours
|
Hourly Wage Rate
|
Total Respondent Costs
|
Part A Grant Recipients |
26 |
$16.241 |
$422.24 |
Part B Grant Recipients |
29.5 |
$16.24 |
$479.08 |
Total |
55.5 |
|
$901.32 |
Estimates of other Total Annual Cost Burden to Respondents or Recordkeepers/Capital Costs
Other than their time, there is no cost to respondents.
Annualized Cost to Federal Government
The contract task that supports the initial system setup and supports system maintenance and data collection efforts each year is $40,000. In addition, there will be costs for a GS-14 at 8% (approximately $10,000) and a GS-13 at 10% (approximately $10,000) time to monitor the project. The estimate total cost is $60,000.
Explanation for Program Changes or Adjustments
This is a new information collection.
Plans for Tabulation, Publication, and Project Time Schedule
The exact amount of UOB must be reported on the final Federal Financial Report (FFR), due annually on July 30 after the end of the Part A and Part B recipient budget period, in accordance with the Reporting Requirements listed on the Notice of Award (NoA). Drug rebates addendums should accompany the final FFR and final carryover request due July 30, and no later than August 30. In addition, RWHAP Part B recipients must report anticipated UOB on the interim FFR, due 150 days after receipt of their final award. The interim FFR is submitted to assess recipient compliance with the requirement to obligate 75% of the Part B award within 120 days. HRSA HAB added the Unobligated Balance of Federal Funds by Subprogram Table to both the interim and final FFRs.
HRSA compiles the data received from the grant recipients and produces an annual report for the Secretary of DHHS and Congress.
Reason(s) Display of OMB Expiration Date is Inappropriate
The OMB number and Expiration date will be displayed on every page of every form/instrument.
Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to the certification.
List of Attachments
Tab A: Authorizing Legislation
Tab B: UOB and Addendum Tables
Tab C: 60-day Federal Register Notice
1 The annualized burden costs for recipients is based on the April 2019 National Occupational Employment and Wage Estimates by the Bureau of Labor. https://www.bls.gov/oes/current/oes_nat.htm
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Instructions for writing Supporting Statement A |
| Author | Jodi.Duckhorn |
| File Modified | 0000-00-00 |
| File Created | 2021-01-15 |