THV Form 2 Supporting Statement 2020_final

Tribal Maternal, Infant, and Early Childhood Home Visiting Program

Form 2: Grantee Performance Measures

OMB Information Collection Request

0970-0500

Supporting Statement Part A - Justification

January 2020

Submitted By:

Office of Child Care, Tribal Maternal, Infant and Early Childhood Home Visiting Program

Administration for Children and Families

U.S. Department of Health and Human Services

SUPPORTING STATEMENT A – JUSTIFICATION

1. Circumstances Making the Collection of Information Necessary

Section 511 of the Social Security Act, created the Maternal, Infant, and Early Childhood Home Visiting Program (MIECHV) and authorized the Secretary of the Department of Health and Human Services (HHS) (in Section 511(h)(2)(A)) to award grants to Indian tribes (or a consortium of Indian tribes), tribal organizations, or urban Indian organizations to conduct an early childhood home visiting program. The legislation set aside 3 percent of the total MIECHV program appropriation for grants to tribal entities.

The Administration for Children and Families (ACF), Office of Child Care, in collaboration with the Health Resources and Services Administration, Maternal and Child Health Bureau, awards grants for the Tribal MIECHV Program. The Tribal MIECHV grant awards support 5-year cooperative agreements to implement high-quality, culturally-relevant, evidence-based home visiting programs in at-risk Tribal communities.

Tribal MIECHV grants, to the greatest extent practicable, are to be consistent with the requirements of the MIECHV grants to states and jurisdictions (authorized in Section 511(c)), and include conducting a needs assessment and establishing quantifiable, measurable benchmarks.

Specifically, the MIECHV legislation requires State and Tribal MIECHV grantees to collect data to measure improvements for eligible families in six specified areas (referred to as "benchmark areas") that encompass the major goals for the program and are listed below:

1. Improved maternal and newborn health

2. Prevention of child injuries, child abuse, neglect, or maltreatment, and reduction in emergency department visits

3. Improvement in school readiness and achievement

4. Reduction in crime or domestic violence

5. Improvement in family economic self-sufficiency

6. Improvement in the coordination and referrals for other community resources and supports

As part of their implementation plans, Tribal MIECHV grantees are required to propose a plan for meeting the benchmark requirements specified in the legislation and must report performance data to HHS, with improvement assessed at the end of Year 4 and Year 5 of their 5-year grants. The Tribal Home Visiting (HV) Form 2 provides a template for Tribal MIECHV grantees to report data on their progress in improving performance under the six benchmark areas, as stipulated in the legislation.

2. Purpose and Use of the Information Collection

The purpose of this information collection request is to renew the existing approval under OMB No.: 0970-0500 so ACF can continue to use Tribal MIECHV Form 2 to:

• Track and improve the quality of benchmark measures data submitted by the Tribal grantees;

• Improve program monitoring and oversight;

• Improve rigorous data analyses that help to assess the effectiveness of the programs and enable ACF to better monitor projects; and

• Ensure adequate and timely reporting of program data to relevant federal agencies and stakeholders including Congress and members of the public.

3. Use of Improved Information Technology and Burden Reduction

Grantees will collect information from home visiting participants using their own established methods. Grantees will aggregate and report this information to ACF using the Tribal Home Visiting Reporting System (THVRS) which is an electronic reporting tool used by all Tribal MIECHV program grantees for quarterly, annual demographic and service utilization data and performance reporting.

4. Efforts to Identify Duplication and Use of Similar Information

This information is not available from any other source and is specific to the Tribal MIECHV program.

5. Impact on Small Businesses or Other Small Entities

There are no small businesses responding to this data request. Some organizations may be considered small entities (i.e. non-profit organizations), in this case the information being requested has been held to the absolute minimum required by the legislation for its intended use.

6. Consequences of Collecting the Information Less Frequently

Section 511 of Title V of the Social Security Act requires Tribal MIECHV grantees to collect data to measure improvements for eligible families in the six specified benchmark areas on an annual basis. A less frequent collection of performance measure information would be inconsistent with HHS grants policy and undermine the federal government’s ability to track progress of grantees in achieving improvement and would limit the ability to provide technical assistance in a timely and targeted manner during the period defined in legislation.

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

The collection of information will be conducted in accordance with 5 CFR 1320.5.

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 November 15, 2019, Volume 84, Number 221, page 62533, and provided a sixty-day period for public comment. During the notice and comment period, we received no comments from the public.

9. Explanation of Any Payment or Gift to Respondents

No payments or gifts are provided to respondents.

10. Assurance of Confidentiality Provided to Respondents

The information collection is not of a confidential nature, and therefore does not require assurance of confidentiality.

11. Justification for Sensitive Questions

There are no personal questions of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

Information Collection Title	Total Number of Respondents	Annual Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours		Average Hourly Wage		Total Annual Cost
Tribal MIECHV Form 2	23	1	500	11,500		$34.44		$396,060
Estimated Annual Burden Total:					11,500		Estimated Annual Cost Total:		$396,060

Example of description of costs for Social and Human Services Assistants with 100 hours of burden:

The job code is 21-1093 and wage data from 2018 is $17.22 per hours. Therefore to account for fringe benefits and overhead the rate is multiplied by two which is $34.44. The estimate of annualized cost for hour burden is $34.44 times 500 or $17,220 per respondent and $396,060 for all respondents.

https://www.bls.gov/oes/current/oes211093.htm

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

Other than their time, there is no cost to respondents.

14. Annualized Cost to the Federal Government

Costs to the federal government fall into two categories:

1. Costs of contractual support for modifying the reporting system, maintenance, data cleaning and aggregation of data.

2. Cost of federal staff time for project oversight and development.

Type of Cost	Description of Services	Annual Cost
Tribal Home Visiting Reporting System (THVRS) Contracted	Modifications, maintenance, data cleaning and aggregation of the electronic reporting system.	$75,000
Government Program Analyst (10%)	Project management and oversight, and consultation.	$11,200
Total Estimated Annual Cost		$86,200

Government costs include personnel costs for federal staff involved in project and contract oversight, instrument design, and analysis which includes approximately 10% of a GS-14 Program Analyst.

15. Explanation for Program Changes or Adjustments

The number of respondents has been updated from 20 to 23 based on the current number of grantees.

16. Plans for Tabulation and Publication and Project Time Schedule

Aggregation and descriptive statistics on performance data will be conducted in order to summarize the performance of grantees, and to provide vital information for TA purposes. This summary information may be made public through data briefs, fact sheets, professional presentations, and/or published manuscripts.

ACF is requesting a three-year renewal and clearance for this data collection activity.

Project Timeline

Activity	Time Schedule
Continue to distribute data collection forms and instructions to Tribal MIECHV grantees	Ongoing
Current Tribal MIECHV Form 2 Reporting Period (10/1/19-9/30/20)	Due by 12/31/20
Form 2 reporting will continue on an annual schedule throughout the OMB approved clearance timeframe.

17. 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.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

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