ombrocisTRIBALSASP2020supportstatement

Supporting Statement for Paperwork Reduction Act Submission
Semi-Annual Progress Report for the Tribal Sexual Assault Services Program
A. Justification
1.

Statutorily-Mandated Need for Information

The Sexual Assault Services Formula Program (SASP Program) was created by the
Violence Against Women and Department of Justice Reauthorization Act of 2005, as amended
by the technical amendments to that Act. The SASP Program directs grant dollars to states and
territories to assist them in supporting rape crisis centers and other nonprofit, nongovernmental
organizations or tribal programs that provide direct intervention and related assistance to victims
of sexual assault, without regard to age. This program is authorized by 34 U.S.C. §12511.
Survivors of sexual assault from culturally specific communities frequently confront
unique challenges when seeking assistance, such as linguistic and cultural barriers. Sexual
assault advocates report that survivors are more inclined to seek services from organizations that
are familiar with their culture, language, and background and that there is no “one size fits all”
solution to adequately address these critical needs. Tribes and tribal organizations are more
likely to understand the complex, multi-layered challenges and obstacles that victims from their
communities face when attempting to access services in response to the sexual assault.
In order to provide the most appropriate services to tribal victims, the SASP Tribal
Program targets nonprofit organizations that focus primarily on tribes and tribal organizations
that have experience in the area of sexual assault or who partner with an organization having
such expertise. The goal of the SASP Tribal Program is to create, maintain, and expand
sustainable sexual assault services provided by tribal organizations, which are uniquely situated
to respond to the needs of tribal sexual assault victims. 34 U.S.C. 12511 (e)
Currently, there are different statutory and regulatory reporting requirements that affect
SASP Tribal Program grantees. VAWA 2000 requires all VAWA grantees, including SASP
Tribal Program grantees, to report on the effectiveness of their programs to the Attorney General
who, in turn, must report to Congress every two years. Section 1003 of VAWA 2000 states that
(a) REPORT BY GRANT RECIPIENTS.- The Attorney General or Secretary of
Health and Human Services, as applicable, shall require grantees under any
program authorized or reauthorized by this division or an amendment made by
this division to report on the effectiveness of the activities carried out with
amounts made available to carry out that program, including number of persons
served, if applicable, numbers of persons seeking services who could not be
served and such other information as the Attorney General or Secretary may
prescribe.
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(b) REPORT TO CONGRESS.- The Attorney General or Secretary of
Health and Human Services, as applicable, shall report biennially to the
Committees on the Judiciary of the House of Representatives and the
Senate on the grant programs described in subsection (a), including the
information contained in any report under that subsection.
34 U.S.C. 10238.
OVW must also comply with the Government Performance and Results Act of 1993
(GPRA) (Pub. L. 103-62) which was enacted to increase Congressional and Administrative focus
on the results from government programs and activities. To meet its GPRA reporting obligations
and elicit more meaningful information about grantee performance, OVW has recently developed
performance measures, including output measures, regarding which the SASP Tribal Program
grantees must report on a semiannual basis.
2.

Use of Information

OVW uses data from the information collection 1 in different ways. OVW will use the
information collected from SASP Tribal Program grantees to monitor their grant-funded
activities and qualitatively assess those activities. In particular, OVW is seeking data that
includes baseline information to review activities supported with SASP Tribal Program funds,
including, for example, an increase in the number of trainings or an increase in the number of
victims served. OVW will review semiannual progress report to monitor individual SASP Tribal
Program grantee’s performance and ensure that the goals and objectives set forth in applications
for funding and award documents are met.
The SASP Tribal Program grantees collect information that addresses the following grantfunded activities (different sections on the reporting form): staff, statutory purpose areas,
informational materials, and victim services. Narrative questions at the end of these different
sections enable grantees to give more detailed qualitative information about their grant-funded
activities. In addition, SASP Tribal Program grantees must answer narrative questions on the
most significant areas of remaining need with regard to improving services to victims/survivors
of sexual assault, increasing victims/survivors safety, and enhancing community response
(including offender accountability or sex offenders), what has SASP Tribal Program funding
allowed the grantee to do that the grantee could not do prior to receiving funding, additional
information about the SASP Tribal Program grant and/or the effectiveness of the grant and any
additional information about the data submitted.
1 Under a cooperative agreement between OVW and the University of Southern Maine’s
Muskie School of Public Service, data collected from OVW grantees on all of OVW’s progress
report forms is transmitted to the Muskie School for analysis. For the analysis of the data,
standard descriptive statistics (frequency, sum, percentage, mean, etc.) are used to describe the
characteristics of the grantees and report basic findings. All analyses are conducted in SPSS 13.0.
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In addition to the proposed information collection, OVW will continue to use a number of
other techniques to assess the performance of SASP Tribal Program grantees. These may include
OVW staff attendance at site visits, grant-funded training and technical assistance events, staff
review of products prior to dissemination, and ongoing consultation with OVW staff.
OVW will aggregate data from all SASP Tribal Program grantees’ progress reports to assess
the performance of the SASP Tribal Program as a whole and to respond to Congressional,
Department of Justice, and other inquiries about how SASP Tribal Program funds are being used.
In addition, information collected from SASP Tribal Program grantees will support the following
OVW GPRA measures:
Number of victims receiving requested services;
Percentage of victims requesting services who received them;
Number of policies developed/revised; and
Number of communities with improved CCR.
Information collected from SASP Tribal Program grantees will enable OVW to respond to
statutory requirements to report on the effectiveness of grant-funded activities. The 2016
Measuring Effectiveness Report to Congress, which includes information about how funds were
expended and an assessment of the effectiveness of funded programs- see
https://www.justice.gov/ovw/reports-congress. This report is based on data submitted by SASP
Tribal Program grantees reflecting SASP Tribal Program awards made and SASP Tribal
Program‐funded activities engaged in during calendar years July 1, 2013- June 30, 2015. OVW is
in the process of submitting the 2018 Report to Congress.
The data that OVW collects on the semiannual progress reporting forms is currently not used
in connection with an evaluation of the SASP Tribal Program. OVW is currently exploring the
development of a multi-layered evaluation agenda for its grant programs.
3.

Use of Information Technology

The collection of information will involve the use of automated, electronic, mechanical or
other technological collection techniques or other forms of information technology. OVW
grantees are required to submit semiannual progress reports through the Grants Management
System (GMS).
4.

Duplication of Information Request

There is no other mechanism by which OVW collects information about grant funded
activities including number of victims served, victims seeking services who could not be served,
or persons trained.

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5.

Impact on Small Entities

There is no impact on small entities as the collection of this type of information is
routinely kept by most grantees receiving funds under the SASP Tribal Program.
6.

Consequences to Federal Programs or Policy

By statute, Congress has mandated that SASP Tribal Program grantees report to the
Attorney General on the effectiveness of their activities funded under VAWA. If OVW was not
able to collect the information necessary to complete these reports on behalf of the Attorney
General, not only would it be failing to meet a statutorily required reporting mandate, but also the
existence of this important and necessary grant program could be jeopardized.
7.

Special Circumstances

There are no special circumstances as identified in the specific instructions for a
supporting statement for Paperwork Reduction Act Submissions.
8.

Federal Register Publication

OVW has consulted with persons outside the agency who have advised that the data
proposed to be collected is available, the semiannual collection of such data is not burdensome,
the form is clear, and that the information is routinely kept by most grantees receiving funds
under the SASP Tribal Program. OVW has solicited public comment on this form in accordance
with the requirements of the Paperwork Reduction Act. A 60 day notice was published in the
Federal Register on December 13, 2019 (Federal Register, Volume 84, page 68193) and a 30-day
was notice was published in the Federal Register on March 26, 2020 (Federal Register, Volume
85, page 17097). OVW did not receive any public comments.
9.

Payment or Gift to Respondents
There will no payment or gift to respondents.

10.

Confidentiality

Although this information is needed for a public report to Congress, it will not involve
any personal information about victims that could identify them as specific individuals.
However, anecdotal, non-identifying information about the effectiveness of individual programs
may be included in the report. There is no assurance to confidentiality.
11.

Specific Questions
The semiannual progress report will not contain any questions of a personal, sensitive
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nature such as sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private.
12.

Hour Burden of the Collection of Information

This semiannual progress report is not overly burdensome. The data collection tool will
be completed by approximately 15 SASP Tribal grantees twice a year. There will be 30
semiannual responses and it is estimated that it will take grantees no more than 1 hour to
complete the progress report form. Thus, the semiannual reporting and recordkeeping hour
burden is 30 hours. SASP Tribal Program grantees are informed about the reporting
requirements during the grant solicitation process and during the grant award process.
OVW is seeking basic information that is routinely kept by the SASP Tribal Program
grantees in the normal course of their operations. Thus, the requirement that grantees complete
this progress report within a period of less than 30 days after receipt of it is not overly
burdensome. OVW estimates that it will take approximately 1 hour for a grantee to complete the
form. OVW developed this estimate based on the fact that information of this nature is already
kept by grantees receiving funds under the SASP Tribal Program and that the grantees have been
apprised of these reporting requirements during the solicitation process and reminded throughout
the grant award process. The progress report is divided into sections that pertain to the different
types of activities that grantees may engage in, i.e. training, product development, victim
services. Grantees will only have to complete the sections of the form that relate to their specific
activities.
13.

Cost Burden of the Collection of Information

OVW does not believe that there is any annual cost burden on respondents or
recordkeepers resulting from the collection of this information.
14.

Annualized Costs to the Federal Government

The annualized costs to the Federal Government resulting from the OVW staff review of
the progress reports submitted by grantees are estimated to be $1680.
15.

Program Changes or Adjustments

There are no program changes or adjustments for the estimates identified in Section 13
and in Section 14. This is a information collection that is necessary for OVW and its SASP
Tribal Program grantees to comply with the statutory reporting requirements and the Government
Performance and Results Act of 1993 (Pub. L. 103-62).
16.

Published Results of Information Collections

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There will be no complex analytical techniques used in connection with the publication of
information collected under the request. Information will be gathered once a year at the end of
the reporting periods. OVW is statutorily required to submit a report on the effectiveness of all
grant-funded activities on a biennial basis.
17.

Display of the Expiration Date of OMB Approval

OVW will display the Expiration Date of OMB Approval in the upper right hand corner
of the Progress Report.
18.

Exception to the Certification Statement

OVW is not seeking any exception to the certification statement identified in Item 19,
Certification for Paperwork Reduction Act Submissions, of OMB Form 83-I.

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