Social Services Block Grant (SSBG) Post-Expenditure Report, Pre-Expenditure and Intended Use Plan
OMB Information Collection Request
0970-0234
Supporting Statement Part A - Justification
February 2021
Submitted By:
Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
SUPPORTING STATEMENT A – JUSTIFICATION
Summary
The Administration for Children and Families (ACF) is requesting a revision to the Social Services Block Grant (SSBG) Post-Expenditure Report, Pre-Expenditure Report, and Intended Use Plan (OMB #0970-0234), previously titled, “Social Services Block Grant (SSBG) Post-Expenditure Report”). ACF is proposing to expand the information collection to include the collection of states’ Intended Use Plans and retitle the information collection to clarify the role of the Pre-Expenditure Report. An Intended Use plan is a narrative to accompany a state’s pre-expenditure report and allows the ACF Office of Community Services to identify recipients, methods, and categories for state expenditure of SSBG funds. The proposed form will standardize reporting submissions for SSBG, which will increase the efficiency in reporting and assessment for grantees and federal staff.
Circumstances Making the Collection of Information Necessary
The Social Services Block Grant (SSBG) program is authorized under Title XX of the Social Security Act, as amended, and is codified at 42 U.S.C. §1397 through §1397e. The implementing regulations for this and other block grant programs authorized by Omnibus Budget Reconciliation Act of 1981 are published at 45 C.F.R. Part 96. Those regulations include both specific requirements and general administrative requirements in lieu of 45 CFR Part 92 (the HHS implementation of the A-102 Common Rule) for the covered block grant programs. Requirements specific to SSBG are found in 45 C.F.R. §96.70 through §96.74.
The SSBG program provides funds to States, the District of Columbia, Guam, Puerto Rico, American Samoa, the Virgin Islands, and the Commonwealth of the Northern Mariana Islands (hereinafter referred to as States) to support social services for adults and children in support of five statutory goals (42 U.S.C. §1397). Funds are allocated to the States on the basis of population as block grants for the administration of their social services programs.
Within specific legal limitations (42 U.S.C. §1397d), States have substantial discretion in the use of funds and may determine what services will be provided, who will be eligible, and how funds will be distributed among the various services. State or local SSBG agencies (i.e., county, city, and regional offices) may provide the services or purchase them from qualified agencies or organizations. States report recipients of SSBG-funded services as any individuals who receive a service funded, in whole or in part, by SSBG.
Before a State receives SSBG funds, it must provide information specifying the intended use of the block grant. Annually, states must provide the ACF Office of Community Services (OCS) with information on the types of activities to be supported, the characteristics of individuals to be served, and the estimated amount of SSBG funding that will be allocated to each service category (42 U.S.C. §1397c). Historically, there was no specific format required for states to submit this information and ACF recommended that grantees use the post-expenditure reporting form to identify the intended use funding estimates. A state’s plan for intended use of funds are used to provide funding OCS with pre-expenditure estimates, which are most commonly provided through the post-expenditure reporting form and are referred to as the pre-expenditure report. Estimated burden for the submission of pre-expenditure report data has historically been included within the burden estimates for the SSBG Post-Expenditure Report (0970-0234).
This revision request is to provide a standard form and clear instructions for the Intended Use Plan, which is a narrative to accompany the pre-expenditure report, and to update the supporting statement to provide more specific information about and burden related to the reporting requirements for Intended Use Plans. We would like to implement these changes prior to the next due date (June 1, 2021).
There are no changes requested to the standard post-expenditure reporting form, which is required of states to report expenditures of SSBG funds. Information reported includes an annual total of adults and children served and expenditures in each of 29 service categories. Post-expenditure reporting requirements for SSBG are codified at 45 C.F.R. § 96.74. States must submit their annual Post-Expenditure Report within 6 months of the end of the period covered by the report, and must address:
The number of individuals (broken out by children, adults age 59 and younger, adults age 60 and older, and adults of unknown age) who receive services paid for in whole, or in part, with Federal funds under the SSBG.
The amount of SSBG funds spent in providing each service.
The amount of funds transferred into SSBG from the Temporary Assistance for Needy Families (TANF) block grant.
The amount of carryover funds expended in the current fiscal year, and intended to be carried over into the next fiscal year.
The total amount of Federal, State and local funds spent in providing each service, including SSBG funds.
The method(s) by which each service was provided, showing separately the services provided by public and private agencies, or both.
Eligibility for services with each SSBG Service Category determined by the state.
State definitions of child, adult, and family as they relate to services provided by SSBG funds.
Assurances related to the appropriate use of TANF transfer funds, based on statute.
Purpose and Use of the Information Collection
Information collected on the Post-Expenditure Report is analyzed and described in an annual report produced by OCS. The report is available for grantees, federal partners, and stakeholders and provides information regarding State SSBG expenditures and service recipients. The report can be accessed on the SSBG website. Annual reports have been completed each year for the years 1998 – 2018. The 2019 annual report is currently being finalized. The information contained in this report is used to establish how SSBG funding is used for the provision of services in each State. The information collected is the only source of information on the use of SSBG funds by the States. It is also the only source of information on the number of recipients of services funded, in whole or in part, by SSBG.
In addition, the Government Performance and Results Act of 1993 (GPRA) requires all Federal agencies to develop long-term Strategic Plans defining general goals and objectives for their programs; to develop Annual Performance Plans specifying measurable performance goals for all of the program activities in their budgets; and to publish an Annual Performance Report showing actual results compared to each annual performance goal. Toward this end, two performance measures were developed to improve efficiency and accountability within States’ SSBG programs. The first of these measures aims to minimize administrative costs and maximize the amount of funds used for the provision of direct services. The second performance measure analyzes the degree to which States spend SSBG funds in a manner consistent with their intended use as required by the Federal law [42 U.S.C. §1397e (a)]. These performance measures require both pre-expenditure and post-expenditure data.
The Intended Use Plan allows the ACF OCS to identify recipients, methods, and categories for state expenditure of SSBG funds. The proposed form will standardize reporting submissions for SSBG, which will increase the efficiency in reporting and assessment for grantees and federal staff.
Use of Improved Information Technology and Burden Reduction
States enter the Pre-Expenditure Report, Intended Use Plan (narrative) and Post-Expenditure Report data on the SSBG Portal. The SSBG Portal is a secure web-based data collection platform which is monitored by Walter R. McDonald and Associates, contractor. The SSBG Portal allows for efficient data submission without increasing the overall burden on States. It provides a user-friendly means for States to submit and access their Intended Use Plan, Pre-Expenditure data, and Post-Expenditure Report.
Efforts to Identify Duplication and Use of Similar Information
The Post-Expenditure Report is the only instrument for collecting data on actual expenditures for, and recipients of, the 29 SSBG-supported service categories. SSBG grantees use the Pre Expenditure form to estimate SSBG expenditures at the beginning of the budget period. Grantees and SSBG staff use the comparison between the pre and post expenditure data to analyze and support effective planning and budget reconciliation.
Impact on Small Businesses or Other Small Entities
This data collection does not impact small business or other small entities.
Consequences of Collecting the Information Less Frequently
States are required to submit an annual Post-Expenditure Report on the use of SSBG funds [42 U.S.C. 1397e]. States may also use the Post-Expenditure Report form to provide pre-expenditure data for the required annual Intended Use Plan. This information is critical for understanding the impact of SSBG funding and for assessing States on the two SSBG program performance measures.
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
There are no special circumstances for the Pre-Expenditure information, Intended Use Plan and Post-Expenditure Report.
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 December 9, 2020, Volume 85, Number 237, page 79185, and provided a sixty-day period for public comment. During the comment period, no comments were received.
Explanation of Any Payment or Gift to Respondents
No payment or gift will be provided to respondents.
Assurance of Confidentiality Provided to Respondents
No assurance of confidentiality will be provided to respondents. All reported expenditure data are from State public financial records and all recipient data are aggregate counts, not individual case-level data. No personal identifiers will be collected. IRB review is not required for data reporting.
Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature.
Estimates of Annualized Burden Hours and Costs
Information Collection Title |
Total Number of Respondents |
Total Number of Responses Per Respondent |
Average Burden Hours Per Response |
Total Burden Hours |
Annual Burden Hours |
Average Hourly Wage |
Total Annual Cost |
Pre-Expenditure Report Form |
56 |
3 |
2 |
336 |
112 |
$62.45 |
$6,994.40 |
Intended Use Plan |
56 |
3 |
40 |
6,720 |
2,240 |
$62.45 |
$139,888.00 |
Post-Expenditure Reporting Form |
56 |
3 |
110 |
18,480 |
6160 |
$62.45 |
$384,692.00 |
Estimated Annual Burden Total: |
8,512 |
Estimated Annual Cost Total: |
$531,574.40 |
||||
The estimated annual cost is based upon the average hourly salary for social and community service managers, job code 11-9151 based on May 2019 Occupational Employment Statistics from the Bureau of Labor and Statistics1. The base wage is equal to the mean salary of $32.28 per hour. The base wage was multiplied by two to calculate wage plus fringe benefits and overhead.
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
States will not incur any additional costs.
Annualized Cost to the Federal Government
The annual cost to the Federal Government is shown in the following table:
AGENCY |
Year 1 |
Year 2 |
Year 3 |
Average Annual Cost |
Office of Community Services |
$41,853 |
$43,182 |
$44,511 |
$43,182 |
Contractor Staff |
$156,123 |
$168,255 |
$179,930 |
$168,103 |
Total |
$197,976 |
$211,437 |
$224,441 |
$211,285 |
The dollar amounts displayed for the Office of Community Services represents a portion of two Federal staff salaries at a GS-12 level to perform the duties of a social services program specialist.
The dollar amount displayed for the Contractor Staff represents a team from Walter R. McDonald & Associates, Inc. who provides data collection and support annually for the Office of Community Services.
Explanation for Program Changes or Adjustments
This request includes the addition of a standard reporting form for states to submit Intended Use Plans and also identifies burden for the pre-expenditure report more clearly in A12. The addition of the Intended Use Plan form and instructions increases burden under OMB #0970-0234.
Plans for Tabulation and Publication and Project Time Schedule
States’ Pre-Expenditure, Intended Use Plan and Post-Expenditure Reports provide data for the annual report on SSBG expenditures and recipients. The report is shared with grantees, federal partners, and stakeholders through the SSBG website. The schedule for the annual report is as follows:
Pre-Expenditure Report/Intended Use Plan :
An annual Pre-Expenditure Report that describes how the State plans to administer its SSBG funds for the upcoming year must be submitted prior to receipt of a SSBG allotment. This report must be submitted 30 days prior to the start of the fiscal year (June 1 if the state operates on a State Fiscal Year, or September 1 if the state operates on a Federal Fiscal Year.
Examples:
The report or plan covers State Fiscal Year 2021, which runs from July 1, 2020 to June 30, 2021.
The report or plan covers Federal Fiscal Year 2021, which runs from October 1, 2020 to September 30, 2021.
Post-Expenditure Reporting
States will submit the Post-Expenditure Report no later than 6 months after the end of their fiscal year. Grantees that report on a State Fiscal Year, which will end on June 30, will submit the Post-Expenditure Report by December 30. States that report on the Federal Fiscal Year, which will end on September 30, will submit their Post-Expenditure Reports by March 30 of the following calendar year.
The OCS contractor develops a draft and submits to OCS for review in June, 3 months after States reporting on the Federal Fiscal Year submit their Post-Expenditure Reports.
The second draft will be submitted for clearance within ACF in July.
The final report will be submitted for review by ACF’s Office of Administration in August.
The annual report will be submitted for publication in September.
Reason(s) Display of OMB Expiration Date is Inappropriate
The expiration date for OMB approval will be displayed.
Exceptions to Certification for Paperwork Reduction Act Submissions
No exceptions to the certification statement are necessary.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Wilson, Camille (ACF) (CTR) |
| File Modified | 0000-00-00 |
| File Created | 2021-03-17 |