OTIP-0564 - DVHT New - Supporting Statement_1.22.20

Domestic Victims of Human Trafficking Program Data

OMB Information Collection Request

New Collection

Supporting Statement Part A - Justification

January 2020

Submitted By:

Office on Trafficking in Persons

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

The Trafficking Victims Protection Act of 2000 (TVPA), as amended, authorizes the Secretary of Health and Human Services (HHS) to expand benefits and services to victims of severe forms of trafficking in persons in the United States (U.S.), without regard to their immigration status. The TVPA also authorizes HHS to establish and strengthen programs to assist United States citizens and lawful permanent residents who have experienced sex trafficking or severe forms of trafficking in persons (22 U.S.C. § 7105(f)(1)).

Acting under a delegation of authority from the Secretary of HHS, the Administration for Children and Families (ACF) awards cooperative agreements to organizations to establish a program to assist U.S. citizens and lawful permanent residents who have experienced human trafficking, the Domestic Victims of Human Trafficking (DVHT) Program. The DVHT Program will include: (1) the Domestic Victims of Human Trafficking Services and Outreach Program, (2) Demonstration Grants to Strengthen the Response to Victims of Human Trafficking in Native Communities Program, and (3) the Strengthen the Health Care Response for Victims of Human Trafficking Program. Through the DVHT Program, grantees will provide comprehensive case management to domestic survivors of human trafficking in a traditional case management, Native community, or health care setting.

ACF proposes to collect information on a quarterly and annual basis. The information collection captures information on participant demographics (e.g., age, sex, and country of origin), types of trafficking experienced (e.g., sex, labor, or both), types of enrollment, types of services requested and provided along with their cost, barriers to service delivery, subrecipients enrolled into the grantee’s network, victim outreach activities, and the types of training provided to subrecipient organizations or other partners.

ACF collects information to provide to Congress in an annual report on U.S. Government activities to combat trafficking that is prepared by the U.S. Department of Justice. Congress requires HHS and other appropriate Federal agencies to report, at a minimum, information on the number of persons who received benefits or other services under subsections (b) and (f) of section 7105 of Title 22 of the U.S. Code, the TVPA, in connection with programs or activities funded or administered by HHS. See Attachment A for legislative authority for the activities that are the basis of the information collection.

2. Purpose and Use of the Information Collection

This request is a new information collection. ACF is requesting to collect client level information on those served through the DVHT Program to better evaluate service delivery efforts, inform prevention programming, and monitor program outcomes. ACF is requesting to collect information on the type and cost of services provided through the program to respond to congressional inquiries related to program spending and to provide technical assistance to grantees on managing available funding for individuals and households enrolled in the program. ACF is requesting to collect information on the type of services being provided by subrecipients of the grantee to better understand service gaps across the United States. ACF is requesting information on the types of barriers the grantee experiences while trying to deliver services to clients to inform the development of technical assistance, policy, and resources to mitigate barriers and improve service delivery to clients.

The central purpose of DVHT is to connect survivors with the services they need to improve their well-being and health outcomes. Thus, ACF will use the information collected in the following ways:

1. To measure grant project progress and performance;

2. To assess program outcomes and success;

3. To assist the individual grantee(s) to assess and improve their projects over the course of the project period through technical assistance;

4. To improve the program over time through evaluation;

5. To provide information to Congress, other federal agencies, the public, and other countries and international bodies on the outputs and outcomes of the grant; and

6. To inform policy and program development that is responsive to the needs of victims of human trafficking.

Another purpose of this information collection is to fulfill a provision of the TVPA of 2000, as amended, that requires the Attorney General to submit annually the number of persons who received benefits and services through HHS funded programs and activities as victims of human trafficking (22 U.S.C. § 7103(d)(7)(A)). In addition to the Attorney General’s Annual Report to Congress and Assessment of U.S. Government Activities to Combat Trafficking in Persons, the U.S. Department of State reports annually on the performance and activities of the United States of America in combatting human trafficking and protecting victims, and the information received from ACF trafficking program grantees will be included in this report. Both of these reports, in turn, may help inform strategies and policies to prevent trafficking in persons and to identify and protect victims. ACF will also use this information to create infographics that share program successes and inform program evaluation efforts.

3. Use of Improved Information Technology and Burden Reduction

The DVHT grantees will collect the information and report it to ACF through online system, GrantSolutions. ACF will continue to look into developing technology that will allow for automated, secure data transfers in the future to further reduce the burden of reporting by the grantees.

4. Efforts to Identify Duplication and Use of Similar Information

The data to be collected relates to the ACF grants to implement the DVHT Program. Participants assisted by these grants will not concurrently be assisted by another federal program. ACF is the only agency to collect this information, so there is no duplication.

5. Impact on Small Businesses or Other Small Entities

Not applicable.

6. Consequences of Collecting the Information Less Frequently

The information collected on clients enrolled in the DVHT program is submitted on a quarterly and annual basis to monitor grantee performance throughout the fiscal year as outlined in the Funding Opportunity Announcements (inclusive of the Domestic Victims of Human Trafficking and Services Outreach Program, Demonstration Grants to Strengthen the Response to Victims of Human Trafficking in Native Communities Program, and the Strengthen the Health Care Response for Victims of Human Trafficking Program). Grantees are required to demonstrate progress towards achieving grant project activities and a less frequent collection would impede the project officer’s ability to assess grant performance and weaken the analysis used during the annual non-competing continuation application process to award funding for these cooperative agreements.

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

There are no special circumstances relating to the Guidelines of 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 February 8, 2019, Volume 84, Number 27, page 2873, and provided a sixty-day period for public comment. During the notice and comment period, two comments were received, which are attached.

ACF received comments suggesting: increasing the estimated time to complete the Client Characteristics and Enrollment Form, removing all information that is not needed to determine client eligibility for the program, limiting the capture of information through the Partnership Development Forms to subrecipient organizations, removing information on the client’s service use through the Client Service Use and Delivery Form, and removing information from the Client Case Closure Form on the client’s social determinants of health such as their employment status and housing stability.

ACF increased the burden estimate for the Client Characteristics and Enrollment Form to one hour and eliminated data elements on the client’s victimization history, risk factors, school enrollment, English fluency, county level geographic locations, and systems involvement in response to public comment. ACF maintained data elements necessary for grant performance monitoring and program evaluation, such as the services needed and received by clients while enrolled in the program along with information on the client’s social determinants of health, and provided guidance that the disclosure of detailed information about the client’s trafficking experience is not required for services and that the grantee should mark unknown when the information is not provided. ACF limited the collection of partnership data to the grantee’s subrecipients only and eliminated the Technical Assistance Form to reduce burden.

ACF also consulted with the Administration for Native Americans and the Health Resources and Services Administration within HHS to ensure that the information collection is responsive to the needs of Native community and health care organizations who may apply to implement the DVHT program through the Demonstration Grants to Strengthen the Response to Victims of Human Trafficking in Native Communities Program and the Strengthen the Health Care Response for Victims of Human Trafficking Program.

In addition to modifying the information collection based upon public comments, ACF added two new forms on outreach and direct service spending due to a program merger with the Look Beneath the Surface Regional Anti-Trafficking Program, formerly the Rescue and Restore Victims of Human Trafficking Program, to improve the outreach, victim identification, and service delivery strategies to domestic victims of human trafficking. The Victim Outreach Form collects information on the settings where outreach took place, populations targeted, and number of individuals identified as having experienced human trafficking. The DVHT Spending Form captures the amount of grant funding spent on direct services and program administration.

9. Explanation of Any Payment or Gift to Respondents

Not applicable.

10. Assurance of Confidentiality Provided to Respondents

Respondents include participants working with case managers who will abide by confidentiality agreements established by the grantee organization for which they work. The grantee’s confidentiality agreements/privacy disclosures explain what information will be shared through routine reporting to the funding organization (ACF) for analysis, assessment of the program’s success, congressional reporting, evaluation, and research. The grantees will provide the information collected from their subrecipients sharing a system generated client identifier in lieu of personally identifiable information such as the client’s name or social security number.

11. Justification for Sensitive Questions

ACF has received inquiries and direction from anti-trafficking stakeholders, including the U.S. Advisory Council on Human Trafficking, to collect data on specialized populations who disproportionately experience human trafficking or may be at risk including individuals with disabilities and those who identify as lesbian, gay, bisexual, transgender, or queer. ACF has retained questions asking about the client’s disability status, sexual orientation or gender identity, and trafficking experience to better understand the populations at risk of human trafficking, inform program development, assess the unmet needs of these populations, and respond to recommendations from the Advisory Council’s 2019 report. Clients have the right not to disclose this information and the grantee will inform their subrecipients and clients of how their information will be used through their confidentiality agreements/privacy disclosures.

12. Estimates of Annualized Burden Hours and Costs

Instrument	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
Client Characteristics and Enrollment Form	1,908	1	1	1,908	636	$44.28	$28,162.08
Client Service Use and Delivery Form	1,908	3	.25	1,431	477	$44.28	$21,121.56
Client Case Closure Form	1,908	1	.167	319	106	$44.28	$4,693.68
Barriers to Service Delivery and Monitoring Form	36	15	.167	90	30	$44.28	$1,328.40
DVHT Spending Form	36	3	.75	81	27	$44.28	$1,195.56
Partnership Development Enrollment Form	25	1	.25	6	2	$68.92	$137.84
Partnership Development Exit Form	25	1	.083	2	1	$68.92	$68.92
Training Form	36	15	.5	270	90	$68.92	$6,202.80
Victim Outreach Form	36	15	.3	162	54	$68.92	$3,721.68
Estimated Annual Burden Total:					1,423	Estimated Annual Cost Total:	$66,633

The job code is 21-1099 and wage data from May 2018 is $22.14 per hour. Therefore to account for fringe benefits and overhead the rate is multiplied by two which is $44.28. This accounts for the forms filled out by case management or direct services staff members (e.g., client forms, barriers to service delivery, and spending form). The other job code for the forms is 11-9151 and wage data from May 2018 is $34.46. Therefore to account for fringe benefits and overhead the rate is multiplied by two which is $68.92 for those forms filled out by program managers (e.g., partnership, training, and victim outreach forms). The estimate of annualized cost to respondents for hour burden is $44.28 times 1,276 or $56,501.28 along with $68.92 times 148 or $10,200.16 for a total cost to respondents of $66,632.52. https://www.bls.gov/oes/current/oes211093.htm

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

Grant performance progress reports are reviewed by salaried staff who assess program performance as a regular part of their work. ACF anticipates that the review of the information reported by the grantee(s) will cost $44.52 per hour (job code 15-2041 and wage data from May 2018 of $44.52 per hour) and take 130 hours annually costing $5,787.60 annually. This includes the time it takes for the data to be cleaned, organized, interpreted, and summarized into usable information. An additional 40 hours will be spent annually by the grant officer to review and discuss the submissions with the grantee at $41.22 per hour (job code 19-3099 and wage data from May 2018 of $41.22 per hour) for an annual total of $1,648.80. The annual cost to the federal government is $7,436.40 in staff time.

15. Explanation for Program Changes or Adjustments

This is a new information collection.

16. Plans for Tabulation and Publication and Project Time Schedule

ACF will conduct univariate analysis to describe the service population and ascertain patterns. Summary findings will be presented in briefings, infographics, fact sheets, federal reports, responses to congressional inquiries or Freedom of Information Act requests, and presentations.

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

Not applicable.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions are necessary for this information collection.