0970-0351 State Plan Supporting Statement 2021.03.18

State Plan for Grants to States for Refugee Resettlement

OMB Information Collection Request

0970 - 0351

Supporting Statement

Part A - Justification

March 2021

Submitted By:

Office of Refugee Resettlement

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

In order for a State or Replacement Designee (RD) to receive refugee resettlement assistance funds, it must submit a plan that meets the requirements of 8 U.S.C. 1522 of the Immigration and Nationality Act (the Act) [Title IV, Sec. 412 of the Act] for each state agency requesting federal funding for refugee resettlement under 8 U.S.C. 524 [Title IV, Sec. 414 of the Act]) and 45 CFR Part 400. The State Plan Template for Grants to States for Refugee Resettlement provides states and RDs with the required components and mandatory sequence of a State Plan. The collection is necessary for the Office of Refugee Resettlement (ORR) to ensure that a state or RD administering an ORR-funded refugee assistance program has prepared a plan that meets the requirements of 45 CFR Part 400.

This information collection request is to extend approval of the existing State Plan Template with revisions to reflect the current number of RDs and incorporate clarifications based on Public/Private Program (PPP) guidance that was published in the Fiscal Year (FY) 2020.

2. Purpose and Use of the Information Collection

The information provided through the State Plan assures ORR that the states, the District of Columbia, and RDs under 45 CFR 400.301(c), administering or supervising the administration of programs under Title IV of the Act are capable of administering refugee assistance and coordinating employment and other social services for eligible caseloads in conformity with specific requirements of title IV of the Act and 45 CFR Part 400.

The State Plan serves as the application to participate in the Refugee Resettlement Program describing and assuring that all aspects of the program will be implemented to conform with 45 CFR Part 400. This information also helps ORR analyze assistance rates in various states while reviewing CMA budget estimates.

3. Use of Improved Information Technology and Burden Reduction

Data for this information collection will be accepted electronically via email. ORR is exploring options for web based online submission in the future.

4. Efforts to Identify Duplication and Use of Similar Information

No other data source collects similar information.

5. Impact on Small Businesses or Other Small Entities

N/A

6. Consequences of Collecting the Information Less Frequently

States and RDs must submit a new or amended State Plan annually. ORR’s Cash and Medical Assistance and Refugee Support Services program funds are allocated to states and RD’s based on refugee and other eligible population data. The absence of an approved annual state plan would impede the awarding of such funds.

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

There are no special circumstances required in the collection of this information in a manner other than required by OMB.

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 9, 2020, Volume 85, Number 217, page 71347, and provided a sixty-day period for public comment. ORR did not receive any comments.

After the sixty-day period for public comment, ORR received a recommendation from the State of Arizona to implement the revised instrument one year after the OMB approval.

ORR response: ORR plans to implement the instrument for FY 2022 (immediately after OMB approval) because the revised instrument includes provisions that address the emergence of programs administered by Replacement Designees since the instrument was last updated and approved by OMB. There are now 18 RDs that administer all or part of the Refugee Resettlement Programs in various states. The revised instrument also incorporates PPP clarifications that were published in the new PPP guidance document in FY 2020.

9. Explanation of Any Payment or Gift to Respondents

N/A

10. Assurance of Confidentiality Provided to Respondents

Information provided in the State Plans is not confidential.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature in the application requirements.

12. Estimates of Annualized Burden Hours and Costs

There are 62 respondents, which includes 43 states, 18 RDs and District of Columbia. The response frequency is annual, if the State Plan is approved by OMB for three years it would amount to three responses total per respondent. Since the previous approval of the State Plan, ORR divisions responsible for specific parts of the RRP (Division of Refugee Assistance, Division of Refugee Health, and Unaccompanied Refugee Minors) reviewed the estimated time to complete and revise the template and revised the estimated time per response. Based on their experience and regular communication with states, ORR updated the estimated time for respondents to address all aspects of the Plan and make necessary revisions to a total of 18 hours per response, which represents a 3-hour increase since the previous approval.

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
Title IV State Plan	62	3	18	3,348	1,116	$71.84	$80,173
Estimated Annual Burden and Cost Totals:					1,116		$80,173

The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for Social and Community Services Managers [11-9151] and wage data from May 2019, which is $35.92 per hour. To account for fringe benefits and overhead the rate was multiplied by two which is $71.84. The estimate of annualized cost to respondents for hour burden is $71.84 times 1,116 hours or $80,173.

https://www.bls.gov/oes/current/naics4_999200.htm

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

There are no costs to respondents or record keepers.

14. Annualized Cost to the Federal Government

Instrument	Number of Respondents	Average Burden Federal Hours Per Review	Total Burden Hours Per Response	Average Hourly Wage	Total Annual Cost
Title IV State Plan	62	8	496	$45.50	$22,568
Estimated Total Annualized Cost to the Federal Government					$22,568

The cost to respondents was calculated using the Bureau of Labor Statistics (BLS) job code for Management Analysts [13-1111] and wage data from May 2019, which is $45.50 per hour. The estimate of annualized cost to respondents for hour burden is $45.50 times 496 hours or $22,568. This total amount covers time and effort of staff to review, clarify and correct plans, submit to approval process, and file.

https://www.bls.gov/oes/current/naics4_999100.htm

15. Explanation for Program Changes or Adjustments

This request is a renewal of the existing instrument with revisions. With the elimination of the Wilson-Fish Alternative Program, there are now 18 Replacement Designees along with 43 states participating in refugee program. The instrument was revised to reflect the increase in number of RDs and to incorporate PPP clarifications that were published in the new PPP guidance.

16. Plans for Tabulation and Publication and Project Time Schedule

States must submit by August 15 each year a new or amended State Plan for the next Federal FY.

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

N/A

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification statement.