ombrocisElder2021supportstatement

Supporting Statement for Paperwork Reduction Act Submission
Semi-Annual Progress Report for Enhanced Training and Services to End
Violence Against Women Later in Life Program
A. Justification
1.

Statutorily-Mandated Need for Information

Recognizing that older individuals, as well as victims who are persons with disabilities,
who are victims of abuse and sexual assault face unique barriers to receiving assistance,
Congress originally created the Training Grants to Stop Abuse and Sexual Assault Against Older
Individuals or Individuals with Disabilities Program to provide training to assist law enforcement
officers, prosecutors, and relevant officers of Federal, State, tribal, and local courts in
recognizing, addressing, investigating, and prosecuting instances of elder abuse, neglect, and
exploitation, and violence against individuals with disabilities, including domestic violence and
sexual assault, against older or disabled individuals. In 2005, Congress re-authorized the
Violence Against Women Act (VAWA) and amended the Training Grants Program to add
additional authorized grant-funded activities. The Enhanced Training and Services to End
Violence Against Women Later in Life Program (Elder Program) funds projects that will
provide training to criminal justice professionals, governmental agency staff and victim
assistants to enhance their ability to address elder abuse, neglect and exploitation in their
communities; provide cross training opportunities to professionals working with older victims;
develop or enhance a community coordinated response to elder abuse; and provide or enhance
services for victims who are 50 years of age or older.
Currently, there are different statutory and regulatory reporting requirements that affect
Elder Program grantees. VAWA 2000 requires all VAWA grantees, including Elder 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.
(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
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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 Elder
Program grantees must report on a semi-annual basis.
2.

Use of Information

OVW uses data from the information collection 1 in different ways. OVW will use the
information collected from Elder 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 Elder Program funds, including, for example, an
increase in the number of trainings or an increase in the number of victims served. OVW will
review each semi-annual progress report to monitor individual grantee’s performance, including
the grant-funded activities and to ensure that the goals and objectives set forth in applications for
funding and award documents are met.
The Elder Program grantees collect information that addresses the following grant-funded
activities (different sections on the reporting form): staff, statutory purpose areas, training,
community coordinated responses, education, policies, 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, Elder Program grantees must answer
narrative questions on the status of the grant goals and objectives, the most significant areas of
remaining need with regard to obstacles faced by individuals and what Elder Program funding
has allowed the grantee to do that it could not do prior to receiving the funding. There are also
optional narrative questions addressing additional information on the Elder Program grant and/or
the effectiveness of the grant and on additional information on the data submitted.
In addition to the proposed information collection, OVW will continue to use a number of
other techniques to assess the performance of Elder 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.
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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OVW will aggregate data from all grantees’ progress reports to assess the performance of
the Elder Program as a whole and to respond to Congressional, Department of Justice, and other
inquiries about how Elder Program funds are being used. In addition, information collected from
grantees will support the following performance measures:
Number of victims receiving requested services;
Number of protection orders issued;
Number of policies developed/revised;
Number of communities with improved community coordinated responses;
Percentage of victims requesting services who received them;
Number of grant funded multi-disciplinary training events that have occurred; and
Number of professionals trained to respond to domestic violence, dating violence, sexual assault,
and stalking.
Information collected from Elder Program grantees will enable OVW to respond to statutory
requirements to report on the effectiveness of grant-funded activities. . OVW has submitted the
2018 Measuring Effectiveness Report to Congress, which includes information about how funds
were expended and an assessment of the effectiveness of funded programs. This report is based
on data submitted by grantees reflecting Elder Program awards made from July 1 2015 - June
30, 2017.
The data that OVW collects on the semi-annual progress reporting forms is currently not
used in connection with an evaluation of the Elder Program. OVW is currently exploring the
development of a multi-layered evaluation agenda for its grant programs.
It is important that OVW collect this information from Elder Program grantees on a semiannual basis so that OVW can ensure that they are performing within the statutory limitations of
the program in a timely manner. Because OVW is not able to perform site visits with every Elder
Program grantee, the review of progress reports every six months enables OVW to monitor
grantees in timely manner. It is easier to identify a potential resolution for a matter that needs
correction or modification if the issue is identified sooner rather than later. An annual report
would increase the potential for grantees, unintentionally or intentionally, to spend grant funds
inappropriately for a longer period of time. Semi-annual reporting periods allow for more
frequent course corrections and interaction between the grantee and OVW.
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 semi-annual 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
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activities including number of victims served, victims seeking services who could not be served,
or persons trained.
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 Elder Program.
6.

Consequences to Federal Programs or Policy

By statute, Congress has mandated that Elder 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 semi-annual 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 Elder 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 August 23, 2021 (Federal Register, Volume 86, page 47158) and a 30-day was notice
was published in the Federal Register on November 26, 2021(Federal Register, Volume 86,
page 67497).
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
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The semi-annual progress report will not contain any questions of a personal, sensitive
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 semi-annual progress report is not overly burdensome. The data collection tool will
be completed by approximately 18 Elder Program grantees twice a year. There will be 36 semiannual responses and it is estimated that it will take grantees no more than 1 hour to complete the
progress report form. Thus, the semi- annual reporting and recordkeeping hour burden is 36
hours. Elder 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 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 Elder Program and that the grantees have been apprized 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 grant-funded activities.
13.

Cost Burden of the Collection of Information

OVW does not believe that there is any semi-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 $2016.
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 Elder
Program grantees to comply with the statutory reporting requirements and the Government
Performance and Results Act of 1993 (Pub. L. 103-62).
16.
of

Published Results of Information Collections
There will be no complex analytical techniques used in connection with the publication
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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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