ombrocisSASP2022supportstatement

Supporting Statement for Paperwork Reduction Act Submission
Progress Report for Sexual Assault Services Formula Grant 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.
Currently, there are different statutory and regulatory reporting requirements that affect
SASP Program grantees. VAWA 2000 requires all VAWA grantees, including SASP 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
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
Program grantees must report on an annual basis.
2.

Use of Information
1

OVW uses data from the information collection 1 in different ways. OVW will use the
information collected from SASP State Administrators and subgrantees to monitor their grantfunded activities and qualitatively assess those activities. In particular, OVW is seeking data that
includes baseline information to review activities supported with SASP Formula Grant funds,
including, for example, an increase in the number of trainings or an increase in the number of
victims served. OVW will review each annual progress report to monitor individual SASP State
Administrator’s performance, including the grant-funded activities of subgrantees, and ensure
that the goals and objectives set forth in applications for funding and award documents are met.
The SASP subgrantees grantees collect information that addresses the following grant-funded
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
subgrantees to give more detailed qualitative information about their grant-funded activities. In
addition, SASP subgrantees 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 funding allowed the subgrantee to do that
subgrantee could not do prior to receiving funding, additional information about the SASP
subgrant and/or the effectiveness of the subgrant and any additional information about 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 SASP grantees and subgrantees. 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 grantees’ and subgrantees’ progress reports to
assess the performance of the SASP as a whole and to respond to Congressional, Department of
Justice, and other inquiries about how SASP funds are being used. In addition, information
collected from SASP grantees will support the following OVW GPRA measures:
Number of victims receiving requested services;
Percentage of victims requesting services who received them;
Number of protection orders issued;
Number of policies developed/revised; and
Number of communities with improved CCR.
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.
2

Information collected from SASP grantees will enable OVW to respond to statutory
requirements to report on the effectiveness of grant-funded activities. The SASP 2016 Report to
Congress, which includes information about how funds were expended and an assessment of the
effectiveness of funded programs- see 2016 Sexual Assault Services Program (SASP)
Report to Congress - August 2018 (justice.gov). This report is based on data
submitted by SASP administrators and SASP subgrantees reflecting SASP awards made and
SASP‐funded activities engaged in during calendar years 2013 and 2014.
The data that OVW collects on the annual progress reporting forms is currently not used in
connection with an evaluation of the SASP 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 annual progress reports through the Just Grants Management
System.
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.
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 Program.
6.

Consequences to Federal Programs or Policy

By statute, Congress has mandated that SASP 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.

3

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 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 SASP 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 October 29, 2021 (Federal Register, Volume 86, page 60074) and a 30-day was
notice was published in the Federal Register on December 27, 2021(Federal Register, Volume
86, page 73347). OVW received a single comment questioning the use of federal funds for this
program.
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 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 annual progress report is not overly burdensome. The data collection tool will be
completed by approximately 606 SASP grantees and subgrantees once a year. There will be 606
annual responses and it is estimated that it will take grantees and subgrantees no more than 1
hour to complete the progress report form. Thus, the annual reporting and recordkeeping hour
burden is 606 hours. SASP 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 grantees and
subgrantees in the normal course of their operations. Thus, the requirement that grantees and
subgrantees 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 or a
subgrantee to complete the form. OVW developed this estimate based on the fact that
information of this nature is already kept by grantees and subgrantees receiving funds under the
SASP and that the grantees have been apprised of these reporting requirements during the
4

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 and subgrantees 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 $33,936.
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
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
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.

5

6