CMA ORR-2 Supporting Statement_8.10.22

ORR-2 Quarterly Report on Expenditures and Obligations

OMB Information Collection Request

0970 - 0407

Supporting Statement Part A - Justification

August 2022

Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services

1. Circumstances Making the Collection of Information Necessary

The Refugee Cash and Medical Assistance (CMA) program, implemented by the Office of Refugee Resettlement (ORR) in the Administration for Children and Families (ACF), Department of Health and Human Services (HHS), is a reimbursement program for costs incurred by States and non-profit organizations in providing assistance to refugees, asylees, Cuban/Haitian entrants, Amerasians, Afghans and Iraqis with Special Immigrant Visas, and victims of trafficking. The program reimburses States and non-profit organizations for the costs they incur in providing four types of assistance: cash assistance, medical assistance, medical screening, and services for unaccompanied minors. The program also reimburses grantees for their administrative costs. Reimbursement is provided through both mandatory and discretionary grant awards.

Currently, grantees under this program submit the ORR-2 Quarterly Report on Expenditures and Obligations on a quarterly basis. In the ORR-2 Quarterly Report on Expenditures and Obligations, grantees report total expenditures and unliquidated obligations that include costs for all components of the program and for administrative costs combined.

Since CMA is a reimbursement program, it is essential that ORR be able to project accurately what the costs of the program will be for each fiscal year in order to ensure that States are fully reimbursed. ORR regulations at 45 CFR Part 400.211 (attached) prescribe a specific methodology to be used by ORR each year in determining the number of months for which each year’s appropriation will provide full reimbursement (the time-eligibility period). Currently, ORR provides reimbursement for up to eight months of cash and medical assistance to eligible populations and for services to unaccompanied minors until emancipation. During the year, ORR continuously updates the estimating model to ensure that funds will be available to reimburse grantees for the current time-eligibility period. If ORR were to determine that funds were inadequate for the time-eligibility period, ORR would reduce the number of months of eligibility so that funds would be available for the entire year for cost reimbursement. This process ensures that all grantees are reimbursed for the services and assistance that they provide during the time–eligibility period.

The methodology at 45 CFR Section 400.211 requires that cost estimates be derived for each component of the program separately. The reason for this requirement is that the different components of the program increase in cost each year at differing rates. For instance, grantee administrative costs generally increase at a slower rate than do medical assistance costs. Since the accuracy of the overall cost prediction is greatly enhanced by using different inflators for each component of the program, financial reporting for each component of the program separately is critical to accurate predictions and to ensuring full reimbursement of grantees’ costs.

ORR is therefore proposing an extension of data collection form – the ORR-2 - Quarterly Report on Expenditures and Obligations. No revisions are proposed.

2. Purpose and Use of the Information Collection

As noted above, the ORR-2 quarterly information collection fulfills both the financial reporting requirement of the SF-425 Federal Financial Report and the program component cost reporting requirement of 45 CFR Part 400.211. In addition to providing ORR with the data necessary for accurate cost estimation to ensure that grantee expenditures on refugee resettlement will be fully reimbursed for the allowable time-eligibility period, these data are also critical for effective monitoring of grantees’ use of federal funds. The data is and will continue to be used internally only.

Review of grantee expenditures and obligations is an ongoing component of grantee monitoring to ensure that funds are being used appropriately. The ORR-2 provides data broken out by program component which greatly enhances this ongoing monitoring effort by providing information on changes and trends in each component of the program.

In addition, the program-component-level cost data contributes to the accuracy of the estimating model for program expenditures. The ORR-2 data will continue to enhance ORR’s ability to verify continually that funds will be adequate for the entire fiscal year and to ensure that no grantee experiences a reimbursement shortfall.

The ORR-2 - Quarterly Report on Expenditures and Obligations provides, in a manner that minimizes grantee reporting burden, both the data needed to meet the requirements of the SF-425 Federal Financial Report as well as the additional breakdowns of expenditures and obligations by program component that are critical to accurate cost projections.

3. Use of Improved Information Technology and Burden Reduction

This data collection form is and will continue to be completed and submitted through ACF’s online data collection system (Grant Solutions/OLDC).

4. Efforts to Identify Duplication and Use of Similar Information

No similar information collection exists that could be substituted for the information needed for program cost projections as required by 45 CFR Part 400.211. This form simultaneously fulfills the two requirements of providing data for financial review of grantee implementation of CMA projects and the data needed for accurate cost projections, which eliminates all potential duplication in information collection. The ORR-2 Quarterly Report on Expenditures and Obligations fulfills the requirement of the SF-425.

5. Impact on Small Businesses or Other Small Entities

The information to be collected is the minimum needed to meet the requirements of financial monitoring and cost projection. There will be no impact on small businesses.

6. Consequences of Collecting the Information Less Frequently

Collecting this information less frequently than quarterly would make ongoing monitoring of the costs being incurred under this reimbursement program less timely, thus significantly impact program effectiveness. Quarterly reporting allows sufficiently frequent tracking to ensure that CMA allocations fully reimburse grantees for their costs. ORR-2 reports are reviewed by program specialists and are tracked throughout each year.

ORR also uses financial data from grantees on an ongoing basis to update cost estimates. Quarterly cost estimates contribute to ensuring that federal funds are available to reimburse all grantees for the time-eligibility period. Quarterly reporting is also used in determining quarterly allocations of funds to grantees. Costs among grantees can vary significantly over the course of a year depending on the number and characteristics of the eligible population being resettled in their State. Allocations are recalculated each quarter so that awards will provide adequate reimbursement to grantees for their costs each quarter. ORR’s ability to determine quarterly allocations to grantees that will adequately reimburse their costs would be adversely affected by less frequent reporting.

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

There are no special circumstances pertaining to this form. Respondents will report quarterly. Respondents have more than 30 days to prepare responses; the data collection form will be available continuously to grantees from the beginning date of an award, thus allowing ample time for collecting data and reporting. Respondents submit one form electronically through ACF’s Grant Solutions/OLDC. Respondents do not need to retain records for more than three years after submission of the final expenditure report. There is no requirement for confidential information. The data collection is not a statistical survey.

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 May 27, 2022, Volume 87, Number 103, page 32168, and provided a sixty-day period for public comment. We did not receive comments.

9. Explanation of Any Payment or Gift to Respondents

There will be no payment or gift to respondents.

10. Assurance of Confidentiality Provided to Respondents

Since the respondents will be grantee organizations, rather than individuals, and since the reporting will be on expenditures and obligations of federal grant funds, there will be no assurance of confidentiality; and no Privacy Act System of Records will be established.

11. Justification for Sensitive Questions

There are no sensitive questions in this data collection. The collection is for grantee data on expenditures and obligations of federal grants.

12. Estimates of Annualized Burden Hours and Costs

There will be approximately 63 respondents. State agencies and State Replacement Designees are allocated funds through mandatory grant actions.

These grantees will prepare the ORR-2 Quarterly Report on Expenditures and Obligations four times a year; it is estimated that the time required each quarter will be 1.5 hours, or 6 hours per year. The ORR-2 is not anticipated to involve any additional data collection burden on grantees since these data are already being collected, cumulated, and reported quarterly. There is no additional incremental cost.

The ORR-2 data collection form will include only the data actually needed by the Office of Refugee Resettlement to monitor grantees and to provide data for program cost projections.

Information Collection Title	Total Number of Respondents	Annual Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours		Average Hourly Wage		Total Annual Cost
ORR-2 Quarterly Report on Expenditures and Obligations	63	4	1.5	378		$73.84		$27,911.52
Estimated Annual Burden Total:					378		Estimated Annual Cost Total:		$27,911.52

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 2021, which is $36.92 per hour. To account for fringe benefits and overhead the rate was multiplied by two which is $73.84. The estimate of annualized cost to respondents for hour burden is $73.84 times 1,920 hours or $141,773.

https://www.bls.gov/oes/current/oes119151.htm

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

It is not anticipated that there will be any Other Annual Cost Burden to Respondents and Record Keepers.

14. Annualized Cost to the Federal Government

We estimate that, for four reporting periods of the fiscal year, the review and analysis of the ORR-2 data on cash and medical assistance, child welfare and employment services by ORR staff will require four hours per state for each fiscal year ORR-2 submission, or one hour for each quarterly report.

Instrument	Number of Respondents	Average Burden Federal Hours Per Review	Total Burden Hours Per Response	Average Hourly Wage	Total Annual Cost
ORR-2	63	4	252	$48.33	$12,179
Estimated Total Annualized Cost to the Federal Government					$12,179

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 2021, which is $48.33 per hour. The estimate of annualized cost to respondents for hour burden is $48.33 times 252 hours or $12,179. This total amount covers time and effort of staff to review, clarify and correct reports, submit for approval process, and file. https://www.bls.gov/oes/current/oes131111.htm

15. Explanation for Program Changes or Adjustments

This is a renewal of an existing data collection and there are no changes proposed.

16. Plans for Tabulation and Publication and Project Time Schedule

There are no plans to publish these data. These data are for internal use only in monitoring the performance of grantees, in providing ongoing estimates of program cost to ensure that all costs can be reimbursed, and in allocating sufficient funds each quarter to ensure that grantees are reimbursed for all costs incurred. These data will be entered into a spreadsheet and tracked by program component and total cost. Program Specialists will have access to the forms as submitted and to the program-wide spreadsheet to assist them in financial monitoring of the grantees for which they are responsible. Additionally, the program component totals will be entered into the estimating methodology and used to project costs.

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

The OMB Expiration Date will be displayed on the information collection.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions.