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ACF
Response to Public Comments on the Tribal Maternal, Infant, and Early
Childhood Home Visiting Program: Form 2 Grantee Performance Measures
(OMB #0970-0500)
The
Association for State and Tribal Home Visiting Initiative (ASTHVI)
Tribal Committee provided comments during the 60-day comment period
(87 FR 43529) for the request to extend approval of Tribal Maternal,
Infant, and Early Childhood Home Visiting Program: Form 2 Grantee
Performance Measures
(OMB
#0970-0500). After reviewing the comments, ACF has provided the
following responses.
ASTHVI
Comment
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ACF
Response
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Tribal
MIECHV grants are much smaller than the grants that are awarded to
states, and the administrative burden of meeting Tribal MIECHV
requirements is proportionally greater. Most Tribes have
proportionally fewer staff to assist with reporting associated
with MIECHV grants.
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ACF
is sensitive to the administrative burden of meeting the Tribal
Maternal, Infant, and Early Childhood Home Visiting (Tribal
MIECHV) reporting requirements, including reporting on performance
data associated with Form 2. In anticipation of the MIECHV program
being reauthorized, ACF is reviewing all reporting requirements,
including Form 2, to see if there are opportunities to reduce
burden and eliminate redundancies. Because 23 of the current
Tribal MIECHV grant recipients are in their final year of the
grants, ACF elected to renew Form 2 as-is, to not cause any
disruptions in the reporting process for these grant recipients.
We appreciate this feedback and will factor it in regarding any
future policy decisions, pending reauthorization.
ACF
plans to review current requirements and will engage grant
recipients to inform potential updates to reporting for future
funding recipients.
It
is also important to remember that current MIECHV legislation
(Section
511 of the Social Security Act) requires that
State and Tribal MIECHV awardees collect performance data to
measure improvements for eligible families in six specified areas
(referred to as "benchmark areas") that encompass the
major goals for the program. Stipulated in the legislation, the
Tribal MIECHV recipients, like their state counterparts, must meet
the required reporting of benchmark areas. Tribal MIECHV awardees
are required to propose a plan for meeting the benchmark
requirements specified in the legislation and must report on
improvement on constructs under each benchmark area.
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When
asked if the new proposed annual burden of 500 hours for each
respondent was an accurate reflection of the work required for
Form 2 reporting, most attendees disagreed. Although this is a
significant increase from previous estimates, Tribal Committee
members feel that this estimate does not account for the countless
hours put in by staff whose salaries are not paid by MIECHV to
complete this report—hours that awardees may not even be
able to
track
or count themselves. Staff supported by MIECHV funds carry out
work including capturing missing data, organizing, compiling,
carrying out quality control on, and analyzing data, and
completing forms.
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ACF
appreciates the opportunity to provide additional information on
how it calculates the average burden hours. Per OMB guidance, ACF
estimates the time it takes for a respondent to complete the form.
In the case Form 2 performance data, ACF considers the average
time and the effort required to fulfill a request along with the
financial cost. In general, estimated time includes the time for
reviewing instructions, compiling and reviewing for data quality
and reporting the data. The estimated time to complete and how it
is calculated varies greatly among grant recipients based on the
differences among recipient program size, staffing, each program’s
organizational reporting structure, etc. Since programs vary
across many factors, ACF then tries to come up with an average
time per response. Absent additional concrete evidence of higher
burden, ACF feels that the updated burden estimates (which were
based on experience over the past 8 years with Form 2 reporting)
accurately reflect the average burden to recipients. ACF will take
into consideration all feedback and consultation regarding burden
and will factor this in when preparing for future funding
recipients.
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Even
awardees who agreed that 500 hours a year was a fair estimate
pointed out that 500 hours represents nearly 25% of just one staff
person’s annual FTE for this single form. A 500 hour burden
means that staff spend, on average, 10 hours a week (and, awardees
suggest, that estimate is the low end of the range) just working
on Form 2. Tribal Committee members would like to take this
opportunity to reiterate their belief that a better balance is
needed between
gathering
the crucial information the agency needs to best serve families
and children, and knowing when the burden of collecting
information outweighs the value of what is collected.
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ACF
has heard from grant recipients individually as well as in
consultation, concerns on the amount of time staff must dedicate
to reporting performance measures (along with other grant
requirements) and the potential time taken away from providing
services. While reporting on these benchmark areas is required for
tribal grant recipients per the MIECHV legislation, ACF
understands and takes very seriously the fundamental goal of the
Tribal MIECHV program is to provide critical home visiting
services to children and families. Over the last 10 years ACF has
repeatedly made attempts to reduce burden to ensure that while
satisfying the legislative mandates, information collected by
grant recipients is also important information they can use
individually to assess and improve their own program’s
performance. Examples of this process include the redesign of
performance measures in 2016, development of the Tribal
Home Visiting Reporting System (THVRS) to make submitting data
easier and to streamline the process, creating grantee tools and
resources, as well as targeted and individualized technical
assistance with the intention of reducing administrative burden
for awardees. ACF has also increased focus on continuous quality
improvement efforts that support Tribal MIECHV grant recipients to
engage with and use performance data to meet their own goals and
continually improve practice.
While
there are additional reports grantees submit as part of their
cooperative agreement requirements, each report is different in
certain critical areas and provide vital information to ACF and as
was stated above - useful information to reflect and continually
improve practice and to tell the story of grant recipients to the
broader field. Information collected also informs development of
current and future funding opportunities and the kinds of supports
needed for grant recipients. We look forward to continuing to make
these improvements to the program and receiving feedback from
organizations like ASTHVI and its Tribal Committee will inform how
ACF can support future grant recipients.
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Tribal
Committee members continue to believe that while some data
reporting is
essential,
it would be helpful to analyze the percentage of the relatively
small Tribal MIECHV awards dedicated to reporting and
administrative costs.
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ACF
appreciates the suggestion to analyze the average costs smaller
programs dedicate to the reporting requirements for the program
and considers this useful information towards future policy
decisions. ACF wants to stress as part of the cooperative
agreement, project officers work closely with grant recipients to
review the budgets recipients submit to ensure each program is
functioning adequately. The investment in data for Tribal MIECHV
grants goes beyond reporting and supports quality improvement and
accountability that is critical to the success of programs. Often,
the same staff who support reporting are also supporting quality
improvement and accountability processes.
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File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
Author | Bergan, Anne (ACF) |
File Modified | 0000-00-00 |
File Created | 2022-10-21 |