Supporting Statement A

SSA Template - Formative for ACF Program Support_UHP Assessment 2-27-23.docx

Formative Data Collections for ACF Program Support

Supporting Statement A

OMB: 0970-0531

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Uniting for Ukraine Survey




Formative Data Collections for Program Support


0970 – 0531




Supporting Statement

Part A - Justification

February 2023


Submitted By:

Office of Refugee Resettlement

Administration for Children and Families

U.S. Department of Health and Human Services


4th Floor, Mary E. Switzer Building

330 C Street, SW

Washington, D.C. 20201


Project Officer:


Ken Tota, Deputy Director

Office of Refugee Resettlement



A1. Necessity for the Data Collection

The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services (HHS) seeks approval for the Uniting for Ukraine (U4U) Survey.


This proposed information collection meets the following goals of ACF’s generic clearance for formative data collections for program support (0970-0531):

  • Delivery of targeted assistance related to program implementation or the development or refinement of program and grantee processes.

  • Planning for provision of programmatic or evaluation-related training or technical assistance (T/TA).


Background

In May 2022, the Additional Ukraine Supplemental Appropriations Act of 2022 (AUSAA), Public Law 117-12 authorized the ACF Office of Refugee Resettlement (ORR) to provide resettlement assistance to specific Ukrainian arrivals, including Ukrainian Humanitarian Parolees. The nature and scale of the rapid influx of Ukrainian arrivals is unprecedented and is made more challenging by the reduction in resettlement capacity over the past several years. Ukrainian parolees are eligible for ORR services, but are not automatically connected with resettlement agencies in the manner that traditional refugee clients who participate in the Reception and Placement (R&P) program are connected. As a result, states may need additional resources and T/TA to adequately meet the needs of these arrivals. ORR seeks to better identify ORR-eligible Ukrainians’ immediate and intermediate needs, their knowledge of ORR services and benefits, and the level of federal support required to ensure their economic and housing stability to advance their overall health and well-being.

ORR needs relevant, timely, and up-to-date information to inform appropriate and targeted T/TA and to inform refinement of programs and grantee process. The information collected through the proposed U4U Survey would help ORR to identify service needs and gaps in resettlement services, and grantee processes (such as case management follow-up frequency).




Legal or Administrative Requirements that Necessitate the Collection

There are no legal or administrative requirements that necessitate the collection. ACF is undertaking the collection at the discretion of the agency.



A2. Purpose of Survey and Data Collection Procedures

Overview of Purpose and Use

The U4U Survey is designed to collect data from adult (18 years and older) Ukrainian parolees who arrived under AUSSA. The purpose of the data collection is to inform refinement and improvements to ORR’s programs and services (in the areas such as case management process refinement on client follow-up frequency). The data collected will help ORR identify targeted T/TA needs by geolocation, service providers, and professional assistance. Information collected will also inform ORR to address the service gaps through program improvements and development where ORR currently does not have designated program, service component, or service referral networks. Limited and aggregated tabulations and descriptive summaries might be shared with states, resettlement agencies, service providers, and partnering federal resettlement agencies upon request and approval to facilitate bilateral discussions and inform ORR decisions on specific targeted assistance related to program implementation, refinement of current grantee process, and provision of programmatic or evaluation-related T/TA to these stakeholders. The information collection may inform a full information collection request in the future if a need is identified for more information.


Key Questions

The key learning questions this survey aims to answer are:

  • Do ORR’s employment and language training programs facilitate employment in the household and provide language learning opportunities?

  • Do ORR’s health and housing programs and services support the immediate and long-term needs of Ukrainian parolees?

  • How can ORR improve resettlement placement and assurance process (such as initial resettlement location designation) and case management practice?

  • What underlying needs of Ukrainian parolees are not met with existing ORR programs?

  • What types of training, technical assistance, and resources are needed by grantee and service providers?



This proposed information collection meets the following goals of ACF’s generic clearance for formative data collections for program support (0970-0531):

  • Delivery of training or technical assistance (TA) and/or workflows related to program implementation or the development or refinement of program and grantee processes.

  • Planning for provision of programmatic or evaluation-related training and TA.

  • Obtaining feedback about processes and/or practices to inform ACF program development or support.



Processes for Information Collection

The U4U Survey will be conducted using an online survey. Unique online survey links will be distributed to Ukrainian parolees, age 18 and older, through SMS, email, and WhatsApp in their preferred languages (Ukrainian, Russian, English). Parolees can submit online survey response after their consent is received by ORR. This survey is voluntary and should take around 10 minutes to complete.



As of November 4, 2022, there are 189,562 Ukrainian individuals who have entered the U.S. since March 24, 2022, including 77,952 Ukrainian parolees. The survey will be sent to Ukrainian individuals who are 18 years and older and have contact information (either phone number or email address) per the Department of Homeland Security (DHS) U.S. Citizenship and Immigration Services (USCIS) Form I-134 - Declaration of Financial Support. The survey will close once ORR has received 800 respondents, per OMB clearance requirements (see Supporting Statement B for more information about the universe of respondents).




A3. Improved Information Technology to Reduce Burden

This information collection utilizes improved information technology and self-administered online survey mode. Respondents will submit survey responses through the newly developed ORR survey data collection website system. The survey data submission website allows ORR to verify receipt of the consent from respondents, verify receipt of survey response, provide the survey in preferred languages selected by respondents, and perform front-end verification to immediately reject duplicate survey responses from the same parolee. This process ensures data privacy protection, maximizes data quality and accuracy, improves the efficiency of survey administrative, and reduces the burden on respondents.




A4. Efforts to Identify Duplication

ORR is sensitive to the time and resource constraints of service providers during the surge and influx of Ukrainian arrivals. ORR believes that no information collection currently available can be used as a sole resource, nor is sufficient to meet the goals and purpose described in section A1 and A2 above. The U4U Survey instrument was developed in coordination with other ORR data collection and reporting activities to avoid duplicative efforts.



A5. Involvement of Small Organizations

No small organizations will be involved in the proposed U4U Survey.



A6. Consequences of Less Frequent Data Collection

Respondents will be asked to complete the survey once. Information is intended to provide ORR with timely information related to services provided for Ukrainian parolees. If the data collection is not conducted or not conducted in a timely manner, it will result in little to no data on whether Ukrainian parolees’ needs are met during the critical and vulnerable initial resettlement phase. It will also jeopardize ORR’s timely program development and refinement and risk ORR’s ability to appropriately provide T/TA to states and service providers.




A7. Special Circumstances

There are no special circumstances for the proposed data collection efforts.



A8. Federal Register Notice and Consultation

Federal Register Notice and Comments

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 request to extend approval of the umbrella generic with minor changes. The notice was published on January 28, 2022, (87 FR 4603), and provided a sixty-day period for public comment. ACF did not receive any comments on the first notice. A second notice was published, allowing a thirty-day period for public comment, in conjunction with submission of the request to OMB. ACF did not receive any comments on the second notice.


Consultation with Outside Experts

No consultations have taken place with experts outside of the project team.



A9. Tokens of Appreciation for Respondents

No tokens of appreciation for respondents are proposed for this information collection.




A10. Privacy of Respondents

Respondents will be informed of all planned uses of data, that their participation is voluntary, and that their information will be kept private to the extent permitted by law.  

 

As specified in the Refugee Arrivals Data System (RADS) contract, the Contractor shall protect respondent privacy to the extent permitted by law and will comply with all federal and departmental regulations for private information. The Contractor has developed data safety and monitoring processes that assesses all protections of respondents’ personally identifiable information. The Contractor shall ensure that all of its employees, subcontractors (at all tiers), and employees of each subcontractor who perform work under this contract/subcontract, are trained on data privacy issues and comply with the above requirements. 

 

As specified in the evaluator’s RADS contract, the Contractor shall use Federal Information Processing Standard compliant encryption (Security Requirements for Cryptographic Module, as amended) to protect all instances of sensitive information during storage and transmission. The Contractor shall securely generate and manage encryption keys to prevent unauthorized decryption of information, in accordance with the Federal Processing Standard. The Contractor shall: ensure that this standard is incorporated into the Contractor’s property management/control system; and establish a procedure to account for all laptop computers, desktop computers, and other mobile devices and portable media that store or process sensitive information. Any data stored electronically will be secured in accordance with the most current National Institute of Standards and Technology (NIST) requirements and other applicable federal and departmental regulations. This survey does not collect personally identifiable information and the survey response submitted by respondents is automatically entered and stored on the secured survey data system.



A11. Sensitive Questions

There are no sensitive questions in this data collection.



A12. Estimation of Information Collection Burden

Burden and Cost Estimates

The estimated burden to respondents is 136 burden hours. Respondents will be asked to participate in one survey that is estimated to take an average of 10 minutes to complete. ORR plans to collect information from about 800 Ukrainian parolees.



The estimated annual cost to respondents to the U4U Survey is calculated using the U.S. Department of Labor federal minimum wage of $7.25.1 To account for fringe benefits and overhead, the rate was multiplied by two, totaling $14.50 per hour. The estimated cost to respondents per hour is $14.50, times 136 hours, for a total annual cost of $1,972. (https://www.bls.gov/oes/current/oes_stru.htm)


Instrument

Total Number of Respondents

Total Number of Responses Per Respondent

Average Burden Hours Per Response

Total

Burden Hours

Average Hourly Wage

Total Annual Cost

U4U Survey Questionnaire

800

1

0.17

136

$14.50

$1,972

Total Burden and Cost Estimates:

136


$1,972



A13. Cost Burden to Respondents or Record Keepers

There are no additional costs to respondents.



A14. Estimate of Cost to the Federal Government

The total cost for the data collection activities under this current request will be $135,310.



A15. Change in Burden

This is for an individual information collection under the umbrella formative generic clearance for program support (0970-0531).



A16. Plan and Time Schedule for Information Collection, Tabulation and Publication

Survey and data collection will begin following OMB approval. Data collected with be tabulated and analyzed soon after the data collection is completed. Limited and aggregated tabulations and descriptive summaries might be shared with states, resettlement agencies, service providers, and partnering federal resettlement agencies upon request and approval to facilitate bilateral discussions and inform ORR decisions on specific targeted assistance related to program implementation, refinement of current grantee process, and provision of programmatic or evaluation-related T/TA to these stakeholders.




A17. Reasons Not to Display OMB Expiration Date

All instruments will display the expiration date for OMB approval.



A18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions are necessary for this information collection.




Attachments

  • Supporting Statement B

  • U4U Survey Instrument

1 U.S. Department of Labor, Minimum Wage, https://www.dol.gov/general/topic/wages/minimumwage (last visited February 24, 2022).

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File TitleOPRE OMB Clearance Manual
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