HRSA HAB RSR Non-Substantive Change Memo _ OMB 0906 0039_ 06132025_v2.0_Draft_Final

DATE: June 30, 2025

TO: Dan Cline, Desk Officer, Office of Management and Budget

FROM: Samantha Miller, Information Collection Clearance Officer, Office of Planning, Analysis and Evaluation, Health Resources and Services Administration

______________________________________________________________________________

Request: The Health Resources and Services Administration’s HIV/AIDS Bureau (HAB) requests approval for changes to “Ryan White Services Report – Client Level Data on File” (Form No. 3) in the information collection titled “Ryan White HIV/AIDS Program Client-Level Data Reporting System OMB Control No. 0906-0039 - Revision expiration date September 30, 2027.

Purpose: The purpose of this request is to make non-substantive changes to "Form 3: Documents on File" to align with Executive Order 14168 titled "Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government," Section 7 (January 20, 2025). This executive order requires the Secretary to take action to ensure that future information collection forms, as outlined in Section 3(e) of EO 14168, stipulate that agency forms requiring an individual's sex must only list "male" or "female" and must not request gender identity.

This memo explains the changes.

Changes: The following changes will be made to Form 3:

• GenderID will no longer be collected in the report.

• Transgender will not be collected in the report.
  
  
  

Time Sensitivity: The changes to data collection must be completed promptly to ensure their inclusion in the Fiscal Year 2026 Ryan White Services Report – Client Level Data collection form. Approval for these changes is needed as soon as possible, to allow for updates to the form and modifications to the data collection application system used by RWHAP recipients and providers for their annual data submissions.

Burden: The changes outlined here do not alter the estimated reporting burden for RWHAP providers. This burden is expected to remain consistent with the approved Notice of Office of Management and Budget Action (NOA) dated September 17, 2024.

PROPOSED CLARIFICATIONS AND NON-SUBSTANTIVE CHANGES:

Table A

Instrument	Section	Existing Language	Change Made	Rationale
Form 3: Ryan White Services Report – Client Level Data on File	RSR Client -Level Data - Demographics	GenderID	Remove	Alignment with EO 14168
Form 3: Ryan White Services Report – Client Level Data on File	RSR Client -Level Data - Demographics	Transgender	Remove	Alignment with EO 14168

Attachments:

Form 3: Ryan White Services Report – Client Level Data on File - OMB 0906-0039_06.13.2025_v2.0 Final