Corporation for National and Community Service (AmeriCorps)
AmeriCorps Seniors Grant Applications, Progress Reporting, Independent Living and Respite Surveys
OMB Control No. 3045-0035
Justification – Part A Supporting Statement
Overview of Information Collection:
This is a revision to an information collection that consists of the application for AmeriCorps Seniors RSVP grants and Foster Grandparent Program (FGP), Senior Companion Program (SCP), and Senior Demonstration Program (SDP) grants; project progress reports and the progress report supplement (PRS) for AmeriCorps Seniors grant projects; and independent living and respite surveys. The information is collected through eGrants.
Revisions to the information collection include adjustments to burden hours to reflect actuals collected since the last approval and revisions to the PRS. Revisions to the PRS are being made to combine the three separate forms (one for RSVP, one for FGP, and one for SCP) into a single, uniform form in pursuit of Goal 4, effectively steward federal resources, Objective 1, simplify AmeriCorps’ application and administration procedures for grants and projects. In addition, revisions to the PRS are made to:
Add a new the “Income” section to include two questions:
The first question requests counts of volunteers falling into various income brackets based on the combined income of the volunteer and their spouse partner or an alternate version of the question that requests counts based on the combined income of the volunteer and all the individuals living in their household (AmeriCorps is requesting clearance for both versions of this question but will use only one).
The second question requests counts of volunteers or who live in residences that they or someone in their household own with or without a mortgage, rent, occupy without payment or rent, or unknown.
Under the “Service Information” section:
Within “Volunteers”
The PRS is combined to apply to all programs (RSVP, SCP, FGP) rather than having a separate form for each program;
Five questions are deleted (number of RSVP recruited, number of community volunteers recruited, number of Armed Forces Service members serving as volunteers, number of volunteers with a family member actively serving in the military)
One question is added for the total count of volunteers below the 200% state poverty line
Within a new section “For Stipend Programs Only,” three questions currently asked on the FGP and SCP forms are moved to this section.
The following sections and their questions are deleted:
Hours served
Volunteers Separated
Volunteer-Client Ratio
Under the “Client Information” tab:
Deleted the “Age of Clients Served”
Within “Clients Served”
Deleted two questions regarding the number of adult ex offenders served and total number of immigrants served;
Moved a few questions for logical grouping;
Added three questions on the number of direct project beneficiaries, direct project beneficiaries in poverty, and percentage of direct project beneficiaries for whom poverty level is known.
Under the “Stations Information” section:
Deleted seven questions on the total number of faith-based stations/volunteers; disaster service stations/volunteers; stations/volunteers supporting Legal Aid or Elder Justice initiatives; stations/volunteers supporting STEAM programs; stations/volunteers supporting evidence-based programs; stations/volunteers supporting prescription drug/opioid abuse prevention initiatives; and stations/volunteers serving to address COVID-19
Added three questions on the total number of stations/volunteers; total volunteer stations that collect data to count the number of direct beneficiaries; and total volunteer stations that do not collect data to count the number of direct beneficiaries in poverty.
These revisions are requested in order to allow AmeriCorps to examine its performance in meeting strategic goal objectives. See AmeriCorps Strategic Plan 2022-2026 at https://americorps.gov/sites/default/files/document/AmeriCorps-Strategic-Plan-2022-2026.pdf. Specifically, this information will help AmeriCorps Seniors determine whether it is meeting:
Goal 1, Partner with communities to alleviate poverty and advance racial equity, objective 4, prioritize investment in the most underserved individuals and communities. Per this objective, our agency goal is for 40% of all those served by AmeriCorps members and AmeriCorps Seniors volunteers are people in poverty. Thus, AmeriCorps Seniors needs information related to the total number of beneficiaries and those that are in poverty.
Goal 1, Partner with communities to alleviate poverty and advance racial equity, objective 5: Require a diverse corps of members and volunteers who reflect those we are serving. Per this objective, success is defined if the race, ethnicity, gender, socioeconomic and geographic diversity of members and volunteers progressively reflects the demographic diversity of those we serve. Thus, we need to add question related to a volunteers’ income and socioeconomic status. Questions have been drafted after an extensive literature review by AmeriCorps Seniors staff, in close collaboration with our Office of Research and Evaluation, and through feedback from our grantees.
AmeriCorps Seniors engaged in a review of all data requests over several years and analyzed which pieces of information are being used by the agency and deleted those PRS questions not being used. AmeriCorps is committed to asking grantees for only information that we use, so we are removing questions for which data is not used by our agency or been requested by internal or external stakeholders.
No changes are being made to the application, project progress reports, or independent and respite surveys.
1. Need & Method for the Information Collection
The Corporation for National and Community Service (AmeriCorps) dba AmeriCorps awards grants to states, institutions of higher education, non-profit organizations, Indian tribes, and U.S. Territories to operate AmeriCorps Seniors programs. This information collection comprises the application package for AmeriCorps Seniors grants, progress reports and the progress report supplement (PRS), and independent living and respite surveys.
Collection of the information is necessary for several reasons. Application information is required to meet the legislative requirements in the Domestic Volunteer Service Act (DVSA) that AmeriCorps Seniors RSVP grants enter in competition and to implement AmeriCorps’ authority to award FGP, SCP, and SDP grants. See 42 U.S.C. 5001, 5011, 5013, 5028. Information within the application is needed to make award decisions to ensure the awarded funds are used for the purposes set out in the DVSA. The DVSA does not impose any deadline for collection of the information, but in order to award grant funds in a timely manner, AmeriCorps establishes deadlines for applicants to submit their application materials (e.g., April 1 deadline for grant awards being made June 1).
Collection of the progress report and PRS is needed to meet the requirements in 42 U.S.C. 5056 for evaluating programs and the government-wide regulations in 2 CFR § 200.329 (monitoring and reporting program performance), which state that the “non-Federal entity must submit performance reports at the interval required… to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually....” Requirements are also found in AmeriCorps General and AmeriCorps Seniors Terms and Conditions. While the regulations do not establish specific deadlines for progress reports, AmeriCorps Terms and Conditions issued with each grant establish specific deadlines. AmeriCorps does not collect the surveys; rather, they are provided as a tool for grantees if they wish to use them in collecting their own information for reporting in the progress report and PRS.
Information will be collected electronically, via AmeriCorps’ grant management system (eGrants). Application information is reviewed by AmeriCorps staff to ensure compliance with requirements and by reviewers. AmeriCorps Seniors staff oversees the overall collection of the information. Electronic collection is fillable and submittable. Progress report information is reviewed by regional staff and then AmeriCorps evaluators at Headquarters.
If the information is not collected, AmeriCorps Seniors will not have the information needed to make awards and AmeriCorps Seniors will not be able to review and aggregate program performance information. The legal obstacles to reducing burden are that information is collected as least frequently (annually) as allowed in 2 CFR § 200.329 and the information collected is necessary for AmeriCorps to determine whether providing funding meets statutory and regulatory requirements and the grantee is performing in accordance with applicable laws.
2. Use of the Information.
Applicants respond to the questions included in these instructions in order to apply for AmeriCorps Seniors funding and to report out on performance of their project. AmeriCorps Seniors will use the information collection to select grantmaking entities that will identify, support, and evaluate nonprofit organizations to implement and scale evidence-based solutions to community challenges.
There is no travel time associated with collecting or submitting this information, nor is there time waiting to speak with agency personnel. Cognitive load, discomfort, and stress is similar to other federal applications. While new questions are being proposed for the annual Progress Report Supplement, AmeriCorps Seniors is deleting several questions to overall reduce the number of questions asked, potentially leading to increased institutional trust as AmeriCorps is committed to only asking information from grantees and applicants that is determined is needed. AmeriCorps recognizes that grantees will not have information on hand immediately to report out on the new questions being proposed in the PRS and does not expect a full dataset for a year after approval to allow grantees time to determine how best to collect the new information.
The principal uses that AmeriCorps makes of the information collected through the applications is to review whether the applicant is eligible for AmeriCorps Seniors grants and whether their program should receive AmeriCorps Seniors grant funding based on the strength of the application and review of risks. Progress report, PRS, and survey information is used to review the work accomplished by grantees during the reporting period and enable staff to monitor grant operations of the award supported activities in accordance with 2 CFR 200.329. Information collected through progress reports is also used in multiple agency report-outs, including the Congressional Budget Justification and in support of agency Strategic Plan objectives. Additionally, the information is used by AmeriCorps staff to track and measure progress, measure contributions of senior volunteers, and review progress toward work plan objectives agreed upon in the granting of the award.
3. Use of Information Technology
AmeriCorps will be eliciting and accepting applicants’ response to these questions electronically via eGrants the AmeriCorps’ secure online grants management system. If applicants are unable to apply or report on-line, they can use the attached forms and instructions to submit their application.
4. Non-duplication.
There are no other sources of information by which AmeriCorps can meet the purposes described in 2 (above).
5. Burden on Small Business.
This collection of information does not impact small businesses because they are not eligible to apply for AmeriCorps Seniors grants. There is no economic burden to any other small entities beyond the cost of staff time to collect and report the data. This is minimized to the degree possible by only asking for the information absolutely necessary to assess an organization’s eligibility to apply to administer an AmeriCorps Seniors grant and only information required to assess a grantee’s annual performance.
6. Less Frequent Collection.
If this information were collected less frequently, AmeriCorps would be unable to assess prospective AmeriCorps Seniors grantees, nor able to assess the performance of AmeriCorps Seniors grants.
7. Paperwork Reduction Act Guidelines
There are no special circumstances that would require the collection of information in ways that violate the Paperwork Reduction Act Guidelines.
8. Consultation and Public Comments.
The 60-day Notice soliciting comments was published on April 27, 2023, at 88 FR 25625. 32 comments were received, as described below.
Additionally, AmeriCorps Seniors proactively reached out to AmeriCorps’ Office of Research and Evaluation who, in conjunction with AmeriCorps Seniors, to identify reporting questions that allow AmeriCorps Seniors to report out on key metrics in as minimally burdensome process as possible. Additionally, AmeriCorps Seniors reached out the board members of the AmeriCorps Seniors Associations – representatives of AmeriCorps Seniors grantees with proposed changes to the Progress Report Supplement, the only document proposed being changed. The Associations were appreciative of efforts by AmeriCorps to reduce the overall number of questions in the annual report. They provided feedback that guidance would need to be updated and they would need time to implement data collection mechanisms to report out on new questions. AmeriCorps agreed that time may be needed to implement data collection mechanisms for new reporting questions and, thus, would not make them required for the first year implemented.
There were 32 total comments submitted in response to the 60-day notice. Of these, 26 were the same comment. Of the other comments, one was in support, one was without specific comment, and the others detailing that the Progress Report Supplement (PRS) is a burden. In relation to the Progress Report Supplement (PRS), the only document with proposes revisions, AmeriCorps Seniors agrees that reporting may be burdensome and is thus deleting a questions for each new question required within the Progress Report Supplement. The substantive comments and responses are summarized here:
Comment: AmeriCorps Seniors grants are awarded for a three-year period with required annual budget submissions. ASPN questions the value and additional time needed to update the grant application and workplan submission annually. With a three-year performance period, ASPN proposes for a grantee to submit an annual budget application and an executive summary to update amended community needs and changes instead of the entire grant application. This change would not only reduce the time needed of grantee staff, but also regional staff grant reviewers.
AmeriCorps
Response: AmeriCorps is in the process of modernizing our grant
management systems. As part of the modernization effort that will
update the electronic grants management system, AmeriCorps will
propose grantees to submit a simplified budget application and an
update through a simplified amendment process rather than an entire
grant continuation application. These agency-wide steps to update
technology will enable AmeriCorps to address this burden in the
future.
Comment: While the Progress Report
at the end of a grant year is straightforward, there is confusion as
to how much information is needed in the narrative section.
Instructions about the examples of info that is most helpful in the
narrative sections would be welcome.
AmeriCorps
Response: In addition to Progress Report Instructions and
training, AmeriCorps provides Appendix A.4 – AmeriCorps Seniors
Progress Report Tips in each Program Handbook. This document shares
examples about what information is worth considering for the
narrative sections of the Progress Report. In addition, grantees can
also speak with their Portfolio Manager about what information and to
what extent they should include.
Comment: The
Progress Report Supplement has been referred to as many different
things over the years. With current Performance Measure workplans
being very specific as to the special needs served by volunteers,
this complete demographic report is burdensome for both program and
station staff. ASPN has been told that there is no way for CNCS to
aggregate the data reported into a national needs snapshot. As such,
ASPN strongly believes that is CNCS unable to aggregate this data,
programs should not be asked to collect it. The current reporting
dates do not take into account grant years; therefore, programs are
reporting on portions of two different grant years, causing the
information to often be incorrect. Demographics of the volunteers
should be rolled into the annual Progress Report. The PPR-S should be
eliminated and would reduce the administrative burden for both
grantees and agency staff.
AmeriCorps
Response: AmeriCorps can and does aggregate the demographic
section of the Progress Report Supplement (PRS). At this time,
AmeriCorps is in the process of updating their grant management
systems to enable volunteer information to be able to be entered
directly into the system. AmeriCorps Seniors anticipates that this
will eliminate the need for the Progress Report Supplement, reducing
the administrative burden for grantees and agency staff. These
agency-wide steps to update technology will enable AmeriCorps to
address this burden in the future.
Comment:
Independent Living and Respite Surveys: SCP directors report that
national work-plans do not require all the information requested on
these surveys. If the workplan does not request the information, it
would be best if those questions were eliminated from the survey and
would possibly result in a better return on the number of clients
completing the surveys. As Senior Companions serve those with
dementia, it is often the caregiver of the client that completes this
survey. In an effort to mitigate adding to caregiver burden, a
shortened survey could be more easily completed which would then in
turn, produce a better response rate.
AmeriCorps Response: At only 13 questions, AmeriCorps Seniors disagrees that this survey is too burdensome. However, AmeriCorps Seniors will review the Independent Living and Respite Survey over the next few years and continue outreach. AmeriCorps Seniors is interested in the specific questions which SCP Directors propose to be eliminated.
9. Gifts or Payment.
There are no payments or gifts to respondents
10. Privacy & Confidentiality
AmeriCorps publishes only public use data that contains no personal information and has been coded to shield potential identification of participants. Respondents are not required to submit proprietary trade secrets or other confidential information. AmeriCorps Seniors does not collect personally identifiable information. Per the Federal Cybersecurity Enhancement Act of 2015, all data are protected from cybersecurity risks through screening of the systems that transmit data.
11. Sensitive Questions
The information collection does not include questions of a sensitive nature.
12. Burden Estimate.
ICR Summary of Burden
The ICR Summary of Burden in ROCIS shows a change due to adjustment in agency estimate as follows because AmeriCorps removed the information collections (ICs) and associated hourly burdens remaining from approvals prior to the last approval in 2021, as shown in the table below:
|
Requested |
Program Change Due to New Statute |
Program Change Due to Agency Discretion |
Change Due to Adjustment in Agency Estimate |
Change Due to Potential Violation of the PRA |
Previously Approved |
Annual Number of Responses |
6,250 |
0 |
0 |
-5,650 |
0 |
11,900 |
Annual Time Burden (Hr) |
6,250 |
0 |
0 |
-16,395 |
0 |
22,645 |
Annual Cost Burden ($) |
309,313 |
0 |
0 |
190,875 |
0 |
119,438 |
IC Burden
We expect approximately 1250 respondents to apply via the application package, submit a progress report, submit a progress report supplement, and complete each of the annual surveys. The instruments used to collect this information are the application package for AmeriCorps Seniors grantees, progress reports and progress report supplement, and Independent Living and Respite Surveys. This is submitted by all AmeriCorps Seniors grantees and each is collected annually (resulting in a frequency per respondent of 5 times a year) and should not exceed one hour of effort per respondent per response.
The estimated respondent burdens and labor costs are shown in the following table.
Estimation of Respondent Burden |
|
Number of respondents |
1250 |
Responses per respondent |
5 |
Number of responses |
6250 |
Hours per response |
1 |
Total estimated hours (number of responses multiplied by hours per response) |
6250 |
Cost per hour (hourly wage) |
$49.49 |
Annual public burden (estimated hours multiplied by cost per hour) |
$309,313 (rounded) |
Note: The cost per hour is based on the average of eight 2023 OPM GS hourly rates (base + locality) for a GS-11, step 1 employee living in our eight regions of operation, plus the 36.25% civilian personnel full fringe benefit rate from OMB memorandum M-08-13. The average cost per hour is $36.32 (average hourly rate) + $13.17($36.32 average hourly rate x 36.25% fringe) = $49.49/hour (rounded to the nearest penny).
The 2023 GS-11, step 1 hourly rates for the eight regions of operation are as follows: Austin, TX ($33.94), Atlanta, GA ($39.97), Columbus, OH ($34.47), Concord, NH ($37.25), Denver, CO ($36.68), Kansas City, MO ($33.59), Los Angeles, CA ($38.34) and Philadelphia, PA ($36.34). The average hourly rate is the sum of these hourly rates divided by eight = $36.32/hour (rounded to the nearest penny). See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2023/general-schedule/.
This ICR requests a change in net burden to account for an agency adjustment of time per response from 0.42 hours per response to 1 hour per response. AmeriCorps arrived at this re-estimation of burden through its outreach described in number 8 above, through consultation with a sample of potential respondents. This results in an increase of 3,625 total hour burden. The cost burden is also updated to reflect this increase in hours and a $49.49 hourly rate, as explained above.
|
Requested |
Program Change Due to New Statute |
Program Change Due to Agency Discretion |
Change Due to Adjustment in Agency Estimate |
Change Due to Potential Violation of the PRA |
Previously Approved |
Annual Number of Responses for this IC |
6,250 |
0 |
0 |
0 |
0 |
6,250 |
Annual IC Time Burden (Hour) |
6,250 |
0 |
0 |
3,625 |
0 |
2,625 |
Annual IC Cost Burden (Dollars) |
309,313 |
0 |
0 |
190,875 |
0 |
118,438 |
The following tables show that these burden hours consist of time required for reporting:
Burden per Response:
|
|
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Annual Burden:
|
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13. Estimated nonrecurring costs.
AmeriCorps does not estimate any annual cost burden to respondents apart from the hourly burden reflected in the above section – applicants and grant recipients are expected to already have a computer and internet access to provide the information in the format requested.
14. Estimated cost to the Government.
The estimated cost to the Government is shown in the following table. It is estimated that it will take the Government 1 hour to review and verify the information contained in each response. This estimate was developed by staff involved in the management of current activity.
Estimation of Cost to the Government |
|
Number of responses |
3750 |
Hours per response |
1 |
Total estimated hours (number of responses multiplied by hours per response) |
3750 |
Cost per hour (hourly wage) |
$49.49 |
Annual burden (estimated hours multiplied by cost per hour) |
$185,588 (rounded) |
Note: The cost per hour is based on the average of eight 2023 OPM GS hourly rates (base + locality) for a GS-11, step 1 employee living in our eight regions of operation, plus the 36.25% civilian personnel full fringe benefit rate from OMB memorandum M-08-13. The average cost per hour is $36.32 (average hourly rate) + $13.17($36.32 average hourly rate x 36.25% fringe) = $49.49/hour (rounded to the nearest penny).
The 2023 GS-11, step 1 hourly rates for the eight regions of operation are as follows: Austin, TX ($33.94), Atlanta, GA ($39.97), Columbus, OH ($34.47), Concord, NH ($37.25), Denver, CO ($36.68), Kansas City, MO ($33.59), Los Angeles, CA ($38.34) and Philadelphia, PA ($36.34). The average hourly rate is the sum of these hourly rates divided by eight = $36.32/hour (rounded to the nearest penny). See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2023/general-schedule/.
15. Reasons for changes.
AmeriCorps Seniors updated the estimated Hours per Response from 0.42 to 1 hour due to a re-estimation of the amount of burden that the collection imposes. AmeriCorps’ new estimate is based on consultation with a sample of potential respondents. The decrease in adjustment results from removal of information collections (ICs) from prior years so that this ICR includes only the most current versions of the instruments in use. In most of the instruments, the agency has not made any change to the collection itself since the last approval, and thus there is simply an adjustment to a previously approved burden estimate. The only revisions being made to an information collection instrument are revisions to the Progress Report Supplement, which deletes several questions for which data is not currently used and adds a fewer number of questions that now relate to AmeriCorps’ Strategic Plan goals. The newly added questions are needed to report out on Strategic Plan objectives, specifically the socioeconomic status of AmeriCorps Seniors volunteers.
The revision results in an increase in hours for the IC of 3,625 hours. However, the two legacy ICs that are deleted result in a decrease of 20,020 hours (17,820 hours + 2,200 hours), resulting in an overall decrease in hours of 16,395 for this ICR. The number of responses also decreases because the legacy ICs are deleted, resulting in a decrease of 5,650 responses (1,250 responses + 4,400 responses) for this ICR.
16. Publicizing Results
AmeriCorps publishes the results of their grant competition on the agency website within six months of the award. Aggregate results of the annual Progress Reports are published annual via the Congress Budget Justification and annually contribute to updating AmeriCorps’ Strategic Plan. Annual Progress Reports are collected and analyzed in September-November. Aggregated results for publication are identified in November-December. There are no complex analytical techniques that will be used.
17. OMB Not to Display Approval.
Not applicable.
18. Exceptions to "Certification for Paperwork Reduction Submissions."
There are no exceptions to the certification statement in the submitted ROCIS form.
19. Surveys, Censuses, and Other Collections that Employ Statistical Methods.
AmeriCorps will not employ statistical methods as part of these collection mechanisms.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Attached is the final version with some differences with RPD about the costs defiend in A12 and not included in A13 |
| Keywords | OMB |
| Author | vperry |
| File Created | 2025:05:19 08:22:42Z |