This information collection is a direct response to recommendations for strengthening LIHEAP program integrity made by the Government Accountability Office in 2010 and the LIHEAP Program Integrity Work Group, which consisted of a sample of LIHEAP grantees. The purpose of this data collection is to gauge the capacity of LIHEAP grantees to perform two critical tasks.
1. To implement third-party verification of household data obtained during the LIHEAP intake process, in order to strengthen program integrity by reducing the risk of making LIHEAP benefit payments to ineligible households or in the wrong amount. These risks arise in large part when there are errors or fraud in the reporting of household members' identity and income during the LIHEAP intake process.
The information collection is a direct response to recommendations for strengthening LIHEAP program integrity made by the Government Accountability Office (GAO) in 2010 and the LIHEAP Program Integrity Work Group which consisted of a sample of LIHEAP grantees. The information collection for both contracts are essential tasks and are initially required in order for the contractor to proceed with the major development of the web based data collection tool and the implementation of the program integrity recommendations such as third party verification of household data. Clearance for the questionnaire could not be sought prior to the award of the contracts, because the content development of the instrument was as requirement under the two new contracts that DEA entered into. DEA is finalizing the questionnaire content for those assessments and can submit them as soon as OMB is ready to receive them. At the same time, other tasks under the contracts are contingent upon the information collected by the survey. Without an expedited clearance, successful completion of the contract tasks is at risk. Contractors have projected that they will need to begin data collection through this questionnaire in October 2013 in order to proceed with the other tasks on a timely manner and meet their legal obligations per the contracts with our office. Contractors are expected to submit other required deliverables that depend on the results of this questionnaire no later than April 18, 2014. These deliverables are needed in order for grantees to make preparations in time to begin the performance measures data collection on October 1, 2014. The normal OMB clearance process would not be completed until after these contractual deadlines.
According to the 5 C.F.R. Part 1320.13, an agency head or Senior Official, or their designee, may request OMB to authorize emergency processing of submissions of collections of information in writing. Specifically, if the agency cannot reasonably comply with the normal clearance procedures because an unanticipated event occurred, expedited processing may be used. In the instant case, P.L. 110-351 gives ACF a very narrow window in which to provide technical assistance prior to the effective date of the new sections of the Act. If we are unable to obtain expedited clearance for the information collection, the contractors' ability to deliver their required tasks and outputs will be severely compromised and affect the planned training and technical assistance services to grantees.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.