SUPPORTING STATEMENT FOR REQUEST FOR OMB APPROVAL

**UNDER THE PAPERWORK REDUCTION ACT OF 1995**

**TABLE OF CONTENTS**

  --------------------------------- -------------------------------------
  **SECTION**                       PAGE

  --------------------------------- -------------------------------------

A. JUSTIFICATION 2

A.1 Circumstances Necessitating Data Collection 2

A.2 How, by Whom, and For What Purpose the Information is to be Used 7

A.3 Use of Technology to Reduce Burden 8

A.4 Efforts to Identify Duplication 8

A.5 Methods to Minimize Burden on Small Businesses 8

A.6 Consequences of Less Frequent Data Collection 9

A.7 Special Circumstances for Data Collection 9

A.8 Summary of Public Comments 9

A.9 Payment of Gifts to Respondents 9

A.10 Confidentiality Assurances 9

A.11 Additional Justification for Sensitive Questions 10

A.12 Estimates of the Burden of Data Collection 10

A.13 Estimated Cost to Respondents 13

A.14 Estimates of Annualized Costs to Federal Government 13

A.15 Changes in Burden 14

A.16 Publication of Results 14

A.17 Approval Not to Display OMB Expiration Date 15

A.18 Exceptions to OMB Form 83-I 16

B. Collection of Information Employing Statistical Methods 16

**SUPPORTING STATEMENT**

**APPLICATION FOR PRIORITY OF SERVICE DATA COLLECTION**

**A. Justification**

*A.1. Circumstances that make the collection of information necessary.*

The information collection is requested to support the implementation of
the priority of service provisions contained in the Jobs for Veterans
Act (JVA). These provisions provide that veterans and certain spouses of
veterans (together comprising the category of covered persons) are
entitled to priority over non-covered persons for the receipt of
employment, training, and placement services provided under new or
existing qualified job training programs.

The Department of Labor's (DOL) Veterans' Employment and Training
Service (VETS) is in the process of proposing a rule - 20 CFR Part
1010 - to implement priority of service requirements for qualified job
training programs as prescribed in section 2(a)(1) of the JVA, Public
Law (Pub. L.) No. 107-288 (Nov. 7, 2002). In conjunction with this
effort, DOL is publishing a 60-day [Federal]{.underline}
[Register]{.underline} Notice of Proposed Rulemaking (NPRM) that
contains proposed reporting requirements, which will assist DOL in
assessing the extent to which employment and training programs are
implementing priority of service.

Qualified job training programs are defined at 38 U.S.C. § 4215(a)(2) as
any workforce preparation, development or delivery program or service
that is directly funded, in whole or in part, by the Department of
Labor. This Information Collection Request (ICR) specifically impacts
the programs administered by DOL's Employment and Training
Administration (ETA). For purposes of this ICR, there are six affected
programs that have served an average of 1,000 or more covered persons
per year during their three most recent years of operation. These
programs are: Workforce Investment Act (WIA) Adult, WIA Dislocated
Worker, National Emergency Grants (NEGs), Wagner-Peyser (W-P) State
Grants, Trade Adjustment Assistance (TAA), and the Senior Community
Service Employment Program (SCSEP).

Under existing reporting requirements, the six affected ETA programs
collect, for covered participants, data on demographic characteristics,
services received and outcomes experienced. In conjunction with these
reporting requirements, for all the programs except the Wagner-Peyser
State Grants, data records are submitted annually for participants who
"exit" from participation. With the proposed rule to implement priority
of service in employment and training programs, additional data are
needed to make a full account to Congress on the services delivered to
covered persons. Therefore, the new reporting requirements proposed for
these programs primarily involve: 1) identifying *covered persons* at
the *initial point of entry;* and, 2) expanding the collection of
participant data records to include those *covered persons* served by
Wagner-Peyser State Grants*.*

Under the proposed information collection, a new customer classification
would be created called *covered entrants* - a precursor to the
*participant* customer classification, which already exists in ETA
reporting. The new classification seeks to identify and capture data on
*covered persons* at the *initial point of entry*, the earliest point
that a *covered person* contacts the system in either a physical
location (e.g., One-Stop Career Center or affiliate site) or remotely
through electronic technologies. In this way, the proposed information
collection offers a new dimension to DOL's reporting procedures by
making a distinction between *covered entrants* (those not yet receiving
services) and *covered* *participants* (those receiving services). Under
the provisions of the NPRM, the six programs affected by this ICR are
required to collect and report data on covered entrants.

Those ETA programs serving less than 1,000 covered persons per year will
not implement data collection and reporting on covered entrants.
However, those programs must adopt the covered, non-covered, veteran and
eligible spouse definitions as outlined in the JVA. Those programs will
adopt these definitions in conjunction with the first approved ICR whose
effective date falls on or after the effective date of this ICR, whether
that ICR is for a renewal of an existing approved information collection
or for approval of a new information collection.

The table below identifies: 1) the approved information collections
impacted by this ICR; and, 2) the relationship between the impacted
information collections and the six programs required to collect and
report data on covered entrants.

+----------+--------------------------------------------+--------------+
| **       |                                            |              |
| Approved |                                            |              |
| Inf      |                                            |              |
| ormation |                                            |              |
| Col      |                                            |              |
| lections |                                            |              |
| Impacted |                                            |              |
| by this  |                                            |              |
| ICR**    |                                            |              |
+----------+--------------------------------------------+--------------+
| OMB      | Title of Information Collection            | Submission   |
|          |                                            | of Exiter    |
| Number   |                                            | Records      |
+----------+--------------------------------------------+--------------+
| 1        | [WIA Management Information and Reporting  | Yes          |
| 205-0420 | System]{.underline}                        |              |
|          |                                            |              |
|          | -   Adult Worker Program                   |              |
|          |                                            |              |
|          | -   Dislocated Worker Program              |              |
|          |                                            |              |
|          | -   National Emergency Grants              |              |
+----------+--------------------------------------------+--------------+
| 1        | [Labor Exchange Reporting                  | No           |
| 205-0240 | System]{.underline}                        |              |
|          |                                            |              |
|          | -   Wagner-Peyser State Grants             |              |
+----------+--------------------------------------------+--------------+
| 1        | [Trade Act Participant Report]{.underline} | Yes          |
| 205-0392 |                                            |              |
|          | -   Trade Adjustment Assistance program    |              |
+----------+--------------------------------------------+--------------+
| 1        | [SCSEP Performance Measurement             | Yes          |
| 205-0040 | System]{.underline}                        |              |
|          |                                            |              |
|          | -   Senior Community Service Employment    |              |
|          |     Program                                |              |
+----------+--------------------------------------------+--------------+

This ICR proposes that the six affected programs will submit aggregate
quarterly reports on: 1) the number of covered entrants; and, 2) the
number of covered entrants who become participants. In addition, this
ICR also proposes that data records will be submitted for all covered
entrants. For all of the affected programs except the Wagner-Peyser
State Grants, the submission of data records for covered entrants will
be an adjunct of those programs' current procedures for compiling and
submitting participant data records. For those covered entrants who make
their initial contact with the Wagner-Peyser State Grants, this ICR
proposes that the data records will be compiled and submitted according
to the procedures currently in effect under the WIA Management
Information and Reporting System. This would serve two purposes: 1)
assist DOL in receiving data records on [all]{.underline} covered
entrants who access workforce investment services; and, 2) support
integration between WIA and the Wagner-Peyser State Grants.

The preceding paragraphs are based on the assumption that the reporting
requirements proposed in this ICR will take effect prior to the
effective date of the reporting procedures included in the Workforce
Investment Streamlined Performance Reporting (WISPR) system, a new
information collection proposed by ETA but not yet approved by OMB. Once
approved by OMB, WISPR will replace three of the approved information
collections impacted by this ICR:

-   The WIA Management Information and Reporting System (OMB No.
    1205-0420);

-   The Labor Exchange Reporting System (OMB No. 1205-0240); and

-   The Trade Act Participant Report (OMB No. 1205-0392).

Therefore, if WISPR is approved to take effect on or before the
effective date of this ICR, the reporting requirements proposed here
will impact two information collections (WISPR and the SCSEP Performance
Measurement System) rather than the four information collections
currently anticipated to be impacted.

As indicated above, the relationship between the effective date of the
reporting requirements proposed in this ICR and the effective date of
the reporting requirements proposed under WISPR is significant. In
addition to reducing the number of impacted information collections from
four to two, there are two other advantages to implementing the
reporting requirements proposed in this ICR on or after the effective
date of WISPR. The first advantage relates to the twin facts that the
Labor Exchange Reporting System is: 1) the only one of the four impacted
information collections that does not compile and submit data records;
and, 2) the system responsible for reporting on approximately 96% of the
veterans served by the six affected programs. Since WISPR will include
compilation and submission of data records for all participants in the
Wagner-Peyser State Grants, compilation and submission of data records
for the anticipated large number of covered entrants who first contact
this program will be consistent with the procedures already in place
under WISPR.

The second advantage of having the reporting requirements proposed in
this ICR take effect on or after the effective date of WISPR is that a
duplicate burden of effort would be avoided. Specifically, if: 1) the
reporting requirements proposed in this ICR were to take effect prior to
the effective date of WISPR, thus impacting the four currently approved
information collections; and, 2) WISPR were to take effect subsequently;
the effort required to revise the reporting requirements of both the
currently approved information collections and of WISPR would represent
a duplicate burden of effort.

Within the context of implementing the reporting requirements proposed
in this ICR on or after the effective date of WISPR, it would be most
advantageous if WISPR and the reporting requirements proposed here were
to take effect on the same date. That is because simultaneous
implementation of these two related reporting requirements would avoid a
scenario under which WISPR would be implemented without including the
reporting requirements proposed here and then would be revised
subsequently to include these reporting requirements. This second type
of potential duplication of effort would be avoided if both sets of
requirements were approved to take effect on the same date.

ETA proposes that WISPR will take effect on July 1, 2009. In conjunction
with that target date, ETA also assumes that the state agencies
responsible for implementing WISPR will require a preparation period of
approximately six months between the approval of WISPR and its effective
date in order to make the preparations necessary to implement this new
system. Therefore, if: 1) WISPR is approved for implementation on July
1, 2009; 2) the reporting requirements proposed in this ICR are approved
to take effect on that same date; and, 3) the approval of the reporting
requirements proposed in this ICR is received by December 21, 2008, the
advantage of simultaneously implementing WISPR and the reporting
requirements proposed here would be realized.

The new data elements associated with *covered entrants* and the
expanded participant level data will enable DOL to more adequately
assess the number of covered persons who entered the workforce
investment system, how many received services, and how many did not
(See: *Individual Record Data Elements*; and *Proposed Reporting Format
for Priority of Service Quarterly Aggregate Report*). If priority of
service is taking place, the number of *covered entrants* to the
workforce investment system should be comparable to the number of
*served covered persons* or *participants* (e.g., those who ultimately
receive a service).

Once the priority of service rule is implemented, DOL anticipates that
the six affected ETA programs will report on *covered entrants* as well
as apply the new priority of service data elements for covered
*participants*. Therefore, this supporting statement includes an
estimate of the hourly burdens and costs for implementing these
requirements across the six affected ETA programs.

**PRIORITY OF SERVICE REPORTING FRAMEWORK**

**[Glossary of Key Terms]{.underline}**

***Covered Entrant*** -- A *covered person* at the *initial point of
entry*. This classification occurs at the earliest point that a *covered
person* contacts the system in either a physical location (e.g.,
One-Stop Career Center or affiliate site) or remotely through electronic
technologies. Designation as a *covered entrant* occurs prior to receipt
of a service, but receipt of a service will likely occur almost
simultaneously for many *covered entrants*, at which point the covered
person also would be counted as a *participant.*

***Covered Person*** -- A person entitled to priority of service under
section 2(a) of the Jobs for Veterans Act, codified at 38 U.S.C. §
4215(a). Priority is extended to:

(a) A veteran;

(b) The spouse of any of the following individuals:

> \(1\) Any veteran who died of a service-connected disability;
>
> \(2\) Any member of the Armed Forces serving on active duty who, at
> the time of application for the priority, is listed in one or more of
> the following categories and has been so listed for a total of more
> than 90 days:
>
> \(i\) Missing in action;
>
> \(ii\) Captured in line of duty by a hostile force; or
>
> \(iii\) Forcibly detained or interned in line of duty by a foreign
> government or power;
>
> \(3\) Any veteran who has a total disability resulting from a
> service-connected disability;
>
> \(4\) Any veteran who died while a disability so evaluated was in
> existence.

***Covered Person Entry Date*** -- The date that the *covered person*
first made contact with the workforce investment system, as defined in
*initial* *point of entry,* making them a *covered entrant*.

***Initial Point of Entry** --* The earliest point that a *covered
person* contacts the workforce investment system, either in-person (at a
physical location - One-Stop Career Center or affiliate site) or
remotely through electronic technologies. Data on *covered entrants* is
captured at the *initial point of entry*.

***Participant*** -- A *participant* is an individual who is determined
eligible to participate in the program (to the extent a program has
eligibility requirements) [and]{.underline} receives a service funded by
the program in either a physical location (One-Stop Career Center or
affiliate site) or remotely through electronic technologies.

***Served Covered Person** --* A *covered person* who received a program
service within 45 days of their *covered person entry date* (a *served
covered person* is also a *participant*).

***Unserved Covered Person*** -- A *covered person* on who *covered
entrant* data was collected, but who did not receive a service within 45
days of their *covered person entry date*.

***Veteran -*** A person who served in the active military, naval, or
air service, and who was discharged or released under conditions other
than dishonorable. See 38 U.S.C. § 101(2).

*A.2. How, by whom, and for what purpose the information is to be used.*

In order to meet its statutory responsibilities under the JVA, the
Department is requesting a new collection of information pertaining to
*covered entrants* to the workforce investment system. The Department
will use the information collected to begin to assess the extent to
which priority of service is being implemented in the following
programs: Workforce Investment Act (WIA) Adult, WIA Dislocated Worker,
Wagner-Peyser (W-P) State Grants, National Emergency Grants (NEGs),
Trade Adjustment Assistance (TAA), and the Senior Community Service
Employment Program (SCSEP).

*A.3. Extent to which collection is automated, reasons for automation,
and considerations for reducing impact on burden.*

It is anticipated that the collection of this information will be
incorporated into web sites that provide workforce services, so the
process will be automated for the electronic *initial point of entry*.
However, when it comes to provision of services in a physical location,
such as One-Stop Career Centers, affiliated One-Stop partner sites, or
other specialized centers and sites designed to address special customer
needs (such as company work sites for dislocated workers), intake forms
and reporting processes that are not automated may be used, as DOL does
not specify *how* data is collected. To assist grantees, DOL will
provide grantees the approved data elements and accompanying forms for
*covered entrants*. DOL also plans on providing technical assistance to
grantees. For instance, DOL plans to provide program-specific
information identifying available options for capturing data associated
with this new customer classification.

In compliance with the Government Paperwork Elimination Act, the
Department anticipates approval by the Office of Management and Budget
(OMB) for specified data elements that will amend existing electronic
reporting systems (see the table above for impacted systems/records).
All data reported back to DOL will be submitted electronically.

*A.4. Efforts to identify duplication -- why similar information already
available cannot be used for purpose described in A.2.*

The type of data being sought by this data collection (information on
when *covered persons* first come into contact with the workforce
investment system) is not currently available. The only data that
currently exists on veterans is data collected on them after they have
begun participation in a program(s). The newly proposed data elements
are inclusive of all of the data needed for both these instances (i.e.,
*covered participants* **and** *covered entrants*) to assess priority of
service, so many of the request elements are already captured in
existing reporting systems. Reporting systems will only need to be
amended for those data elements that are not currently captured (e.g.,
Covered Entrant Identifier, Covered Person Entry Date, etc.) (see the
Information Collections: *Individual Record Data Elements*; and
*Proposed Reporting Format for Priority of Service Quarterly Aggregate
Report*).

*A.5. Efforts to minimize burden on small businesses*.

The recordkeeping and reporting requirements contained in this
information collection request are addressed to state formula grant
recipients and as such do not impact small businesses or other small
entities.

*A.6. Consequences to Federal program if collection not done or done
less frequently and any technical or legal obstacles to reducing the
burden.*

Both the ETA and recipient states are mandated to implement priority of
service requirements in qualified job training programs, as prescribed
in section 2(a)(1) of the JVA, Public Law (Pub. L.) No. 107-288 (Nov. 7,
2002), and the proposed rule that would implement these provisions.

The inability to collect the information requested would negatively
impact ETA's responsibilities for oversight and monitoring of priority
of service in these programs, because there is no other vehicle
available for helping to assess the extent to which the priority of
service provisions are being adhered to in workforce programs. Further,
the Department would not have the data it would need to provide a
complete report to Congress on priority of service to covered persons,
as required by the JVA.

*A.7. Special circumstances for conducting information collection.*

There are no special circumstances that would require the information to
be collected or kept in any manner other than those normally required
under the Paperwork Reduction Act.

*A.8. Summary of public comments.*

The public is being given 60 days to comment on the proposed data
collection requirements as part of the Notice of Proposed Rulemaking for
Priority of Service. Any comments received will be addressed at the
final rule stage.

*A.9. Explanation of decision to provide any payment or gift to
respondents.*

There will be no special payments or gifts to respondents other than the
formula funds and incentive funds provided for in the affected programs'
authorizing statutes.

*A.10. Assurance of confidentiality provided to respondents.*

ETA is responsible for protecting the confidentiality of any data and
will maintain the data in accordance with all applicable Federal laws,
with particular emphasis upon compliance with the provisions of the
Privacy and Freedom of Information Acts. The proposed data collection
does [not]{.underline} contain any individually identifying information
(e.g., names or Social Security Numbers). The quarterly report forms
provide data in the aggregate. States also will submit individual data
records to the Department each quarter, but these data records do not
include any identifiers that permit retrieval of information on the
identity of individuals. It should be noted that for all of its Privacy
Act systems of records, DOL has established and published in the Federal
Register a set of routine uses that apply to and are incorporated by
reference into each system of records. (*see Federal Register, V. 67,
No. 67, dated April 8, 2002, pp. 16815-16948*).

*A.11. Justification for any sensitive questions*.

There are no sensitive questions included in the proposed data
collection. The only questions that would need to be asked of customers
to comply with the new information collection requirements pertain to
their veteran status and the opportunity to provide their basic
demographic information.

A*.12. Estimated hourly burden*.

Several sections of the proposed rule involve Paper Work Reduction Act
(PRA) information collections (See Section 1010.220; 1010.330(b) and
1010.330(c)). The majority of these PRA impacts will effect existing
information collections. There are two information collections, however,
that do not have a current OMB number and therefore are proposed in this
Supporting Statement and ICR submission. These sections outline the
responsibilities of grant recipients to collect and maintain data on
covered and non-covered persons. A discussion of the estimated hourly
burden ensues.

Based on previous program experience, the Department estimates that
approximately 1,569,000 covered persons will access the public workforce
system next year.

In estimating service provider staff time costs, the Department used the
average hourly wage rate of employees in state Unemployment Insurance
(UI) agencies for FY 2006, adjusted the figure for inflation for FY 2008
(\$36.39) and increased it by a factor of 1.42 to account for employment
benefits and compensation for a total of \$51.67. Total estimated annual
collection and reporting burden hours for all respondent data are
**155,449** -- see tables below. By way of explanation, the total
estimated annual national burden for priority of service has two broad
components: 1) an estimate of **92,564** burden hours for record keeping
and reporting on *covered entrants*; and, 2) an estimate of **62,885**
burden hours for record keeping and reporting on new *covered persons
(participants),* which will capture characteristics, services, and
outcomes. The following tables provide further details regarding the
separate burden estimates for each component (e.g., *covered entrant*
data and new *covered person* *participant* data).

**TABLE 1.**

The projected annual counts for *covered entrants* comes from actual
data on *covered persons served (participants)* from the most recent
full year of program reporting. Data was compiled from the following
reporting systems: The WIA Management Information and Reporting System;
The Labor Exchange Reporting System; The Trade Act Participant Report;
and SPARQ. Though our current reporting culture does not recognize
*covered entrants*, *covered participants* should be a good predictor of
the number of [new]{.underline} individual *covered entrant records*
that will need to be produced by grantees.

The projection of 92,564 burden hours is based on the completion of
individual covered entrant records. The burden will be the same
regardless of the mix of reporting systems that are ultimately impacted;
this is because the number of data elements for covered entrants will be
the same regardless of which reporting system they are attached to.

  -------------- --------------- ---------- -------------- ------------ -----------------
  **TABLE 1.                                                            
  Covered                                                               
  Entrant Data                                                          
  Collection**                                                          

  Program        Projected       Hourly     Minutes Per    Annual       Annual National
                 Annual Counts\* Rate\*\*   Record\*\*\*   National     Burden Dollars
                                                           Burden Hours 

  Integrated     1,568,574       \$51.67    3.5            91,500       \$4,727,805
  W-P/,\* WIA                                                           
  Adult, DW, NEG                                                        

  TAA            6,410           \$51.67    3.5            374          \$19,325

  SCSEP          11,831          \$51.67    3.5            690          \$35,652

  **Total**      **1,586,815**   ** **      ** **          **92,564**   **\$4,782,782**
  -------------- --------------- ---------- -------------- ------------ -----------------

\*Note that covered entrants that enter physical offices or web sites
funded by Wagner-Peyser State Grants will still need to be captured in
the Workforce Investment Act Standardized Record Data (WIASRD)
submissions.

\*\*Hourly rate is based on the FY 2006 salary of employees in state UI
agencies adjusted for inflation for FY 2008 and increased by a factor of
1.42 to account for employment benefits and compensation.

\*\*\*Ten percent of this time represents information technology
management including searching the multiple existing data sources needed
to complete the quarterly report form, gathering and maintaining the
data, completing and reviewing the collection of individual records, and
submitting to DOL.

**TABLE 2.**

New covered person *participant* data to be collected under the WIA
Management Information and Reporting System is also factored into the
burden calculation. Some additional increases in the number of veterans
participating in WIA services are likely to occur for the following
reasons: 1) it is expected that priority of service will bring
additional attention to serving veterans and thus create new
opportunities for covered persons to access WIA services; 2) adoption of
the JVA definition of covered person for WIA services will broaden the
pool of those eligible for priority by including eligible spouses of
veterans; and, 3) the reporting integration between W-P and WIA is
expected to increase program integration and thus increase the number of
veterans receiving WIA services. As a preliminary estimate, we believe
these factors could lead to ten percent of those veterans who currently
receive only W-P services also receiving WIA services. Currently, the
W-P State Grants serve 1,151,530 veterans. The table below assumes that
10 percent of that number, or 151,530 covered persons, also will become
WIA participants due to the factors identified above. Please see the
annual burden hours and cost information table for these
[new]{.underline} WIA participants below.

  --------------- ------------- ------------- -------------- ------------ -----------------
  **TABLE 2. New                                                          
  Covered Person                                                          
  Participant                                                             
  Data                                                                    
  Collection**                                                            

                  Projected     Hourly        Minutes Per    Annual       Annual National
                  Annual        Rate\*\*      Record\*\*\*   National     Burden Dollars
                  Counts\*                                   Burden Hours 

  Estimated       **151,530**   **\$51.67**   **24.9**       **62,885**   **\$3,249,268**
  Increase in                                                             
  Covered Persons                                                         
  Served                                                                  
  --------------- ------------- ------------- -------------- ------------ -----------------

\*This represents the new covered participants served as a result of the
ICR. The projection is based on counts from the most recent full year of
W-P reporting. The estimate of 151,530 new covered person participants
in WIA represents 10 percent of the number of veteran participants
currently served by W-P State Grants.

\*\*Hourly rate is based on the FY 2006 salary of employees in state UI
agencies adjusted for inflation for FY 2008 and increased by a factor of
1.42 to account for employment benefits and compensation.

\*\*\*Ten percent of this time represents information technology
management including searching the multiple existing data sources needed
to complete the quarterly report form, gathering and maintaining the
data, completing and reviewing the collection of individual records, and
submitting to DOL.

*A.13. Estimated cost burden to respondents.*

Since these data collection requirements apply to state formula grant
recipients, administrative resources are provided as part of the grant
to off-set staff costs associated with reporting and systems
modifications. As such, there is no additional cost to respondents other
than those reported in Section A.12. above.

*A.14. Estimated cost burden to the Federal government*

To implement the new data collection requirement, ETA must change its
reporting infrastructure to accommodate the new elements (see the
following Information Collection: *Individual Record Data Elements*).
Additionally, programs will need to submit aggregate quarterly reports
(see the following Information Collection: *Proposed Reporting Format
for Priority of Service Quarterly Aggregate Report*). The estimated cost
burden to the Federal Government will vary, depending on what systems
ultimately end up being modified by the new data collection
requirements.

If ETA's proposed Workforce Investment Streamlined Performance Reporting
(WISPR) system is implemented it would replace the current reporting
systems for all of the impacted programs, with the exception of the
SCSEP. If WISPR has been implemented when the priority of service
reporting requirements go into affect, only two reporting systems (WISPR
and the SCSEP Performance and Results Quarterly \[SPARQ\]) will need to
be modified:

WISPR: \$400,000

SPARQ: \$400,000\
**Total: \$800,000**

The estimated cost to the federal government for both WISPR and SPARQ is
largely based on the addition of four new data elements associated with
individual records for *covered person participants*; modifications to
IT systems to collect and store additional data associated with *covered
entrants* and the new quarterly reports; changes to the data validation
software; and technical assistance to the states.

If the priority of service reporting requirements are implemented before
the implementation of WISPR, three program reporting systems would be
impacted (WIA, TAA and SCSEP). **DOL would need a mechanism to capture
individual record information on all *covered entrants* to the public
workforce investment system** (see the following Information Collection:
*Individual Record Data Elements*)**. Since the reporting for the W-P
State Grants does not include individual data records that are submitted
to DOL, *covered entrants* that access services funded only by the W-P
State Grants (in One-Stop physical locations or via virtual service
delivery) will need to be tracked by the Workforce Investment
Standardized Record Data (WIASRD).** This would serve two key
purposes: 1) assist DOL in receiving individual records on
[all]{.underline} *covered entrants* who access workforce investment
services; and, 2) support integration between the WIA and W-P
activities.

WIA: \$2,100,000

TAA: \$375,000

SPARQ: \$400,000

**Total: \$2,875,000**

The estimated cost to the federal government for the aforementioned
systems is largely based on the addition of four new data elements
associated with individual records for *covered person participants*;
modifications to IT systems to collect and store additional data
associated with *covered entrants and covered person participants* and
the new quarterly reports; changes to the data validation software; and
technical assistance to the states.

Note: For WIA, the estimate is larger due to the capturing of *covered
entrants* and a slightly larger universe of *covered person
participants* in the WIASRD submissions.

*A.15. Reasons for any program changes reported in Items 13 or 14 of the
OMB Form 83-1.*

As this is a new information collection request, there is no burden
currently associated with this information collection. The increase in
burden is a result of new data that needs to be collected as a result of
the promulgation of new priority of service regulations and the
associated data collection and reporting requirements.

*A.16. Method for publishing results*.

ETA publishes program performance information on its public access
webpage at: <http://www.doleta.gov/performance>

Based on the new individual record submissions, DOL will report on an
annual basis the number of *covered entrants*, the number who received
services, and the number who went unserved.

States and territories will submit aggregate reports on a quarterly
basis to DOL within 45 days after the end of each Program Year (PY)
quarter. Reports are due on the following dates:

  ------------------------------------------------ ----------------------
  **Report Quarter**                               **Due Date**

  1st Quarter PY July to September                 November 14

  2nd Quarter PY October to December               February 14

  3rd Quarter PY January to March                  May 15

  4th Quarter PY April to June                     August 14
  ------------------------------------------------ ----------------------

*Covered entrant* individual record submissions will also be received
according to the same schedule as the aggregate reports.

Individual record submissions on *covered entrants* that become
*participants* will be received after they complete program services, on
an annual basis, unless WISPR has been fully implemented by the time
this requirement goes into affect. If WISPR is the system that is
modified by this ICR, individual records will be submitted quarterly
according to the above schedule as well.

Data will be analyzed by ETA and VETS staff. Data analysis is used to
identify strategies for continuous improvement and areas where
additional federal guidance is needed. DOL may use these data to prepare
Government Performance and Results Act (GPRA) reports, budget reports,
OMB's Program Assessment Rating Tool (PART), and other ad hoc reports.

Each year, the Department issues an annual report summarizing program
performance against the Secretary's goals. Some of the data included in
the Department's annual report would be generated from these individual
record submissions. Additionally, the Department prepares an Annual
Performance Accountability Report (APAR), which includes performance
data on all programs covered under this ICR. To satisfy its requirements
under Title 38, VETS also submits an annual report to Congress. That
report addresses the statutory requirement at 38 U.S.C. § 4215(d) to
report annually to the Congress on: a) the extent to which covered
persons are fully served; and, b) the extent to which the rate of
representation of covered persons in workforce programs reflects their
rate of incidence in the population. All reports are available on the
Internet and accessible to the general public and interested
stakeholders.

*A.17. If seeking approval not to display the expiration date for OMB
approval, explain why display would be inappropriate*.

The Department will display the expiration date for OMB approval until
the priority of service data collection and reporting requirements are
assimilated into the impacted reporting systems. After that time, a
Request to Discontinue this collection will be submitted to OMB, as this
collection's requirements would become part of the approvals of the
impacted reporting systems.

*A.18. Explanation of each exception in the certification statement
identified in Item 19 "Certification for Paperwork Reduction Act
Submissions" on OMB Form 83-1*.

The Department is not seeking any exception to the certification
requirements.

B.  **Collection of Information Employing Statistical Methods**

This information collection request employs no statistical methods.