Notice2022-08977
Agency Information Collection Activities; Submission for OMB Review; Public Comment Request; of the No Wrong Door (NWD) System Management Tool OMB Control 0985-0062
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Published
April 27, 2022
Issuing agencies
Health and Human Services DepartmentCommunity Living Administration
Abstract
The Administration for Community Living is announcing that the proposed collection of information listed above has been submitted to the Office of Management and Budget (OMB) for review and clearance as required under section 506(c)(2)(A) of the Paperwork Reduction Act of 1995. This 30-Day notice collects comments on the information collection requirements related to the information collection requirements of the No Wrong Door (NWD) System Management Tool OMB Control 0985-0062.
Full Text
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<title>Federal Register, Volume 87 Issue 81 (Wednesday, April 27, 2022)</title>
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[Federal Register Volume 87, Number 81 (Wednesday, April 27, 2022)]
[Notices]
[Pages 25024-25027]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-08977]
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Administration for Community Living
Agency Information Collection Activities; Submission for OMB
Review; Public Comment Request; of the No Wrong Door (NWD) System
Management Tool OMB Control 0985-0062
AGENCY: Administration for Community Living, HHS.
ACTION: Notice.
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SUMMARY: The Administration for Community Living is announcing that the
proposed collection of information listed above has been submitted to
the Office of Management and Budget (OMB) for review and clearance as
required under section 506(c)(2)(A) of the Paperwork Reduction Act of
1995. This 30-Day notice collects comments on the information
collection requirements related to the information collection
requirements of the No Wrong Door (NWD) System Management Tool OMB
Control 0985-0062.
DATES: Submit written comments on the collection of information by May
27, 2022.
ADDRESSES: Submit written comments and recommendations for the proposed
information collection within 30 days of publication of this notice to
<a href="http://www.reginfo.gov/public/do/PRAMain">www.reginfo.gov/public/do/PRAMain</a>. Find the information collection by
selecting ``Currently under 30-day Review--Open for Public Comments''
or by using the search function. By mail to the Office of Information
and Regulatory Affairs, OMB, New Executive Office Bldg., 725 17th St.
NW, Rm. 10235, Washington, DC 20503, Attn: OMB Desk Officer for ACL.
FOR FURTHER INFORMATION CONTACT: Kristie Kulinski, (202) 795-7379 or
<a href="/cdn-cgi/l/email-protection#5e352c372d2a373b70352b3237302d35371e3f3d327036362d70393128"><span class="__cf_email__" data-cfemail="c5aeb7acb6b1aca0ebaeb0a9acabb6aeac85a4a6a9ebadadb6eba2aab3">[email protected]</span></a>. Administration for Community Living.
SUPPLEMENTARY INFORMATION: In compliance with 44 U.S.C. 3507, ACL has
submitted the following proposed collection of information to OMB for
review and clearance.
[[Page 25025]]
The Administration for Community Living (ACL) is requesting
approval to collect data for the No Wrong Door (NWD) System Management
Tool OMB Control 0985-0062.
ACL, the Centers for Medicare and Medicaid Services (CMS), and the
Veterans Health Administration (VHA) have partnered to support states'
efforts in developing coordinated systems of access, or No Wrong Door
(NWD) Systems, to make it easier for people to learn about and access
long-term services and supports (LTSS). When seeking services and
supports, individuals and caregivers often face multiple, fragmented
processes that are complex and confusing. States' access systems have
been built over time as programs and funding streams have been added,
creating duplicative eligibility and intake processes that are
difficult for individuals and their caregivers to use.
To address these issues, the NWD System model supports state
efforts to streamline access to LTSS options for all populations and
provides the infrastructure to promote the collaboration of local
service organizations, making service delivery more efficient and
person-centered. Examples of coordinated efforts include processes
where individuals are assessed once via a common or standardized data
collection method that captures a core set of individual level data
relevant for determining the range of necessary LTSS.
The Federal vision for the NWD System gives states flexibility in
determining how best to organize, structure and operate the various
functions of their NWD System. States continue to integrate, in some
cases restructure, and over time strengthen their existing programs in
order to realize the joint ACL/CMS/VHA vision for a fully coordinated
and integrated system of access. These efforts are supported by a
variety of initiatives, including the VHA's Veteran Directed Care (VDC)
program, an evidence-based self-directed program where person-centered
counselors from aging and disability network agencies within a state's
NWD System provide facilitated assessment and care planning, arrange
fiscal management services, and provide ongoing counseling and support
to Veterans, their families, and caregivers.
The NWD System Management Tool (NWD MT) provides a platform for
data collection necessary to evaluate the four primary functions of a
NWD System: State Governance and Administration, Public Outreach and
Coordination with Key Referral Sources, Person Centered Counseling, and
Streamlined Access to Public LTSS Programs. In addition, this tool will
include data collection for the VDC program to collect qualitative and
quantitative data elements necessary to evaluate the impact of the VDC
program. The VDC Tool will track key performance measures and identify
best practices and technical assistance needs.
The NWD MT and the VDC Tool will enable ACL and its partners to
collect and analyze data elements necessary to assess the progress of
the NWD System model, track performance measures, and identify gaps and
best practices.
These tools have been designed in close collaboration with states
and are intended to simplify grant reporting requirements to reduce
burden on local and state entities and will provide a consistent,
streamlined and coordinated statewide approach to help states govern
their NWD System and manage their programs efficiently.
Comments in Response to the 60-Day Federal Register Notice
The associated 60-day notice Federal Register Vol. 87, No. 8 was
published on Wednesday, January 12, 2022. Three public comments were
received in response to the 60-day notice. ACL's responses to these
comments are included below.
------------------------------------------------------------------------
Data collection form Comment ACL response
------------------------------------------------------------------------
NWD Management Tool......... There is no funding The NWD System
provided to Management Tool
incentivize the will only be
time and effort required for states
needed to collect and territories
and report data in with active
the NWD System discretionary
Management Tool on grants that provide
an ongoing basis. funding for grant
activities,
including the
collection and
reporting of data
in the Management
Tool. Accordingly,
resources will be
made available to
grantees for data
collection and
reporting via their
grant budgets. ACL
has no expectation
that all states and
territories will
complete the
Management Tool.
NWD Management Tool......... Collecting and As stated above,
reporting data in only states and
the NWD System territories
Management Tool receiving
would be time discretionary grant
consuming and place funding will be
undue burden on required to
local sites. complete the NWD
System Management
Tool. Resources
will be provided as
part of any funding
opportunity
requiring
completion of the
Management Tool.
The questions in
the NWD System
Management Tool
closely mirror
those collected
under prior
discretionary grant
reporting
requirements (e.g.,
ADRC COVID-19 CARES
Act grant, NWD
Business Case
grant).
NWD Management Tool......... ACL's estimates of ACL has updated the
burden are burden estimate to
inaccurate for the reflect additional
proposed collection time at both the
of information. Our state and local
state estimates level. The burden
four hours annually estimate is also
for state updated to reflect
completion and 248 the anticipated
hours for local number of states
completion of the and territories
NWD Management Tool. expected to
complete the
Management Tool
annually (reduced
from all 56 states
and territories to
15, which is the
maximum number of
states and
territories
expected to be
funded under
discretionary grant
opportunities over
the next three
years).
[[Page 25026]]
NWD Management Tool......... The NWD Management ACL completed a
Tool asks for crosswalk of the
program data NWD System
collection that is Management Tool
already collected with data elements
by other funders. collected for other
programs and
funding streams,
including Older
Americans Act (OAA)
Title III, Center
for Independent
Living (CIL)
Program, State
Health Insurance
Assistance Program
(SHIP), and
Medicare
Improvements for
Patients and
Providers Act
(MIPPA) funding.
NWD Systems serve
all populations and
all payers. While
there is not a
direct overlap with
other data
collection efforts,
ACL does recognize
that some data
elements collected
for other programs
may contribute to
metrics in the NWD
System Management
Tool (e.g., count
of individuals 60+
served, number of
outreach
activities). ACL
will provide
accompanying
guidance to
grantees on where
they may find
Management Tool
data elements
collected for other
programs.
NWD Management Tool......... Terms used in the The NWD System
NWD Management Tool Management Tool
may have various will be accompanied
interpretations by a user manual,
depending on the which will include
respondent. This a glossary of terms
may lead to data and definitions.
discrepancies when Additionally, any
comparing across funding opportunity
states and requiring reporting
organizations. The in the Management
clarity of the Tool will define
information to be ADRC and NWD so
collected would be that it is clear to
enhanced with applicants. NWD is
clearer an initiative of
definitions. NWD the U.S. Department
remains an of Health and
amorphous term that Services (HHS),
is implemented in including ACL and
many different the Centers for
forms across the Medicare and
country. The OAA Medicaid Services
defines Aging and (CMS), as well as
Disability Resource the Department of
Centers (ADRCs) in Veterans Affairs
the statute; (VA). ACL's support
however, the ACL of NWD is
vision of a state consistent with
NWD system is an HHS's vision.
evolution of the
ADRCs that expands
beyond the
statutory
definition and
associated
operation
requirements.
NWD Management Tool......... The quality could be While there are
enhanced with challenges in
narrative reporting aggregating
(qualitative qualitative data
opportunities) to across grantees,
provide a better ACL welcomes, but
360 view of the does not require,
work of the NWD narrative reporting
system. Mixing as part of the NWD
quantitative and System Management
qualitative data Tool. As described
can provide a more above, reporting in
holistic vision of the Management Tool
the complexity of would be part of a
the work of the NWD discretionary
system as well as funding
the complexity of opportunity, and as
the clientele such, grantees
served. would also have the
opportunity to
share a more
holistic view of
their NWD Systems
and best practices
through regular
monitoring and
technical
assistance calls
with ACL project
officers.
NWD Management Tool......... Ensure that the ACL has piloted the
reporting system is NWD System
functional so that Management Tool web-
end users can based platform with
submit data without three states to
frustration. test user
functionality at
the federal, state,
and local level.
ACL will continue
to refine the
platform to ensure
a seamless user
experience when
inputting and
reviewing data.
NWD Management Tool......... Regarding State ACL agrees that it
Level Question 10 ( is not the
``How frequently responsibility of
does the state any one state
conduct a review to agency to monitor
monitor and assess the entire NWD
the performance of System. A state or
its NWD System? territory's
''), a statewide governing body or
review or governance
monitoring has been structure is
conducted on the responsible for
ADRCs. A NWD review monitoring the
or monitoring has access system. To
not been conducted, address this
but all of the concern in the NWD
programs have System Management
quality assurance Tool, and to align
processes and with the monitoring
procedures and expectations of the
they, as well, are state lead agency,
monitored. ACL is modifying
Monitoring the NWD State Level
System at this time Question 10 as
would be arduous follows: ``Does
and burdensome to your state conduct
all partners. a review to monitor
performance of
ADRCs in your NWD
System? ''
NWD Management Tool......... Regarding State ACL agrees that the
Level Question 11 ( data collected from
``Does the state this question will
have a statewide IT not be robust and
System for NWD? has decided to
''), ADRCs have a remove this
statewide data question from the
reporting system NWD System
and it is those Management Tool.
entities that
anchor the NWD
System--because of
this--this question
becomes one of
interpretation.
[[Page 25027]]
NWD Management Tool......... Regarding State The state lead
Level Question 21 ( agency completing
``How many the NWD System
statewide toll-free Management Tool
numbers does the should identify
state have to those toll-free
increase access to numbers that meet
the NWD System? the criteria of
''), individual being statewide.
programs have 1-800 Toll-free numbers
numbers to support administered by
work--depending how local partners
you interpret the would not be
organization types reported.
above would
determine how this
would be answered.
Interpretation
leads to data that
lacks meaning and
utility for ACL.
VDC Tool.................... We recognize that As noted above, the
the Veterans NWD System
Directed Care (VDC) Management Tool
Program reporting would only be
tool is required by
specifically entities receiving
targeted to the discretionary grant
entities defined as funding with
Hubs, Sole resources provided
Proprietors, and to support data
providers in the collection and
VDC system. entry. Data
However, we do want collected and
to stress that many reported in the VDC
state NWD systems Tool is only
do not perform, recommended for
monitor and/or providers in the
track any VDC program.
information for VDC
programs and
therefore cannot
provide the
oversight,
training, and
coordination that
will likely be
required to
implement this data
collection
requirement. We
also note that the
VDC system entities
included in these
requirements have
substantial overlap
with those local
entities that will
be required to
submit data under
the NWD data
reporting system.
We are concerned
that the VDC
reporting
requirement is
duplicative and
will place further
administrative
burden on these
entities
specifically.
------------------------------------------------------------------------
Estimated Program Burden
ACL estimates the burden of this collection of information as
follows:
Fifty-six lead NWD System state and territorial agencies will
respond to the NWD MT bi-annually and it will take approximately half
an hour to collect the data and an additional half hour to input the
data into a web-based system. Additionally, an estimated 900 local
agencies will take approximately two hours to collect and submit the
data to their lead NWD System state agency. There may be several lead
NWD System state and territorial agencies who will be submitting on
behalf of their local agencies. Therefore, the approximate burden for
the local level agencies may be thirty minutes less than anticipated.
If all state and local agencies respond bi-annually, the national
burden estimate for the NWD MT would be a total of 3,712 hours
annually. This burden estimate is calculated based upon a sample of
ADRC/NWD grantees. Each state entity submitting data will receive
local-level data from designated NWD System entities.
The estimated response burden includes time to review the
instructions, gather existing information, and complete and review the
data entries in a web-based system. An estimated 275 VDC program
entities will respond to the VDC Tool on a monthly-basis, all of which
are also NWD local-level entities, for an annual burden of 1,650 hours.
This burden estimate is calculated based upon information provided
by current VDC program providers testing an abbreviated version of the
VDC Tool. The NWD MT and the VDC Tool have been developed to increase
ease and uniformity of reporting and improve the ability of ACL to
manage and analyze data.
----------------------------------------------------------------------------------------------------------------
Number of Responses per Hours per Annual burden
Respondent/data collection activity respondents respondent response hours
----------------------------------------------------------------------------------------------------------------
NWD Management Tool data collection and entry-- 56 2 1.0 112
State Level....................................
NWD Management Tool data collection and entry-- 900 2 2.0 3,600
Local Level....................................
Veteran Directed Care Tool...................... 275 12 0.5 1,650
---------------------------------------------------------------
Total:...................................... 1,231 .............. .............. 5,362
----------------------------------------------------------------------------------------------------------------
Dated: April 21, 2022.
Alison Barkoff,
Acting Administrator and Assistant Secretary for Aging.
[FR Doc. 2022-08977 Filed 4-26-22; 8:45 am]
BILLING CODE 4154-01-P
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