FR 2024-29825

The document is a notice from the Department of Labor (DOL), specifically from the Employment and Training Administration (ETA), seeking public comments on an information collection request related to the Resource Justification Model (RJM). The RJM is a tool used by state agencies to provide detailed cost data, which informs the allocation of administrative funding. The DOL aims to secure the Office of Management and Budget's (OMB) approval to continue using this model for three more years.

General Summary

The DOL has issued a notice inviting public feedback on a proposed data collection process called the Resource Justification Model. The purpose of this model is to gather cost-related data from state agencies, aiding in effective funding allocations for administrative functions. Comments can be submitted until January 16, 2025, allowing stakeholders to express their views on how this data collection might impact them.

The submission process involves accessing a government website where stakeholders can find the pertinent information collection under review and submit comments. The DOL underscores its need for OMB approval to proceed with using this model, noting the procedural necessity of such approval under the Paperwork Reduction Act of 1995.

Significant Issues or Concerns

The document presents several areas of potential concern:

1. Lack of Detailed Impact Explanation: While the document outlines the purpose of collecting data through the RJM, it does not detail how these data affect specific funding decisions. This vagueness may prevent readers from understanding the actual significance or utility of the model.

2. Broad and Undirected Public Comment Categories: The call for comments is broad, asking for feedback on the necessity, accuracy, and potential improvements of the data collection process. However, without guidance or specific questions, stakeholders might find it challenging to provide concrete and actionable feedback.

3. Reference to Related Notices: The notice refers to a previous Federal Register publication but fails to summarize its key points. This oversight could leave readers unsure of where to find background information necessary to contribute informed commentary.

4. Specification of Data Submission Format: The document mentions submitting data in a "structured format (spreadsheet file)" but does not specify what software or platform is required. This ambiguity might affect the readiness of stakeholders to participate.

5. Lack of Burden Breakdown: The document provides an overall time burden estimate of 5,380 hours but does not break down which activities or processes contribute to this estimate, leaving potential respondents uninformed about what specific tasks require their time and resources.

Broader Public Impact

Overall, the document's invitation for public comment provides an opportunity for people and organizations affected by such data collection to express their views and influence how the DOL manages administrative funding. By participating in this process, the public can help ensure that federal allocations are informed by accurate and useful data, potentially leading to more efficient use of government resources.

Impact on Specific Stakeholders

For state, local, and tribal governments, which are the primary stakeholders in this data collection model, the impact could be significant. A transparent and efficient RJM process may result in better funding decisions that reflect the actual needs and costs of administering programs at the state and local levels.

On the negative side, the ambiguity surrounding the specifics of the data submission process and the lack of detailed burden information might place an undue initial burden on governments trying to comply with the requirements. A clearer understanding of these requirements would allow these entities to prepare adequately and minimize disruptions in their operations.

By recognizing these nuances, stakeholders can better engage with the DOL during this feedback period to influence the refinement and improvement of the RJM process. Additionally, comments emphasizing clarity and transparency could lead to more actionable and tailored guidance for respondents, enhancing the effectiveness of this solicitation for feedback.

The document from the Department of Labor discusses an information collection request related to the Resource Justification Model (RJM) and its implications for financial allocations within the Employment and Training Administration. The financial references within the document focus primarily on the absence of additional costs and how data collected are used to inform budgetary decisions.

Salary and Benefits Allocation

One of the key financial elements mentioned involves the data collected on salary and benefit rates. This information is crucial because it helps the Employment and Training Administration (ETA) allocate administrative funding effectively among different state agencies. The mechanisms of these allocations, however, are not detailed, aligning with an identified issue in the document: the lack of specific examples illustrating how the RJM data materially affect funding decisions.

Non-Personal Services Dollars

The document also references the non-personal services dollars, which are part of the overall financial data collected to aid funding decisions. This suggests money spent on non-salary-related items, possibly including operational costs. Although the document indicates that these figures are used to guide allocations, there is no detailed explanation regarding their direct impact, leaving room for interpretation and fitting under the issue of a lack of guidance for stakeholders to offer targeted feedback.

Estimated Costs and Burdens

Interestingly, the document specifies that there are no additional annual costs burdened by this information collection effort, denoted as $0. This aspect might be reassuring to stakeholders concerned about new financial responsibilities. However, it does not provide a breakdown of the estimated time burden of 5,380 hours needed for data submission, meaning the understanding of the time investment, an indirect financial cost, is limited. This ties back to the issue where the effort required is not clearly communicated.

In summary, while the financial references point to data's role in effective budgeting and assert no additional costs to participants, the document falls short of offering clarity on the direct financial implications and utility of the collected data, an aspect critical for informed public commentary.