Overview
Title
Agency Information Collection Activities; Submission for OMB Review; Comment Request; Department of Labor-Only Performance Accountability, Information, and Reporting System
Agencies
ELI5 AI
The Department of Labor wants to collect information to help improve work programs and needs permission to do so, and they are asking people what they think about this plan. The gathering of this information will cost a lot of money and involve many people, but the details about what exactly they need and how it will help aren't very clear yet.
Summary AI
The Department of Labor (DOL) has submitted an information collection request to the Office of Management and Budget (OMB) to fulfill reporting requirements under the Workforce Innovation and Opportunity Act (WIOA). This request involves collecting performance indicators and includes new requirements for apprenticeship grant reporting. The department invites public comments on the necessity and burden of this data collection. The OMB will consider these comments by February 5, 2025, as part of their approval process.
Abstract
The Department of Labor (DOL) is submitting this Employment and Training Administration (ETA)-sponsored information collection request (ICR) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995 (PRA). Public comments on the ICR are invited.
Keywords AI
Sources
AnalysisAI
The document in question is a notice issued by the Department of Labor (DOL) regarding a proposed information collection request. This request is a part of the Employment and Training Administration’s efforts to fulfill reporting requirements under the Workforce Innovation and Opportunity Act (WIOA). The document is open for public comments, and the agency eagerly seeks input by February 5, 2025, prior to potential approval from the Office of Management and Budget (OMB).
General Summary
The notice focuses on efforts by the Department of Labor to fine-tune its data collection practices under WIOA, a law intended to help job seekers access employment, education, training, and support services. This proposal particularly emphasizes the need for collecting detailed performance indicators, aiming to streamline performance reporting, especially for apprenticeship programs.
The document outlines that this information collection is intended to satisfy legal requirements but also aims to aid in assessing the success and efficiency of various programs under its purview.
Significant Issues and Concerns
Despite the document's focus on public participation and transparency through comments, it does present some challenges for laypeople. The language used is technical and assumes prior knowledge of governmental processes and the WIOA, which could inhibit meaningful public engagement.
One of the notable figures is a considerable cost burden estimate of over $9 million annually, yet there’s a lack of detail about what these costs specifically include. This omission could generate confusion or concern among stakeholders and the public. Similarly, the document lists extensive quantitative data on respondents and responses but offers no insight into how these figures were calculated, which is essential for assessing the proposal's validity.
Moreover, the emphasis on specific forms without detailed descriptions could cause misunderstandings for those unfamiliar with DOL’s bureaucratic processes.
Public Impact
For the general public, the potential approval of this data collection is likely seen as a part of ongoing governmental operations. However, the estimated cost and the extensive amount of data collection could raise questions about resource allocation and administrative efficiency. Consequently, public interest might focus on understanding the tangible benefits and improvements spurred by such data collection initiatives.
Impact on Stakeholders
State, local, and tribal governments are directly affected as they are identified as the "Affected Public." A successful implementation of the proposed collection system could lead to more effective and efficient service delivery at these levels of government, potentially improving workforce-related program outcomes. However, there could be concerns over the logistics and the administrative burden implicit in handling large volumes of data and responding to new reporting requirements.
Stakeholders who will be directly involved in apprenticeship and employment training programs may view these developments as beneficial, facilitating clearer insights into program outcomes and areas needing adjustment. On the contrary, the additional reporting requirements could inevitably create more administrative work for these stakeholders, which might not be seen as favorable unless adequately justified by clear utility and outcomes associated with the reported data.
In conclusion, while the notice seeks to address statutory needs and improve program accountability, its execution and communication are key to gaining public trust and ensuring the involvement of relevant stakeholders in a supportive capacity.
Financial Assessment
The document delineates an important financial aspect, mentioning a total estimated annual other costs burden of $9,491,287. This figure is significant, reflecting the financial resources anticipated to cover additional costs associated with the information collection efforts spearheaded by the Department of Labor's Employment and Training Administration. However, the document does not specify what these costs sustain, leaving room for conjecture about how such resources might be distributed across various functions or why they are necessary.
Furthermore, the financial cost references relate to several identified issues:
Lack of detail on cost calculation: A key issue with the document is its failure to provide a breakdown or explanation of how the $9,491,287 cost burden is computed. For a reader, understanding the allocation and justification of this amount is crucial for assessing the potential efficacy and necessity of the funding. Clearer insights into this figure would help address questions about resource allocation and ensure that public comments are well-informed.
Accessibility of financial information: The document's technical language could be a barrier for the general public, preventing a full understanding of the financial implications without prior knowledge. Presenting a detailed account of how the funds are expected to be used could make the information more accessible and encourage constructive public engagement.
Lack of cost-benefit analysis: Although the document seeks public comments on the necessity of the information collection, it fails to provide context regarding how the $9,491,287 cost burden will translate into practical benefits or improvements for the Department. An illustrative explanation of how the expenditure contributes to the agency's objectives would better substantiate the financial investment.
Overall, while the document highlights an important financial commitment as part of its regulatory requirements, details explaining the specific use and justification of budgetary allocations remain sparse. Addressing these gaps could enhance transparency, allowing the public to better assess the justification and reasonableness of the projected cost burden.
Issues
• The document mentions a total estimated annual other costs burden of $9,491,287, which is a significant amount but does not provide detailed information on how this cost is calculated or what it specifically covers.
• The language used in the document is technical, which may make it difficult for the general public to fully understand without prior knowledge of the Workforce Innovation and Opportunity Act (WIOA) and related reporting requirements.
• The document requests public comments on whether the collection of information is necessary, but it does not provide specific examples or scenarios illustrating how this data will practically benefit or improve the functions of the Department.
• The document includes numerous references to specific forms (e.g., ETA-9172, ETA-9173-APPSHP), but does not offer explanations or summaries of what these forms entail, which may limit understanding for individuals not familiar with these documents.
• The total estimated number of respondents (22,687,331) and responses (46,167,618) suggests a large scale of data collection, but there is no discussion of the methodology used to arrive at these numbers, which could be critical in assessing the reasonableness and necessity of the data collection.