[Federal Register Volume 87, Number 81 (Wednesday, April 27, 2022)]
[Notices]
[Pages 25024-25027]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[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 
www.reginfo.gov/public/do/PRAMain. 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 
[email protected]. 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
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    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