Low Income Home Energy Assistance Program (LIHEAP) Performance Data Form
OMB Information Collection Request
Supporting Statement Part A - Justification
Type of Request: Reinstatement with changes
Submitted By:
Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
This request is for a reinstatement of the currently approved Low Income Home Energy Assistance Program Performance Data Form to allow for use until June 30, 205 and revisions to the form to begin use beginning July 1, 2025. Revisions include substantive changes to one module to ensure the information requested is current and the request is clear. Details about the proposed revisions are provided throughout this document.
The Low Income Home Energy Assistance Program (LIHEAP) block grant (42 U.S.C. 8621) was established under Title XXVI of the Omnibus Budget Reconciliation Act of 1981, Public Law 97-35. The Office of Community Services (OCS) within the U.S. Department of Health and Human Services (HHS), Administration for Children and Families (ACF) administers LIHEAP at the federal level.
The LIHEAP statute requires the program to report to Congress on program impacts annually, to develop performance goals, to ensure that benefits are targeted to those households with the greatest home energy need, and to assure that timely resources are available to households experiencing home energy crises. More specifically:
Section 2610 of the Low-Income Home Energy Assistance Act of 1981 (LIHEAP Act) [42 U.S.C. 8629(b)(2)] stipulates that the Secretary shall provide for the collection of certain data. This section also requires the Secretary to submit to Congress each fiscal year a report on the data collected, on how States carry out certain requirements, on the impact of each State's program on recipient and eligible households, and on other relevant data.
Section 2605(b) of the LIHEAP Act [42 U.S.C. §8624(b)] requires HHS to develop, in consultation with LIHEAP grant recipients, model performance goals that measure the success of each State’s LIHEAP activities.
Section 2610(b)(2) of the LIHEAP Act [42 U.S.C. §8629(b)(2)] requires that HHS annually report to Congress on the impact LIHEAP is making on recipient and income-eligible households.
Section 2605(b)(5) of the LIHEAP Act [42 U.S.C. §8624(b)(5)] requires LIHEAP grant recipients to provide, in a timely manner, that the highest level of energy assistance will be furnished to those households that have the lowest incomes and the highest energy costs or needs in relation to income, taking into account family size.
Section 2604(c) of the LIHEAP Act [42 U.S.C. §8623(c)] requires that grant recipients reserve a reasonable amount of LIHEAP funds (based on data from prior years) until March 15 of each program year for energy crisis intervention. Furthermore, grant recipients are required to address home energy crises within expedited timeframes.
The LIHEAP Performance Data Form (LPDF) is an annual data collection effort conducted by OCS to collect information from state LIHEAP grant recipients and the District of Columbia to meet statutory requirements and program objectives. Data are collected in five distinct modules:
Module 1 (Grant Recipient Survey) – This module collects information on the different purposes for which LIHEAP funding is used and the estimated average benefits furnished to clients for each type of assistance. This information has been collected by OCS and reported annually to Congress for over thirty years. These data collection efforts have furnished OCS with important information on how each grant recipient has chosen to implement the LIHEAP program to address the needs of low-income households in their jurisdiction. (Note: Data from this module are included in the LIHEAP Annual Report to Congress and in the LIHEAP Data Warehouse on the LIHEAP Performance Management Website.)
Module 2 (Required LIHEAP Performance Measures) – This module collects information for four developmental performance measures: the Benefit Targeting Index for High Burden Households, the Burden Reduction Targeting Index for High Burden Households, the restoration of home energy service, and the prevention of loss of home energy service. These measures were approved for data collection by OMB in 2014 and mandatory data collection began for Fiscal Year 2016. (Note: Data from this Module are included in the annual LIHEAP Report to Congress1 in the annual Congressional Budget Justification, and in LIHEAP Data Warehouse on the LIHEAP Performance Management Website.)
Module 2A (Required LIHEAP Performance Measures CARES) – This module collects information for the targeting indices into which the data in Module 2 flow. However, it limits such data to the subset of households that were assisted with supplemental LIHEAP funding from the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
Module 2B (Required LIHEAP Performance Measures ARPA) – This module collects information for the targeting indices into which the data in Modules 2 and 2a flow. However, it limits such data to the subset of households that were assisted with supplemental LIHEAP funding from the American Rescue Plan Act of 2021 (ARPA).
Module 3 (Optional LIHEAP Performance Measures) – This module is optional and allows grant recipients to voluntarily collect and report supplementary information that compliments the required performance measures data. These optional data increase the individual grant recipient’s ability to use the performance data for LIHEAP program management.
This data is necessary to report to Congress on state-specific and aggregated fiscal and performance measures data for the most recent fiscal year on the program.
This request is to extend approval of the current LPDF through June 30, 2025 and for revisions to the form to use beginning July 1, 2025. Revisions include substantive changes to Module 1 to ensure the request is current and clear. See the following section for details on the changes.
This section provides a summary of the types of information requested, the purpose of collecting these data, and how these data are used.
OCS uses the mandatory Module 1 to collect and report on the states' annual estimates of their sources and uses of LIHEAP funding and LIHEAP average household benefits.
The purpose of collecting the data for Module 1 is to obtain fiscal and benefits data from all 50 states and the District of Columbia. These data are used by OCS to analyze how grant recipients have chosen to implement the LIHEAP program to address the needs of low-income households and to report aggregated and state-specific fiscal data in the Secretary's annual LIHEAP Report to Congress2 and in the LIHEAP Data Warehouse. The data also are used to respond to inquiries from Congress, OMB, and the White House relating to budget and program decisions.
In addition, OCS makes this information public so grant recipients, stakeholders, and researchers can compare state LIHEAP programs and approaches.
ACF is proposing the following changes to Module 1:
Adding an item for reporting carryover of Residential Energy Assistance Challenge (REACH) funds to the following FY
Adding an item for reporting non-administrative IT enhancements
Removing maximum income cutoffs from funding uses
Replacing the reporting sections for CARES Act and ARPA with one for Infrastructure Investment and Jobs Act (IIJA) funds
Implementing minor wording or label changes
Updating the name of Module 1 from “Grantee Survey” to “Grant Recipient Survey”, in keeping with the definitions specified in 45 CFR Part 75.2.
These changes would go into effect beginning July 1, 2025 and are intended to improve the form and assist grant recipients with reporting information on the sources and uses of all federal LIHEAP funds, including regular funds and IIJA funds. ACF expects grant recipients to be able to report IIJA funds separately, like they did for CARES Act and ARPA funds. ACF notified recipients through the associated Notices of Award (NOAs) that they must separately track and report on the uses of these funds. NOAs are the official documents through ACF notifies recipients about their awards and the requirements attached to those awards.
OCS uses the mandatory Modules 2, 2A, and 2B to collect and report data for four developmental performance measures. The four performance measures are as follows:
The benefit targeting index for high burden households receiving LIHEAP fuel assistance. This measure quantifies LIHEAP’s benefit targeting performance by measuring the extent to which the highest LIHEAP benefits are provided to households with the highest energy costs3 relative to household income.
The burden reduction targeting index for high burden households receiving LIHEAP fuel assistance. This measure quantifies LIHEAP’s burden reduction targeting performance by measuring the extent to which households with the highest energy costs relative to income have a larger percentage of their energy bill paid with LIHEAP than households with average energy costs relative to income.
The number of occurrences where LIHEAP benefits restored home energy services. This measure includes the number of occurrences where energy service was restored after disconnection, where fuel was delivered after the household ran out of fuel, and where inoperable home energy equipment was repaired or replaced.
The number of occurrences where LIHEAP prevented the loss of home energy services. This measure includes the number of occurrences where a household had a past due or disconnect notice at the time of application and receipt of LIHEAP benefits, where assistance was provided to a household at imminent risk of running out of fuel, and where operable home energy equipment at imminent risk of failure was repaired or replaced.
The purpose of collecting the data for Modules 2, 2A, and 2B is to obtain data from all 50 states and the District of Columbia that directly relates to the LIHEAP statutory mandate that LIHEAP assistance be targeted to those low income households with the highest home energy needs, i.e., vulnerable households and high-energy burden households. The four performance measures quantify how each grant recipient’s program is targeting benefits to high energy burden and vulnerable households to help them maintain healthy, safe, and continuous use of home energy services, allowing for comparison over time and providing each grant recipient with information valuable for effective performance management and program implementation.
OCS uses the performance measures data to calculate aggregate performance data and report the results through the annual Congressional Justification budget process and in the annual LIHEAP Report to Congress. At least some grant recipients use these data to demonstrate their programs’ results to their chief executives, legislative bodies, and other stakeholders.4 These data also allow grant recipients to adjust benefit levels, revise eligibility standards, alter outreach strategies, and make other program-level decisions to meet LIHEAP’s statutory mandate: Ensuring that assistance is targeted to the households that have the lowest incomes and the highest home energy costs or needs. To that end, OCS identifies the extent to which grant recipients meet this mandate and helps grant recipients that fall short by offering benefit simulations, outreach strategies, and other forms of technical assistance.
In FY 2022 through FY 2026, LIHEAP received or expects to receive $100 million in IIJA funds. LIHEAP grant recipients may also expend CARES Act funds or ARPA funds that they received and obligated in FFY 2020 and FFY 2021. OCS plans to continue to ask grant recipients to report the same information for the subsets of households that received any of these funds. This will help grant recipients, OCS, internal stakeholders, and the public understand the impacts of these funds separately from the impacts of annual LIHEAP funds. It will also help grant recipients, individually and with OCS’ help, set policies for using these and future supplemental funds in ways that meet the program’s statutory mandate.
No changes other than minor wording changes are being proposed to mandatory Modules 2, 2A, and 2B.
Module 3 is optional. OCS includes this module to allow grant recipients to report additional data that supplements the data reported for Modules 2, 2A, and 2B, including data on energy consumption, air conditioning use, and home energy service restoration and prevention of loss. Individual grant recipients use the information voluntarily reported in this module to help analyze and interpret their performance measures’ results. No changes other than minor wording changes and the addition of a Notes item are being proposed to optional Module 3.
Every effort is made to minimize the burden of this data collection by providing grant recipients with resources for efficient data collection, data processing, and data reporting.
Data Collection – OCS has provided grant recipients with multiple resources to assist with collecting the necessary data to complete the LPDF, including a data collection guide, data collection templates, and training webinars reviewing data collection procedures. OCS also has furnished one-on-one training and technical assistance to numerous grant recipients and makes such assistance available annually.
Data Processing – OCS has developed guidance documents to assist grant recipients with data processing. In addition, the ACF On-Line Data Collection System (OLDC) calculates some of the data fields, rather than requiring the grant recipient to do so.
Data Reporting – Grant recipients use the OLDC to complete several LIHEAP reports, including the LPDF. The OLDC tool assists grant recipients with completing the form by providing instructions, alerting grant recipients to possible errors, and allowing grant recipients to access prior versions of their report. OCS also provides extensive resources and training on data reporting with the intention of minimizing the burden associated with reporting accurate information. This includes detailed instructions on data reporting, webinars, a “Check before you submit” document, one-on-one technical assistance, and providing a summary of data reporting issues or questions following the review of each grant recipient’s submitted information.
Since 2010, the LIHEAP Performance Measures Work Group (PMIWG), consisting of state LIHEAP directors and HHS staff, has worked with OCS to develop resources and to encourage grant recipients to share information to assist with minimizing the burden of this data collection. Since the LPDF was approved by OMB in 2014, a number of grant recipients have implemented or enhanced their existing data systems, client applications, client waivers, and vendor agreements to support collecting and reporting the required data.
OCS has not identified duplicate sources of the state-level data elements required for the LPDF.
For Module 1 (Grant Recipient Survey), no similar data are available for all categories of sources and uses of federal LIHEAP funds.
For Modules 2, 2A, and 2B, (LIHEAP Performance Measures), similar data are available from two surveys published by the U.S. Energy Information Administration (EIA): the Residential Energy Consumption Survey (RECS) and the energy consumption, price, and expenditure estimates from the State Energy Data System (SEDS). However, while these surveys provide similar information, neither survey provides adequate data for measuring LIHEAP performance:
RECS – This survey collects utility consumption, energy expenditure, and energy insecurity data for a nationally representative sample of households. However, the RECS data is not suitable for annual LIHEAP performance measurement. That’s because the RECS is conducted approximately every five years rather than annually.
SEDS – This is an annual survey that furnishes information on energy consumption and energy expenditures for a number of different fuels at the state level. However, the SEDS data cannot furnish any information on the LIHEAP population and LIHEAP performance.
In summary, while both RECS and SEDS provide useful information that is used by OCS for a number of purposes, neither data source can furnish information on the annual performance of LIHEAP.
There are three sources for the data that is needed for the LPDF–LIHEAP grant recipients, LIHEAP sub-grant recipients (e.g., local agencies and energy vendors), and energy vendors. LIHEAP grant recipients are the primary entity that collect data and complete the report. LIHEAP sub-grant recipients and energy vendors provide data to the grant recipients as needed. They have, through their respective grant recipients, responded to this form’s data requests every year since this form was first approved in 2014. LIHEAP sub-grant recipients are often small community-based organizations. Plus, some energy vendors are small businesses.
LIHEAP grant recipients consist solely of states, including the District of Columbia; certain territories; and certain Indian tribes and tribal organizations. Only the states and the District of Columbia complete the LPDF. None of those entities is a small business.
This is an annual data collection. Collecting these data any less frequently will prevent fiscal and performance measures data from being reported in the annual LIHEAP Report to Congress and will invalidate their usefulness as a timely benchmark of performance and measure of impact. Without this collection effort, there would be no timely uniform data available to comply with requests from Congress, OMB, and the White House. Nor would information regarding the impact of program funds be available for hearings, and during the appropriations and oversight process.
This schedule allows OCS and its grant recipients, as well as Congress and other decision-makers and stakeholders, to understand how grant recipients use federal LIHEAP funds and to gauge the impact LIHEAP services are having on its recipients each year. In addition, LIHEAP grant recipients can use the results of their own data to track their use of funds, average benefit levels, and their performance measure outcomes to observe year-after-year changes and to make adjustments to their programs, if desired. They will also be able to see the impact of program changes in future years’ data.
No special circumstances apply to this data collection.
In
accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13)
and Office of Management and Budget (OMB) regulations at 5 CFR Part
1320 (60 FR 44978, August 29, 1995), ACF published a notice in the
Federal Register announcing the agency’s intention to request
an OMB review of this information collection activity. This notice
was published on December 2, 2024 (89 FR 95218) and provided a
sixty-day period for public comment. We did not receive
comments.
Prior to the most recent OMB approval in 2022,
OCS consulted with outside parties regarding the form’s renewal
and modification. OCS and its contractor communicated with state
grant recipient members of the LIHEAP PMIWG and a small number of
additional grant recipients to understand how grant recipients were
utilizing supplemental LIHEAP funds and tracking households that
received these funds. Based on this information, OCS worked closely
with its contractor that furnishes training, technical assistance,
and data validation for the LPDF, to develop the proposed revisions
to the form and to ensure that burden resulting from changes was
minimized. OCS and its contractor also collected information from a
small number of PMIWG members to understand how the proposed
modifications would impact grant recipients and to estimate changes
to the data collection burden.
The proposed changes to the LPDF impact energy vendors only minimally—by leaving burden unchanged and by increasing cost only 11.0%. For this reason and because OCS did not receive public comments on previous ICRs for this form, OCS did not consult with such entities on this matter outside of the standard public comment periods.
No payments or gifts of any kind will be provided to respondents.
We will protect the information to the extent allowed by Federal law.
No sensitive questions are asked in this data collection.
The estimated annual burden hours and costs associated with this data collection are shown in the table below. These estimates derive from experience to date and updates to the request. The changes in estimates are detailed below the table.
The average hourly wage used for state grant recipients is based on publicly available information on grant recipient staff salaries and assumed overhead costs. These data were compiled for the 2020 RECS LIHEAP Match (Control Number is 0970-0486) and adjusted for federal salary increases since then.
The average hourly wage used for sub-grant recipients and energy vendors is based on the average of Bureau of Labor Statistics (BLS) job code for Data Entry and Information Processing Workers [43-9020] (80%) and Computer and Information Systems Managers [11-3020] (20%). Wage data from 2020 was used, and rates were multiplied by two to account for fringe benefits and overhead. Wages were adjusted for federal salary increases since then.
LPDF |
Total Number of Respondents |
Annual Number of Responses Per Respondent |
Average Burden Hours Per Response |
Annual Burden Hours |
Average Hourly Wage |
Total Annual Cost |
|
State Grant Recipients — Module I |
51 |
1 |
30 |
1,530 |
$83.24 |
$127,357 |
|
State Grant Recipients — Modules II and III |
51 |
1 |
158.6 |
8,088.6 |
$83.24 |
$673,295 |
|
Sub-Grant Recipients (in states with sub-grant recipient managed systems) — Modules II and III |
100 |
1 |
6.3 |
630 |
$66.59 |
$41,952 |
|
Energy Vendors (largest 5 electric, 5 natural gas, 10 fuel oil, and 10 propane vendors per state - average) — Modules II and III |
1,530 |
1 |
8.5 |
13,005 |
$66.59 |
$866,003 |
|
Estimated Annual Burden and Cost Total: |
23,253.6 |
- |
|||||
For Module 1, there are large decreases to the expected burden for all parties because of the elimination of the CARES Act items, ARPA items, and income-eligibility threshold fields; and the insertion of, other than two additional use items, only IIJA items. The burden estimate for that module originally was 36 hours per grant recipient respondent, of which 30 comprised the time needed each year to provide the data associated with annual LIHEAP funding. The 30-hour figure arose from in-depth interviews of certain grant recipients as part of revisions made in 2018 and was adjusted in the most recent approval to account for reporting additional data associated with CARES Act and ARPA funding. With only 2.7% of CARES Act and ARPA funds remaining to be drawn and with the change in the number of items, this figure was returned to 30 hours.
The burden estimate for grant recipients to complete Modules 2, 2A, 2B, and 3 has been decreased from 200 hours per response to 158.6 hours per response. The 200-hour figure arose from same in-depth interviews conducted prior to revisions in 2018 and comprises the average of the times that the interviewees believed they needed each year to collect the data and enter it into OLDC. The decrease accounts for the expected number of submissions based on the numbers of recipients with CARES and ARPA funds remaining plus Module III reporting trends partially offset by increases in the numbers of items.
To varying extents for all five modules, the activities that this average encompasses cover a wide range depending on the automation and centralization of the grant recipients’ systems. For grant recipients with automated systems the burden encompasses the incremental time required to prepare, check, and submit the required reports. For grant recipients with ad hoc centralized systems—i.e., systems that are centralized and that have the capacity to communicate with vendors electronically but that are not automated—the burden additionally encompasses the time required to request, obtain, and check the data from the grant recipients’ vendors. For grant recipients with ad hoc subgrant recipient managed systems—i.e., systems that are managed by sub-grant recipients or that lack the capacity to communicate with vendors—the burden additionally encompasses the time required to collect and process (1) the client data from the sub-grant recipients; and (2) the data on energy expenditures from the energy vendors.
ACF expects the grant recipients themselves to match performance data with the underlying benefit source. Thus, the expected burden for energy vendors and subgrant recipients in answering Modules 2, 2A, and 2B was changed accordingly.
The associated data collection procedures should not require any new capital expenditures by grant recipients, sub-grant recipients, or energy vendors. Those for reporting performance data for supplemental CARES Act and ARPA funds build on existing systems and so should not require any new capital expenditures by grant recipients, sub-grant recipients, or energy vendors. In addition, ACF plans to eliminate the CARES Act-related procedures after FY26, given that at least the substantial majority of those funds will expire after that year. ACF plans to do likewise for the ARPA-related procedures after FY27.
Federal Government Staff tasks associated with the collection of these data include:
Grant recipient Monitoring – Notifying grant recipients of the reporting requirement and conducting follow-up with grant recipients.
Report Review – Reviewing submitted reports and working with grant recipients to furnish reliable data.
Analysis and Reporting – Conducting analysis of the reported data and preparing tables to be submitted with targeted administrative reports (e.g., LIHEAP Report to Congress).
The table below furnishes information on the estimated Federal Staff hours and costs associated with each task:
Annual Federal Staff Hours and Costs
Task |
Number of Hours |
Rate |
Annual Cost |
Grant Recipient Monitoring |
40 |
$124.99/hour |
$5,000 |
Grant Recipient Report Review |
63 |
$124.99/hour |
$7,874 |
Analysis and Reporting |
100 |
$124.99/hour |
$12,499 |
Subtotal: |
$25,373 |
||
Costs have been updated based on an assumed 3.53% annual wage inflation since the last approval of this form. This is the average annual increase in federal salaries under the General Schedule for Steps 5 of Grades 12, 13, and 14 since the time after that request’s approval.
The table below furnishes information on the estimated Federal Contractor Staff hours and costs associated with each task:
Annual Federal Contractor Staff Hours and Costs
Task |
Number of Hours |
Average Rate |
Annual Cost |
Grant Recipient Report Review |
365 |
$96.85/hour |
$35,350 |
Analysis and Reporting |
194 |
$96.85/hour |
$18,789 |
Technical Assistance |
274 |
$96.85/hour |
$26,537 |
Subtotal: |
$80,676 |
||
The contractor hour and cost estimates assume a 10.3% decrease in in hours from the estimates provided in the last review and approval of this form. This reflects the adjustments to the form. They also assume the aforementioned 3.53% annual wage inflation.
Total annual federal government costs are $106,049.
This request is for revisions to the LPDF. The changes proposed to the LPDF consist of (1) replacing CARES Act and ARPA items in Module 1 with IIJA items; (2) adding items in Module 1 for reporting carryover use of REACH funds and non-administrative IT enhancements; (3) removing maximum income cutoffs from funding uses; and (4) minor wording changes and item restructuring. The total impacts of these changes results in a reduction in burden estimates, as described in A12.
OCS believes that this form’s respondents, by and large, have the capacity to meaningfully separate the performance measures data for households that received benefits supported by CARES Act funds, ARPA funds, or non-supplemental funds. For FY 2020, the respondents were largely successful in reporting similar data broken out by CARES Act funds. Of the 51 states that were required to complete this form and the CARES breakouts on their Household Reports, 96 percent reported total CARES funds used in Module 1. OCS is providing training and technical assistance to the two states that could not report these funds.
These changes help LIHEAP’s stakeholders understand the impacts of the supplemental appropriations for FY 2020 and afterwards. They also help state grant recipients isolate the temporary changes to their programs linked to using these supplemental funds from their programs’ overall progress in improving performance. Some grant recipients used CARES or ARPA funds to implement new types of services for their clients. By segmenting out the CARES and ARP recipients, they can get a better understanding of how well those services worked.
The data from Module 1 of the LPDF is included in the LIHEAP Report to Congress to furnish Congress with information on how LIHEAP funds are used by grant recipients to deliver services to clients.
The data from Modules 2, 2A, and 2B will be synthesized into the four performance measures described above and published in the annual LIHEAP Report to Congress. In addition, the raw data, as well as the synthesized performance measures will be made available to each grant recipient through the LIHEAP Data Warehouse. Each grant recipient will also be able to access their performance measures, the measures for other grant recipients, and national and regional summaries.
Activity |
Weeks Following Report Submission Deadline |
Completion of quality assurance testing on performance measures data (requires review of data inconsistencies and outliers with grant recipients) |
8 Weeks |
Synthesis of data into performance measures indicators |
12 Weeks |
Draft of statistical tables for inclusion in annual LIHEAP Report to Congress – text and appendices |
16 Weeks |
Final statistical tables for inclusion in annual LIHEAP Report to Congress |
20 Weeks |
Publication of annual LIHEAP Report to Congress5 |
-- |
Live launch of raw data and performance measures indicators on the LIHEAP Data Warehouse |
1 day post publication of Report to Congress |
The FY 2024 version of this form will be due by grant recipients on January 31, 2025, pending OMB approval. Future versions will be due on January 31 of the fiscal year following the applicable year of the form.
Not applicable.
Not applicable.
1 The FY 2016 Report to Congress is the first to contain performance measures data.
2 Section I of the 2014 Report to Congress.
3 LIHEAP is intended to assist low-income households with their “home energy” costs. Home energy is energy used for home heating or cooling. This performance measure asks grant recipients to report on total residential energy bills because grant recipients and energy vendors do not have the statistical tools needed to estimate home energy usage. However, analysis of the 2009 RECS data shows that the correlation between households with high home energy costs and high residential energy costs averages 85%.
4 As a block grant program, LIHEAP allows each grant recipient to set its own policies and procedures within broad federal parameters. In setting these policies and procedures, OCS encourages each grant recipient to balance its program’s performance with its stakeholders’ preferences.
5 The schedule for publication of the LIHEAP Report to Congress is dependent upon the Department’s clearance process.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Jones, Molly (ACF) |
| File Modified | 0000-00-00 |
| File Created | 2025-05-19 |