Justification and Anticipated Results. The Privacy Act requires that each matching agreement specify the justification for the program and the anticipated results, including a specific estimate of any savings. 5 U.S.C. § 552a(o)(1)(B).
Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other "Marketplace" matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs are approximately $39 million, but does not quantify direct governmental cost saving benefits sufficient to offset the costs because the Marketplace matching programs are not intended to avoid or recover improper payments. The CBA, therefore, does not demonstrate that the matching program is likely to be cost effective.
Justification and Anticipated Results. Pursuant to the Privacy Act’s subsection 552a(o)(1)(B) requirement, the justification for the program and the anticipated results, including a specific estimate of any savings, is described below:
Justification and Anticipated Results. A. Cost Benefit Analysis The cost benefit analysis (Attachment 2) conducted for the PARIS matching programs (consisting of this matching program using DoD data, a related matching program using Department of Veterans Affairs (VA) data, and the interstate data matching program) demonstrates that the matching programs are likely to be cost effective and provides additional qualitative benefits supporting Data Integrity Board approval. See analysis for details.2
Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other "Marketplace" matching programs which CMS conducts with other Federal agencies. The CBA demonstrates that monetary costs to operate the eight Marketplace matching programs are approximately $58.9 million, but does not quantify direct governmental monetary benefits sufficient to estimate whether they offset such costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost effective (i.e., does not show that the program is likely to pay for itself) and does not produce a favorable benefit-to-cost ratio. However, other supporting justifications and mitigating factors support approval of this CMA, as described below in Section B. OMB guidance provides that the Privacy Act "does not require the showing of a favorable ratio for the match to be continued”. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 FR 25818 at 25828.
Justification and Anticipated Results. A. Cost-Benefit Analysis As directed by the Privacy Act at 5 U.S.C. § 552a(u)(4)(A), the FCC has conducted a cost-benefit analysis of this matching program. This analysis, which is attached to this Agreement as Attachment 1, demonstrates that the Federal Programs are cost effective, and includes a specific estimate of the savings.
Justification and Anticipated Results. As requested by 5 U.S.C. §552a(o)(1)(B), the justification for the program and the anticipated results, including a specific estimate of any savings, is described below:
Justification and Anticipated Results. The disclosure of NDNH information for the research conducted by OPRE is justified for several reasons. Employment and earnings outcomes are critical measures of the success of TANF programs’ efforts to promote self-sufficiency. The NDNH is a centralized database of new hire, quarterly wage, and unemployment insurance information, providing an effective and efficient means for OPRE to obtain employment and earnings data, and to track that information over an extended period. Baseline and follow-up new hire, quarterly wage, and unemployment insurance information allows the analysis of income and benefits receipt, job stability, job changes, and re- hire. The use of NDNH records is preferable to the use of state records as a source of information for research purposes because the NDNH contains individual employer, wage, and unemployment insurance records across states, uses a uniform format for records, includes employment information pertaining to federal employees, and is systematically and consistently collected and submitted to the NDNH by employers and state workforce agencies. NDNH records can be collected for a large number of individuals relatively cost-effectively and data request processes are well-defined. Lastly, security and access provisions for NDNH research purposes are clearly defined. OPRE anticipates that the NDNH information from new hire, quarterly wage and unemployment insurance information is the best way to evaluate the employment and unemployment status of TANF recipients and the effect of the economy on TANF recipient employment long-term. Use of the NDNH, will allow OPRE to complete statistical analyses that include geographic and demographic information and case-level information that will inform the agencies on employment trajectories and experiences of low wage workers and their families, including the impact of Covid-19.
Justification and Anticipated Results. A. Cost Benefit Analysis As required by § 552a(u)(4) of the Privacy Act, a cost benefit analysis (CBA) is included as Attachment 1, covering this and seven other matching programs which CMS conducts with other Federal agencies for the purpose of implementing Insurance Affordability Programs. The CBA demonstrates that monetary costs to operate the eight matching programs exceed $30.5 million but does not quantify direct governmental cost saving benefits sufficient to estimate whether they offset such costs. The CBA, therefore, does not demonstrate that the matching program is likely to be cost-effective and does not provide a favorable benefit/cost ratio. However, other supporting justifications and mitigating factors which support approval of this Agreement are provided below in Section B. Further, OMB guidance provides that when a matching program is being negotiated for re-establishment, pursuant to OMB Circular A-108, the Privacy Act “does not require the showing of a favorable ratio for the match to be continued. The intention is to provide Congress with information to help evaluate the cost-effectiveness of statutory matching requirements with a view to revising or eliminating them where appropriate.” See OMB Guidelines, 54 Fed. Reg. at 25828.
Justification and Anticipated Results
