IG-Justification for 5 CFR 1320 Emergency Processing Edited

A. Justification

1. The Office of the Inspector General at the Peace Corps is conducting an emergency information collection pursuant to its obligation to conduct audits relating to the programs of the Peace Corps. See 5 USC Appx §§ 2(1) and 6(2). The audit concerns the medical clearance process for applicants for volunteer service in the Peace Corps. The medical clearance process at Peace Corps is integrally related to Peace Corps’ mission, as the Peace Corps Act mandates that applicants for Volunteer service in the Peace Corps receive “health examinations preparatory to their service.” 22 USC § 2504(e).

The Inspector General is undertaking this audit in order to assist the Peace Corps in ensuring that its medical clearance process has not become an impediment to Volunteer service.

As a result of two unanticipated events, it is critical for the Office of the Inspector General to evaluate the Peace Corps medical clearance system and provide recommendations for necessary changes in policies and procedures prior to the start of the next fiscal year.

1. The Director of Peace Corps, the Office of the Inspector General, and Congress have recently received multiple letters from former applicants to the Peace Corps who have concerns with the timeliness and transparency of the medical clearance process. The proposed survey is intended to respond to concerns raised in these letters, and thereby to meet Peace Corps’ strategic goal of increasing diversity among Volunteers.

2. The Director of Peace Corps has announced an initiative to recruit more applicants who are 50 years old or older. Personnel in the Office of Medical Screening have reported that in general it takes longer to process a medical clearance for an applicant over the age of 50. The planned increased recruitment of older applicants will further lengthen a medical clearance process that is already eliciting customer complaints. Prior to fulfilling the Director’s initiative, it is likely that well-informed changes to the medical clearance system policies and processes will have to be made.

The first development makes especially clear the necessity of an audit in order to take all possible steps as quickly as possible to protect the safety and health of Volunteers. Because Peace Corps is concerned about delaying any efforts to ensure the safety and health of Volunteers, it is requesting emergency clearance for this request.

In sum, the Office of the Inspector General is requesting emergency clearance in order to respond to new developments related to the safety and health of Volunteers, and in order to provide the Peace Corps with recommendations for improving the medical clearance system in FY 2008, which is also related to the safety and health of Volunteers.

2. The Peace Corps Office of the Inspector General is conducting an investigation into the efficiency and effectiveness of the Peace Corps medical clearance system and would like to collect information on a voluntary basis from former Peace Corps applicants. The investigation will use surveys, and telephone and face to face interviews to collect information from former applicants. The investigation will be used to assess the significance of complaints that the IG and the Director of the Agency have received concerning the clearance process; and it will be used to assist in making the medical clearance process efficient for an anticipated influx of volunteers older than 50. Most importantly, it will be used to ensure the safety and health of all Volunteers.

3. The study will use surveys, and telephone and face to face interviews to maximize the accurate collection of information from applicants. The four main reasons we are using a research design that involves multiple modes of collection are to decrease cost, increase response rates, better validation of data and proven effectiveness. This means of collection has been used for previous Peace Corps surveys and has proven to be efficient and cost-effective for the agency and easy and convenient for respondents. Survey design, deployment, submission and preliminary analysis will be automated using an online electronic tool and survey portal.

4. The evaluation team conducting this study has met with Peace Corps’ headquarters offices involved in the Medical Clearance process to determine whether they have the type of information that the evaluation team expects to collect using the surveys and interviews. The evaluation team has found no evidence that the agency has ever collected feedback on the medical clearance process from applicants who were not invited to serve in the Peace Corps.

5. Not Applicable - The collection of this information will not impact small businesses or other small entities.

6. There are multiple negative consequences to the Peace Corps medical services program and policies if this information from former applicants is not collected as soon as possible. Several former applicants have raised concerns to Peace Corps and Congress about the medical clearance process. In an effort to understand the problems with the medical clearance system from the applicants’ perspective we need to be responsive and open to feedback from applicants. Therefore, Peace Corps needs to systematically collect a statistically significant number of responses from former applicants in order to analyze and determine whether the recent criticism of the medical clearance process is random noise or if it constitutes a trend that is indicative of a problem that must be addressed quickly in order to ensure the safety and health of current Volunteers. Peace Corps is also concerned that qualified applicants may be dropping out of the application process because of disillusionment with the medical clearance process. By collecting this information, we hope to make it easier and more transparent for applicants to navigate through the medical clearance process; to make recommendations for any necessary changes that will better ensure the safety and health of Volunteers; and to streamline the process for applicants to become Peace Corps Volunteers. A second negative consequence of not collecting this information is that the Peace Corps will not be informed regarding the necessary changes it must make to medical clearance programs and policies to ensure that it can meet the Director’s mandate to recruit more applicants who are older than 50. This mandate is consistent with the agency’s strategic goal of increasing the diversity of the Peace Corps.

7. Not applicable--The collection of this information will be a one time event. The survey and interviews will be conducted on a voluntary basis; and no deadlines of 30 days for response will be required. No copies of documents will be collected. Respondents will not be required to retain records.

A survey will be administered to former applicants that is designed to produce valid and reliable results that can be generalized to the universe of study. Due to the fact that this is a voluntary survey, our ability to produce statistically significant results is dependent on the number of responses we receive and the demographics of the respondents. The statistical analysis we will run will be frequencies, percentages and correlations.

Our study will adhere to the requirements and guidelines as set forth in the Privacy Act, 5 USC § 552a. Applicants may voluntarily share medical information as part of this study; however, our study will not share the information with any other unit, office, department or agency. The study will take every measure to ensure respondent confidentiality.

8. Not Applicable - We are requesting simultaneous publication of the Federal Register Notice for emergency processing. We have not consulted with other agencies to obtain this information because the information is about former applicants’ experience completing the Peace Corps medical clearance. Other agencies do not have this information.

9. Not Applicable - Respondents will not be compensated for sharing information during this study.

10. Private information collected during this study will be protected by the U.S. Privacy Act.

11. Applicants may voluntarily share medical information as part of this study, however, our study will not share the information with any other unit, office, department or agency. As the study concerns the medical clearance process, respondents will likely provide some medical information. Peace Corps’ Office of the Inspector General will ensure respondent confidentiality, consistent with the Privacy Act, 5 USC § 552a.

12. The voluntary survey and interviews will be conducted one time (not annually), and will target roughly 3346 applicants. The written survey will take approximately 15-30 minutes to complete. The oral interview will take 1 hour. The timeframes for completing the survey and for the interview were established by having a person in our office who is not affiliated with the study be interviewed and take the survey. We anticipate a 50% response rate from each of the three subgroups from whom we intend to collection information: active Volunteers, returned Volunteers, and applicants who did not serve. The number of targeted respondents for each group was generated by reviewing the number of people in each subgroup population and the number of responses required in order to ensure 95% confidence with 4% error for each subgroup. There will be no cost burden on the respondents.

13. Not Applicable – There will be no cost burden and no annual cost burden on the respondents.

14. This is a one time information collection. Information will not be collected on an annual basis; therefore there are no annual costs. However, there will be a one-time cost to the government. The Peace Corps Office of Inspector General has budgeted $1,400 for the information collection cost of the Medical Clearance System study. The major cost of this study is long distance telephone interviews. These costs will be incurred from May through August of fiscal year 2007.

15. Not Applicable – This is a one time information collection. There are no program changes or adjustments.

16. As with all federal studies, general findings, not including respondent medical information, will be made public and may be requested through the Freedom of Information Act. However, there will not be any effort to publish findings in academic journals or with media channels. The collection of information is anticipated to run from April through August of fiscal year 2007.

17. Not Applicable

18. Not Applicable

B. Collections of Information Employing Statistical Methods

The Peace Corps Office of the Inspector General is conducting a study of the Peace Corps Medical Clearance System; this is the system by which Peace Corps assesses whether an applicant is healthy and fit enough to volunteer for 27 months of Peace Corps service in a developing country. The study aims to collect information from former Peace Corps applicants. From a research perspective and logistics perspective it is important to sample three different subgroups:

• Active Peace Corps Invitees, Trainees and Volunteers¹

• Returned Peace Corps Volunteers

• Applicants who did not serve

Active Peace Corps Invitees, Trainees and Volunteers will have had recent experience with the medical clearance process. The returned Peace Corps Volunteers will be able to bring their seasoned experience of being a Volunteer to the questions raised during the medical clearance process. They will also be able to respond to whether the medical clearance process was pertinent to assessing their fitness to serve overseas. Lastly the perspective of the applicants who did not serve may identify medical clearance barriers to service that must be addressed to improve the medical clearance process. It is critical to get multiple perspectives because applicants who did not get through the medical clearance process may complain more than the other two subgroups, and might skew results if the study did not collect statistically relevant information from the other two subgroups. The study will compare the findings from each subgroup and analyze whether there is a convergence of data on certain issues thereby pinpointing possible areas for improvement. The study will also examine whether the medical clearance process created any barriers to service for those respondents who did not become Volunteers.

Initial quantitative and qualitative data will be collected from each subgroup using an online survey that will ask open and closed ended questions (see attached survey). The quantitative data will help our study identify trends regarding the applicants’ experience completing the medical clearance portion of the Peace Corps application. Follow-up interviews with a subset (approximately 45 people)of the people who completed the survey will be conducted to provide rich qualitative data that will be particularly relevant to making recommendations for program improvement. We will not interview anyone who has not completed the survey, as varying survey methods would jeopardize confidence in the accuracy of our results.

2. The following discusses how we determined our plan for the collection of information and lists the population, i.e. universe, sample, and number of responses needed for collecting statistically relevant findings from each of the identified subgroups.

Subgroup 1 Population = Approximately 7749 Active Volunteers

Number of responses needed for 95% confidence and 4% error = 557

Sample = We will need to send the survey to 1114 Volunteers.

Response Rate = This requires an estimated response rate of 50%

The number of active Volunteers is from the Peace Corps Office of Planning, Policy and Analysis Historical Volunteers Onboard by Year report which states that there were 7749 active Volunteers in 2006. We will need to send the survey to 1114 Volunteers. We will target current PCVs serving at 3 posts in each of the Peace Corps’ 3 regions ((1) Africa, (2) Inter-America and the Pacific, and (3) Europe, Mediterranean, Asia). We used the following formula:

The average number of Volunteers overseas in 2006 was 7749. We divided 7749 by the Agency’s 67 posts, which equals 116. This gives us the average number of Volunteers at Agency posts. We then multiplied the 116 Volunteers per post by the 9 posts we will be surveying (3 in each of 3 regions.) Nine times 116 yields a sample size of 1044 active Volunteers. We will slightly exceed 116 Volunteers per post in order to reach a statistically significant number of 1114 surveyed active Volunteers.

We will email these Volunteers a memo explaining the purpose of the survey, an electronic version of the paper survey, and a link to the online survey. We will conduct approximately 15 telephone follow-up interviews with active Volunteers in Peace Corps countries worldwide. These follow-up interviews will provide the rich qualitative data that will be helpful in determining programmatic recommendations for improvement.

Subgroup 2 Population = Approximately 8190 Returned Volunteers

Number of responses needed for 95% confidence and 4% error = 559

Sample = We will need to send the survey to 1118 Returned Volunteers

Response Rate = This requires an estimated response rate of 50%

The number of Volunteers who returned in 2006 and 2005 is approximately 8190. This number was derived from the Peace Corps Office of Volunteer Recruitment Services 2006 Peace Corps Volunteer Applicant Funnel Report that states that 4095 Volunteers were placed in the field in 2006 (4095 Volunteers multiplied by two years = 8190) to replace the Volunteers who are concluding their service with the Peace Corps. Our study intends to request a report from the Agency’s Office of the Chief Information Officer (OCIO) which will provide an exact number and contact information for Volunteers who returned in 2005 and 2006.

We will email the sample of returned Volunteers a memo explaining the purpose of the survey, an attachment containing a paper version of the survey and a link to the online survey. We will need to send the survey to 1118 Returned Volunteers; this population may not have a high response rate. Therefore, we have expanded the sample to include returned Volunteers from both 2006 and 2005. We will conduct 15 telephone or face to face follow-up interviews with Returned Volunteers who complete the survey.

Subgroup 3 Population = Approximately 7662 applicants who did not serve as Volunteers.

Number of responses needed for 95% confidence and 4% error = 557

Sample = We will need to send the survey to 1114 applicants who did not serve

Response Rate = This requires an estimated response rate of 50%

According to the Peace Corps Office of Volunteer Recruitment Services 2006 Peace Corps Volunteer Applicant Funnel report, there were approximately 3831 people who applied in 2006 and dropped out after being nominated to serve and before becoming a Trainee. Our study will survey people in this subgroup who applied in 2005 and 2006. This should result in a sample size of approximately 7662 people. We will need to send the survey to 1114 applicants who did not serve. This population may not have a high response rate. We will, therefore, survey applicants from both 2005 and 2006. We will conduct 15 telephone or face to face follow-up interviews with applicants who did not serve as Volunteers in the Peace Corps.

3. In order to be able to generalize the results of the survey to the Peace Corps applicant population as a whole, we will make sure our sample selection contains approximately the same demographic percentages as the applicant population.  The demographic attributes that we will match the survey sample to the population are:  ethnicity, marital status, education, gender, and age.

Our study has taken several measures to increase the likelihood of an adequate response rate. The study will use multiple modes of collection in order to provide alternative methods by which our respondents can easily and conveniently provide information on the medical clearance process. Survey deployment and submission will be automated using an online electronic tool and survey portal. This will allow many survey respondents to provide information on the medical clearance process from their own homes without the inconvenience of having to return a paper survey through the mail.

Following OMB approval, we anticipate distributing the survey at the end of May 2007. Our study will send out electronic reminders every two weeks during the months of June and July (for a total of 4 reminders) to our subgroup samples emphasizing the importance of completing this brief survey and detailing how the information collected will be used by our office and the agency to make improvements to the Medical Clearance system. If our data appears to be skewed by a lack of response from certain subgroups or demographic groups, electronic reminders will be targeted to contact certain demographic groups to ensure we collect data from them and our statistics are reliable and can be generalized to the universe studied.

If we cannot obtain reliable contact information for Returned Volunteers, we will ask the National Peace Corps Association to contact its Returned Volunteer members from 2005 and 2006, in order to deliver the survey on behalf of the Peace Corps.

4. Not Applicable

5. Shelley Elbert, Senior Evaluator, and Sarah Magallanes, Assistant Evaluator, comprise the Peace Corps Office of Inspector General Medical Clearance System study team Shelley designed the statistical methods to collect the information for the study and will be the lead for analyzing the information for the agency. Shelley Elbert can be reached at 202.692.2904. Sarah Magallanes can be reached at 202.692.2912.

1 As Peace Corps Trainees and Volunteers are considered employees for the purposes of the Paperwork Reduction Act, they are not a part of Peace Corps’ request for approval of the survey.