CCHT justification A (V4)

CCHT justification A (V4).doc

Care Coordination Home Telehealth (CCHT) Patient Satisfaction Survey

OMB: 2900-0766

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Supporting Statement A
Care Coordination Home Telehealth (CCHT) Patient Satisfaction Survey
VA Form 10-0481 OMB 2900-XXXX


A. JUSTIFICATION


1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.


Legal authority for this data collection is located in 38 USC, Part I, Chapter 5, Section 527, Veterans Benefits, which authorizes the collection of data that will allow measurement and evaluation of the Department of Veterans Affairs Programs, the goal of which is improved health care for veterans.


2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.


The Office of Telehealth Services (OTS) seeks approval from the Office of Management and Budget (OMB) for the Care Coordination Home Telehealth (CCHT) patient satisfaction survey. The questions developed for this survey are the product of field staff development working through the OTS’ CCHT Outcomes Committee. The goal is to collect appropriate data regarding current patient perceptions of their satisfaction specifically with the CCHT program and the messaging devices it utilizes.


Many aspects of the CCHT program have evolved substantially since the inception of the program in 2000. The CCHT satisfaction survey is required to capture current patients’ perspectives on satisfaction with specific aspects of the program and equipment.


This satisfaction survey is not a traditional paper and pencil survey method but rather a totally automated method. The survey will be delivered electronically to patients enrolled in the CCHT Program via a messaging device located in the patient’s home. These devices will provide a total of eight questions to each enrolled patient on a small screen and then the patient will select the appropriate answer using either buttons or a touch screen application. In some cases, the questions are electronically spoken to the patient, such as for those patients who are visually impaired or utilizing technology called Interactive Voice Response. Patient responses regarding their satisfaction will be captured electronically and reported back to the OTS data set, located behind the VA firewall, for review and analysis. The VA Form 10-0481 survey list of questions will be delivered to each enrolled patient every 90 days via the home telehealth device.


3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.


Respondent burden can be significantly reduced by utilizing the electronic home telehealth device already in the home that will be programmed to deliver the survey questions to patients in the comfort of their own home, at designated intervals. The patient responds to the questionnaire by pressing one simple button or by touching the screen for the appropriate answer. This information is then later downloaded securely through the phone line to a database behind the VA firewall.



4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.


CCHT is a relatively new program in VHA and is a unique and very innovative service. CCHT delivers clinical care with the assistance of new technology in the home that is used to capture patient responses to Disease Management questions focused on the patient’s symptoms, knowledge and behaviors associated with a chronic illness. Because this program is so distinct in the key elements of clinical care, business practice, and types of technology used, currently approved questions/surveys are not able to capture the true essence of this program. Hence, there is no duplication of information with any other survey.


5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


Every effort has been made to minimize the burden to small businesses by keeping questions simple and to an absolute minimum.


6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.


VA would not be responsive to the needs of patients if information were collected less frequently.


7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.


There are no such special circumstances.


8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.


The notice of Proposed Information Collection Activity was published in the Federal Register on January 15, 2010, page 2595). We received one public, complimentary comment in response to this notice


Public Comment:

I am commenting on the VA Telehealth regulation. I have worked in health care for over twenty-five years. Many of those years I worked with Veterans. I agree that telehealth for our Veterans will be extremely beneficial to them. Many are at home alone and no convenience of transportation. The devices in their home will allow them access they may not have otherwise. I am also impressed with the variety of options that are available to assist them with any impairment that may prohibit them from taking the survey. I believe the buttons, touch screen application and also the Interactive Voice Response system will be beneficial.

VHA Response:

Thank you so much for your comments and support.


b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.


Outside consultation is conducted with the public through the 60- and 30-day Federal Register notices.


9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


No payment or gift is provided to respondents.


10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


Assurances of confidentiality are contained in 38 U.S.C. 5701 and 7332. Respondents are informed that the information collected will become part of the Consolidated Health Record that complies with the Privacy Act of 1974. These forms are part of the system of records identified as 24VA19 “Patient Medical Record – VA” as set forth in the Compilation of Privacy Act Issuances via online GPO access at http://www.gpoaccess.gov/privacyact/index.html.

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.


There are no questions of a sensitive nature.


12. The number of respondents, frequency of responses, annual hour burden, and explanation for each form is reported as follows:


a. VA form 10-0481 (1 form) x 16,400 quarterly respondents x 4 responses = 65,600 x 1.5 minutes = 98,400 ÷ 60 minutes = 1640 burden hours.


            b.        If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB 83-I.


 This collection covers one electronic survey.   See 12a.


            c.         Provide estimates of annual cost to respondents for the hour burdens for collections of information.  The cost of contracting out or paying outside parties for information collection activities should not be included here.  Instead, this cost should be included in Item 14.

 

There is no cost to respondents for completing this survey.


13.    Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.  (Do not include the cost of any hour burden shown in Items 12 and 14).

        

    There are no capital, start-up, operation or maintenance costs to respondents or record keepers since this is all collected electronically.


14.    Provide estimates of annual cost to the Federal Government.  Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.  Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

All costs associated with collection of the response data to the survey, calculation of averages and display of the data on a web site is accomplished electronically. There will be a one-time cost to modify the software program for capture of the responses to the new survey questions.


Reprogramming for data capture, calculations and display: GS12 salary $32.25/hour x 20 hours= $645

There are no other anticipated annual costs of the Telehealth Survey to the Federal Government.


15.      Explain the reason for any burden hour changes since the last submission.

 

    This is a new collection and all burden hours are considered a program increase.

 

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.


We do not plan to publish this data.


17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


VA seeks to minimize the cost to itself of collecting, processing and using the information by not displaying the expiration date. We seek an exemption that waives the displaying of the expiration date since no actual VA form will be used. If we are required to display an expiration date, it would result in unnecessary contract revisions and in programming of the home telehealth device at significant expense. Inclusion of the expiration date would place an unnecessary burden on the VA.


18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.


There are no exceptions.

File Typeapplication/msword
File TitleDepartment of Memorandum
AuthorVHA User
Last Modified Byvhacoharvec
File Modified2010-03-16
File Created2010-03-16

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