OMB Supporting Statement A&B - revised

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OMB SUPPORTING STATEMENT

RAND Update of 1993 Study on Sexual Orientation and U.S. Military Personnel Policy

A. Justification

1. Need for Information

In his January 27, 2010, State of the Union Address, the President announced that he will work with Congress this year to repeal 10 U.S.C. § 654, the law commonly known as "Don't Ask, Don't Tell." On February 2, 2010, Secretary Robert Gates, in testimony before the Senate Armed Services Committee (SASC), announced that he had "appointed a high-level working group within the Department that will immediately begin a review of the issues associated with properly implementing a repeal of the 'Don't Ask, Don't Tell' policy." He also announced "the Department will, as requested by this committee, ask the RAND Corporation to update their study from 1993 on the impacts of allowing homosexuals to serve openly in the military." Subsequently, the Department of Defense (DoD) established a Comprehensive Review Working Group, which requested the RAND update study.

The 1993 RAND study looked to the experiences of other organizations that were in some respects analogous to the U.S. military. To learn about these experiences, the study team conducted interviews with officials from selected U.S. police and fire departments to learn about the organizations’ experiences regarding the service of gay personnel. The study statement of work requires updates of the analogous experiences since 1993 of domestic police and fire departments and other potentially analogous government agencies.

The statement of work also includes an update regarding implementing policy change in large organizations. To update the 1993 report’s chapter on implementation, the RAND team will incorporate experiences from large U.S. corporations, including major oil companies and defense contractors that deploy personnel to austere environments overseas, and from colleges and universities regarding dormitory assignments.

To complete these tasks, RAND will conduct interviews, similar to interviews conducted for the 1993 study but focused on experiences in the intervening years.

2. How, by Whom, and for What Purpose Information Will Be Used

Almost all of the interviews will be conducted in person, guided by protocols developed for each type of organization. The corporate and college interviews will be conducted by telephone. The protocols, which include open-ended questions, will serve as a guide for the interviews rather than in a strict question-and-answer format. Detailed notes will be taken during the interviews and these will be systematically coded using standard qualitative research methods. The interviews will be conducted by RAND researchers in all instances.

The purpose of this study is to provide information to the DoD Comprehensive Review Working Group for use in their report to the Secretary of Defense. The RAND report may also be made available before publication to others, including DoD officials and the Congress, at the request of the Working Group co-chairs. When cleared for publication through the usual DoD clearance process required for all reports of work conducted by RAND’s National Defense Research Institute, the report will be available to the general public in hard copy and on the RAND website.

3. Forms of information collection

The data collection effort will be conducted through in-person and telephone interviews. Technological methods will not be employed.

4. Efforts to Avoid Duplication

We know of no other external organization that has or is planning to conduct similar interviews that would provide the information needed for this study. It is important that the data collection be conducted by RAND researchers to be fully consistent with the scope of the 1993 RAND study.

5. Small Business Impact

We do not believe that any of the participating organizations would be considered a small business, so do not anticipate any impact on any small businesses.

6. Consequences of Not Collecting Information

Without this data collection, it will not be possible to update all sections of the 1993 study.

7. Special Circumstances

There are no special circumstances involved in this data collection effort.

8. Applicability to 5 CFR 1320.8(d)

This collection is being processed under emergency clearance procedures. Public comments were solicited in the Federal Register under a shortened timeframe. The Federal Register notice published on June 18, 2010 (75 FR 34707). No comments were received.

The RAND Corporation is conducting these interviews under contract to the Department of Defense. RAND has reviewed other research studies to identify existing data relevant to the issues to be addressed in this report, as outlined in the signed project description. Given the very specific requirements for this study, other data provides useful information but cannot substitute for the interviews outlined here.

9. Remuneration to Respondents

Interviewees will receive no remuneration.

10. Confidentiality

Volunteers who participate in this study will be subject to assurances and safeguards as provided by the Privacy Act of 1974 (5 USC 552a), which requires the safeguarding of individuals against invasion of privacy. The Privacy Act also provides for the confidential treatment of records maintained by a Federal agency according to either the individual's name or some other identifier. Information will be kept private to the extent permitted by law.

The project has a Data Safeguarding Plan, approved by the RAND Institutional Review Board (IRB) for securing all data and information collected. All information will be aggregated with those of other respondents before it is reported in the update report.

11. Questions of a Sensitive Nature

The interview protocols are designed to elicit information about policies that may be relevant to the service or employment of gay personnel and room assignments for college students, and about the experiences of the organizations in implementing these policies. The interviews will ask about any specific incidents or issues involving gay personnel or students that have arisen in the organizations’ experience and how these were handled consistent with the organization’s policies and procedures. It is possible that these questions may be considered sensitive by the organizations. These topics were essential to the 1993 study and are therefore important for this study.

12. Hour Burden Estimate

Table 1 shows the estimated annualized burden hours for the interviewees' time to participate in this information collection. The interviews are being scheduled for one hour. The total number of hours is 90.

Table 1. Estimated annualized burden hours

Interviewee type	Number of respondents	Number of responses per respondent	Hours per response	Total burden hours
Police, fire	70	1	1	70
Corporations and colleges	20	1	1	20
All interviews	90	1	1	90

Table 2 shows the estimated annualized cost burden for interviews, estimated to total $17,140. Since the specific individuals to be interviewed have not yet been identified by the organizations, we cannot be certain of their rank or job level. For all civilian occupations, we obtained hourly wages from the Occupational Employment Statistics data for May 2009, published by the Bureau of Labor Statistics. Since we plan to interview police and fire departments in large cities and human resources personnel in large corporations, we used the 90^th percentile of wages for these groups. We used median wages for college administrators and the.

Table 2. Estimated annualized cost burden

Form Name	Number of respondents	Total burden hours	Average hourly wage rate	Total cost burden
Police, fire	70	70	$55	$ 3,850
Corporations and colleges	20	20	$42	$ 840
All interviews	90	90	--	$4,690

13. Total Annual Cost to Respondents or Recordkeepers

Capital and maintenance costs include the purchase of equipment, computers or computer software or services, or storage facilities for records, as a result of complying with this data collection. Respondents will not be asked to maintain records and there are no direct costs to respondents other than their time to participate in the study.

14. Annualized Cost to Federal Government

The Department of Defense is supporting the conduct of these interviews as part of a federally funded research and development contract with the RAND Corporation (award number W74V8H-06-C-0002 ). The estimated cost for the one-time survey component is $435,000 in fiscal year 2010. The estimated cost of data collection includes labor costs, fringe expenses, overhead per the contract, and other direct costs (including travel). There is no capital acquisition associated with this effort.

15. Changes from OMB Form 83-I

This is a new information collection.

16. Outside Publication

Data collected will be analyzed using standard qualitative methods to identify results across the organizations included in the study in each category. The results of the interviews will be included in a published RAND Monograph Report that will cover all the research conducted to update the work done in 1993. Assuming expedited OMB approval is received promptly, the schedule for the project is shown in Table 3 below.

Table 3. Project Schedule

Task/Activity	Timeline And Proposed Date Of Completion
Conduct interviews	Mid-June through Mid-July
Analyze results	Mid-July through Mid-August
Initial briefing on results due	August 2, 2010
Draft final report due	September 30, 2010
Revised final report due	October 30, 2010
Publication of final report	When cleared for public release

17. Expiration Date

We will provide information about the expiration date to the organizations whose personnel we will be interviewing.

18. Certification Statement

There are no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods

These are elite interviews of officials from organizations that are analogous in important respects to the U.S. military. Statistical methods are not appropriate in this instance.

1. Respondent Universe and Selection Methods

The selection criteria for the organizations where the interviews will be are shown in Table 4, along with the number of organizations to be visited, the organizations that have been identified based on the criteria, and the types of individuals to be interviewed in each type of organization. Cities for the police/fire interviews will be chosen to provide a mix of these characteristics. Some of the cities where interviews were conducted in 1993 have been selected again (Houston, Chicago, San Diego), but this is not a longitudinal design. RAND is seeking a more diverse group of cities than the ones visited in 1993.

	Police/Fire Depts.	Corporations	Colleges
Selection Criteria	(1) whether state law makes homosexuals a protected class, (2) size, (3) racial mix, (4) veterans population, (5) participation in the military and (6) the percent of their total vote for conservative candidates in 2004	deployment of personnel to austere locations, including Iraq and Afghanistan and other locations	(1) size, (2) public versus private, (3) approaches for making dorm assignments
Number	6 cities	Max. 10	Max. 10
	Philadelphia, Charlotte, Houston, Chicago, Oklahoma City, San Diego	Requesting interviews with major oil companies and defense contractors supporting deployments	Selections not made yet
Number, types of interviewees	5 individuals per department in each city: department leader, unit leader, Human Resources managers responsible for recruiting and equal opportunity, union official	Human Resources Department, Directors of Diversity	Officials from Dean of Students Office

These interviews are designed to learn about policies and procedures used in analogous situations that may be applied to the military; they are not designed to describe the prevalence of policies and procedures in these institutions. For the colleges and universities, we will ask interviewees about other institutions they know of that use different approaches. This and published information on dorm assignment policies will be used to identify some of the institutions to be interviewed.

2. Procedures for Data Collection

The interviews will be conducted in person or by telephone following protocols with open-ended questions; the protocols will be used as guides to the discussions, not as scripts. Questions will be asked only when previous answers indicate that they are relevant and in each area, lower priority questions will be asked only when time permits. The criteria used to select organizations are described in Table 4. Formal sampling procedures are not being used; instead, the criteria guide the selection of the most analogous organizations and ensure legal, demographic, and social diversity for the police and fire departments. The research interviews will be conducted by experienced RAND researchers. The team leader directs RAND’s research program in public safety and the team also includes an expert in qualitative data collection. The teams will include dedicated note takers and the notes will be analyzed using standard qualitative research coding methods. There will be no statistical methods used.

3. Response Rates

The Comprehensive Review Working Group is assisting the RAND team in requesting cooperation from the selected organizations, as needed. Based on the experience in 1993 and preliminary contacts, RAND expects that all the organizations will agree to participate. If any refuse, RAND will select replacements with similar characteristics.

4. Tests of Procedures

These interviews are highly similar to the ones conducted for the 1993 study. No other tests are planned.

5. Contact Information

A statistical consultation was not relevant for these interviews since they do not involve statistical methods. The data collection will be carried by a team of RAND researchers; the contacts at RAND are:

Bernard Rostker, Project Leader

Susan Hosek, Co-Project Leader

John Winkler, Co-Project Leader