Supporting Statement A -040516 clean

Supporting Statement A

Revision

NCHS Vital Statistics Training Application

OMB No. 0920-0217

(Expiration date: 05-31-2016)

Contact Information:

Kelly Brown, CDR, USPHS

Acting Chief, Registration Methods Program

Division of Vital Statistics

National Center for Health Statistics/CDC

3311 Toledo Road, Room 7313

Hyattsville, MD 20782

301-458-4639

FAX: 301-458-4034

kdbrown@cdc.gov

April 4, 2016

Section A TABLE OF CONTENTS

Section Page
A. Justification............................................................................................................................. 3
1. Circumstances Making The Collection Of Information Necessary...................................... 3
2. Purpose And Use Of The Information Collection................................................................. 4
3. Use Of Information Technology And Burden Reduction..................................................... 5
4. Efforts To Identify Duplication And Use Of Similar Information....................................... 5
5. Impact On Small Businesses Or Other Small Entities......................................................... 5
6. Consequences Of Collecting The Information Less Frequently........................................... 5
7. Special Circumstances Relating To The Guidelines For 5CFR1320.5.................................. 5
8. Comments In Response To The Federal Register Notice And Efforts To Consult Outside The Agency................................................................................................................. 6
9. Explanation Of Any Payment Or Gifts To Respondents.......................................................... 6
10. Protection of the Privacy and Confidentiality of Information Provided by Respondents....... 6
11. Institutional Review Board (IRB) and Justification for Sensitive Questions.......................... 7
12. Estimates of Annualized Burden Hours and Costs................................................................... 7 13. Estimate Of Other Total Annual Cost Burden To Respondents Or Record Keepers.............. 8 14. Annualized Cost To The Federal Government........................................................................ 8 15. Explanation For Program Changes Or Adjustments................................................................. 8 16. Plans For Tabulation And Publication And Project Time Schedule........................................ 8 17. Reason(S) Display Of OMB Expiration Date Is Inappropriate............................................... 8 18. Exceptions to Certification for Paperwork Reduction Act Submissions................................. 8

SUPPORTING STATEMENT

• Goal of the study: To collect information needed to register staff, statisticians, and coding specialist for training offered by the Registration Methods Program.

• Intended use of the resulting data: To create a participant list that is ultimately used for logistical purposes.

• Methods to be used to collect: Respondents provide information using a fillable form and thereafter submit the document via email or fax.

• The subpopulation to be studied: Staff from 57 registration areas in the United States. These are the 50 states, the District of Columbia, New York City, Puerto Rico, Guam, American Samoa, Northern Mariana Islands, and the Virgin Islands. Canadian counterparts will also be notified.

• How data will be analyzed: Basic summary statistics

NCHS VITAL STATISTICS TRAINING APPLICATION

This is a request for a revision of the NCHS Vital Statistics Training Application (OMB No. 0920-0217, expires May 31, 2016), conducted by the National Center for Health Statistics (NCHS), Centers for Disease Control and Prevention. A three-year clearance for the forms is requested. Changes include:

• Additions/Updates to the application training form

A. Justification

1. Circumstances Making the Collection of Information Necessary

The compilation of national vital statistics by the federal government dates back to the beginning of the 20^th century. In July 1946, the President's Reorganization Plan No. 2 transferred this function from the U.S. Bureau of the Census to the Federal Security Administrator. It was subsequently transferred to the Secretary of the Department of Health, Education, and Welfare, which was later renamed the Department of Health and Human Services (DHHS). To administer these functions, the National Office of Vital Statistics (NOVS) was established in the Public Health Service in April 1953. In August of 1960, the NOVS was reorganized as the Division of Vital Statistics in the newly created National Center for Health Statistics (NCHS), which is now part of the Centers for Disease Control and Prevention (CDC), DHHS.

One of the functions of the NCHS is to plan and administer a program, called the National Vital Statistics System (NVSS), to collect, process, and disseminate national statistics on births, deaths, and fetal deaths and summary statistics on marriages and divorces reported to NCHS by the state vital registration jurisdictions. This includes promoting the uniform collection of data on these events and providing technical assistance to the registration jurisdictions; preparing life tables and analyses of life table phenomena; and investigating the quality and reliability of data and methodology. The collection of data is authorized by 42 USC 242k, Section 306 (h) (1) of the Public Health Services Act in Attachment A.

Since 1902, when the Federal Government first became actively involved in the development and promotion of state vital statistics programs, many programs have been employed in an effort to bring about more uniformity and a higher degree of quality in data collection and dissemination through these state programs. Such uniformity of quality is essential if the data from the individual states are to be aggregated at the national level to produce reliable national vital statistics data. The programs offered by the Federal Government have included the development and funding of quality control and registration promotion programs; they have also included training programs for persons involved in various aspects of the vital registration and vital statistics systems at the local, state and national levels. This technical assistance is provided currently by NCHS under the legislative authorization of 42 USC 242b (Section 304(b)(1) of the Public Health Service Act), which states that the "Secretary may utilize personnel and equipment, facilities and other physical resources of the Department of Health and Human Services...to...provide technical assistance and advice...." Attachment A contains the full text of this legislation. All of this is in support of the annual collection of data from the records of births, deaths and fetal deaths and summary statistics on marriages and divorces in registration areas, which is to be done "...only from and restricted to such records of the States and municipalities which...possess records affording satisfactory data in necessary detail and form." as mandated by Section 306(h) of the Public Health Service Act.

Proposed changes captured in this revision submission include the following additions and updates to the application training form:

• The addition of two questions 1) to identify the training personnel as either State or locally-based and 2) to determine if the registrant has previously attended the training. And if so, when?

• An update to the information listed for the NCHS contact person

2. Purpose and Use of Information Collection

NCHS assists in achieving the comparability needed for combining data from all States into national statistics, by conducting a training program for State and local vital statistics staff to assist in developing expertise in all aspects of vital registration and vital statistics. The training offered under this program includes courses for registration staff, statisticians, and coding specialists, all designed to bring about a high degree of uniformity and quality in the data provided by the States. NCHS notifies State and local vital registration officials, as well as Canadian counterparts, about upcoming training. Individual candidates for training then submit an application form including name, address, occupation, and other relevant information.

There are two application forms, one relates to courses in general vital statistics areas (Attachment B) and the second refers to courses in mortality medical coding (Attachment C). The form is to be completed by each individual who wishes to receive the training. If this information is not obtained, course instructors will not be able to schedule and plan their courses to meet the existing needs of state and local personnel. This application for training is usually sent with a course announcement, such as in Attachment D.

3. Use of Improved Information Technology and Burden Reduction

Respondent burden in this collection will be kept to a minimum, and there are no technical or legal obstacles to burden reduction. Course announcements will also be transmitted by e-mail, with the training application form either imbedded in the message or transmitted as an attachment. Applicants for training will preferably submit the completed form to NCHS by fax, because NCHS requires that both the applicant and his/her supervisor sign the application. This is done to confirm that the applicant's sponsoring institution is aware of its responsibility for the travel costs of the trainee.

4. Efforts to Identify Duplication and Use of Similar Information

No comparable training or information about needs for the training exists. NCHS, which is the locus of the World Health Organization Collaborating Center for Classification of Disease in North America, one of six such centers in the world, is the only U.S. source for mortality coder training.

5. Impact on Small Businesses or Other Small Entities

No small businesses will be involved in this data collection.

6. Consequences of Collecting the Information Less Frequently

Information is only collected when a person requests taking a course.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

In the event that a respondent desired to attend more than one course, it would be necessary to complete a second training application.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

A 60-day notice (Attachment E) was published in the Federal Register, Volume 80, No. 223, pp. 72434-72436, on November 19, 2015.    There were no public comments.

Consultation on the application form has not been deemed necessary. These forms will be used only to identify the need for training and to obtain the minimum amount of information needed by course instructors to determine the relevant background of applicants.

9. Explanation of Any Payment or Gift to Respondents

There are no payments to respondents. Moreover, training is provided to trainees without charge for tuition or training costs. Trainees or their sponsoring agencies are responsible only for their travel and per-diem costs to the training site.

10. Assurance of Confidentiality Provided to Respondents

This submission has been reviewed by the Information Collection Review Office (ICRO), who determined that the Privacy Act does apply. The Privacy Act System of Records for this project is 09-20-0163 - Applicants for NCHS Technical Assistance.

Section 304(b)(1) of the PHS Act (42 USC 242b) authorizes the DHHS Secretary to provide technical assistance in matters relating to health statistical activities. The principal purpose of the information requested in this form is to select students for training. Provision of the requested information is voluntary; however, failure to supply all information may delay or prevent action on your application.

Applicants are told that their information may be shared with course instructors to assist in planning the class.

Information in Identifiable Form (IIF)

The list of requested items considered to be in identifiable form includes the following on the application for training:

1. Name and Signature

2. Organization Name and Address

3. Office Phone Number

4. E-mail Address

5. Occupation

6. Brief Description of Present Job

Information obtained will be processed manually and stored in file cabinets, access to which will be limited to NCHS staff involved with the development and presentation of the training programs. The information concerning applicants will be kept secure and will not be shared with other organizations or persons. On an annual basis the information will be obsolete and will be destroyed.

The Applications for Training (Attachments B and C) indicates that “this information may be disclosed in confidence to instructors. Provision of the requested information is voluntary; however, failure to supply all information may delay or prevent action on your application.”

11. Institutional Review Board and Justification for Sensitive Questions

The NCHS Ethics Review Board (ERB) has found that the project described in these documents does not meet the regulatory definition of research. Therefore, ERB approval is not required. (See Attachment F)

There are no sensitive questions on these documents.

12. Estimates of Annualized Burden Hours and Costs

There is no cost to individual respondents other than their time to complete the forms.

It is estimated that each applicant will require 15 minutes to complete the individual application forms. An individual would be unlikely to apply for more than one course per year.

Based on previous experience, the resultant expected annual respondent burden (30 hours) is thus estimated as follows:

Estimated Annualized Burden Hours

Type of Respondent	Form Name	Number of respondents	Number of responses per respondent	Average burden per response (in hours)	Total burden hours
State, Local health department and Canadian vital health employees	Annual Survey of Training	60	1	15/60	15
State, Local health department and Canadian vital health employees	NCHS Vital Statistics Training Application	60	1	15/60	15
Total					30

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There are no additional costs to respondents resulting from completing the application for training

form.

14. Annualized Cost to the Government

The annualized Federal costs for duplicating, mailing, and reviewing these documents is estimated to be approximately $10,000 per year. This is based on previous experience.

15. Explanation for Program Changes or Adjustments

The proposed changes captured in this revision submission include the addition of two questions 1) to identify the training personnel as either State or locally-based and 2) to determine if the registrant has previously attended the training. And if so, when? Likewise, the information listed for the NCHS contact person has been updated. The total burden time of 30 hours remains unchanged.

16. Plans for Tabulation and Publication and Project Time Schedule

This project will not produce results to be published for statistical use. However, the overall time schedule is as follows pending OMB approval: On an annual or as needed, a schedule will be developed and provided to state and local governments and to Canadian locations. Sessions will be given as interest and needs dictate. Applications from individual applicants will be accepted until approximately 2 weeks before each session.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

The display of the OMB expiration date is not inappropriate.

18. Exceptions to Certificate for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

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