Supporting Statement A: State and Local Human Services Customer Feedback

State and Local Human Services

Customer Feedback

OMB Information Collection Request

0970 - 0356

Supporting Statement

Part A

October 2017

Submitted By:

Office of Planning, Research and Evaluation

Administration for Children and Families

U.S. Department of Health and Human Services

4^th Floor, Mary E. Switzer Building

330 C Street, SW

Washington, D.C. 20201

Project Officers:

Melissa Lim Brodowski, Office of Regional Operations

Molly Jones, Office of Planning, Research and Evaluation

A1. Necessity for the Data Collection

The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services (HHS) seeks approval to conduct a two-part formative study that will gather actionable data, feedback and recommendations from state and local human services agencies, harvesting their best thinking and recommendations about their key priorities and challenges and ways that ACF can support their work. ACF will use this information to develop a strategy and plan to remove barriers and support state/local systems change and redesign of services that is human-centered and improves the economic and social well-being of families.

Study Background

ACF is interested in soliciting feedback from state and local jurisdictions to inform agency priority actions. ACF has not engaged its state and local human services leaders in developing cross-system and cross-program solutions to tackle poverty and improve family well-being. The majority of ACF's over $50 billion budget flows directly to state and county agencies, where services are delivered on the ground. In a recent survey conducted by the American Public Human Services Association (APHSA), 97% of state and local leaders reported that outmoded federal laws and regulations had the highest level of impact on their ability to improve well-being. ACF has long operated in program office silos and has not developed a strategy or goals that are cross-cutting or that are responsive to how state and local agencies administer its programs, or other federal agency programs, even though low-income families receive benefits across federal agencies and programs. There are limited effective federal-state-local feedback loops to test and support on-the-ground solutions and innovations.

The current information collection request is for gathering preliminary information about the needs of state and local human services agency leadership inform the technical assistance and support that ACF provides, to help further the proper performance of the functions of the agency, as well as identify areas to improve the state-federal relations.

Legal or Administrative Requirements that Necessitate the Collection

There are no legal or administrative requirements that necessitate the collection. ACF is undertaking the collection at the discretion of the agency.

A2. Purpose of Survey and Data Collection Procedures

Overview of Purpose and Approach

The purpose of this research is to solicit feedback from state and local human services commissioners about their key priorities, current challenges, and to inform the development of a plan to engage state/local human services agencies to improve family economic and social well-being through federal, state, and local partnerships.

Phase 1 of this project will involve a web-based survey of every state and territory human services commissioner (or secretary, director, chief executive officer) and a sample of county human services commissioners. The county sample will be drawn from the American Public Human Services Association’s (APHSA) National Council of Local Human Service Administrators membership list. Similar questions will be used for state and county leadership, however there will be questions for county human services commissioners will be adapted because of their unique reporting relationship to states and federal government. Phase 2 of this project will involve regional listening sessions with state human services commissioners in order to ask more in-depth questions regarding their experiences with ACF and existing barriers that impact their ability to achieve positive outcomes for families. The questions for the Listening Sessions will be developed based on the data and overall themes identified through the Phase 1 survey.

Research Questions

This project will explore the following research questions:

1. What are state and local human services agency leadership priorities and challenges? What are federal barriers that may be getting in their way?

2. What are state and local county human services leadership’s experiences with implementing ACF programs? What is their level of satisfaction with the assistance provided by the Regional and Central Offices?

3. What role would state and local county human services leadership want to see ACF play in the upcoming year to help them achieve agency priorities?

4. What recommendations do state and county human services leadership have for ACF to help improve family economic and social well-being for families served by ACF programs?

Study Design

This collection serves as a preliminary step to gather information that will inform a strategy and plan to remove barriers and support state/local systems change efforts and redesign of services that improves the economic and social well-being of families. The study team will include the state human services commissioner in every state and territory and include county human services commissioners who are members of the APHSA National Council of Local Human Service Administrators. A limitation is that this process will not yield a representative sample of all county human services; however, it will identify many of the key leaders and innovators across the country with direct experience implementing systems change and reform efforts.

Upon OMB approval of the information collection instruments, the study team will send each state and local human services commissioner included in the sample a request to participate in a web-based survey via email (see Appendix A, Email Template Invitation). The email will be addressed to state and county human services commissioners. It will introduce the survey and its goals and the reason ACF is conducting the survey. The survey is voluntary (see Appendix B, State Human Services Commissioner Feedback Survey and Appendix C, County Human Services Commissioner Feedback Survey). The survey is designed to collect the minimum information necessary to allow us to understand the key priorities, challenges, and feedback about state and county human services commissioner experiences with working with ACF and recommendations for the agency. It is anticipated that the initial survey will take approximately 30 minutes to complete.

After the first phase is completed, the study team will analyze the results of the survey and identify key themes and barriers that will be used to refine more in-depth questions that will be asked through Regional Listening Sessions. We will submit the final Listening Session protocol once it is refined as a nonsubstantive change request. The sample for the listening sessions will include the state and a sub-sample of county human services commissioner leadership in the Region. Using a semi-structured protocol that will be developed, the study team will seek to gain a better understanding and more detailed information about the key barriers and recommendations for addressing for those barriers from state and local human services commissioners as they implement ACF-funded programs.

Universe of Data Collection Efforts

There are two main data collection efforts involved with the current request for approval.

(1a) State Human Services Commissioner Customer Feedback Survey (Appendix B): An initial 15-30 minute web-based survey for state human services commissioners.

(1b) County Human Services Commissioner Customer Feedback Survey (Appendix C): An initial 15-30 minute web-based survey for county human services commissioners.

(2) Regional Listening Sessions Semi Structured Protocol (Appendix D): Subsequent Listening Sessions based on a semi-structured interview protocol with questions drawn from key themes the initial survey. A sample of proposed questions is included. Listening Sessions will be approximately 120 minutes.

Both the surveys and the semi-structured protocol cover similar research questions. However, there is additional time allotted for the Listening Sessions to allow the state and county leadership to share more information about their experiences, priorities, and challenges.

A3. Improved Information Technology to Reduce Burden

To maximize efficiency, this project will use Qualtrics to develop and administer the web-based survey. This technology has the capacity to develop a simple, user-friendly interface to administer the survey.

A4. Efforts to Identify Duplication

To our knowledge, systematic information about the state and county human services’ needs, priorities, experience with ACF programs, and key federal barriers is not available.

A5. Involvement of Small Organizations

We expect that respondents will be public state and local human services organizations and not small organizations. Burden will be minimized for respondents by keeping the survey short and including multiple choice questions, and in-person listening sessions to be scheduled at times convenient for the respondents, and by requiring no record-keeping or written responses on the part of the programs.

A6. Consequences of Less Frequent Data Collection

This is the first time ACF will be seeking feedback directly from state and county human services organizations, the primary customer for the agency. The initial web-survey is needed to move forward with the Listening Sessions. This information will be used by ACF leadership to identify priorities for working with state and local human services agencies, and to further the proper performance of the functions of the agency.

A7. Special Circumstances

There are no special circumstances for the proposed data collection efforts.

A8. Federal Register Notice and Consultation

Federal Register Notice and Comments

In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on September 15, 2014 in Volume 79, No. 178, page 54985, and provided a sixty-day period for public comment The second notice was published on January 9, 2015, Volume 80, No. 6, page 1420, and provided a 30-day period for public comment. ACF did not receive any comments.

Consultation with Experts Outside of the Study

ACF consulted with 3 state human services commissioners, 2 county human services commissioners, and one former state commissioner to solicit their feedback regarding the proposed survey questions during the month of September 2017.

A9. Incentives for Respondents

No incentives for respondents are proposed for this information collection.

A10. Privacy of Respondents

Information collected will be kept private to the extent permitted by law. Respondents will be informed of all planned uses of data, that their participation is voluntary, and that their information will be kept private to the extent permitted by law.

ACF shall protect respondent privacy to the extent permitted by law and will comply with all Federal and Departmental regulations for private information. ACF shall ensure that all of its employees, subcontractors (at all tiers), and employees of each subcontractor, who perform work under this contract/subcontract, are trained on data privacy issues and comply with the above requirements.

ACF shall use Federal Information Processing Standard compliant encryption (Security Requirements for Cryptographic Module, as amended) to protect all instances of sensitive information during storage and transmission. ACF shall securely generate and manage encryption keys to prevent unauthorized decryption of information, in accordance with the Federal Processing Standard.  ACF shall: ensure that this standard is incorporated into the property management/control system; establish a procedure to account for all laptop computers, desktop computers, and other mobile devices and portable media that store or process sensitive information. Any data stored electronically will be secured in accordance with the most current National Institute of Standards and Technology (NIST) requirements and other applicable Federal and Departmental regulations. In addition, the Contractor must submit a plan for minimizing to the extent possible the inclusion of sensitive information on paper records and for the protection of any paper records, field notes, or other documents that contain sensitive or personally identifiable information that ensures secure storage and limits on access.  

Information will not be maintained in a paper or electronic system from which data are actually or directly retrieved by an individuals’ personal identifier.

A11. Sensitive Questions

There are no sensitive questions in this data collection.

A12. Estimation of Information Collection Burden

Total Burden Requested Under this Information Collection

Instrument	Sample Size	Number of Respondents (with Response Rate)	Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Average Hourly Wage	Total Annual Cost
State Human Services Commissioner Feedback Survey	77	46 (60% response rate)	1	0.5	23	$52.24	$1,202
County Human Services Commissioner Customer Feedback Survey	348	87 (25% response rate)	1	0.5	44	$54.11	$2381
Regional Listening Sessions Semi Structured Protocol	75	60 (80% response rate)	1	2	120	40 states at $52.24 20 counties at $54.11	$3172 ($2090 + $1082)
Estimated Annual Burden Total					187		$6755

Total Annual Cost

To calculate the annualized cost to respondents for the hour burden, we assume that the typical respondent will be state or local government officials. Based on data on our expected respondents from the Bureau of Labor Statistics, we use a mean hourly wage of $52.24 for state government chief executive officials and $54.11 for county government chief executive officials¹.

A13. Cost Burden to Respondents or Record Keepers

There are no additional costs to respondents.

A14. Estimate of Cost to the Federal Government

Based on previous costs, we estimate the annual costs to the Federal Government to be around $16,000. This includes the costs for information collection, including agency and contractor staff salaries.

A15. Change in Burden

This is an additional generic IC under 0970-0356

A16. Plan and Time Schedule for Information Collection, Tabulation and Publication

Phase 1: Web-based survey to be administered in November 2017 (pending OMB approval). Responses received within one month and analysis to be conducted in the following month.

Phase 2: Regional listening sessions to be conducted between January 2018 to February 2018, pending OMB approval and dependent on the schedule for the web-based survey. Analysis and an internal report expected to be completed by March 2018.

A17. Reasons Not to Display OMB Expiration Date

All instruments will display the expiration date for OMB approval.

A18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions are necessary for this information collection.

1 This is an average of the mean hourly wages for state chief executive government officials ($52.24), local chief executive government officials ($54.11). See: https://www.bls.gov/oes/current/oes111011.htm

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