Supporting Statement A - PREP PMAPS Formative Generic

PREP STUDIES OF PERFORMANCE MEASURES
AND ADULT PREPARATION SUBJECTS

OMB Information Collection Request - Formative Data Collection

0970 - 0356

Supporting Statement

Part A

January 2018

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:

Tia Zeno

Caryn Blitz

A1. Necessity for the Data Collection

In April 2017, the Administration for Children and Families (ACF) Office of Planning, Research, and Evaluation (OPRE) received approval to collect a revised set of performance measures (PM) from Personal Responsibility Education Program (PREP) grantees through various instruments including participant entry and exit surveys administered to program participants (OMB Control No. 0970-0497). The objective of the PREP PM data collection is to document how PREP-funded programs are operationalized in the field and assess program outcomes.

In the current information collection request, ACF seeks approval to survey PREP grantees on how they currently use or would use data obtained through the revised performance measures, with the goal of identifying potential ways to reduce grantee burden or enhance usefulness of the existing performance measures. Specifically, ACF is seeking feedback to determine whether data collected through measures on the participant entry and exit surveys are used to manage programs, make program improvements, work with funders, policy makers, and partners, disseminate results, or in some other capacity. Using the information obtained, ACF will determine whether adjustments need to be made to the entry and exit surveys that would enhance the value of the measures to grantees.

Study Background

In March 2010, Congress authorized PREP as part of the Patient Protection and Affordable Care Act (ACA); it was reauthorized in 2015 for an additional two years of funding through the Medicare Access and CHIP Reauthorization ACT of 2015. PREP provides grants to states, tribes, and tribal communities, and community organizations to support evidence-based programs to reduce teen pregnancy and sexually transmitted infections (STIs). The programs are required to provide education on both abstinence and contraceptive use. The programs also offer information on adulthood preparation subjects such as healthy relationships, adolescent development, financial literacy, parent–child communication, education and employment skills, and healthy life skills. Grantees are encouraged to target their programming to high-risk populations—for example, youth in foster care, homeless youth, youth with HIV/AIDS, pregnant youth who are under 21 years of age, mothers who are under 21 years of age, and youth residing in geographic areas with high teen birth rates. Per legislation, there are four PREP programs:

1. States and other entities can access allotted PREP funding through a formula grants program, known as State PREP, or SPREP.

2. If a state does not access PREP funding, competitive grants are available for programs in that particular state: the grants are known together as Competitive PREP, or CPREP.

3. Grants to tribes and tribal communities are made through a competitive process: the grants are known together as Tribal PREP, or TPREP.

4. Funding is also available to fund new and innovative approaches to teen pregnancy prevention: the grants are known together as Personal Responsibility Education – Innovative Strategies, or as PREIS.

On April 3, 2017 ACF obtained approval to collect performance measures across all PREP programming through various data collection instruments, including participant entry and exit surveys (OMB Control No. 0970-0497). This approval supports PREP-funded programs in collecting and reporting their performance data through the PREP data warehouse and provides grantees and federal program staff with near real-time data for program monitoring and improvement. The measures were designed to be used by federal program staff, policymakers, and grantees to understand how programs are operationalized in the field, and assess program outcomes.

The current information collection request seeks approval for gathering feedback from grantees on how they currently use or would use the data collected through the performance measure items on the entry and exit surveys. Information on whether and how grantees use the measures will be useful in considering potential ways to reduce grantee burden or enhance usefulness of the existing performance measures.

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

ACF requires PREP grantees to submit data using a set of performance measures collected through various instruments (approved on April 3, 2017; OMB Control No. 0970-0497). The collection and analysis of PREP PM play a unique and important role in current federal evaluation efforts to expand the evidence base on teen pregnancy prevention programs. The objective of the PREP PM effort is to document how PREP-funded programs are operationalized in the field and assess program outcomes.

Through the performance measures, grantees are required to submit data annually on PREP program structure and PREP program delivery. The purpose of the current proposed data collection is to 1) gather information on how grantees would use the data obtained through the performance measures, and 2) ensure the measures are relevant to grantees and facilitate use by providers and evaluators. Based on the information collected, the entry and exit surveys may be revised to meet the needs of grantees.

Research Questions

The data collection and analysis activities to be conducted as part of the current request for approval will seek to address the following research questions:

Have the performance measures data collected through the entry and exit surveys been used, or how grantees would use them, to:

• Manage the program?

• Make program improvements?

• Work with funders?

• Work with policy makers?

• Work with partners?

• Disseminate results?

• For other uses?

Study Design

ACF is interested in learning more about whether and how grantees use data they collect through the entry and exit surveys, to ensure the information collection is as useful as possible to the grantees. To gain an understanding and address the research questions above, ACF proposes administering a short survey to PREP grantees. The survey will be web-based and will document the perspectives of up to 94 grantees. The survey is estimated to take 15 minutes to complete.

ACF will send an advance email to grantee agency directors notifying them that Mathematica will invite them to complete the survey online. The email will describe the purpose of the survey, and emphasize its importance. Next, Mathematica will send invitation emails to the grantees asking them to complete their survey. The invitation email will include a description of the data collection, provide grantee’s unique survey URL and password, and contact information for the study team. Only one URL will be generated for each grantee and once a survey has been completed and submitted, respondents will not be able to re-enter the survey. The email will note that while the agency directors may consult with others to complete the survey, only one per grantee is allowed. We will also ask that administrators refrain from sharing the URL and password with others. Mathematica and ACF will each send additional email reminders to respondents encouraging their participation (Appendix A).

Universe of Data Collection Efforts

The current request for approval includes a short web survey to be completed by grantees (Instrument 1). Survey questions focus on how grantees have used or would use each category of survey items. The study team will utilize an email template for invitations that will contain a unique URL and password for grantees to access the survey online. Mathematica and ACF will also utilize email templates to send reminders to respondents.

A3. Improved Information Technology to Reduce Burden

The web-based application allows respondents the flexibility to complete the survey at a time convenient to them and can be completed on multiple devices, including a desktop, laptop computer, or mobile device, if they prefer.

A4. Efforts to Identify Duplication

ACF has carefully reviewed the information collection requirements to avoid duplication with existing studies or other ongoing federal teen pregnancy prevention evaluations and believes that this requested data collection complements, rather than duplicates, other ongoing federal teen pregnancy prevention evaluations and projects. Specifically, this information collection will gather information on how grantees currently use or would use the data obtained through the participant entry and exit surveys.

A5. Involvement of Small Organizations

We expect some of the grantees will be small organizations. Burden will be minimized for respondents by restricting the interview length to 15 minutes and allowing grantees to complete the survey at work or on their own time and their own devices, whichever is more convenient. There is no additional burden placed on these small organizations.

A6. Consequences of Less Frequent Data Collection

Without the information collected from this proposed effort, it will be unclear whether some or all categories of the information obtained through participant entry and exit surveys has or may be used by grantees, and how they might use the information. Information collected through this effort can help inform potential reductions in the number of measures collected through the entry and exit surveys if needed, to potentially minimize burden and improve effectiveness of the measures.

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, (vol. 79, no. 178, p. 54985) and provided a 60-day period for public comment. ACF did not receive any comments in response to this notice.

Consultation with Experts Outside of the Study

We will not consult any outside experts for the current information collection.

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.

As specified in the contract, the Contractor shall protect respondent privacy to the extent permitted by law and will comply with all Federal and Departmental regulations for private information. The Contractor 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.

As specified in the evaluator’s contract, the Contractor 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. The Contractor shall securely generate and manage encryption keys to prevent unauthorized decryption of information, in accordance with the Federal Processing Standard. The Contractor shall: ensure that this standard is incorporated into the Contractor’s 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. Data is stored on servers that are hosted and maintained by Mathematica. Data at rest is secured using FIPS 140-2 compliant encryption.

A11. Sensitive Questions

There are no sensitive questions in this data collection.

A12. Estimation of Information Collection Burden

Table A12.1 shows the estimated burden associated with this information collection request. Ninety-four grantees will be invited to complete the survey and we expect a response rate of 80 percent, resulting in 75 respondents to the survey. The estimated time to complete the survey is 15 minutes. The total burden for this data collection is estimated to be 19 hours.

Table A12.1. Total Burden Requested Under this Information Collection

Instrument	Grantee Type	Annual Number of Respondents	Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Average Hourly Wage	Total Annual Cost
Survey of Grantees	State/Tribal	47	1	0.25	12	$21.35	$256.20
	CPREP	18	1	0.25	4	$20.76	$83.04
	PREIS	10	1	0.25	3	$20.76	$62.28
	Total Respondents	75
Estimated Annual Burden Total					19		$401.52

Total Annual Cost

The total cost burden for this data collection is estimated to be $401.52 (The hourly wage rate for State and Tribal grantees represents the mean hourly wage rate for all occupations ($21.35); for CPREP and PREIS it is the mean hourly wage rate for community and social service occupations ($20.76) (National Occupational Employment and Wage Estimates, Bureau of Labor Statistics, Department of Labor, May 2010).

A13. Cost Burden to Respondents or Record Keepers

There are no additional costs to respondents.

A14. Estimate of Cost to the Federal Government

The estimated cost for development, collection, and analysis of the current information request is $18,565; data will be collected for one year.

A15. Change in Burden

This is a new information collection request under a generic clearance (OMB Control No. 0970-0356).

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

Data collection will occur upon OMB approval through March 2018. Mathematica will compile feedback to ACF in April 2018. There are no plans for publication of the information collected.

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.

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