Appendix D: 60-Day FRN Public Comment 3

Assistant Secretary Lynn Johnson
Administration for Children and Families
US Department of Health and Human Services
330 C St. SW, Washington DC 20201
Proposed Information Collection Activity; Family Level Assessment and State of Home Visiting
(FLASH-V) Outreach and Recruitment Study (New Collection)
March 26, 2020
Dear Assistant Secretary Johnson,
The Association of State and Tribal Home Visiting Initiatives (ASTHVI) is a collaboration
of administrators of home visiting funds dedicated to supporting the effective implementation
and continuous quality improvement of home visiting programs. We are writing to respond to
the Administration for Children and Families’ (ACF) request for comment on the proposed
information collection activity titled, Family Level Assessment and State of Home Visiting
(FLASH-V) Outreach and Recruitment Study.
ASTHVI members are grateful for the opportunity to offer feedback on the proposed
study. We appreciate ACF’s interest in developing and testing innovative strategies to address
bottlenecks in the recruitment and enrollment process and look forward to seeing future
iterations of this study. To accurately capture member feedback, the ASTHVI Data Committee
held a call to review the study and accompanying instruments. Our comments are a summary
of the questions and concerns raised by the more than 25 home visiting data experts from
around the country who joined that conversation.
As we reviewed the FLASH-V study, administrators offered two important global
observations.
First, ASTHVI members feel that having additional context regarding the motivation for
designing the study in this particular manner would be helpful when reviewing the proposed
mechanisms detailed in the notice. Additional background on the rationale behind the study
design and intended use will help administrators to better understand the objective, review and
critique the intricacies of the study and its instruments, and, ultimately, present this study to
local implementing agencies (LIAs). Many of the questions raised on the Data Committee call
focused on trying to deduce the intent behind particular features of the study while parsing

what information would be most useful and could also be collected in a time- and costsensitive way. Administrators asked how the study would identify effective strategies to
address caseload capacity issues if it only considers LIAs that are under capacity? The exclusion
of LIAs with full caseloads would seem to result in the omission of effective, time-tested
strategies. ASTHVI members fully support and promote innovation in the delivery of home
visiting services, including those funded by MIECHV, but administrators question the decision to
focus solely on under-capacity programs.
Administrators also expressed a concern that the study has the potential to feel
punitive. LIAs are likely to feel understandably apprehensive about participating in a study
where they are identified as chronically under-capacity, and as a result, their referral
procedures and protocols are under review. The aforementioned exclusion of full capacity LIAs
highlights those concerns. ASTHVI strongly encourages ACF to include a clear commitment that
the study will not be used to punish LIAs, and recommends including continuous quality
improvement or other improvement- or strength-based language to clearly signal that intent.
The Data Committee also raised a number of questions about study logistics. Will ACF
and/or HRSA be charged with completing this work, or will a TA provider or other third party
oversee the study? Will Tribal programs be invited to participate? What is the expected time
period, including both the anticipated start date and timeframe for the two data collection
phases? How many LIAs and referral partners is ACF hoping to review? How will ACF be
communicating with and identifying LIAs? What role will state and Tribal home visiting leads,
model developers, HARC members, and others be expected to play in helping to facilitate this
study? Will additional technical assistance be offered to LIAs that participate? The answers to
these questions will help ASTHVI members support LIAs participating in this study and be more
prepared for its roll-out.
It would also be helpful for important study instructions and parameters laid out in the
various instruments to be summarized and included in future notices. For example, the “LIA
Eligibility Assessment Form” explicitly states that participation in this study is voluntary. It
instructs LIAs to complete the form only if they are typically or currently under capacity.
Awardees reviewing the Federal Register notice on its own would be unaware that the
proposed data collection activities are voluntary, and only intended for under-capacity LIAs.
Summarizing this information up front, along with other important details such as the $2,500
compensation for the “MIS Data Submission,” in the study summary would be helpful.
With these global comments in mind, we are pleased to offer the following specific
comments on the instruments:

ASTHVI to ACF re: FLASH-V Outreach and Recruitment Study

2

Instrument
LIA Eligibility
Assessment Form

Comments
While this form is apparently straightforward, it raises questions
about how appropriate LIAs will be identified. The instrument
seems to identify four stages of outreach: (1) contacting LIAs in
Phase I, (2) contacting LIAs through the HARC LIA Member list, (3)
contacting LIAs based on HARC Network Member, and (4)
contacting LIAs through MIECHV State Leads. It is unclear how
LIAs will be identified for outreach in the various stages,
particularly the first three, and why the state lead is consulted last.
If, for example, an LIA that has been operating under-capacity
because of staffing challenges, it may not be appropriate for
inclusion in a study focused on improving referral practices. This is
information that is most likely to be learned through consultation
with state leads.

LIA Eligibility
Assessment Form for
MIS Data

ASTHVI Data Committee members unanimously agree that this
form would take more than the estimated 15 minutes to
complete. In many cases, the LIA would not be able to provide all
the necessary information without coordination with model
developers or state leads; it would also require involvement of
other data staff/contractors to pull a custom report. Perhaps,
given the purpose of the form, rough estimtes rather than precise
numbers would be adequate. The time required to complete this
form is tied to the level of accuracy of these estimates. Additional
detail regarding the level of accuracy needed would be helpful.
Additionally, some LIAs may use as many as three data systems.
Will LIAs be required to fill out one form for each system? Focus
on one system? Attempt to summarize the three systems in one
report? Clarification is needed for LIAs using multiple data
systems.

Request for LIA
Recommendations
from HARC State
Networks

The request for HARC State Networks to recommend LIAs for this
study has the potential to create some disconnect in the field. It
raises questions about what can and cannot be shared with
regards to data, particularly if awardees are not consulted.
ASTHVI members recommend that future versions of this
instrument encourage HARC Members to contact state or Tribal
home visiting leads before recommending LIAs.

Request to LIAs for
Community Referral

Strong relationships with referral partners are essential for LIAs to
serve their families. Similar to the recommendation above,

ASTHVI to ACF re: FLASH-V Outreach and Recruitment Study

3

Partner Contact
Information

administrators recommend that LIAs notify their referral partners
that they may be contacted by ACF for the purposes of this study,
along with a timeline for that contact, when sharing their names
with ACF.
Members of the Data Committee requested confirmation that this
study intends only to contact referral partners that refer families
to home visiting programs, and not partners that home visiting
programs refer out to. Requiring information about both types of
referral partners would significantly increase the workload and
time associated with completing this form.

Interview Protocol
Local Implementing
Agency

This form in particular is the most difficult to review without
additional information about the study’s purpose and the
intended use of the findings. Absent that background,
administrators cannot determine if there are questions that
should be added, removed, or updated.

Interview Protocol
Community Referral
Partner

Administrators expressed caution that these interviews be
conducted in ways that do not damage partners’ relationships
with LIAs. For example, an important and strong referral partner
might feel singled out or undervalued when probed about ways to
increase the number of referrals provided. ASTHVI members
understand that it is not the intent of these interviews to disrupt
relationships, but caution that questions – and the need and
purpose for the interviews – be presented with sensitivity.

MIS Data Submission

Administrators are concerned that 16 hours is a substantial
underestimation of the time required to complete this data
submission. Complete information will require LIAs to coordinate
with data staff and contractors, along with model developers and
state leads. LIAs that are part of a centralized system might not
have the ability to make those data requests. LIAs may be
uncomfortable sharing data without a HIPAA agreement.
The compensation provisions raised several questions. Do referral
partners receive an incentive to participate? Is the LIA responsible
for distribution of compensation received to referral partners,
data contractors, state leads, etc.? If additional costs are incurred
to pull a custom data extract, is that reimbursable for
participating LIAs?
Finally, Administrators recommend creating a data dictionary to
refer to when pulling these data elements. Different awardees

ASTHVI to ACF re: FLASH-V Outreach and Recruitment Study

4

collect this information in different forms. Without some level of
standardization, the data received will be difficult to analyze.

Thank you for your attention to these comments. We look forward to seeing how the
FLASH-V study evolves, and continuing to work with you to improve health, child welfare, and
early education outcomes for even more children across the country.

Sincerely,
Kassondra Kugler, Washington
ASTHVI Data Committee Co-Chair
Ginny Zawistowski, Minnesota
ASTHVI Data Committee Co-Chair

ASTHVI to ACF re: FLASH-V Outreach and Recruitment Study

5