Supporting Statement A

Alternative Supporting Statement for Information Collections Designed for

Research, Public Health Surveillance, and Program Evaluation Purposes

Family Level Assessment and State of Home Visiting (FLASH-V) Outreach and Recruitment Study

OMB Information Collection Request

0970 – New Collection

Supporting Statement

Part A

September 2020

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:

Laura Nerenberg

Kelly Jedd McKenzie

Part A

Executive Summary

• Type of Request: This Information Collection Request is for a new request. We are requesting two years of approval for data collection efforts that will occur within a 13-month period.

• Description of Request:

This is a request to use surveys and semi-structured telephone interviews to gather information about how Maternal, Infant, and Early Childhood Home Visiting (MIECHV) state and territory local implementing agencies (LIAs) and tribal grantees (hereafter referred to collectively as MIECHV funded LIAs) recruit families for program participation and work with their community referral partners to recruit families. The request also includes collection of select MIECHV funded LIAs’ outreach and recruitment materials to gather information on the content and messages contained within. We do not intend for this information to be used as the principal basis for public policy decisions. The request is for a descriptive study with the purpose of understanding challenges programs may face in reaching caseload capacity to help identify ways programs can reach more families who could benefit from home visiting.

A1. Necessity for Collection

This collection is necessary to provide information on how to better identify and recruit families for program participation to maximize the number of families that benefit from home visiting.

There are no legal or administrative requirements that necessitate the collection. The Administration for Children and Families (ACF) is undertaking the collection at the discretion of the agency.

A2. Purpose

Purpose and Use

The purpose of this data collection is to provide descriptive research on how MIECHV funded LIAs recruit families for program participation and work with community referral partners to recruit families. The project is designed to examine challenges programs experience reaching caseload capacity and how challenges might be overcome. This descriptive work is intended to assist ACF and the Health Resources and Services Administration (HRSA) in identifying potential bottlenecks in the recruitment and enrollment process to inform the development and future testing of strategies to improve the delivery of MIECHV funded services.

The information collected is meant to contribute to the body of knowledge on ACF and HRSA programs. It may also be used to support future technical assistance (TA) to programs, home visiting’s continuous quality improvement (CQI) work, and future evaluation efforts. It is not intended to be used as the principal basis for a decision by a federal decision-maker and is not expected to meet the threshold of influential or highly influential scientific information.

Guiding Questions

1. What are current approaches used by MIECHV funded programs to identify, reach, and recruit potential eligible families? What opportunities exist to increase the number of identified potential eligible families?

2. What is the current landscape for programs in terms of capacity? What accomplishments and challenges have programs experienced in maintaining caseloads, including those experienced during the COVID-19 pandemic?

3. What types of community organizations currently refer families to home visiting? How do programs communicate and work with community referral partners? How can MIECHV funded programs work with community referral partners to strengthen the flow of incoming referrals and improve rates of successful enrollment?

Study Design

This is a descriptive study that will utilize both qualitative and quantitative approaches to address the research questions.

Data collection includes: (1) a national survey of MIECHV funded LIAs and (2) semi-structured interviews with a subset of MIECHV funded LIAs and a review of program outreach and recruitment materials. First, we will request LIA contact information from MIECHV leads (Instrument 1) for which that information is not already available. Prior to this request, an informational webinar will be offered to all MIECHV leads to inform them of the study and the upcoming outreach. Next, we will use the LIA contact information obtained to request LIAs participate in a survey (Instrument 2). Finally, we will recruit a subset of MIECHV funded LIAs who completed a survey to request participation in a semi-structured interview (Instrument 3) and request that they share their program’s outreach and recruitment materials. The request for program outreach and recruitment materials does not impose burden, as the request is only for existing materials in their current format.

Although findings are not intended to be representative, the use of a national survey of MIECHV funded LIAs is appropriate to provide a snapshot of the landscape of program capacity, challenges, and accomplishments across MIECHV funded LIAs. Additionally, the nature of semi-structured interviews allows collection of data across a consistent set of questions and concepts, while at the same time also allows for deeper probing of particular issues that may emerge over the course of the conversation. The document review portion of the study will help describe the content and nature of program outreach and recruitment materials. Data collected from interviews, program outreach and recruitment materials, and surveys will be used to develop a comprehensive picture from a subset of programs about challenges and promising strategies related to program outreach and recruitment. Limitations will be noted in any publications resulting from the information collection.

Data Collection Activity	Instrument(s)	Respondent, Content, Purpose of Collection	Mode and Duration
Collect contact information for MIECHV funded LIAs	1-Request for LIA Contact Information from MIECHV Leads	Respondents: MIECHV leads. Content: Request for name and contact information for MIECHV funded LIAs. Purpose: To identify eligible LIAs for study participation.	Mode: Email Duration: .25 hours
Survey of MIECHV funded LIAs	2-LIA Survey	Respondents: Staff from MIECHV funded LIAs. Content: Program caseload capacity; challenges and accomplishments in maintaining caseloads; outreach and recruitment strategies; work with community referral partners. Purpose: Document landscape of program capacity and challenges and accomplishments related to outreach and recruitment.	Mode: Web-based survey Duration: .50 hours
Interview of MIECHV funded LIAs	3-LIA Interview Protocol	Respondents: Staff from LIAs selected for participation in semi-structured interviews. Content: Program caseload capacity; challenges and accomplishments in maintaining caseloads; outreach and recruitment strategies; work with community referral partners. Purpose: In-depth program descriptions and perspectives on outreach and recruitment efforts.	Mode: Telephone semi-structured interview Duration: .75 hours

Other Data Sources and Uses of Information

To inform survey and interview protocol development, the Study Team reviewed available information on findings from MIECHV grantee evaluations focused on the topic of family outreach and recruitment. To document the content and nature of program outreach and recruitment materials, we will also complete a review of outreach and recruitment materials for LIAs that participate in an interview. The review of MIECHV awardee evaluations and request for program outreach and recruitment materials does not impose burden, as the request is only for existing materials in their current format.

A3. Use of Information Technology to Reduce Burden

Surveys will be completed using a secure web-based platform (Qualtrics) to reduce participant burden. The proposed survey content was designed to capture the aspects of recruitment that are appropriate for collection in this format. Additionally, semi-structured interviews will be completed via telephone to reduce participant burden. Interviews will be recorded (upon participant agreement) so that participants do not need to repeat responses or wait for the interviewer to document detailed responses. Direct person-to-person communication is required. Though the semi-structured interview format may be more burdensome than an alternative form of computerized assisted data collection (such as a survey or questionnaire), our interview protocol was designed to collect information about a complex process that may be difficult and time-consuming to capture by hand through a survey or questionnaire. An interview allows the interviewer to probe as necessary and to move through lower priority questions at a faster pace depending on how long the interview is running. Data elements that are expected to yield high quality data through a survey format have been included in our survey; data elements where the semi-structured interview format is expected to yield higher quality data than would be possible in a survey are included in the semi-structured interview.

A4. Use of Existing Data: Efforts to reduce duplication, minimize burden, and increase utility and government efficiency

Information to achieve purposes stated in A.2 does not exist for the field of home visiting. There currently is not information on the specific processes LIAs engage in for the purposes of program outreach and recruitment. The Study Team has reviewed existing research, evaluation, and MIECHV TA materials and incorporated relevant information into data collection protocols.

A5. Impact on Small Businesses

Surveys and interviews will include staff at state and territory LIAs and tribal grantees. These entities may be small businesses. Since tribal grantees implement services and/or have close coordination with the sites they fund, tribal grantees are considered LIAs for the purposes of this data collection. The requested information is the absolute minimum necessary for the intended use of the data.

The Study Team will minimize the burden on program staff by keeping the survey and interview as short as possible. We will also schedule the interviews at a time most convenient for participants, and will not request written responses.

A6. Consequences of Less Frequent Collection

This is a one-time data collection.

A7. Now subsumed under 2(b) above and 10 (below)

A8. 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 January 23, 2020, Volume 85 Number 15 page 3922-3923, and provided a sixty-day period for public comment. A copy of this notice is attached as Appendix A. During the notice and comment period, 3 sets of comments were received, which are attached (see Appendix B-D). Comments:

• requested clarification on study logistics, including eligibility requirements, inclusion of tribal programs, and number of participants interviewed;

• recommended expanding the data collection to include LIAs at capacity as well as under capacity to expand the opportunity to learn from all LIAs and to minimize perceptions that the data collection is punitive by focusing only on LIAs under capacity; and

• recommended increasing the burden estimate for management information system (MIS) data collection.

To respond to comments received during the 60-day comment period, we revised the study design to include a broader range of LIAs (MIECHV funded LIAs at capacity and below capacity) in the data collection, among other changes. Due to the inclusion of a broader range and greater number of LIAs, we also eliminated collection of management information system (MIS) data. A detailed list of study design changes is provided in Appendix E. Additionally, due to the impacts of the COVID-19 pandemic, we have added items to capture data related to the impacts of COVID-19 since publication of the 60-day FRN. Materials with these items and all changes based on public comment are available for public comment in response the 30-day Federal Register Notice.

Consultation with Experts Outside of the Study

The Study Team consulted with MIECHV training and TA providers, such as the Home Visiting Collaborative Improvement and Innovation Network (CoIIN), who were asked to share materials on the topic of program outreach and recruitment. These materials were reviewed by the Study Team and relevant topics from TA and training materials were incorporated into the interview protocols.

A9. Tokens of Appreciation

The study will not include tokens of appreciation.

A10. Privacy: Procedures to protect privacy of information, while maximizing data sharing

Personally Identifiable Information

Individual names and contact information for points of contact at LIAs will be collected from MIECHV leads as part of Instrument 1. This information will enable the Study Team to reach out directly to MIECHV funded LIAs about study participation. Additionally, individual names of LIA staff participating in interviews will be asked during the interview. This information will be asked to enable interviewers to refer to respondents by their names during the interview. Information will not be maintained in a paper or electronic system from which data are actually or directly retrieved by an individual’s personal identifier.

Assurances of Privacy

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. Respondents will receive a copy of informed consent forms and will be read the consent form before interviews begin (See Instrument 2 for survey consent and Appendix K for interview consent). As specified in the contract, the Study Team will comply with all Federal and Departmental regulations for private information.

As specified in the evaluator’s contract, the Study Team will protect respondent privacy to the extent permitted by law and will comply with all Federal and Departmental regulations for private information. The Study Team will ensure that all 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. Study Team members are required to read and sign a confidentiality pledge.

The Study Team will maintain participants’ privacy by not sharing respondents’ identities with anyone outside of the research team. Interviews will be recorded with the consent of participants and those recordings will be saved on a secured drive. Once the interviews have been transcribed, the recordings will be destroyed. The transcriptions will not contain the full name of the participant. The Study Team will share information collected in aggregate and will not divulge the individual names of participants in publicly released documents.

In addition, the Study Team will 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.  

Data Security and Monitoring

The Study Team will protect respondent privacy to the extent permitted by law and will comply with all Federal and Departmental regulations for private information. The Study Team has developed a Data Security Plan that assesses all protections of respondents’ personally identifiable information. The Study Team will ensure that all 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 Study Team will 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 Study Team will securely generate and manage encryption keys to prevent unauthorized decryption of information, in accordance with the Federal Processing Standard. The Study Team will: ensure that this standard is incorporated into the Study Team’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.

A11. Sensitive Information ¹

There are no sensitive questions in this data collection.

A12. Burden

Explanation of Burden Estimates

• Request for LIA Contact Information from MIECHV Leads: The maximum number of participants is based on a total of 56 state and territory MIECHV leads. Burden estimate is based on the maximum number of potential participants taking a maximum of 15 minutes to provide LIA contact information. There may be variance in the time to provide recommendations depending on how many LIAs they provide funding to, how readily available necessary information is to provide LIA recommendations, and whether contact information and funding source for each LIA is consistently kept up to date. To insure we do not underestimate the burden associated with requesting LIA contact information, we conservatively used the higher end of the estimate.

• Survey: The maximum number of participants is based on a total of 779 MIECHV funded LIAs. Burden estimate is based on one respondent at each LIA taking an average of 30 minutes to complete the survey. There may be variance in the time to complete the survey, ranging between 15-35 minutes, depending on how much information is provided in open ended responses.

• Interview Protocol Local Implementing Agency: LIAs may include up to three staff in the interview. Burden estimate is based on the maximum number of staff total across 40 LIAs participating in interviews (3 staff * 40 LIAs = 120 respondents) and interviews taking an average of 45 minutes to complete.

Estimated Annualized Cost to Respondents

The estimated total annual cost to respondents is approximately $6,060.55 (see burden table below). This cost to respondents is based on the average wage of community and social service staff persons for LIA (occupation code 21-1000) and on the average wage of social and community services managers (occupation code 11-9151) for the state network participants. Estimates come from the 2019 Bureau of Labor Statistics report on Wage Estimates (retrieved from https://www.bls.gov/oes/current/oes_nat.htm).

Instrument	No. of Respondents (total over request period)	No. of Responses per Respondent (total over request period)	Avg. Burden per Response (in hours)	Total Burden (in hours)	Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
1-Request for LIA Contact Information from MIECHV Leads	56	1	.25	14	7	$35.05	$245.35
2-LIA Survey	779	1	.50	390	195	$24.23	$4,724.85
3-LIA Interview Protocol	120	1	.75	90	45	$24.23	$1,090.35
Total				494	247		$6,060.55

A13. Costs

The Study Team proposes providing a $25 honorarium, in the form of a gift card, to be provided to LIAs for each staff that participates in an interview to offset the cost of staff participation. While the qualitative data from semi-structured interviews is not intended to be statistically generalizable, the study’s findings will be more relevant for practice if we are able to secure participation from a wide range of LIAs, including LIAs that may face resource challenges or other barriers to study participation. The honorarium is intended to offset costs of participation in the study, such as staff time away from other necessary work, or other expenses that might otherwise prevent programs from participating in the study. The amount for the honorarium was determined by averaging the average hourly wage rates for staff that might participate in an interview and using this average to calculate an average wage rate for 45 minutes. Up to three $25 gift cards will be provided to the LIAs according to the number of staff that participate in an interview (i.e. LIAs will receive one gift card if one staff member participates, two gift cards if two staff participate, etc.).

A14. Estimated Annualized Costs to the Federal Government

The total cost for the data collection under this request is $938,061.97. The estimate includes the costs of Study Team staff time on instrument development and OMB clearance, data collection, analysis, and writing up the results. This request is for two years of approval.

Activity	Detail	Estimated Cost
Survey Design Instrument Development Pilot and User Testing OMB Clearance	FTE time Operational expenses (such as equipment, overhead, printing, and staff support) Other expenses which would not have been incurred without this collection of information	$109,345.42
Survey and interview administration	FTE time Operational expenses (such as equipment, overhead, printing, and staff support) Other expenses which would not have been incurred without this collection of information	$440,193.16
Analysis and initial dissemination	FTE time Operational expenses (such as equipment, overhead, printing, and staff support) Other expenses which would not have been incurred without this collection of information	$388,523.39
Total costs over the request period		$938,061.97
Annual costs		$460, 030.99

A15. Reasons for changes in burden

This is a new information request.

A16. Timeline

Data collection activities will occur within a 13-month period after OMB approval. Data analysis will occur within 6 months of completing data collection. We anticipate producing internal written reports and summaries approximately 6 months after completing data collection and producing final reports for publication approximately 15 months after completing data collection.

A17. Exceptions

No exceptions are necessary for this information collection.

Attachments

Instrument 1: Request for LIA Contact Information from MIECHV Leads

Instrument 2: LIA Survey

Instrument 3: LIA Interview Protocol

Appendix A: 60 Day FRN

Appendix B: 60 Day FRN Public Comment 1

Appendix C: 60 Day FRN Public Comment 2

Appendix D: 60 Day FRN Public Comment 3

Appendix E: Family Level Assessment and State of Home Visiting (FLASH-V) Outreach and Recruitment Study Design Changes in Response to Public Comments

Appendix F: Email Templates to LIAs Requesting Survey Participation

Appendix G: Project Description

Appendix H: Email Templates to LIAs Requesting Interview

Appendix I: Email Templates Providing Interview Information, Confirmation, and Thank You

Appendix J: Interview Topics and Sub-Topics

Appendix K: Interview Consent Form

1 Examples of sensitive topics include (but not limited to): social security number; sex behavior and attitudes; illegal, anti-social, self-incriminating and demeaning behavior; critical appraisals of other individuals with whom respondents have close relationships, e.g., family, pupil-teacher, employee-supervisor; mental and psychological problems potentially embarrassing to respondents; religion and indicators of religion; community activities which indicate political affiliation and attitudes; legally recognized privileged and analogous relationships, such as those of lawyers, physicians and ministers; records describing how an individual exercises rights guaranteed by the First Amendment; receipt of economic assistance from the government (e.g., unemployment or WIC or SNAP); immigration/citizenship status.

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