NonSub Change Memo - HPOG 2.0 CovidCohortSurvey Intro Language (Privacy)

DATE: December 6, 2021

TO: Jordan Cohen

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

FROM: Nicole Constance and Lisa Zingman

Office of Planning, Research, and Evaluation (OPRE)

Administration for Children and Families (ACF)

SUBJECT: Request for Non-Substantive Changes to the National and Tribal Evaluation of the 2^nd Generation of the Health Profession Opportunity Grants (HPOG 2.0) (OMB #0970-0462)

This memo requests approval of three non-substantive changes to the recently approved information collection for the National and Tribal Evaluation of the 2^nd Generation of the Health Profession Opportunity Grants (HPOG 2.0) (OMB # 0970-0462).

Background

Between August 2015 and July 2019, OMB has approved several information collection instruments, procedures, and supporting materials in support of the HPOG 2.0 National and Tribal Evaluation. Materials in support of the HPOG 2.0 Tribal Evaluation include baseline data collection from study participants, data collection protocols and procedures. Materials in support of the National Evaluation impact study include baseline data collection from study participants, and Short-Term and Intermediate Follow-up Surveys. In July 2021, OMB approved Instrument 12a COVID-Cohort Short-term Survey (COVID-19 Cohort STS) and supporting materials. In October 2021, OMB approved minor revisions to Instrument 12a and supporting materials, and an alternative shortened version of Instrument 12 (Instrument 12b COVID-Cohort Short-term Survey Critical Items Only).

Since approval, the OPRE privacy analyst recommended some additional minor revisions to the materials to remind participants of uses of their data and privacy protections described in the consent form they signed at the time of study enrollment. To address those recommendations, OPRE seeks approval to make three modifications to the survey introductions to Instruments 12a and 12b.

Overview of Requested Changes

1. First, in the survey introduction, we moved up the statement about how survey responses will be used (edits shown below in yellow highlight).

2. Next, to remind participants of privacy protections with regard to data archiving, we added a statement that data sets that are developed for use by other researchers will be stripped of personally identifiable information. This statement already appears in the consent forms that participants signed at enrollment. Adding the language here ensures greater consistency between the consent form language and the survey introduction and will serve as a reminder to participants (edits shown below in cyan highlight).

3. Finally, the OPRE privacy analyst recommended that participants be reminded of the long-term use of administrative data. We added a statement at the end of the paragraph reminding participants that we will continue to collect information from administrative data sources such as the National Directory of New Hires and the National Student Clearinghouse until the end of HHS’s research on HPOG (edits shown below in cyan highlight).

For easy comparison, we first show the section of the survey introduction as currently approved:

• Before we begin the survey, I would like to assure you that all of your responses on this survey will be kept private; your name will not appear in any written reports we produce. Your responses to these questions are completely voluntary. That means you may choose not to answer any question, or you may stop the interview if you wish, but we hope you don’t. Your responses to these questions will in no way affect your participation in any programs or your receipt of any kinds of public benefits or services. The information you provide will be kept private and only used for studies about the different types of education and employment trainings and services that are the focus of this study. By participating in this study, you will help the government learn if and how programs like [PROGRAM NAME] make a difference in people’s lives and how to improve programs in the future. 

Below is the revised introduction:

• Before we begin the survey, I would like to assure you that all of your responses on this survey will be kept private and only used for studies about the different types of education and employment trainings and services that are the focus of this study. Any data sets that are developed for sharing with other researchers will be stripped of information that would make it easy to identify you. Your name will not appear in any written reports we produce. Your responses to these questions are completely voluntary. That means you may choose not to answer any question, or you may stop the interview if you wish, but we hope you don’t. Your responses to these questions will in no way affect your participation in any programs or your receipt of any kinds of public benefits or services. By participating in this study, you will help the government learn if and how programs like [PROGRAM NAME] make a difference in people’s lives and how to improve programs in the future. As we mentioned at the time of enrollment, we will continue to collect information from data sources such as the National Directory of New Hires and the National Student Clearinghouse so researchers can learn more about your future employment, earnings, and post-secondary education until the end of HHS’s research on HPOG grants, or when you choose to withdraw permission.

Time Sensitivity

ACF requests a response about these changes as quickly as possible. A prompt response will allow the COVID-19 Cohort STS data collection to remain on schedule, as data collection is scheduled to begin the week of December 13, 2021.

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