Supporting Statement A - CMI Data Linkages Formative Generic Request

Child Maltreatment Incidence Data Linkages

OMB Information Collection Request

0970-0356

Supporting Statement

Part A

December 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, DC 20201

Project Officer:

Christine Fortunato, Ph.D.

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CONTENTS

A1. Necessity for the Data Collection 1

Study Background 1

Legal or Administrative Requirements that Necessitate the Collection 1

A2. Purpose of Survey and Data Collection Procedures 2

Overview of Purpose and Approach 2

Research Questions 2

Study Design 2

Universe of Data Collection Efforts 4

A3. Improved Information Technology to Reduce Burden 4

A4. Efforts to Identify Duplication 4

A5. Involvement of Small Organizations 4

A6. Consequences of Less Frequent Data Collection 4

A7. Special Circumstances 5

A8. Federal Register Notice and Consultation 5

Federal Register Notice and Comments 5

Consultation with Experts Outside of the Study 5

A9. Incentives for Respondents 5

A10. Privacy of Respondents 5

A11. Sensitive Questions 6

A12. Estimation of Information Collection Burden 6

Total Annual Cost 6

A13. Cost Burden to Respondents or Record Keepers 6

A14. Estimate of Cost to the Federal Government 6

A15. Change in Burden 6

A16. Plan and Time Schedule for Information Collection, Tabulation and Publication 6

A17. Reasons Not to Display OMB Expiration Date 7

A18. Exceptions to Certification for Paperwork Reduction Act Submissions 7

REFERENCES 8

TABLES

1 Annual burden hours requested under this information collection (over 24 months) 6

2 Data collection schedule for CMI Data Linkages project 7

appendices and Attachments

APPENDICES

Appendix A: CMI Data Linkages Protocol for Key Informant Semi-Structured Interviews

Appendix B: CMI Data Linkages Questionnaire on Personnel and Non-personnel Resources

ATTACHMENTS

Attachment 1: Email Templates

Attachment 2: Topics and Respondents for Interviews and Questionnaire

Attachment 3: Project Description

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A1. Necessity for the Data Collection

The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services seeks approval to collect information from select research teams and partners for the Child Maltreatment Incidence Data Linkages (CMI Data Linkages) project. The goal of CMI Data Linkages is to gather information on the feasibility of using linked administrative data to understand the incidence of child maltreatment and related risk and protective factors. The project team will collect information from six sites through semi-structured interviews and a brief questionnaire. Permission to collect information for this limited purpose is requested under ACF’s generic clearance for Formative Data Collections for ACF Research (OMB Number 0970-0356). These activities fulfill the following goals of the formative generic: (1) inform the development of ACF research, (2) maintain a research agenda that is rigorous and relevant, and (3) inform the provision of future technical assistance.

Background

Accurate and ongoing surveillance of the incidence of child maltreatment and related risk and protective factors can help to inform policy and programs as well as shape prevention and intervention efforts. Linking administrative records from health, social services, education, public safety, and other agencies shows promise for capturing the incidence of child maltreatment and related risk and protective factors. The field is beginning to develop “best practices” in linking data systems to inform policy and programs (Fantuzzo and Culhane, 2015), but these practices must be further developed and advanced to measure and understand child maltreatment. CMI Data Linkages, funded by the ACF Office of Planning, Research, and Evaluation, will examine promising practices and assess the feasibility of scaling or enhancing promising practices related to linked administrative data that can inform child maltreatment incidence and related risk and protective factors.

The data collection under this formative generic clearance aims to (1) examine the factors (including, but not limited to, state and local context, resources, organizational capacity, peer support, training, and existing infrastructure) that promote or impede sites’ scaling or enhancement efforts to link and analyze administrative data related to child maltreatment at selected sites; and (2) determine the availability and quality of information on child maltreatment incidence and associated risk and protective factors that can be gleaned from linking administrative data. The project team will provide site consultation and develop a cross-site learning network among the participating sites. This cross-site learning network will include support for individual sites through collaborative discussions with other sites and access to a network of experts in administrative data and data-linking practices.

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 information collected under this formative generic clearance will be used to help ACF make decisions about necessary supports to carry out ongoing, accurate, and timely surveillance of child maltreatment incidence and related risk and protective factors. The project team’s plan is to conduct semi-structured interviews and administer a brief questionnaire with key respondents from the project’s six partnering sites. Additionally, the project team will gather and review documents from these partnering sites as well as take notes and extract lessons learned from site consultation and participation in the cross-site learning network.

Together the data gathering activities will inform ACF about the practical feasibility of leveraging administrative data linkages and/or innovative analyses to gain a better understanding of child maltreatment incidence and related risk and protective factors. To illuminate the promising approaches and challenges within and across sites, the project team will assess the sites’ data-linking methods and metrics, history and quality of partnerships with agencies/organizations for accessing administrative data, activities to link and analyze data, organizational capacity, and potential costs where possible.

The summary of findings from this data collection effort will be included in memos to inform ACF’s future research and technical assistance planning relevant to the antecedents and consequences of child maltreatment, strategies for prevention of maltreatment, and service needs and service outcomes for children who come to the attention of child welfare. Memos will discuss the experiences, successes, and challenges each site encounters as it executes its plan to link and analyze administrative data, as well as the findings on child maltreatment or related risk and protective factors.

Research Questions

This information collection will explore the following research questions:

1. What are promising methods or practices, within and across the sites, for using linked administrative data to inform the incidence of child maltreatment and related risk?

2. What contextual and organizational factors promote or impede enhancement or scaling of existing data linkages?

Study Design

The project team anticipates conducting three data collection tasks: semi-structured interviews with key informants from each of the six partnering sites; a brief questionnaire gathering information on the personnel and non-personnel resources sites use in completing their projects, administered quarterly; and document review. The document review does not impose any burden.

During site consultations and document review, the project team will discuss potential respondents for the key informant semi-structured interviews and questionnaire. Site consultations will provide an overview of the topics to be covered in data collection activities (Attachment 2). The project team will schedule two rounds of semi-structured interviews with respondents using an email (Attachment 1) describing the interview purpose and offering times for a meeting and requesting completion of a questionnaire on personnel and non-personnel resources. The email will include a project description (Attachment 3).

Universe of Data Collection Efforts

These are the descriptions of the three data collection tasks:

• Key Informant Semi-Structured Interviews (Appendix A). The project team anticipates conducting a semi-structured interview with 5 or fewer individuals from each of the partnering six sites, including site liaisons or principal investigators; administrators, directors, or managers at agencies or organizations that provide administrative data to the site; information technology or data managers; research staff; and legal staff. As mentioned above, site consultations and document review will help us identify the respondents for the semi-structured interviews. The semi-structured interviews will capture, for each site, information about the child welfare policy context; the capacity of participating organizations and quality of partnerships; the activities sites undertake to link and analyze administrative data; and factors that promote or impede the enhancement and scaling of administrative data linking related to child maltreatment. The project team will work with their site liaisons to coordinate the administration of the semi-structured telephone interviews with key informants and questionnaire in each site. The specific positions of respondents for the interviews are likely to differ among sites depending on the characteristics of participating entities. See Supporting Statement B for additional information about expected respondents. The project team will seek to identify people who fulfill similar roles across sites while tailoring the respondent group to each site’s organizational arrangements and plan. The protocol for the key informant semi-structured interviews (Appendix A) will not be administered in its entirety in each interview. Rather, in each of the two rounds of interviews, the project team will select and ask questions that are relevant to each respondent and the current implementation of the site’s project plan. The first round of semi-structured interviews is expected begin in the first quarter of 2019 (pending OMB approval) and the second round of semi-structured interview will begin a year later in 2020. For the second round of semi-structured interviews, the project team will select and ask questions from the protocol based on the respondent’s role in the project and the site’s progress in completing its plan.

• Questionnaire on Personnel and Non-Personnel Resources (Appendix B). This questionnaire requests information about the amount of time that staff from participating agencies and organizations spend on the CMI Data Linkages project and the value of goods or services that sites purchase to implement their projects (for example, expenses related to information technology or fees for data access or Institutional Review Board approval). The respondent will be the site liaisons or another individual with the most knowledge about the resources each site is using to implement its plan. The project team will seek a respondent in each site who is well positioned to respond given his or her role. The questionnaire will be administered once per quarter from the first quarter of 2019 through the second quarter of 2020.

• Document Review. The project team will also review site documents including project plans, interim report memos, final report memos, data sharing agreements; memoranda of understanding; descriptions of administrative data sets and data dictionaries; summaries of approaches to and results of data linkage; budget and expenditure summaries; summaries of findings; notes from site consultations; and products from cross-site learning network activities. This activity does not impose any burden on study participants.

A3. Improved Information Technology to Reduce Burden

The information that is the subject of this Generic Information Collection (GenIC), collected through semi-structured interviews and a questionnaire, provides opportunities to use information technology. Telephone conversations offer the best opportunity to tailor interviews to the specific site with the least imposed burden on the site (or partner). We will also audio record the semi-structured interviews to reduce burden. The questionnaire will be emailed to respondents, given its brevity and the small number of respondents. Respondents can either print the questionnaire, complete it on paper, and email a scanned copy of the completed questionnaire back to the project team, or they can complete an electronic copy and email the file back to the project team.

A4. Efforts to Identify Duplication

For this GenIC, the project team will not collect information from sites until it thoroughly reviews the relevant organizations’ websites and other available information (for example, documents discovered through the site selection process, documents shared through the cross-site learning network, or other publicly available information). The project team will not collect information directly from the sites that is available from existing sources.

This project will be collecting information that does not already exist in the field. An earlier effort of ACF to identify options for assessing the incidence of child maltreatment and related risk and protective factors, found that linking data to estimate child maltreatment incidence might be a promising approach. However, the field lacks information on the feasibility of this approach.

A5. Involvement of Small Organizations

This study might include small, nonprofit organizations. The project team will minimize burden for respondents by restricting the interview length to the minimum required and conducting interviews at times convenient for the respondents.

A6. Consequences of Less Frequent Data Collection

For this phase of data collection, ACF seeks to collect information that will inform the in-depth case studies and cross-case analyses that examine the process and results of efforts to use linked administrative data to research the incidence of child maltreatment and related risk and protective factors. This information will be collected over 18 months through regular calls with a site liaison and the administration of two rounds of semi-structured interviews and a brief questionnaire to selected respondents at each site. Document review may continue for another six months, for a total of 24 months. Collecting data throughout this period will allow the project team to document information over time and capture the experiences of sites as they work to complete their proposed project plans. Less frequent data collection may impact the accuracy and specificity of the project team’s findings.

Without collecting information according to this schedule, ACF will have an incomplete picture of the effort and challenges associated with using linked administrative data to understand the incidence of child maltreatment. This information is necessary to inform ACF about the practical feasibility of supporting these administrative data linkages and/or innovative analyses to gain a better understanding of child maltreatment incidence and related risk and protective factors and to inform the provision of future technical assistance.

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 the overarching generic clearance for formative information collection. This notice was published on October 11, 2017, Volume 82, Number 195, page 47212, and provided a sixty-day period for public comment. During the notice and comment period, no substantive comments were received.

Consultation with Experts Outside of the Study

A panel of experts comprising staff providing child welfare services, individuals conducting research with administrative data, and staff from ACF agencies have and will continue to consult with the CMI Data Linkages project team and OPRE staff beginning in spring 2018 and continuing throughout the project.

A9. Incentives for Respondents

No incentives for respondents are proposed for this information collection.

A10. Privacy of Respondents

As specified in the contract, the Contractor will protect respondent privacy to the extent permitted by law and will comply with all federal and departmental regulations for private information. The Contractor will 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. Respondents are not considered human subjects, but they will still be informed of all planned uses of data, that their participation is voluntary, that some of the information they provide will be shared with OPRE, and that any information they request to be kept private will be kept private to the extent permitted by law.

A11. Sensitive Questions

This data collection does not include any sensitive questions.

A12. Estimation of Information Collection Burden

The site’s point of contact will review materials and speak with the project team member about the project. These individuals will not incur any expense other than the time spent answering questions.

Table 1. Annual burden hours requested under this information collection (over the 3 year period of the umbrella generic)

Instrument	Total number of respondents over study	Number of responses per respondent	Average burden hours per response	Total burden hours over study	Annual burden hours	Average hourly wage	Total annual cost
Appendix A: Protocol for Key Informant Interviews	30	2	1.5	90	30	$57.44	$1,723.20
Appendix B: Questionnaire on Personnel and Non-personnel Resources	6	6	.5	18	6	$57.44	$344.64
Estimated annual burden total				123	36	$57.44	$2,067.84

Total Annual Cost

To estimate the total annual cost associated with the value of burden hours, the total burden hours were multiplied by the estimated average hourly wage for the site’s point of contact (Table 1). According to the Bureau of Labor Statistics’ Occupational Employment Statistics (2017), the annual mean wage, nationally, for postsecondary social science professors is $89,600. To calculate the number of hours postsecondary professors work in a year, we assume a 9-month rather than a 12-month contract to reflect postsecondary professors’ typical school year. As such, the annual salary represents 1,560 hours (2,080 × .75). Dividing the annual mean wage by the number of hours, the estimated mean hourly wage is $57.44.

A13. Cost Burden to Respondents or Record Keepers

There are no direct costs to respondents.

A14. Estimate of Cost to the Federal Government

The total cost for the data collection activities under this current request will be $553,459.20.

A15. Change in Burden

This is a new GenIC under the ACF/OPRE Formative Generic (0970-0356).

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

The information collected will serve primarily to document and analyze sites’ data-linking processes. Document reviews and site consultations will begin in quarter 4 (Q4) 2018. The project team will review cross-site learning products, conduct telephone interviews, and administer questionnaires from Q1 2019 to Q2 2020. Table 2 below provides a schedule of the data collection activities. The project team will begin site-specific and cross-site analysis in Q2 2020. The project team will use primarily qualitative methods to code and summarize information gathered from the sites, identify commonalities and differences among sites, and specify descriptive or explanatory themes regarding the study’s questions. The project team will be producing memos primarily for ACF, but some findings may be used to inform documents or presentations that may be made public to inform future research design or technical assistance efforts. As described earlier, the memos will share the experiences, successes, and challenges each site encounters as it executes its plan to link and analyze administrative data, as well as the findings on child maltreatment or related risk and protective factors that each site produces through its analysis.

Table 2. Data collection schedule for CMI Data Linkages project

Data collection activities	2018		2019				2020
	Q3	Q4	Q1	Q2	Q3	Q4	Q1	Q2
Document Review and Site Consultations								
Key Informant Semi-Structured Interviews							
Questionnaire of Personnel and Non-personnel Resources								

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.

REFERENCES

Fantuzzo, John, and Dennis P. Culhane. Actionable Intelligence: Using Integrated Data Systems to Achieve a More Effective, Efficient, and Ethical Government. New York: Palgrave MacMillan, 2015.

U.S. Department of Labor, Bureau of Labor Statistics. Occupational Employment Statistics. Washington, DC: U.S. Department of Labor, 2017