Justification for Nonsubstantive Change

DATE: March 22, 2024

TO: Daniel Cline, OMB Desk Officer

FROM: Joella Roland, HRSA Information Collection Clearance Officer

_____________________________________________________________________________

Request: The Health Resources and Services Administration (HRSA) requests approval for a non-substantive change to the Maternal and Child Health (MCH) Jurisdictional Survey (OMB #0906-0042, expires 04/30/2025). The survey consists of 1) a core MCH Jurisdictional Survey Questionnaire and 2) Jurisdiction-Specific Survey Questionnaires.

Purpose: The proposed non-substantive adjustment as outlined below will increase the survey’s sample size in Puerto Rico, Guam, US Virgin Islands, and the Republic of Marshall Islands. An increase in sample size will improve the precision of the data in all Jurisdictions. Many of the estimates for the National Outcome and National Performance Measures in the first two rounds of data collection maintained large confidence intervals, which means the estimates are not precise and must be interpreted with caution. An increase in sample size would help to remedy the problem.

Time Sensitivity: The MCH Jurisdictional Survey is planning for the third round of data collection for four Jurisdictions (Puerto Rico, Guam, US Virgin Islands, and the Republic of Marshall Islands) between October 2024 and January 2025. The proposed changes must be incorporated by August 2024, before data collection begins in October 2024, in order to incorporate an increase in sample size to improve data accuracy.

Burden: The original estimated survey completion time was 45 minutes and the increase in sample size would not increase the total burden per respondent.

However, increasing the sample size, as well as updating the number of screeners needed based on eligibility rates from previous rounds of data collection, does mean an increase in the overall burden hours. This is discussed in more detail below.

PROPOSED EDIT TO THE MCH JURISDICTIONAL SURVEY:

Currently, the number of surveys completed for each Jurisdiction is 250. Based on feedback from the jurisdictions, it is recommended to increase the sample size in each jurisdiction based on the population of children within that jurisdiction. Given the varying populations of children in each jurisdiction, the increased sample size varies for each jurisdiction. The sample size for Puerto Rico would increase to 1,250; the sample size in the Republic of the Marshall Islands would increase to 300; the sample size in the US Virgin Islands would increase to 300, and the sample size in Guam would increase to 450.

The increased burden of 1,300 additional responses in the four jurisdictions is offset by improving the utility of the data by the jurisdictions to inform program planning and monitoring. More precise estimates make it easier to detect statistically significant improvements over time.

The total number of burden hours would increase by 1479, from 2002 to 3481 (Appendix A). This burden estimate reflects the proposed increase in sample size, based on each jurisdiction’s population size, as well as adjustments to the number of screened respondents in each jurisdiction based on the eligibility rates from previous rounds of data collection (Appendix B).

Attachments:

Appendix A_Table 1

Appendix B_Table 2