Form 1 comments

Finalized by the Data Work Group 6/19/2012

Form 1
60-Day Federal Register Notice Public Comments
Table A: Unduplicated Count of Enrollees by Type and Primary Insurance Coverage
Comment
Date

Commenter

Comments

Response

Table A.1 Total Numbers Newly Enrolled and Served during reporting Period
1. Enrollees
3/12/2012
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table A.1: Enrollees
Please add a column – Total # enrolled to the left of the column Numbers Newly Enrolled.
Total Numbers of Enrolled, Newly Enrolled and Served During Reporting
Period
Total Number
Number Newly
Number Served
Enrolled
Enrolled
Enrollees
Index Children
Families
Table A.1: It is not clear how one would report “person or persons” for an unduplicated count. It would be
helpful to define unduplicated for this section and clarify all “persons” that can be included in this count.
Table A.1: Enrollees – is this everyone in the household including the index child?
Table A.1: Enrollees – is this everyone in the household including grandmothers, other children that local
programs have collected data on at any point in the program?

We did not add the suggested
column. We can obtain the
“total number enrolled” by
adding the count for the
“number newly enrolled” for
all reported years to avoid
adding reporting burden to
grantees.

We clarified in the form
instructions the persons to be
included within each
household or family enrolled.
The “enrollee” category
excludes index children. The
“enrollee” category only
includes those individuals in
the household who have
signed up to participate in
the program. Index children
or other children in the
1

3/30/2012

Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov)

5/1/2012

Brighton Ncube

2. Index Children
3/30
Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov)

3. Families
4/5/2012
Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]
4/16/2012

Laura DeBoer, MPH

Table A1: Definitions need to be inconsistent (sic) with the terms/definitions that the evidenced-based
models use model definitions in order to fit together.

Under Table A1: You may decide if it will be important to add a column that shows year to date totals or
statistics.

household are not included in
the enrollee category.
The minimum data collection
required, which involves data
on the enrollee and the index
child for each household is
consistent with the practices
of the evidence-based
models.
The columns “Numbers newly
enrolled” and “Numbers
served” show statistics
related to the reporting
period which is one year.

Table A1: If the target child is not living with the biological mother, do states count that child as the index
child (the definition states that the index child is “the target child in an individual household” (What about
children in the hospital or foster care?)

We clarified the definition of
index child in the
instructions. Since the
identification of the index
child is dependent on the
caregiver voluntarily enrolled
in the program, an index child
could be in a hospital or in
foster care. The primary
caregiver enrolled in the
program need not be the
biological mother.

Section A
Define “Family.” Does family encompass the “enrollee?” Would enrollee = family?

We clarified in the
instructions what persons
need to be counted at a
minimum to constitute a
household or family for
purposes of data collection.

Table A.1: Families – perhaps households is more appropriate with a clear definition. Families can be

2

Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

more difficult to define

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

Section A, Table 1A: Does the family include the enrollee and index child

3/12/2012

CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us

Table A.1- Families
Please clarify what is meant by “Families”.

3/30

Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov)

Table A1- A definition for family is needed. A definition has not been provided for Table A.1.

Household and family are
equivalent concepts in this
context. A family or
household encompasses the
enrollee(s) and must include
at least one enrollee and one
index child(ren).

3

Comment
Date

Commenter

Comments

Response

Table A.2 Enrollees: Insurance Status
1. Enrollees: Insurance Status
3/23
Dianna Frick (MT)
Lead Maternal and Child Health
Epidemiologist
Family and Community Health
Bureau
Public Health and Safety Division
Montana Department of Public
dfrick@mt.gov

Table A.2
We suggest combining the “Biological Mothers” and “Other Female Caregivers” categories into a
“Female Caregivers” category. There does not appear to be any particular purpose for having a separate
category for biological mothers or for requiring programs to report the information. Biological fathers
are not a separate category from other male caregivers. Other types of female caregivers and their
insurance status may have just as much influence on a child’s health and well-being as the insurance
status of a biological mother. Combining the “Biological Mothers” and “Other Female Caregivers”
categories into a “Female Caregivers” category will reduce the data collection and reporting burden to
home visiting sites and states and result in more consistent and high quality data about caregivers.

4/16/2012

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

Table A.2.
We use the State’s public health information database (SPHERE) to record data related to our MIECHV
grant activities. Currently, SPHERE is not set up to differentiate between biological mother enrollees and
other female caregiver enrollees. Through SPHERE, we record the sex of the enrollee and whether the
enrollee is pregnant. We could make changes to SPHERE to capture this information; however, we do not
want to make changes unless they are necessary, or we feel the changes would provide us, our sites, or
HRSA with very useful information. While we see value in better understanding who caregivers are, and
better understanding household composition, in general, we are trying to balance our desire for
additional information with our sites’ data collection burden.

3/23

Dianna Frick
(MT)
Lead Maternal and Child Health
Epidemiologist
Family and Community Health
Bureau
Public Health and Safety Division
Montana Department of Public
dfrick@mt.gov

Table A.2- If an individual identifies themselves as having insurance coverage through the Indian Health
Service (IHS), should we include them in the “No Insurance Coverage” category or the “Private or Other”
category? We suggest that you clarify the guidance for this item, which will increase the quality and
consistency of the information collected.

We agree and have subsumed
the “Biological Mothers” into
the “Female Caregivers”
category. We have retained
the distinction between
pregnant women and other
female caregivers. The
distinction between pregnant
women and female caregivers
is justified since the legislation
identifies pregnant women
less than 21 years as a priority
population.

We clarified in the instructions
that receipt of care through
the IHS or other safety net
provider such as a Federally
Qualified Health Center does
not constitute insurance
coverage.

4

3/30

3/30

4/16/2012

4/16/2012

4/16/2012

Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov)
Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov)
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table A.2. - An “armed forces” (Tri Care) health insurance category is needed given that families in the
armed forces are a priority MIECHV population. If a specific option is not provided for health insurance
(Tri-Care) for those in the armed forces, how should states report on this insurance type? Should it be
reported under the “private or other” category?

We added a column to include
Tri-Care given that families in
the armed forces are a priority
population.

Table A.2. - A “public/private” health insurance category is needed to capture health insurance
programs where there is an employer/Medicaid cost share of premiums (e.g. Rhode Island’s RIte Share
Program).

Public/private insurance
arrangements should be
included under the “Private or
Other” category.

Table A.2: Pregnant women and Biological mothers – please clarify the information to be reported here
is collected at intake

We clarified that the
information for all newly
enrolled caregivers should be
collected at intake and
annually thereafter.

Table A.2: Male Caregivers – why are (aren’t?) biological fathers considered a separate category of male
caregivers to mirror the biological mothers and other female caregivers, especially given the National
Fatherhood Campaign? Please clarify how to provide an unduplicated count of male caregivers when
there might be both a biological father and a foster father included in the home visiting program

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table A.2: Insurance Status – In the Programmatic Letter dated 1/30/2012, HRSA clarifies “Grantees must
report the health insurance status of all participates in the program or, at a minimum, of the index child
and the primary enrolled adult.”

We considered this comment
above and have subsumed the
“Biological Mothers” into the
“Female Caregivers” category.
Because we combined
categories, it is not necessary
to separate out male caregiver
categories to mirror female
caregivers.
Insurance information is
required for all enrollee(s) and
the index child.

Please clarify in instructions the “unduplicated count” for persons with no insurance information in the
enrolled family.

“Unduplicated” means that
the same person is not
counted twice. If a foster
father and a biological father
are enrolled in the program,
5

4/16/2012

Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]

Table A.2 – Enrollees’ Insurance Status
When is the status to be measured – at the beginning or end of the reporting period?

4/16/2012

Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]
Marisa D. Wang,
ACA Tribal Home Visiting
Program Project Director
Planning & Grants Department
Southcentral Foundation
4501 Diplomacy Dr., Ste 200
Anchorage, AK 99516
Telephone: (907) 729-4996
Fax:(907) 729-4997
E-mail: mwang@scf.cc

Table A.2 – Enrollees’ Insurance Status

Brandi Smallwood

Table A.2 – Enrollees: Insurance Coverage

5/1/2012

5/2/2012

There could be a mixture of publicly and privately funded programs included under the column heading,
“Private or Other.” Armed Services/Veterans insurance programs might be included here by some states,
as well as programs whose Title XIX/XXI funding stream is not clear to staff, such as city, country, and/or
non-profit-funded programs. It doesn’t seem informative/helpful to include these programs with
“Private” insurance programs
In Table A.2 #3, there are hash marks across the cell, which is confusing, should the data be reported or
not. If not, we recommend deleting it from the form. If so, remove the hash marked row and have
programs report to the side

the unduplicated number of
male caregivers for that index
child would be 2.
Insurance status for
participants enrolled during
the reporting period (“newly
enrolled”) should be collected
at intake or shortly thereafter.
Insurance information about
participants served during the
reporting period but
previously enrolled should be
collected roughly one year
after enrollment and annually
thereafter.
We included a separate
column for Tri-Care/VA
insurance programs.
public/private insurance.

The hash-marked area was
removed to clarify that
programs need to report this
information.

We clarified in the instructions
6

Better Beginnings ~ Chahta
Inchukka
Tribal Maternal, Infant and Early
Childhood Program
Director
Choctaw Nation of Oklahoma
Phone: 580-326-8304
Fax: 580-326-0115
bsmallwood@choctawnation.co
m
2. Index Children: Insurance Status
4/16/2012
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
4/16/2012

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

In regards to the Choctaw Nation of Oklahoma, all Native Americans can receive medical care including
but not limited to prenatal care, dental, family practice, labs and prescriptions through the Choctaw
Nation Health Service Authority. Native Americans who are not covered by private health insurance
often do not see a need to pursue other means of insurance as they rely on their Native American
heritage to provide them with what they feel is adequate healthcare coverage.

that receipt of care through
the IHS or other safety net
provider such as a Federally
Qualified Health Center does
not constitute insurance
coverage.

Table A.2: Insurance Status Title XIX and Title XXI – in Idaho, Title XXI (CHIP) families do not apply for
SCHIP as a separate program from Title XIX (Medicaid). Families enrolled in Medicaid will likely not know
if they are enrolled in Title XIX or Title XXI as there are no practical differences in the programs. Title XXI
is an expansion of Title XIX from 133% FPL to 185% FPL

We combined title XIX and XXI
into one column.

Table A.2.
In Wisconsin, health insurance benefits through Titles XIX and XXI are combined under the State’s Badger
Care Plus program. It would be difficult for us to separately report on these two categories. We could
report under one of the two categories and add a footnote explaining that enrollees covered by both
Title XIX and Title XXI are included in the figure. HRSA might also consider combining the Title XIX and XXI
columns in this table.

7

Table B: Enrollees and Children: Selected Characteristics by Ethnicity and Race
Comment
Date

Commenter

Table B Race and Ethnicity
4/5/2012
Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]

3/12/2012

Comments

Table B.4.Ethnicity and race: Some clients may report race and not report ethnicity, or vice versa. If only
one is reported, would the client automatically be “unknown/did not report” even though we have one
aspect collected.

Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

Section B, Table B: Is the unknown/did not report for both race and ethnicity or both.

Dianna Frick
(MT)
Lead Maternal and Child Health
Epidemiologist
Family and Community Health
Bureau
Public Health and Safety Division
Montana Department of Public
dfrick@mt.gov
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us

Table B- Is the “Unknown/Did Not Report” column for both race and ethnicity? We recommend having
one “Unknown/Did Not Report” category for ethnicity, and a separate “Unknown/Did Not Report”
category for race. Some families may report ethnicity but not race, or vice versa. Having one
”Unknown/Did Not Report” category that combines race and ethnicity date will result in more people
with unknown data and less useful data overall.

Table B- Race and Ethnicity Table- comments:
 Consider changing Ethnicity to Hispanic or Latino only and delete Hispanic or Latino and Non Hispanic or Latino columns.
 Consider changing Race to Non-Hispanic only and keep categories American Indian through
White.
 Consider making a separate column for More than one category selected.
 No changes to Unknown/Did Not Report

Response

We added an “unknown/did
not report” category to the
form for both the ethnicity
and race categories.

No changes were made to
preserve compliance of
categories with the OMB
standards for data collection
on race/ethnicity.
We substituted the “More
8

1- People who consider themselves to be Hispanic or Latino regardless of race. 2- People who
consider themselves to be Non-Hispanic and one race. 3- People who consider themselves to be
of mixed race and/or ethnicity.
Hispanic Race / Non-Hispanic Ethnicity
More
Unkno
Ethnicity (2)
than
wn Did
(1)
one
Not
catego Report
ry
Selecte
d
(3)
(All
Americ Asian Black or Native Whi
Races)
an
African Hawaii te
Indian
Americ an or
or
an
Other
Alaska
Pacific
n
Islande
Native
r

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

4.
Enrollees
Pregnant
Women
etc.
Section B Table B: Is it necessary to cross-tabulate or stratify all of the enrolled persons by race and
ethnicity or are the primary caregiver and index children sufficient?

than one race” category for
the “more than one category
selected”. This heading is
compliant with OMB
standards.

The table and instructions
indicate that race/ethnicity
data should be collected for all
“enrollees” with the specific
categories provided (ex.
pregnant women,
female caregivers, and male
caregivers) and the index
child(ren). Enrollees should
include at a minimum the
primary caregiver of the index
9

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

Section B, Table B: The guidance indicates the total for ethnicity should equal the total for race; this may
not occur if the client is self-seeking

4/16/2012

Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]

Table B – Enrollees and Children Selected Characteristics by Ethnicity and Race

Comment
Date

Commenter

Table B.4 - Enrollees
3/12/2012
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us
4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

It would be helpful if the instructions for this table were for respondents to answer in both categories
(ethnicity and Race)

Comments

Table B – Pregnant Women/Biological Mother
Instructions- Also, please add more clarity to the difference between biological mothers and pregnant
women by adding something like “whether or not she is caring for another child who is in the program
as an index child “.

Table B: 4. Per enrollee – are there cases in which there might be multiple females or males per enrolled
family? Is this table to be completed for only the primary female and male caregivers?

child.
Total numbers for ethnicity
and race should equal the
total numbers of enrollees
served and will be
automatically calculated by
DGIS.
We clarified in the instructions
that data should be collected
on ethnicity and race.

Response

We combined the category
“Biological mothers with
“Female Caregivers”. We
revised the instructions to
reflect the simplified
categories.
The instructions define
enrollee(s) as the person or
persons who signed up to
participate in the home
visiting program. The category
can include more than one
member of the household if
more than one individual is
10

4/13/2012

Comment
Date

Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

Commenter

TABLE B.5 Enrollees: Marital Status
3/12/2012
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us

4/16/2012

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

Section 1, Table 1B: is the insurance, etc. data self-report?

enrolled in the program (e.g.,
multiple female or male
caregivers).
Data collection on insurance
may be self-reported.

Comments

Response

Table B- Enrollees: Marital Status- Please consider whether this indicator is really necessary. If so please
consider eliminating “Cohabitating/Living with Significant Other”. Please keep the “Unknown” category.
“Cohabitating/Living with Significant Other” seems somewhat intrusive however if this is a common
question in ACF or HRSA databases…..

Marital status is one factor
considered in relationship to
child outcomes, therefore was
retained in the data set. To
make categories mutually
exclusive, we removed the
“cohabitating/living with
significant other” category.
The “unknown, did not report”
category will remain.

Table B
We see the most value in indicating whether the enrollee is single and cohabitating; however, there are
some questions re: whether families will want to record this, as it may affect benefit receipt.

We changed the “single”
category to “Never married”
and removed the
“cohabitating/living with
significant other” category.
Categories are mutually
exclusive and should produce
an unduplicated count.

It seems, too, that the categories here would not produce an unduplicated count of enrollees (i.e., if
someone is widowed and not remarried, s/he is also “single.”). Is the intention that single means “never
married”? If such detailed categorization is necessary, perhaps married/single should be separated, then
“if single” leads to the other categories—separated, divorced, widowed, cohabiting, etc. Alternatively,
HRSA might consider adjusting “single” to read “single, never married”

11

4/16/2012

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

Table B
B.5., Marital Status:
Currently, SPHERE includes three marital status fields: single, married, and unknown. While we see
potential value in obtaining more detailed marital status information, we question whether the cost,
labor and training needed to implement such detailed categories in our data system and home visiting
practice will yield truly useful information.

4/16/2012

Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]
Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]

Table B.5 – Enrollees’ Marital Status

4/16/2012

Comment
Date

Commenter

Is it of interest whether she is living with the father of the index child? The father could be her husband,
or her significant other (or neither).

Table B.5 – Enrollees’ Marital Status
Could the row categories be defined more specifically? Enrollees may fit into more than one of these
categories as they appear now. For example, a woman may be separated from her husband, and living
with a significant other. How would this be entered?

Comments

The categories provide
important information about
family supports, including who
could be involved in home
visits. We revised the
categories however to make
them mutually exclusive and
eliminated the
“cohabitating/living with
significant other” category.
The intent of this variable is to
record the marital status of
the enrollee, not whether the
enrollee is married to the
father of the index child or
some other person.
Data are self-reported,
therefore the data should be
entered according to the
category selected by the
enrollee. We revised the
marital status categories to be
mutually exclusive.

Response

Table B.6 & B.7: Educational Attainment
3/12/2012

CT Dept of Public HealthMargie Hudson, Carol Stone

Table B 6. and B.7- Educational Attainment
– suggest eliminate “High school eligible, not enrolled” and combine “HS diploma with GED to become”

There are significant
differences between the
12

3/23

4/16/2012

4/16/2012

4/16/2012

Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us

HS diploma or GED”.

Dianna Frick
(MT)
Lead Maternal and Child Health
Epidemiologist
Family and Community Health
Bureau
Public Health and Safety Division
Montana Department of Public
dfrick@mt.gov

What does “High school eligible, not enrolled” mean? Does the eligibility refer to the age of the
enrollee? We have varying requirements and eligibility guidelines among the high schools in our
state. An enrollee may be under 18 and have dropped out of high school but not be “eligible” to reenroll in their local high school for a variety of reasons. We would include an enrollee in this situation in
the “Less than HS diploma” category, since finding out each enrollee’s eligibility to re-enroll in their local
high school is unrealistic. We suggest removing the “High school eligible, not enrolled” category or
clarifying who should be included which should improve the quality and consistency of the information
reported.

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]
Kristen Rogers, PhD (CA)
CA Home Visiting Program
Branch
CA Department of Public Health
Maternal, Child & Adolescent

example, a teenage mother is 16 years of

There appears to be a risk of double counting; someone who is currently enrolled in high school could
also be reported in the “Less than HS diploma” category. HRSA might consider adjusting the “Less than
HS diploma” category to read “Less than HS diploma, not HS eligible” and provide a definition of this
category in the form instructions (although, technically, anyone at any age can get a GED—how would
this be defined?).

Presumably, the row headings are hierarchical, i.e., if a client is both “High school eligible, not enrolled”
and “Less than HS diploma” she/he should be entered under the one that comes first. It would be helpful
if this were made more clear.

It is implied that “Vocational School/Technical Training” means attainment only, to the exclusion of
clients who may be currently enrolled in such a training. It would be helpful to have this clarified, and/or
to add an “enrolled” category.

categories. We therefore
retained but revised the “high
school eligible, not enrolled”
category and the
corresponding instructions.
We also retained HS diploma
and GED as separate
categories since they are
associated with different
outcomes.
We revised the categories to
be more distinct, mutually
exclusive, and hierarchical.
“Of high school age, not
enrolled” includes those
individuals who are of high
school age, and are not
currently enrolled in school.
For example, a teenage
mother is 16 years of age and
could be enrolled in high
school, but has not finished
her HS education.
“Less than high school
diploma”, includes individuals
who are not of high school
age, who did not complete
their high school education.
For example, a 23 year old
mother who did not finish her
education would be included
in this category because she is
13

Health Division
[Kristen.Rogers@cdph.ca.gov]
4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table B: 6. Female Enrollees Educational Attainment – are these exclusive categories? There may be
many instances when a female caregiver might be eligible for both categories of: “less than a HS
diploma” and “High school eligible, not enrolled.” Please provide clarification on which category would
be appropriate for instances such as: a sixteen-year-old mother who has dropped out of high school and
then enrolls in the home visiting program.
Table B.7: Male Enrollees Educational Attainment – all comments related to Table B.6 Female Enrollee
Educational Attainment apply to Section B.7
Table B.6: Female Enrollees Educational Attainment Vocational School/Technical Training – it is
becoming increasingly more difficult to distinguish between community college, online college, online
training and vocational school/technical training in the current post-secondary education environment

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table B.6: Female Enrollees Educational Attainment Other” – please provide an example or clarification
of when reporting and other is appropriate

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table B: 6. Female Enrollees Educational Attainment - Does this include only the primary female
caregivers? Please clarify if the information included in this section should only come from one of the
following categories (pregnant Women, Biological Mothers, and Other female Caregivers)

not of high school age and did
not finish her HS education.
We revised the “some college”
category to “some
college/training”. This
category includes those
individuals currently enrolled
in vocational or technical
school.

Data are self-reported,
therefore the data should be
entered according to the
category selected by the
enrollee. The type of
training/level of degree rather
than the method of delivery
should guide the category
selection.
“Other” would include any
type of education that would
not correspond to any of the
other categories. For example,
a teen mother in middle
school would fall into this
category.
Data should be provided for all
female enrollees in the
program. If more than one
female is enrolled in the
program (e.g. teenage mother
and grandmother), data
should be provided for both.
14

Comment
Date

Commenter

Comments

Table B.8 & B.9 – Female Enrollees: Age (in years)/Male Enrollees: Age (in years)
4/16/2012
Laura DeBoer, MPH
Table B.8: Female Enrollees Age (in years) – Does this include only female caregivers? Please clarify which
Idaho Department of Health and female enrollees are including in this count
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
4/16/2012

Comment
Date

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
Commenter

Table B.9: Male Enrollees Age (in years) – Please further define “Male Enrollees” and “Make Caregivers”
as there is inconsistency in terminology used throughout Form 1 (Enrollees, Families, Caregivers)

Comments

Table B.10 – Female Index Children: Age (in years) & Table B.11 – Male Index Children: Age (in years)
4/5/2012
Cynthia Suire, DNP, MSN, RN
Table B.10 and 11.Female and Male Index child: For programs in which all enrollees enter before children
MIECHV Program Manager
are born, would there be anything to report here? Or, do we count the index child of the enrollee who
Louisiana DHH-OPH-MCH
was enrolled during the pregnancy?
[Cynthia.Suire@LA.GOV]

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP

Table B.10 and B.11: Female and Male Index Children Age (in years) – Reporting would likely be easier if
the age categories were in months instead of years. Additionally, there should be more than three age
categories, perhaps the following would be more appropriate: (0-12 months, 13-24 months, 25-36
months, 37-48 months, 49-60 months, and 61-72 months).

Response

Data should be provided for all
female enrollees in the
program. If more than one
female is enrolled in the
program (i.e. teenage mother
and grandmother), data
should be provided for both.
We clarified the meaning of
enrollee in the instructions.
There is only one category of
male enrollees.

Response

Children born to women who
were pregnant upon
enrollment
are counted as “index
children” in the following
reporting year.
We did not modify the age
categories. To reduce burden,
response categories were
limited to three. The response
categories can easily be
15

[DeboerL@dhw.idaho.gov]

Comment
Date

translated from months into
years based on the
instructions provided.

Commenter

Comments

Response

We removed this variable.
Data should be collected on
those individuals enrolled in
the program (index child and
caregivers participating in the
home visiting program).

Table B.12 – Additional Children (Birth – 18 years old) Living in the Home
3/29

Angela Ward
(UT)
Office of Home Visiting
Utah Department of Health
award@utah.gov

Table B-12 asks for race and ethnicity information on “Additional Children.” Currently we are only
collecting information on the index child. Subsequent children may become an index child however, for
school age or older children that are non-index children there is no mechanism in our database to collect
this information. The home visiting programs are not impacting or tracking non-index children.

4/5/2012

Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]

Table B.12.Additional Children: The models do not collect this information and the extra data collection
will be quite burdensome. This collection/analysis is not built into any present state data system.

4/16/2012

Tom Hinds (WI)
Home Visiting Performance
Planner
[Thomas.hinds@wisconsin.gov]

B.12. Currently, our sites do not necessarily record information in SPHERE on family members other than
enrollees and index children. We anticipate collecting this type of information in the future, but have not
prioritized this. We have been focusing on adjusting SPHERE and site data collection practices to be able
to meet our federally approved benchmark reporting requirements. We may have missing data under
B.12. in our initial reports.

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Table B.12: Additional Children (Birth-18 years-old) Living in the Home – Please provide clarification of
these are required fields and updated annually. Additionally, there should be more than four age
categories such as the following (under 1 year, 1-2 years, 3-5 years, 6-12 years, 13-18 years)

OTHER
16

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Section B, Table B 4-12: Please provide more clarification to states to complete this table. For
example, is race and ethnicity required to be completed on each row?

Table B: Total –Should the “total row” be equivalent to the “total enrollees” in Table A.1 or should states
expect there to be discrepancy if all this information is not collected on other household/family
members?

Yes, data are required for each
variable (row) in the table.
The instructions clarify the
categories and that ethnicity
and race should be reported
for each category. The DGIS
will require counts for each
field in every table, including a
“0” where appropriate.
Yes, the total row should be
equivalent to the total
enrollees in Table A.1. We
revised the instructions. Data
should be collected on those
individuals enrolled in the
program (index child and
caregivers participating in the
home visiting program).

Table C: Socioeconomic Data
Comment
Date

Commenter

Table C.1: Family Relationship to Poverty Level
3/12/2012 CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us
3/23
Dianna Frick (MT)
Lead Maternal and Child Health
Epidemiologist

Comments

Response

Table C.1 - Please add “of Families” to “Number” = “Number of Families” for clarity.

We revised the column header
to be “Number of Families.”

Table C.1
There is no category to report families who have an income of 301-399% of the federal poverty
level. We recommend including another category or revising the existing categories so that

We revised the categories and
added a new category for all
families with income above
17

3/29

3/29

3/30

Family and Community Health Bureau
Public Health and Safety Division
Montana Department of Public
dfrick@mt.gov

information can be accurately reported.

Becky Berk (NH)
Integrated Quality Improvement
Director
NH Children's Trust, Inc.
www.nhctf.org
bberk@nhchildrenstrust.org
Angela Ward (UT)
Office of Home Visiting
Utah Department of Health
award@utah.gov

1. There is an error in Section C, Table C.1. Question 13. There is no category that captures poverty
level between 301 and 400% of poverty. The categories should be redefined to include this range, or
this range should be added as a new line.

Cheryl LeClair (RI)
Comments from the Rhode Island

Table C.1. A definition of “family relationship to federal poverty level” is needed (are states reporting
the mother’s income or the family’s income and what is the criteria for counting the family’s income?

Section C asks for socioeconomic data to be reported in relationship to Federal Poverty Level. There is
concern that the need to collect information on the entire household will be detrimental to the home
visitor’s relationship with the individual enrolled in the home visiting program. Currently home visiting
programs are not gathering income information for the entire household. This would be a change and
require multiple changes in data collection and data base structure. There is also some concern that
this data may not accurately reflect the visited family’s relationship to the Federal Poverty Level. The
household for the definition of benchmark collection may be different than the household definition
for poverty level. The definition of households will vary across state programs.

300% of FP level.

We issued a Programmatic
Letter, dated January 10,
2012, and clarified the
definition of household for
reporting purposes.
"Household includes the
person(s) enrolled in the
home visiting program funded
by MIECHV. At a minimum,
grantees should collect
information on the enrollee(s)
in the home visiting program.
The category can include more
than one member of the
household if more than one
member is enrolled in the
program, participates in home
visits, or otherwise
contributes to the support of
the index child or pregnant
woman."
These definitions apply for
18

Department of Health
Email: cheryl.leclair@health.ri.gov

For example, what if the father is present only intermittently?).

both socio-economic data and
benchmark reporting.

4/13/2012 Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
Tom.Jenkins@nursefamilypartnership.or
g

Section C, Table C1: “Family” needs to be defined. In NFP, the “family” is defined as the client and
indexed child

We revised the categories and
added a new category for all
families with income above
300% of FP level.

4/16/2012 Tom Hinds (WI)
Home Visiting Performance Planner
Thomas.hinds@wisconsin.gov

Table C.1., Family Relationship to Federal Poverty Level
Our approved benchmark performance measure is "Percentage of households served by the program
who report an increase in total household income and other sources of cash support between month
of enrollment and 12-months post-enrollment." After consultation with our sites’ staff, we
constructed questions that get at a family's net income and allow household to be defined by the
enrollees. Sites’ staff strongly felt that this information was most relevant to families and to home
visitors working with families to budget, meet monthly expenses, etc., and more likely to be accurate,
compared to estimates of gross income.

4/16/2012 Tom Hinds (WI)
Home Visiting Performance Planner
Thomas.hinds@wisconsin.gov

Table C.1., Family Relationship to Federal Poverty Level
This table asks us to report income relative to the federal poverty level, which requires collecting gross
income and using a specific definition of household. “Federal poverty level” implies a technical
definition that is used for eligibility for a number of benefit programs, and we do not expect home
visitors to acquire this specific information. Can we use net income and our definition of household for
reporting under Table C.1.? Or would it be possible to provide sites with a procedure to roughly
estimate where families fall in terms of the Table C.1. categories if sites are obtaining net income? If
we are not tied to the federal poverty level definition (or maybe even if we are tied to the definition),
HRSA may wish to change the table title to read “Estimated Family Relationship to Federal Poverty
Level” and provide some guidance in the instructions regarding what is and is not acceptable when
estimating. Also, as currently listed in Table C.1, there is no reporting category for 301-400%.

5/2/2012

Table C.1 – Additional information will be necessary to adequately determine the category each family
should be placed in and how to correctly derive the correct income level to calculate this measure.

Brandi Smallwood (OK)
Better Beginnings ~ Chahta Inchukka
Tribal Maternal, Infant and Early
Childhood Program Director

19

Choctaw Nation of Oklahoma
Phone: 580-326-8304
Fax: 580-326-0115
bsmallwood@choctawnation.com
3/30
Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email: cheryl.leclair@health.ri.gov
3/30
Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email:cheryl.leclair@health.ri.gov
4/16/2012 Laura DeBoer, MPH(ID)
Idaho Department of Health and
Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov

4/16/2012 Laura DeBoer, MPH (ID)
Idaho Department of Health and
Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov
4/16/2012 Laura DeBoer, MPH (Id)
Idaho Department of Health and
Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov
4/16/2012 Laura DeBoer, MPH (ID)
Idaho Department of Health and

Table C.1. Why wouldn’t there be a category for “100% and under”?

Table C.1. The table should include an “unknown/did not report” category rather than the current
“unknown” category.

Table C.1 Family Relationships to Federal Poverty Level – in most cases, programs will be collecting
numeric data on income, not income according to FPL ranges

Table C.1 Family Relationships to Federal Poverty Level – It would be helpful to include a table of FPL
and household in the instructions

We added two categories: 1)
under 50% and 2) 51-100%
and revised the under 133%
category to be 101 to 133%.
We added “unknown/did not
report” to the table.

Household gross income and
the number of family
members are required data to
determine the household
income in relation to the
Federal Poverty Guidelines.
We added the link to the
Federal Poverty Guidelines in
the instructions, which
describes the process.
We added the link to the
Federal Poverty Guidelines in
the instructions.

Table C.1 Family Relationships to Federal Poverty Level – Please clarify if the income should be
reported on family gross or net income

We clarified in the instructions
that gross income should be
reported.

Table C.1 Family Relationships to Federal Poverty Level – Nurse-Family Partnership documents family
income in the following ranges, it may be difficult to re-categorize this information to provide data for

Household income ranges in
relation to poverty guidelines
20

5/2/2012

Comment
Date

Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov

Table C.1:
1. Less than or equal to $6,000
2. $6,001 - $9,000
3. $9,001 - $12,000
4. $12,001 - $16,000
5. $16,001 - $20,000
6. $20,001 - $30,000
7.
Over $30,000

Marisa D. Wang, (AK)
ACA Tribal Home Visiting Program
Project Director
Planning & Grants Department
Southcentral Foundation
4501 Diplomacy Dr., Ste 200
Anchorage, AK 99516
Telephone: (907) 729-4996
Fax:(907) 729-4997
E-mail: mwang@scf.cc

Table C.1. 13, the Federal Poverty Level break outs are challenging, because the 134%-250% range will
include those that do and do not qualify for Medicaid, WIC and other programs. Most break-off points
are under 200%, so the relationship to Federal Poverty indicators will be hard to ascertain for that
category.

Commenter

Table C.2: Enrollees: Employment Status
3/29
Becky Berk (NH)
Integrated Quality Improvement
Director
NH Children's Trust, Inc.
Prevent Child Abuse NH
www.nhctf.org
bberk@nhchildrenstrust.org
3/30
Cheryl LeClair (RI)
Comments from the Rhode Island

Comments

are informative. The number
of individuals in the enrollee’s
household could be cross
tabulated with gross income
of those individuals. A
consistent methodology
should be applied to recategorize data based on
income ranges.
We clarified the instructions
to include the household
income in relation to the
Federal Poverty Guidelines.
This variable asks for the
household income in relation
to the Federal Poverty
Guidelines and does not ask
for eligibility for other
programs.

Response

Table C.2 Education/Training Status
There is a discrepancy between the tables on age of enrollees (tables 8, 9, 16) and the tables on
educational attainment (tables 6 and 7). Since the data collection of age starts at age 10, these enrollees
may be attending middle school (or even elementary school), yet HS enrollment is the only choice.

Those participants attending
elementary or middle school
should be included in the
“Other” category under
educational attainment.

Table C.2. - Definitions for “Employed Full-Time” and “Employed Part-Time” are needed.

The Department of Labor does
not provide a definition of full
21

Department of Health
Email: cheryl.leclair@health.ri.gov

3/30

Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email: cheryl.leclair@health.ri.gov

Table C.2. - Definitions for “Enrolled Full-Time” and “Enrolled Part-Time” are needed.

3/30

Cheryl LeClair (RI)
Comments from the Rhode Island
Department of Health
Email: cheryl.leclair@health.ri.gov
Cynthia Squire, DNP, MSN, RN (LA)
MIECHV Program Manager
Louisiana DHH-OPH-MCH
Cynthia.Suire@LA.GOV

Table C.2. - The table should include “unknown/did not report” categories rather than the current
“unknown” categories under both Employment Status and Education Status.

4/5/2012

“

Laura DeBoer, MPH (ID)
Idaho Department of Health and
Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov
4/16/2012 Kristen Rogers, PhD (CA)
CA Home Visiting Program Branch
CA Department of Public Health

Table C2.14. Model data system does not collect employment information in this manner, particularly
“not employed” vs. “unemployed.” Current data system collection will have to be altered to
accommodate and model may or may not change their data collection. Again, the state would have to
add an additional data collection method-a cost and burden not anticipated with present resources.
Table C.2 Enrollees: Employment Status Not Employed – Please clarify the if the categories listed in
parenthesis (student, homemaker, disabled, other) of just examples or grantees will be expected to
report on these categories for reason the care

Table C.2 – Enrollees’ Employment Status and Enrollees’ Education/Training Status
Having only one category for part-time employment and/or education means that enrollees working 35
hours/week are aggregated with those working 1 hour/week

or part-time employment.
http://www.dol.gov/dol/topic
/workhours/full-time.htm.
Grantees have discretion to
define “employed full time”
and “employed part time” for
purposes of this data
collection.
We changed the word
“enrolled” to
“student/trainee” in table
C.2., item 14 to avoid
confusion with home visiting
program enrollment. We
consolidated the full- or parttime student/trainee
categories into one.
We changed the category
“Unknown” in table C.2, items
13 and 14 to “Unknown/did
not report”
We eliminated the
unemployed category and
limited the main categories in
this table to employed (part or
full time) and not employed.
We clarified in the instructions
that these are examples and
removed them from the table
to avoid confusion.
The Department of Labor does
not provide a definition of full
or part-time employment.
22

Maternal, Child & Adolescent Health
Division Kristen.Rogers@cdph.ca.gov

4/16/2012 Tom Hinds (WI)
Home Visiting Performance Planner
Thomas.hinds@wisconsin.gov

4/16/2012 Tom Hinds (WI)
Home Visiting Performance Planner

http://www.dol.gov/dol/topic
/workhours/full-time.htm.
Grantees have discretion to
define “employed full time”
and “employed part time” for
purposes of this data
collection.

Table C.2.14., Employment Status
Our approved benchmark measure related to employment is “Percentage of households served by the
program who increase total weekly hours of paid employment for household members between month
of enrollment and 12-months post-enrollment”. We developed this measure to capture a more holistic
approach to supporting the family; incomes of "all" household members are included a) to begin to
provide some information about fathers and other family members who provide support; and b) because
we may not expect mothers enrolled prenatally to be working much at 12-months post-enrollment.

We consolidated the full- or
part-time student/trainee
categories into a single
category of “student/trainee”.
Reporting on benchmark data
collection plans and their
individual performance
measures is distinct from
demographic and service
utilization data reporting
under this form.

C.2.14. asks for employment status only for enrollees and in a very specific (different) way (full time or
part time). We would need to make significant adjustments to SPHERE and home visiting practice to

Grantees must include at a
minimum the caregiver of the
index child enrolled in the
program. In general, socio
demographic information
required for this form will be
less detailed than that
necessary to report on specific
indicators selected by
grantees under the
benchmark area for family
self-sufficiency.
We simplified the
employment categories for
23

Thomas.hinds@wisconsin.gov

4/16/2012 Tom Hinds (WI)
Home Visiting Performance Planner
Thomas.hinds@wisconsin.gov

4/16/2012

Laura DeBoer, MPH (ID)
Idaho Department of Health and
Welfare
MCH Program
MIECHVP DeboerL@dhw.idaho.gov

collect this data. But a way to combine C.2.14 and our idea (to have a more holistic approach to
employment information) could be to change C.2.14 to read “Families: Employment Status,” and have
states report the number of families/households with at least one member with full-time employment
and the number of households with at least one member with part-time employment. If a household’s
members had both full-time and part-time employment, that family would be reported under “Employed
Full Time”. The total for C.2.14 would equal the number of families reported in Table A.1.
Table C.2.15., Education/Training Status
Currently, although we are collecting information regarding enrollees’ educational activities, SPHERE is
not set up to specifically collect full-time versus part-time education/training status. We could collect this
information, but again, this would require significant changes to SPHERE and collection practices. Is the
full/part-time necessary?
Table C General Comments
Table C.1 and C.2: Family Re Table C: 1 and C: 2. Family Relationship to Federal Poverty Level,
Employment Status, and Educational/Training Status - Please clarify if grantees are to report information
for either female and male caregivers or just primary caregivers. Instructions on page 8 state “…item 13
enter the unduplicated count of families’ income level completed to FPL…item 14 enter the
unduplicated count of enrollees by employment status…item 15 enter the unduplicated count of
enrollees by their education status. Instructions must be clearer on which enrollees (male, female, both,
all) grantees are to report on and how to generate an unduplicated count of these enrollees.

reporting in the table while
maintaining the enrollee
rather than the family as the
unit of analysis.

We consolidated the part- and
fulltime student categories
into one.

Grantees should provide
information on all program
enrollees. The enrollee
category must include at a
minimum the caregiver of the
index child enrolled in the
program but may also extend
to additional enrollees at the
discretion of the
implementing agency and
depending on how the home
visiting model utilized
prescribes data collection
regarding family income,
employment and training.

24

Table D: Demographics
Comment
Date

Commenter

Table D.1 Demographics: Enrollees: Age
3/30
Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email: cheryl.leclair@health.ri.gov
3/30
Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email: cheryl.leclair@health.ri.gov
4/16/2012
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
4/16/2012
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

5/1/2012

Brighton Ncube

Comments

Response

Table D.1- The table should include an “unknown/did not report” category rather than the
current “unknown” category.

We revised the table to include an
“unknown/did not report”
category.

Table D.1.- Definitions for the “Age” categories are needed (For example, is it 10 to 14
years or 10 through 14 years?).

A note in the second paragraph of
the instructions defines age ranges
for all tables.

Section D: Other Demographics – General Feedback. It might be beneficial to include
frequencies/counts of other variables, not cross-tabulated with ethnicity and race in the Other
Demographic

Examples of other variables and a
rationale for including was not
provided, therefore this comment
could not be addressed.

Section D: Other Demographics – Please provide clarification on how many caregivers to include
in an unduplicated count of enrollees by age

These categories are mutually
exclusive. Data should be reported
on all enrollees in the program. For
example, if a pregnant teen, her
mother, and the biological father
are all enrolled in the program,
then data should be reported for
each of these enrollees.
Not able to comment. Suggestions
were not provided.

The MIECHV Form 1: Demographic and Service Utilization Data is well developed and l think it will
be a useful document. I have a couple of suggestions which the developers may think about.

25

Comment
Date

Commenter

Comments

Table D.2 Demographics: Primary Language Exposure of Index Children
3/29
Barbara Markiewicz
General Concerns Demographics
(FL)
The Lawton and Rhea Chiles
The proposal is to ask for demographic data for more members of the household than
Center for Healthy Mothers and
the primary client (usually the mother) and the target child. Our consent forms are
Babies University of South Florida signed by the primary client. So, technically, we do not have permission to collect data
bmarkiew@health.usf.edu
on other household members.
3/30

3/30

4/13/2012

Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov
Cheryl LeClair
(RI)
Comments from the Rhode Island
Department of Health
Email:
cheryl.leclair@health.ri.gov
Tom Jenkins (CO)
Nurse-Family Partnership,
National Service Office
[Tom.Jenkins@nursefamilypartne
rship.org]

Response

Grantees should collect information on the
enrollee(s) and the index child in the home
visiting program.

Table D.2. - More language categories are needed.

The “other” section under table D.2 is intended
to capture other languages. A drop down menu
of additional languages will be provided.

Table D.2.- The table should include an “unknown/did not report” category rather
than the current “unknown” category.

We revised the table to include an
“unknown/did not report” category.

Section D, Table D2: This is not a required question in the NFP model, rather the
question is asked of the enrollee (client). Recommend changing this question to the
client/enrollee

Although the data table seeks to identify the
primary language exposure of the index child,
we expect caregivers to answer this question.

26

Table E: Priority Populations – Actual numbers Enrolled during Reporting Period
Comment
Date

Commenter

Table E: Legislatively Identified Priority Populations
4/13/2012
Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

Comments

Response

Section E:
Recognizing that these priority populations are outlined in the legislation and the SIR
(page 16); HHS needs to provide more detailed guidance to states about exactly
what information needs to be collected. The categories are too broad for
implementation and will lead to confusion and different interpretations. We
recommend that HRSA develop a questionnaire that can be used by the home visitor
to collect the information. We also recommend that HRSA provide specific guidance
to states regarding the manner in which they should solicit information to complete
the questionnaire to reduce any misinterpretation. If standard questions are
provided, they can be completed when the client is referred to reduce or minimize
any potential negative impact on the home visitor/client relationship.

The legislation identified, but did not provide
definitions for the priority populations. Beyond
the definitions provided in the form instructions,
grantees have discretion in interpreting these
categories for reporting purposes.

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Section E: Priority Populations Actual Numbers Enrolled Ruing Reporting Period
Table E.23: “Have or have a child/children with low student achievement” – this
information is particularly challenging to capture in valid or reliable manner.
Additionally, there is such a degree of subjectivity to defining low student
achievement; it may be difficult to provide accurate information for this required
information

4/16/2012

Tom Hinds (WI)
Home Visiting Performance Planner
[Thomas.hinds@wisconsin.gov]

Table E, Legislatively Identified Priority Populations
Based on the broad categories in the SIR, we had a sub-committee of our Home
Visiting Evaluation and Program Improvement Work Group come up with more
specific definitions (although broader for low income) to help home visitors identify
these risk factors. You recommend possible flexibility regarding identification of low
income--is there some flexibility for other categories as well? If so, we recommend
stating this in the form instructions.

4/13/2012

Tom Jenkins (CO)

In its current format, Form 1 does not define several key terms used to solicit
27

Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

4/16/2012

4/16/2012

3/29

4/5/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
Kristen Rogers, PhD (CA)
CA Home Visiting Program Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]
Barbara Markiewicz (FL)
The Lawton and Rhea Chiles Center
for Healthy Mothers and Babies
University of South Florida
bmarkiew@health.usf.edu

Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]

demographic information. For example, terms contained in Table E, such as “low
income,” “low student achievement,” and “interactions with child welfare services,”
do not have standard definitions, and thus are subject to inconsistent interpretations
that may undermine the reliability of the information collected. We therefore
recommend that these terms be defined with enough specificity to provide clear
guidance to states regarding the information collected.
Section E: Priority Populations Actual Numbers Enrolled Ruing Reporting Period
Table E.18 is currently stated “Have low incomes” and should be changed to “have
low income”

Table E – Legislatively Identified Priority Populations
#20-22 – History of child abuse/neglect; history of substance abuse; tobacco users in
home. The instructions for this section specify counting enrollees, when the original
legislation identified priority populations as families with tobacco use. Do you want
to change “enrollees” to “families”?
Specific Concerns – Table. D.1 DEMOGRAPHICS
 Many of the new proposed demographics rely on self-report from the
primary client about past events: her performance in school, her previous
experience with maltreatment and with the child welfare system, her prior
learning disabilities. Unless there is a very important reason to collect these
data, which have a high likelihood of inaccuracy, we should not collect
them.

Overall comments: Since the model does not collect much of this information, will
the model (s) need to give concurrence to extra state data collection to capture
these data points (as occurred with the benchmark plans)? See below for specific
challenges for capturing these constructs.
This data is not collected by model at the present time and the model has not made
a decision as to whether they will add this to their repertoire of data collection and
reporting. Thus, this would have to be collected by state with an additional data

We made this change.

The Supplemental Information Request further
clarified priority populations to include
enrollees.

The purpose of the data collection in this section
is to determine if the MIECHV program is
enrolling the priority populations specified in
H.R. 3590-220. In table E, items 17-24 enter the
count of enrollees who were newly enrolled
during the reporting period and meet each
eligibility priority category as identified in the
grantee’s determination for eligibility, through
the intake process, or through ongoing contact.
Grantees are required to provide assurances
that priority will be given to serve eligible
participants who fall into the priority
populations. The legislation identified, but did
not provide definitions for the priority
populations. Beyond the definitions provided in
the form instructions, grantees have discretion
28

collection system-a cost and burden not anticipated.
Have a history of child abuse or neglect or have had interactions with child welfare
services.
Have a history of substance abuse or need substance abuse treatment.
The “history” is not presently collected in model and the model has not made a
decision as to whether they will add to collection.
Are users of tobacco products in the home.
Use of tobacco products by other than the enrollee is not presently asked via the
model data collection efforts and will need to be added. The model has not made a
decision as to whether they will add to collection.
Have or have a child/children with low student achievement.
The presence (or perception) of low student achievement for the enrollee is not
being captured via the model’s present data collection system and the model has not
made a decision as to whether this collection will be added.

in interpreting these categories for reporting
purposes.
The instructions describe the legislative mandate
for reporting of enrollment of special
populations and populations of high risk. It is
independent of models.
This data would primarily be collected at the
time of enrollment or intake process.
It suffices for grantees to ascertain if enrollees
and index children meet the criteria for the
different priority population categories,
although it is permissible to include other
household members if information is available.

Has a child/ have children with developmental delays or disabilities.
An enrollee having a child with developmental delays or disabilities is not being
captured and will need a new data collection procedure.
Are in families that include individuals who are serving or formerly served in the
Armed forces, including such families that have members of the armed Forces who
have had multiple deployments outside of the United States.
This construct is not captured by model data collection efforts and will constitute
new data collection procedures and systems, again adding to burden/costs that were
not anticipated.
Please further define the family relationship that needs to occur for an enrollee to be
counted as “Are in families that include individuals who are serving or formerly
served in the Armed forces”, particularly if enrollees are entered into program in
pregnancy.
29

Table F: Service Utilization Across all Models
Comment
Date

Commenter

Table F: Family Retention Across all Models
Currently Receiving Services
3/29
Angela Ward
(UT)
Office of Home Visiting
Utah Department of Health
award@utah.gov

4/16/2012

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Comments

Section F (Table F) asks for service utilization across all models. There needs to be a clear operational
definition for family retention. The first category “currently receiving services” is fairly straightforward,
however, “successfully completed program” needs a clear definition.
This is needed since the time length of enrollment specified by HFA (up to 5 years) and NFP (2 years) will
create reporting challenges. Specifically, if all HFA participants were retained in the program, in order to
consider them “successfully completing” they would not finish with the program until 2 or more years
(depending on enrollment) after the first 3-year benchmark cycle is complete. Another challenge
reporting these criteria in this format has to do with reporting across different models. Each model may
have varying standards for the percentage of visits completed that should be considered. Additionally, a
related issue has to do with model specific standards for frequency of visits. For example, NFP has
established a goal for visits during pregnancy at 80% of expected visits. If the implementing agency does
not achieve the 80% completion rate for visits during this phase of services, yet the clients are retained in
the program for 2 years - - would this be considered “successfully completing” the program? We think
there needs to be a performance standard linked to a clear definition for this section.

Response

We eliminated the term
“successfully” from the
table. We revised the
categories to include
“currently receiving
services,” “completed
program”, “stopped
services before
completion” and “other.”

Section F: Service Utilization Across all Models
Table F.26: Family Retention Across All Models – In many cases there is no definition of “successfully
completed program.” For example, there is no minimum length of program participation for either the
Early head Start or Parents as Teachers models. There is no minimum number of home visits, duration of
participation, or achievement of specific outcomes that indicate successful completion of either the Early
Head Start or Parents as Teachers programs. Please provide further instruction on this element or remove
it from Table F

Successfully Completed Program
30

3/12/2012

CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us
Terminated Services
4/16/2012
Kristen Rogers, PhD (CA)
CA Home Visiting Program Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]

Other
4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

Table FFamily Retention Across All Models
-

We eliminated the term
“successfully” from the
table.

Please define success.

Table F – Service Utilization/Family Retention, Across All Models
Terminated cases may differ greatly in length of service. Is it helpful to lump them together? For example,
an HFA client who feels that she has benefitted enough from the program and drops out after 2 or 2 ½
years (when the model calls for 3 years) will be lumped together with a client who drops out after being
visited only once

Section F: Based on the guidance, it appears that the expectation is:
- Number of clients enrolled and receiving services this year
- Number of clients enrolled in this calendar year to successfully complete the program
- Numbers of clients enrolled in this calendar year and have terminated for any reason

We revised the categories
to include “currently
receiving services,”
“completed program”,
“stopped services before
completion” and “other.”
Models may use their
discretion in determining
program completion.

The reporting period for
the MIECHV grants, for
purposes of this data
collection, coincide with
the project period indicated
in the Notice of Award.
Total number of clients
includes those newly
enrolled during the
reporting period and those
enrolled in previous years
who are still actively
participating in the
program at the beginning
of the reporting period.

31

Table G: Comments and Other
Comment
Date

Commenter

Table G: Comments
3/12/2012
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
Margie.Hudson@po.state.ct.us
3/21/2012
Yvonne Goldsmith (AK)
yvonne.goldsmith@alaska.gov
Unit Manager
AK Dept. of Health & Social Services
| MCH-Epidemiology
4/5/2012

Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]

Comments

InstructionsOn page 7 last paragraph- second sentence-

Response

We added the phrase “at
any time” where
requested.



“who have been enrolled in the program while pregnant – please add- at any time- during the
reporting period.”
I estimate the following amount of time will be required, on an annual basis, to fill out:
Form 1 – 150 hours

Overall, the burden, 731 hours, for Form 1 seems underestimated. Louisiana estimates 5418 hours of
additional burden for this particular form, as data collection, reporting and analysis processes will need to
be instituted, as model (s) does not collect or report on this particular data. Other questions/comments
are included below.

The estimation of data
collection burden for
respondents is based on
the additional effort
involved in data collection
(e.g., at the local
implementing agency), data
entry and transfer (e.g., to
state program), analysis,
and uploading into DGIS
required of grantees. Data
collection activities that are
part of the home visiting
model or program
requirements are excluded
from the calculation. Of the
two parties who
commented on the
reporting burden for the
proposed HV form 1, one
estimated the burden
would be 150 hours
annually per respondent
32

4/5/2012

Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[Cynthia.Suire@LA.GOV]

Introduction
Please provide example of “reporting period” since the dates will vary from grantee to grantee.

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

HRSA should define demographic terms and provide states with uniform questions regarding
demographic information to ensure the reliability of information and minimize burden or models.
In addition, Form 1 leaves the manner in which states solicit demographic information to each state and
territory. Each state therefore has discretion regarding how they pose questions to participants to
ascertain their demographic characteristics. As a consequence, it is likely that 47 states will ask
participating families the requested information in 47 different ways to solicit the same information.

and the other estimated it
at 5418 hours. The
estimate we put forth in
the FRN for this form fell
within these values, i.e.,
731 hours annually per
respondent. In light of the
uncertainty involved in
estimating with accuracy
the collection burden of
these activities separately
from other existing
programmatic data
collection requirements,
we will reassess the burden
estimate once actual data
collection is underway (e.g.,
after two years of
experience since the
burden is likely to be higher
during the first year).
The reporting period for
the MIECHV grants, for
purposes of this data
collection, coincide with
the project period indicated
in the Notice of Award.
Demographic terms likely
to be subject to differing
interpretations have been
defined to the extent
practical in the instructions
to the form.

33

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

4/13/2012

Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]

Allowing states to seek this information in different and varied ways may undermine the reliability of the
information because questions asked in different ways yield different answers. For example, a question
asked of a family in one manner in New York and another manner in Colorado may yield different results
based solely on the manner in which the question was asked. For these reasons, we recommend that you
provide states with uniform questions with which to solicit demographic information.
HRSA Should Clarify How Clients will be Counted
Form 1 does not clarify how children and families enrolled in home visiting models will be accounted for
over time. For example, will the count restart every year in order for a family to be considered
unduplicated for more than one-year? In Nurse-Family Partnership’s model, an NFP client enrollee will
participate for up to three calendar years with an index child for up to two years. In this instance, it is not
clear whether the client/index child and family would be considered unduplicated only once or each year.

Estimates of Burden for Form 1 Fail to Take into Consideration the Burden on the Implementing Agency
and Models
We believe that the burden estimate of 731 hours per response may be appropriate for the states;
however, the estimates do not account for the significant time that individual agencies administering the
program must devote to collecting, compiling and submitting the requested information to the state. We
believe that the burden to implementing agencies and home visitors who must solicit the information
directly from the families may exceed 731 hours per response per family. This burden is compounded by
the fact that many states have not yet implemented data systems necessary to easily collect this type of
information, making it likely that this information will be collected manually by pen and paper. We
therefore recommend that you minimize the burden by clarifying and streamlining the requested
information with uniform questions.

We added language to the
instructions to clarify the
term “unduplicated”.
Specifically, the count of
families or enrollees
continuously participating
from one reporting period
to another restarts for each
reporting period.
The estimation of data
collection burden for
respondents is based on
the additional effort
involved in data collection
(e.g., at the local
implementing agency), data
entry and transfer (e.g., to
state program), analysis,
and uploading into DGIS
required of grantees. Data
collection activities that are
part of the home visiting
model or program
requirements are excluded
from the calculation.
We added language to the
instructions in response to
specific comments to clarify
terms. We also simplified in
34

4/13/2012

4/16/2012

4/16/2012

4/16/2012

4/16/2012

Tom Jenkins (CO)
Nurse-Family Partnership, National
Service Office
[Tom.Jenkins@nursefamilypartners
hip.org]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare- MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]

Nurse-Family Partnership appreciates the significant work and progress that you have made to implement
the MIECHV Program in a short time frame. We are also grateful for the collaborative approach you have
taken to engage and solicit advice from the model developers. We look forward to continued dialogue
regarding the data collection and other important aspects of the implementation of this important
program.
Instructions for Completion of Home Visiting Form needs clarification on how to generate unduplicated
counts, further definition needed between enrollees, caregivers, and families, and when during the
reporting year the data should be extracted to populate all elements on Form 1

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
MCH Program
MIECHVP
[DeboerL@dhw.idaho.gov]
Kristen Rogers, PhD (CA)
CA Home Visiting Program Branch
CA Department of Public Health
Maternal, Child & Adolescent
Health Division
[Kristen.Rogers@cdph.ca.gov]

Unduplicated Count Of Enrollees by Type and by Primary Insurance Status, in the “Instructions for
Completion of Home Visiting Form 1” – it states “The enrollees’ include the person or persons who signed
up to participate in the home visiting program. The category can include more than one member of the
household if more than one individual are enrolled in the program or if the program collects data on
them.”

Tom Hinds (WI)
Home Visiting Performance Planner
[Thomas.hinds@wisconsin.gov]

Overall Comment
It might be helpful to include both number and percentage in tables that report on current clients. For
example, the number of clients insured (Table A.2) or number of clients employed (Table C.2) is not nearly
as informative as the percentage would be. Of course, the percentage could be calculated using the
number served (Table A.1) However, including the percentages in the tables might make the reporting
both more accurate and better understood by the reporters
Additional Comments
Although we understand the process for finalizing federal reporting forms is time consuming, we hope
that this form is finalized as soon as possible, so we can make the adjustments necessary to our data
system and home visiting practices required to complete it. Some of our sites have been serving families
under the MIECHV grants since last July and really want to know what they have to report, so they can

some instances the
information requested to
minimize burden.
Thank you.

We agree and clarified the
instructions, revised the
categories to be mutually
exclusive, and specified
that data needs to be
collected at the time of
intake and annually
thereafter.
We clarified the
instructions and revised the
categories to be mutually
exclusive.

The forms are for data
collection only and do not
include the types of
analysis that will be
conducted. To minimize
burden, we have not added
calculations to the table.
We understand and are
following the procedures in
the Paperwork Reduction
Act of 1995, Pub. L. 104-13
to complete the forms as
35

finalize their data collection procedures and focus even more of their energy on using their data and
serving families. We have made many adjustments to our data system and home visiting practices to align
with our approved federal benchmark data collection plan, and we want to avoid as much as possible
asking sites to report on some topic one way, then later asking them to report information differently.
Given the expectation communicated to us that the Demographic and Service Utilization form will not be
finalized until the fall, we will, as instructed, continue to prioritize our time, money and efforts to aligning
our data collection practices with our federally approved benchmark plan, and then will make the
adjustments needed to report on this form. We expect that our first year report for this form will reflect
some missing information, but that completeness will improve over time. In the future, we think it would
also be helpful for the Benchmark TA providers to work with the developers of the demographic/service
utilization form, particularly if there are overlapping constructs that one group wants measured in a
certain way. This would reduce the current confusion and burden around categories such as education
and employment, for example.

expeditiously as possible.
Forms 1 and 2 were
considered in the context
of the benchmark
requirements.

36