19226_ID 0990-0275 2 ASA revised 4-5-13

19226_ID 0990-0275 2 ASA revised 4-5-13.doc

Implementation of an Internet & Paper-Based Uniform Data Set for OMH-funded Activities

OMB: 0990-0275

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Performance Improvement and Management System (PIMS)



Performance Data System (PDS)





Request for Revision on a Previously Approved Collection:
Control No: 0990-0275, Expiration 10/31/2013






Supporting Statement







April 2013






Submitted by:


US Department of Health and Human Services (HHS)

Office of the Assistant Secretary (OASH)

Office of Minority Health (OMH)

1101 Wootton Parkway, Suite 600

Rockville, MD 20852



Table of Contents


A. Justification

A.1 Circumstances Making the Collection of Information Necessary

A.2 Purpose and Use of Information Collection

A.3 Use of Improved Information Technology and Burden Reduction

A.4 Efforts to Identify Duplication and Use of Similar Information

A.5 Impact on Small Businesses or Other Small Entities

A.6 Consequences of Collecting the Information Less Frequently

A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

A.8 Comments in Response to the Federal Register Notice/Outside Consultation

A.9 Explanation of any Payment/Gift to Respondents

A.10 Assurance of Confidentiality Provided to Respondents

A.11 Justification for Sensitive Questions

A.12 Estimates of Annualized Hour and Cost Burden

A.13 Estimates of other Total Annual Cost Burden to Respondents or Recordkeepers/Capital Costs)

A.14 Annualized Cost to Federal Government

A.15 Explanation for Program Changes or Adjustments

A.16 Plans for Tabulation and Publication and Project Time Schedule

A.17 Reason(s) Display of OMB Expiration Date is Inappropriate

A.18 Exceptions for Certification for Paperwork Reduction Act Submissions

B. Collection of Information Employing Statistical Methods

B.1 Respondent Universe and Sampling Methods

B.2 Procedures for Collection of Information

B.3 Methods to Maximize Response Rates and Deal with Nonresponse

B.4 Tests of Procedures or Methods to be Undertaken

B.5 Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data


Attachments

  1. Data Elements in the PDS

Exhibits

  1. Changes in Estimated Burden Hours

  2. Estimated Annualized Burden Hours

  3. Costs to the Federal Government


Supporting Statement for the OMH PDS

This request for Office of Management and Budget (OMB) clearance is intended to continue the operating period for data collection efforts utilizing the Performance Data System (PDS), a web-based system for collecting standardized program and project performance data from grantees and other recipients from programs funds of the Office of Minority Health (OMH). This web-based system is supported via a task order contract to NORC at the University of Chicago (NORC). This data is used in conjunction with systematic efforts to provide evaluation training and technical assistance (T/TA) to grantees and other funding recipients as well as to monitor and promote evaluation of intervention effectiveness throughout the course of a funding period/cycle to ‘grow the science’ regarding ‘what works’ in minority health improvement and health disparities reduction. OMH is requesting revision of a previously OMB-approved data collection, i.e., the Performance Data System (PDS), formerly, the Uniform Data Set (UDS) [OMB No. 0990-0275, Expiration Date 10/31/2013], the tool used by OMH to collect standardized program management and performance data for OMH-funded projects.

A. JUSTIFICATION

  1. Circumstances Making the Collection of Information Necessary

In 1985, the Report of the Secretary's Task Force on Black and Minority Health, the first comprehensive national racial and ethnic minority health study published by the HHS, documented the wide disparity in health status between racial and ethnic minorities and Whites. Although the health of all Americans has continued to improve over two and a half decades since the Report was issued, racial and ethnic health disparities persist and, in some cases, are increasing. The persistence of such disparities suggests that current approaches and strategies are not producing the kinds of results needed to ensure that all Americans are able to achieve the same quality and years of healthy life, regardless of their demographic characteristics.


Since its inception in 1985, OMH has been the organizational entity within HHS that coordinates Federal efforts to improve the health status of racial and ethnic minority populations. The office was established with the passage of the Disadvantaged Minority Health Improvement Act (P.L. 101-527, at http://thomas.loc.gov/cgi-bin/bdquery/z?d101:HR05702:/TOM:/bss/d101query.html) and given a broad mandate to advance efforts to improve minority health and address racial/ethnic disparities in health. Under the recently passed Patient Protection and Affordable Care Act (P.L. 111-148, at http://democrats.senate.gov/reform/patient-protection-affordable-care-act-as-passed) and the Health Care and Education Reconciliation Act (P.L. 111-152, at http://www.gpo.gov/fdsys/pkg/BILLS-111hr4872EH/pdf/BILLS-111hr4872EH.pdf), the responsibility for OMH to “establish, implement, monitor, and evaluate short-range and long-range goals and objectives and oversee all other activities within the US Public Health Service that relate to disease prevention, health promotion, service delivery, and research concerning minority groups” was recodified. In order to achieve this broad mandate, OMH supports research, demonstrations and evaluations of new and innovative programs, and strategies and interventions that increase understanding of ways to improve the health of racial and ethnic minority communities and reduce the burden of disease, disability, and premature death that disparately impacts them.

OMH’s GPRA Reporting Requirements

In response to requirements under the Government Performance and Results Act of 1993 as well as the more recent Government Performance and Results Modernization Act of 2010, in FY 2009, OMH began the development of a Performance Improvement and Management System (PIMS) built on its already completed Strategic Framework for Improving Racial/Ethnic Minority Health and Eliminating Health Disparities (the Framework) (available at: http://www.minorityhealth.hhs.gov/templates/content.aspx?lvl=1&lvlid=44&id=8842) and its Evaluation Protocol for Systematically Evaluating Efforts to Improve Racial and Ethnic Minority Health, Reduce Health Disparities, and Effect Systems Approaches to Racial and Ethnic Minority Health Problems (the Evaluation Protocol) (available at: http://www.minorityhealth.hhs.gov/Assets/pdf/Checked/1/EvaluationProtocol.pdf.) The Framework is intended to present a vision, rationale, and systems approach for addressing OMH’s mission, and the Evaluation Protocol is a general guide for OMH grant applicants/awardees, contractors, other funded partners, and other stakeholders on the development and implementation of evaluation plans that articulate how proposed or planned efforts will be evaluated to determine if intended results are achieved.

Both of these documents have served as the basis for development, implementation, and improvement of two major components of the PIMS: the Evaluation Technical Assistance Center (ETAC) which provides systematic T/TA throughout the course of funded programmatic efforts to promote evaluation of intervention effectiveness; and the Performance Data System (PDS), a web-based system for collecting standardized program, project, and performance data from OMH grantees and other funding recipients. Development of the PIMS and these components was completed at the end of FY 2010, and the system has been fully operational since FY 2011. Through the ETAC, OMH is able to systematically produce results of intervention effectiveness and identify ‘best practices’; and, through the PDS, quarterly, annual, and ad hoc reports can be generated to inform program managers, OMH and HHS leadership, budget personnel, and Congressional staff about the number and demographic make-up of program participants, the nature and extent of funded interventions and their impacts on program participants, efficiencies through resource leveraging and partnerships, the relationship of funded efforts to national goals and objectives, such as Healthy People 2020 (HP2020) and the National Partnership for Action to End Health Disparities (NPA), etc. Such results enable OMH to comply with the requirements under the GPRA Modernization Act.

  1. Purpose and Use of Information Collection

The overall purpose of the PDS is to enable OMH, via an easily accessible database, to collect standardized performance information from its grantees, cooperative agreement partners, and other funding recipients in order to enable generation of routine reports regarding program and project status, inputs, outputs, impacts, and other returns on investment. Grantee-level reports can be accessed and used by the respective grantees and their respective project officers; program-level reports can be generated for use by respective OMH project officers and OMH grants and cooperative agreement coordinators; and OMH-wide and all other reports can be generated for use by OMH project officers, program and Division managers, and office leadership for performance budgeting and reporting as well as program improvement purposes.

The NORC team as well as OMH project officers use the system to review individual grantee reports and aggregate reports on projects in their grant stream and to improve the overall management of their projects. Additionally, the PDS generates aggregate program data on program efficiency, health issues addressed, and funding that will be used to respond to inquiries made to OMH leadership and other policy/decision makers.

  1. Use of Improved Information Technology and Burden Reduction

As noted above in Section 2 (Purpose and Use of Information Collection), the purpose of the PDS is to facilitate collection of performance data from its grantees, partners and others in order to monitor program and project status and generate results that can be reported for program management and performance budgeting purposes.

The PDS is specifically designed as a web-based application to reduce reporting burden by organizing data elements in a logical manner, and designing data elements with skip logic and auto validation features which improve the quality of data submitted. Moreover, the PDS was designed to provide additional capacity to grantees and cooperative agreement partners by providing online and telephonic technical assistance (the PDS HelpDesk), and guidance for completing their data entry. In addition, the PDS system has built-in edit checks to identify inconsistencies and errors in the data entered into the system, thus bypassing the need to use valuable staff time to accomplish such tasks. In short, the PDS system includes many features that both minimize respondent burden and increase respondent capacity.

PDS functionality has been maintained on three server environments for all enhancements and/or new functionalities. The production and staging databases are routinely backed up to prevent data loss as well as to ensure a configuration management roll back feature. Additionally, prior to each reporting period, NORC and OMH staff discuss and refine potential PDS enhancements to be completed either prior to, after the upcoming, or in a future reporting period. Through the use of the PDS Help Desk, feedback from OMH staff, and insight from the PDS NORC staff, an ongoing list of potential enhancements is monitored for consideration.

From this feedback, several PDS system and functionality enhancements have been completed in order to decrease respondent burden. For example, data such as organizational resources and characteristics and project resources that do not change from quarter to quarter are now prepopulated in the PDS system. Should the grantee need to make an update, the option is available; otherwise, the grantees now confirms that the data is accurate by selecting one button as opposed to having to populate the entire section(s).

  1. Efforts to Identify Duplication and Use of Similar Information

Data collection using the PDS does not duplicate other data collection efforts. Data elements included in the PDS are specific to OMH-funded grantees and cooperative partners and, therefore, are not available elsewhere. OMH does not have any other web-based system for the collection of standardized performance information.

  1. Impact on Small Businesses or Other Small Entities

The impact of this data collection will be negligible at best, since, for the most part, the grantees and cooperative agreement partners funded by OMH are public or private non-profit minority-serving community-based organizations, minority-serving institutions of higher education, and State agencies dedicated to addressing minority health concerns. With or without the PDS, these projects would have to provide project and evaluation data. The required PDS data entry represents the minimum data needed to be useful for project reporting, program monitoring, and performance measurement by OMH and its partners.

  1. Consequences of Collecting the Information Less Frequently

Current PDS data are reported once every three months or quarterly in order to synchronize the data reporting with OMH’s other data reporting needs for HHS GPRA and performance budgeting and reporting purposes. Less frequent collections pose challenges to obtaining data that are requested more frequently for other departmental performance reporting needs, and increase the amount of data that the grantees and other users need to accumulate and manage prior to submission to OMH.

  1. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

No special circumstances apply. This request complies with the information collection guidelines of 5 CFR 1320.5(d)(2).   

  1. Comments in Response to the Federal Register Notice/Outside Consultation

NORC on behalf of OMH maintains the PDS and makes recommendations on improved functionality and increased usability. NORC has made systematic improvements based on OMH and grantee feedback. Additionally, in accordance with the Paperwork Reduction Act of 1995, OMH published a notice in the Federal Register announcing the agency’s intention to request an OMB review of data collection activities. The 60-day notice for public comment was published on April 10, 2013 in volume 78, on pages 21369-21370. No comments were made on these notices.

  1. Explanation of any Payment/Gift to Respondents

This data collection does not involve payment or gifts as incentives for respondents. OMH-funded grantees enter data into the PDS as a funding requirement to obtain their grants.

  1. Assurance of Confidentiality Provided to Respondents

Only aggregate, periodic project data from OMH-funded projects is reported. There is no personally identifiable information (PII) collected. All data entered into the system are password-protected. Usernames are generated only for the project director and 2 data entry persons for each grantee, and passwords are randomly generated. At first log-in to the system, project directors and data entry persons are prompted to change their passwords. All data is maintained under a support contract by OMH to NORC. NORC staff manages daily operations of the PDS and provides reports to OMH as requested.

  1. Justification for Sensitive Questions

The PDS requests data from users specific to their OMH-funded project, including: project budget, resources, types of interventions employed/conducted, number of individuals participating in funded activities, and various types of outcomes and impacts (i.e., increases in knowledge and awareness). These data do not include any items of a personal or sensitive nature.

  1. Estimates of Annualized Hour and Cost Burden

Currently, OMH grantees are entering and submitting data on quarterly basis to align with OMH and GPRA reporting requirements. By enhancing the PDS system and functionality, there has been a significant reduction in respondent burden per response from 2.5 hours to 1.5 hours (with a range of 30 minutes to about 3 hours). This estimate is based on the last four quarters of data collection from grantees. Exhibit 1 shows the prior and revised total burden hours for all four responses. Exhibit 2 shows the costs for submitting all reports which totals $18,000.00 per year. Given the nature of the updates/revisions to the data elements that will be made to the PDS (Appendix A: Data Elements in the PDS), it is anticipated that reporting burden will continue to decrease.

Exhibit 1: Changes in Estimated Burden Hours



Type of

Respondent


Form Name

No. of Respondents

No. Responses per Respondent

Average Burden per Response (in hours)

Total Burden Hours

Prior Burden

OMH Grantee

PDS

104

4

2.5

1,040

Revised Burden

OMH Grantee

PDS

100

4

1.5

600


Exhibit 2: Estimated Annualized Burden Costs

Type of Respondent

Total Burden

Hours

Hourly

Wage Rate

Total Respondent

Costs

Project Manager or Evaluator

600

$30.00

$18,000.00


  1. Estimates of other Total Annual Cost Burden to Respondents or Recordkeepers/Capital Costs

The data collection described in this request does not constitute an additional effort for respondents beyond regular project duties/obligations. No additional staff time or cost is anticipated other than the time/cost allocated for regular project administrative requirements. No additional materials or equipment are needed to generate a report using the PDS.

  1. Annualized Cost to Federal Government

The overall annual cost to the Federal government for maintaining the PDS is $326,358. This total includes time to complete all enhancements and modifications, test the system, respond to users’ requests for technical assistance related to navigating and using the system, developing training materials, and training users on system navigation and data entry. Exhibit 3 presents total costs to the Federal government for making and implementing enhancements and modifications.

Exhibit 3: Costs to the Federal Government

Category

Cost

Personnel

$326,358

Other Direct Costs (including travel, consultants, computer equipment, etc.)

$0

Total

$326,358

*G&A and fee included in total.

  1. Explanation for Program Changes or Adjustments

This is a request for a renewal to an existing, OMB-approved data collection. In enhancing the data collection system and streamlining the structure of specific data elements, there has been a reduction in respondent burden of 1.0 hours per response (from 2.5 hours to 1.5 hours). Exhibit 1 (in Section 12) shows there has been a reduction of 440 burden hours per year.

  1. Plans for Tabulation and Publication and Project Time Schedule

The purpose of the PDS, as described herein, is to serve as the regular, ongoing system of standardized data reporting for all grants, cooperative agreements, and other selected programmatic efforts funded by OMH. Data reported as part of this system are used for project management and monitoring, assessment of project implementation and results, and for performance budgeting and reporting purposes in support of OMH strategic priorities, objectives, and goals. In addition, aggregate program data are also used in periodic reports to OMH leadership, other HHS policymakers and decision makers, and Congressional staff, as needed and appropriate.

There are no specific plans to publish results from the PDS system at this time.

  1. Reason(s) Display of OMB Expiration Date is Inappropriate

This collection of information does not seek approval to exclude the expiration date for OMB approval from any data collection instruments.

  1. Exceptions to Certification for Paperwork Reduction Act Submissions

This collection of information involves no exception to the Certification of Paperwork Reduction Act Submissions.

B. Collection of Information Employing Statistical Methods

  1. Respondent Universe and Sampling Methods

This section does not apply to the PDS. The project does not involve sampling. All OMH grantees/cooperative agreement partners report data on their activities using this system.

  1. Procedures for the Collection of Information

This section does not apply to the PDS. The project does not involve sampling. All OMH grantees/cooperative agreement partners report data on their activities using this system.


  1. Methods to Maximize Response Rates and Deal with Nonresponse

This section does not apply to the PDS. The project does not involve sampling. All OMH grantees/cooperative agreement partners report data on their activities using this system.


  1. Tests of Procedures or Methods to be Undertaken

This section does not apply to the PDS. The project does not involve sampling. All OMH grantees/cooperative agreement partners report data on their activities using this system.


  1. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

This section does not apply to the PDS. The project does not involve sampling. All OMH grantees/cooperative agreement partners report data on their activities using this system.




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