Memo - Nonsubstantive change request: Updated PIA and minor revisions to other materials

To: Steph Tatham

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Anna Solmeyer

Office of Planning, Research, and Evaluation (OPRE)

Administration for Children and Families (ACF)

Date: October 13, 2016

Subject: Request for Non-Substantive Changes to Building Bridges and Bonds (B3) Evaluation – Adjustments to Baseline Employment Survey, Mobile Device Survey and Burden Assumptions, and Updated PIA (OMB Control Number 0970-0485)

The Office of Planning, Research and Evaluation (OPRE) in the Administration for Children and Families (ACF) at the U.S Department of Health and Human Services has funded the Building Bridges and Bonds (B3) evaluation. This change request is for minor modifications to 1) the baseline employment survey (9 - Baseline Survey for Sites Testing Employment Intervention), and 2) the mobile device surveys (18 – Mobile Device Employment survey and 19 – Mobile Device Parenting and Coparenting Survey) and burden assumptions. The change request also includes the updated, signed PIA for the nFORM system. Instruments 9, 18, and 19 were previously approved under OMB Control Number 0970-0485, with an expiration date of 09/30/2019.

B3 is a rigorous, multi-site evaluation that includes an implementation study and an impact study. B3 is partnering with six programs that serve low-income fathers to understand the effectiveness of strategies used to enhance fathers’ participation in fatherhood programs, to increase fathers’ stable employment and improve their economic circumstances, to encourage fathers’ consistent and positive engagement with their children, and to improve constructive cooperation with co-parents. The B3 impact study will use a randomized control design, which includes a baseline survey and a 6-month follow up survey, along with other data collection efforts including an in-program mobile device survey.

Updates to Baseline Employment Survey

Minor changes to the baseline employment survey were made as a result of the team testing and programming the survey. A summary of these changes is below; more details are available in the tracked changes version of the survey (9 - Baseline Survey for Sites Testing Employment Intervention_Track Changes_10.12.16).

• Added instructions for survey programmers (the survey is self-administered using ACASI)

• Added and clarified instructions to respondents

• Fixed errors in wording and skip logic

• Made minor wording changes in a few questions or response categories to improve clarity

Updates to Mobile Device Surveys and Burden Assumptions

Minor changes to survey content

Minor changes to the mobile device surveys were made as a result of testing and programming the surveys. More details about the specific changes made are available in the tracked changes version of the surveys (18 – Mobile Device Employment Survey_Tracked Changes_9.28 and 19 – Mobile Device Parenting and Coparenting Survey_Tracked Changes_9.28).

• Simplified wording of the items

• Updated instructions to respondents

• Updated the B3 information that is available via the weblink in the mobile survey

• Revised Module B so it is relevant to fathers who never engaged in the program

Changes in burden assumptions

While the ultimate number of burden hours does not increase, we now expect responses from more respondents than initially planned, and have also refined our plan so that each respondent answers fewer questions, on average. These changes are based on the finalization of the mobile device survey methodology since the initial OMB submission. Specifically, there are three changes that affect the burden assumptions:

1. Increase in number of respondents: Getting at least one survey response from more respondents than planned is now expected. These changes are noted in Appendix E - Assumptions for Calculation of Burden Estimates_TrackedChanges_9.28.16. This is for two reasons:

   1. Fathers with non-smartphones and email addresses will be eligible to receive the mobile device surveys. Initial assumptions were based only on fathers with smartphones because the incentives were going to be delivered via smartphones. Since then, we have adjusted the plan so that incentives are now available via smartphones or email. This expands the eligibility to fathers who do not have smartphones, but who do have active email addresses.

   2. We would like to survey fathers who were randomly assigned but who never participated in services within the first 5 weeks of their random assignment. Questions from Module B already approved by OMB will be sent to these fathers. This group was never factored into initial burden estimates.

2. Decrease in number of questions to which each father responds: Originally, we assumed that all fathers would respond to the same number (5) of survey modules. Our revised assumption is that all fathers are not eligible for the same number of modules. Most fathers will be eligible for far fewer than the maximum number. Only the program group fathers in the parenting sites will be eligible to receive up to 5 surveys. Program group fathers in the employment sites will be eligible to receive up to 4 surveys. Finally, control group fathers in both the parenting and employment sites will be eligible to receive up to 2 surveys total. Averaging these together results in the weighted average of 3.28 responses noted in Table A.4 Burden Estimates (changes reflected in Appendix E – Assumptions for Calculation of Burden Estimates_TrackedChanges_9.28.16).

3. Decrease in survey module length: Originally, we assumed that each survey module would take an average of 7 minutes. The pre-test experience indicated that it will take fewer than 7 minutes, on average, to complete each survey module. The Average Burden Hours Per Response should be adjusted down to 6 minutes. This change is reflected in several places in the OMB package which have been revised and attached here: Table A.3 Incentives for Participation, Table A.4 Burden Estimates in Supporting Statement A, and time estimates in the surveys.

Taken together, the proposed changes result in a slight reduction in overall burden as noted in Table A.4.

Updated Privacy Impact Assessment for nFORM

As discussed during the original review and approval of the B3 information collection request, since some data for B3 will be collected through the nFORM Management Information System (approved under OMB #0970-0460), the nFORM PIA was updated, reviewed, and approved by the appropriate officials in HHS.

Table A.3 Incentives for Participation (Updated)

Research Activity	Length	Incentive Amount	When
Baseline surveys (Attachments 8 & 9)	30 min	$25	At time of study intake
Updating contact information with the survey firm	10 min	maximum of $7	1-4 months after baseline
Follow-up surveys (Attachments 10 & 11)	40 min	$35	6 months after baseline
Participant focus groups (Attachment 16)	120 min	$20	6 or 18 months after baseline
Mobile device surveys (Attachments 18 & 19)	30 min	maximum of $25	1 – 2 months after baseline
Mother focus group (Attachment 17)	60 min	$20	6 or 18 months after baseline

Table A.4 Burden Estimates (Updated)

Instrument	Respondent	Total Number of Respondents	Annual Number of Respondents	Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Average Hourly Wage	Total Annual Cost
1 - Screening questions for parenting intervention	Applicant	4,000	1,333	1	0.083	111	$4.92	$546.12
	Staff1	36	12	111	0.083	111	$27.86	$3,092.46
2 - Screening questions for employment intervention	Applicant	900	300	1	0.250	75	$4.92	$369.00
	Staff2	12	4	75	0.250	75	$27.86	$2,089.50
3 - Consent Materials for Parents of Fathers under 18	Parent of Applicant	500	167	1	0.167	28	$4.92	$137.76
	Staff3	36	12	14	0.167	28	$27.86	$780.08
4 - B3-specific eligibility data	Applicant	6,400	2,133	1	0.017	36	$4.92	$177.12
	Staff4	72	24	89	0.017	36	$27.86	$1002.96
5 - B3-specific enrollment data	Applicant	2,700	900	1	0.153	138	$4.92	$678.96
	Staff5	72	24	38	0.151	138	$27.86	$3,844.68
6 - B3 tracking of attendance in services for program group members	Staff6	72	24	363	0.008	70	$27.86	$1,950.20

Instrument	Respondent	Total Number of Respondents	Annual Number of Respondents	Number of Responses Per Respondent	Average Burden Hours Per Response	Annual Burden Hours	Average Hourly Wage	Total Annual Cost
7 - Additional nFORM burden for non-Grantee site	Applicant	450	150	1	0.250	38	$4.92	$186.96
	Staff7	12	4	1,969	0.0343	270	$27.86	$7,522.20
8 & 9 - Baseline surveys	Applicant	2,842	947	1	0.642	608	$4.92	$2,991.36
10 & 11 - 6 month follow-up surveys	Applicant	2,430	810	1	0.667	540	$4.92	$2,656.80
12 & 13 - Staff and management semi-structured interviews	Staff8	240	80	2	1.5	240	$27.86	$6,686.40
14 & 15 - Staff surveys	Staff9	240	80	1	0.667	53	$27.86	$1,476.58
16 - Participant focus groups	Applicant	160	53	1	2.0	106	$4.92	$521.52
17 - Mother Focus Groups	Co-parent of Applicant	80	27	1	1.0	27	$4.92	$132.84
18 & 19 - Mobile device surveys	Applicant	1,728	576	3.25	0.1	187	$4.92	$920.04
20 - Post-session debrief for sites testing parenting intervention	Staff10	36	12	104	0.083	104	$27.86	$2,897.44
Data Collection Total						3,019		$40,660.98

1This burden is categorized as record-keeping burden.

2This burden is categorized as record-keeping burden.

3This burden is categorized as record-keeping burden.

4This burden is categorized as record-keeping burden.

5This burden is categorized as record-keeping burden.

6This burden is categorized as record-keeping burden.

7This burden is categorized as record-keeping burden.

8This burden is categorized as record-keeping burden.

9This burden is categorized as record-keeping burden.

10This burden is categorized as record-keeping burden.