ACL Public Comment Summary

Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

A 60-day Federal Register Notice (FRN) published in the Federal Register on September 28, 2020,
Volume 85, No. 188, page 60808. AoA also encouraged current and former PPHF grantees to respond to
the Federal Register notice through a reminder sent out to grantee point of contacts. Five public
comments were received and are summarized and responded to below. A 30-day FRN published on
March 11, 2021 Volume 86, No. 46, pages 13904-13907.
In addition to public comment, feedback on the current forms was sought from the following internal
and external stakeholders:



National Falls Prevention Resource Center and falls prevention subject-matter experts



A grantee focus group (with fewer than 9 participants combined)

Summary of Public Comments
In response to the Federal Registrar Notice, ACL received five emails with comments on the data
collection tools.

Participant Information Form and Post Survey

Comment

Response

A suggestion was made to add a purpose
statement to the forms to better inform
participants of why this specific data collection is
pertinent.

ACL did not adopt this suggestion. The
purpose of this data collection is multifold – with different benefits and
potential uses of the data by federal,
state, and local stakeholders.

Suggestions were made to make adjustments to
the wording and/or response options for some
of the demographic questions, such as those
related to race, ethnicity, and gender.

ACL did not adopt these suggestions. The
wording and response options for the
demographic questions included are
consistent with OMB-approved surveys
for other ACL programs. Having this
consistency allows ACL and researchers
utilizing this data to compare outcomes
from the population reached with ACL’s
Falls Prevention Programs to a more

broadly representative population of
older adults.
For some of the non-demographic questions,
suggestions were made to use different
response options, adjust the wording of the
questions, or use different measurement scales.

ACL did not adopt these suggestions. ACL
consulted with experts in the field to
identify validated scales to capture the
information needed to understand the
impact of the programs on critical
domains. Adjusting the wording of the
questions would impact their validity.

Several suggestions were made with respect to
the formatting of the forms.

1. ACL did not adopt these suggestions
in order to keep the Participant
Information Form and Post-Survey to
one sheet (front and back). ACL will
be providing the surveys to grantees
in a Word format so they can make
any formatting edits they deem
necessary, i.e., larger font size, more
white space, etc.

1. Provide a small box on the bottom right
hand corner of each sheet to identify
participant ID. Should paperwork be
separated, it provides another
mechanism to keep forms complete.
Also suggest adding more white space to
the document, increasing the space
between questions and answers, and
increasing the font size.

2. There needs to be further consistency
with bullet point sizes and format of
questions. They seem to be inconsistent.

3. To better align the pre- and post- survey,
it might make sense to move question
number 9 on Participant Information
Form closer to question 12.

2. ACL reviewed the bullet point sizes
and format of questions to ensure
consistency.

3. ACL revisited the ordering of the
forms to ensure the questions align,
to the greatest extent possible.

4. ACL made the spelling correction to
question 7.

4. In question 7, the word “agree,” is
misspelled under “Strongly disagree.”
Some commenters suggested including
definitions of certain terms on the form, for
example, defining what is meant by “vigorous”
or “moderate” exercise.

ACL did not adopt suggestions to provide
detailed definition of terms within the
questions. Including definitions would
increase the length of the forms, resulting
in greater participant burden. Local
program coordinators are available to
assist participants completing the forms,

in the event any questions arise with any
of the specific questions.
A suggestion was made to remove the proposed
Question 19 from the Participant Information
Form, with the comment that it is not relevant
pre-program.

ACL adopted this suggestion.

A suggestion was made to adjust the wording of
the existing Question 11 (and the response
options) to align with the ACL Chronic Disease
Self-Management Education data collection
forms.

ACL did not adopt this suggestion. The
ACL Falls Prevention and Chronic Disease
Self-Management Education grant
programs are two distinct grant programs,
with two distinct lists of chronic
conditions in their OMB-approved data
collections.

A suggestion was made to expand the following
question on the Participant Information Form:

ACL did not adopt this suggestion. This
question was only included in the
Participant Information Form, not the
“Are you limited in any way in any activities
Post Survey. The Participant Information
because of physical, mental, or emotional
Form and Post Survey already include
problems?”
questions to assess limitations due to
physical, mental, and/or emotional
Suggested replacement questions:
problems, so this question was deemed
 “Because of a physical, mental, or emotional duplicative and removed from the
condition, do you:
Participant Information Form entirely to
o Have serious difficulty concentrating, reduce participant burden.
remembering, or making decisions?
Yes, No
o

Have difficulty doing errands alone
such as visiting a doctor’s office or
shopping? Yes, No”



“Do you have serious difficulty walking or
climbing stairs? Yes, No”



“Do you have difficulty dressing or bathing?
Yes, No”

A commenter suggested adding the following
questions to the forms:

ACL did not adopt these suggestions to
avoid increasing participant burden and
the length of the forms beyond one sheet
(front and back).



“Are you deaf or do you have serious
difficulty hearing? Yes, No”



“Are you blind or do you have serious
difficulty seeing, even when wearing glasses?
Yes, No”



“During the past year, did you provide
regular care or assistance to a friend or
family member who has a long-term health
condition or disability?”

Fall Prevention Coversheet
Comment

Response

Some commenters suggested not requiring a
separate Program Information Coversheet –
instead folding some of the questions in the
coversheet into the Participant Information
Form, Post-Survey, and/or the semi-annual
grantee report.

ACL did not adopt this suggestion. The
grantee focus group reported that this
form was useful for organizing their data
collection and program delivery. Adding
questions to the Participant Information
and Post-Survey would also increase their
length beyond 1 sheet (front and back).

A commenter provided the following formattingrelated comments:

ACL adopted these edits.



The dotted lines dictating the start year
appear to be missing – suggest adding
these; and



suggest adjusting the bullet sizes to be
consistent, specifically in question
number 7, the bullet under indicating
“other,” is different from the previous
bullet

A commenter suggested adding a space to note
host/implementation organization.

ACL did not adopt this suggestion.

A commenter suggested adding check boxes to
note if the program was delivered in a remote
format.

ACL did not adopt this suggestion due to
variability in how remote programs are
defined and delivery format.

Host/ Implementation Organization Form

Comment

Response

A commenter suggested adding to Question 2
the statement, “Please check only if you are a
new ______
Host Organization _____
Implementation Site.”

ACL did not adopt this suggestion. The
purpose of this form is to document new
host organizations and implementation
sites, so these additional instructions were
deemed unnecessary.

Fall Prevention Attendance Log
Comment

Response

One commenter suggested using an “X” (rather
than fill in the box) to denote sessions attended.

ACL adopted this suggestion.

One commenter noted that “the last blank for
‘end date’ is not bolded”.

ACL made this correction.

One commenter suggested changing the form to
landscape to account for length of Tai Chi and
Enhance Fitness programs.

ACL adopted this suggestion.

Comment relevant to all forms:

Comment

Response

One commenter suggested that ACL provide
fillable PDF forms.

ACL will be providing the documents in
Word format. If resources allow, we will
also provide fillable PDFs for grantee use.