NonSub Change - Mode of Data Collection

To:	Kelsi Feltz Office of Information and Regulatory Affairs (OIRA) Office of Management and Budget (OMB)
From:	Kathleen Dwyer and Alysia Blandon Office of Planning, Research and Evaluation (OPRE) Administration for Children and Families (ACF)
Date:	May 2, 2023
Subject:	Non-Substantive Change Request – Evaluation of Project Connect (OMB #0970-0575)

This memo requests approval of non-substantive changes to the approved information collection, Evaluation of Project Connect (OMB #0970-0575).

Background

Project Connect is a comprehensive home visitation intervention that provides home-based services and treatment to child welfare-involved, substance-affected families with children and adolescents ages 0 to 17. The Project Connect evaluation includes an implementation study that supports a planned impact evaluation relying solely on existing administrative data to examine the program’s impact on child welfare outcomes. The implementation study aims to elucidate how Project Connect compares to other services that are relevant for families in the child welfare system who are affected by unhealthy substance use. The study is intended to contribute to the research and evidence base on program models for families affected by substance use in the child welfare system.

Project activities for the implementation study include interviews with child welfare agency and program administrators, focus groups with program and child welfare agency staff, interviews and focus groups with participants, and interviews with other program partners.

Due to the COVID-19 pandemic, interviews and focus groups to date have been conducted by phone. The project team’s IRB has recently approved in-person collection with procedures that mitigate the risk of participants contracting COVID-19. The project team’s IRB required additional language regarding COVID-19 risk be added to respondent consent forms and outreach materials.

This nonsubstantive change is intended to ensure participants are fully informed on the risks of in-person participation and the option to participate by phone if desired. It does not alter the purpose of the data collection, nor the expected uses of the data as approved by OMB in August 2021.

Overview of Requested Changes

Changes to the current appendices have been made in response to the project team planning to conduct staff and participant interviews and focus groups (all instruments) in-person, unless requested by a participant to conduct the information collection by phone or Zoom. A virtual interview is also an option is a participant is interested but cannot meet while the team is on site. These changes are requested to accommodate in-person data collection, inform potential participants of the potential risk of COVID-19 transmission during in-person data collection, and outline the steps the field interviewers are taking to minimize risk of COVID-19 transmission.

We are requesting revisions to the following approved appendices:

1. Staff outreach email (Appendix A) and the parent outreach phone script (Appendix B) have been modified to include a disclaimer about the COVID-19 transmission risks associated with in-person data collection and what steps the research team is taking to mitigate risk. It also informs potential participants about the team’s policy around masking. It also includes an option to conduct the interview or focus group virtually.

2. Staff informed consent (Appendix C) and parent informed consent (D) have been modified to inform the participant of the potential risks of COVID-19 transmission and the steps the team has taken to decrease that risk. It also includes information on the masking policy. For parent informed consent, the form now also includes instructions and a line for parent signature if they choose to participate.

In addition to the changes to those specific appendices, we also made a few minor wording changes for clarity.

Time Sensitivities

This work is time sensitive. The project team need to conduct data collection this spring in order to complete this project on schedule. Timely approval of the proposed changes will allow data collection to continue without pause or effect on the project timeline.