NonSubstantive Change Memo

5600 Fishers Lane

Rockville, MD 20857

DATE: June 18, 2024

TO: Dan Cline, OMB Desk Officer

FROM: Joella Roland, HRSA Information Collection Clearance Officer

______________________________________________________________________________

Request: The Health Resources and Services Administration (HRSA) requests approval for changes to the Healthy Start Evaluation and Quality Assurance collection (OMB No. 0915-0338 expiration date 09/30/2026).

Purpose: The purpose of this request is to obtain OMB approval to have the four forms associated with this collection translated into Spanish. The current package contains four forms (i.e., Background Form, Demographic Form, Prenatal Form, and Parent/Child Form). HRSA’s Healthy Start Technical Assistance and Support Center professionally translated the current forms into Spanish for use by grantees serving participants who are Hispanic or primarily Spanish speaking. Approximately 20 to 25 percent of Healthy Start’s participants identify as Hispanic and many of the Hispanic participants require translation services. Adding Spanish versions of our current forms enables the Healthy Start program to standardize the interview process across its grantees serving Hispanic participants, versus having them conduct their own translations that would vary greatly by site, to best enable appropriateness and accuracy in delivering the content matter and the intent of the questions and response options. It also decreases burden on the many grantee sites that serve Hispanic participants as they are not responsible for translating any information in the English forms into Spanish themselves.

This memo explains the changes and supporting rationale.

Changes: The only change to the previously approved package of four data collection forms is the addition of the same four forms translated into Spanish.

Time Sensitivity: Approving the use of the Spanish-translation forms must be completed in a timely manner to ensure that the survey data collection schedule will not experience significant delay. Approval of these changes is requested as soon as possible or by June 28, 2024, so that grantees are best able to better serve their Spanish-speaking program participants.

Burden: There is no change to burden with this request.

PROPOSED CLARIFICATIONS AND NON-SUBSTANTIVE CHANGES:

Table A

Instrument	Variable	Change implemented	Rationale
Demographic Form (Spanish version)	All content	All form content was translated into Spanish	To enable grantees to better serve Spanish-speaking Healthy Start participants and to ensure standardization in the delivery of the survey content to Spanish-speaking participants
Background Form (Spanish version)	All content	All form content was translated into Spanish	To enable grantees to better serve Spanish-speaking Healthy Start participants and to ensure standardization in the delivery of the survey content to Spanish-speaking participants
Prenatal From (Spanish version)	All content	All form content was translated into Spanish	To enable grantees to better serve Spanish-speaking Healthy Start participants and to ensure standardization in the delivery of the survey content to Spanish-speaking participants
Parent/Child Form (Spanish version)	All content	All form content was translated into Spanish	To enable grantees to better serve Spanish-speaking Healthy Start participants and to ensure standardization in the delivery of the survey content to Spanish-speaking participants

Attachments:

1. Demographic Form (Spanish) – Changes were not tracked as the entire form was translated into Spanish

2. Background Form (Spanish) – Changes were not tracked as the entire form was translated into Spanish

3. Prenatal Form (Spanish) – Changes were not tracked as the entire form was translated into Spanish

4. Parent/Child Form (Spanish) – Changes were not tracked as the entire form was translated into Spanish