Appendix D - MIECHV Statewide Needs Assessment Update 60 day comments

From: Hart, Kristi
Sent: Wednesday, June 5, 2024 11:30 AM
To: HRSA Paperwork
Subject: [EXTERNAL] Response to Federal notice
I would like to provide the following questions and comment to the federal register notice about the
HRSA Statewide Needs Assessment Update:
- Will HRSA be providing updated data tables to facilitate updating of needs Assessment Updates?
- We would like to request sub-population level data that is NOT county-based, such as data Race,
Ethnicity and Language, as well as data related to refugee immigration and Native American
populations not residing on tribal lands to support awardees in identifying sub-populations
within communities requiring focused outreach and attention, that may not rise to the level of
significance when viewed at a county level.
- If updated data will not be provided, additional funds to facilitate the work required to update
Needs Assessments will be necessary. The needs assessment update was and will again be laborintensive. Many awardees do not have the internal resources to conduct this work.
o These funds should be ADDITIONAL, and should not be expected to be drawn from
already anticipated grant awards or funds intended for service delivery or program
administration.
o If additional funds cannot be obtained, consider reallocating funds associated with an
All-Grantee Meeting to awardees top be allocated for Needs Assessment Updates.
- While a needs assessment update may be helpful, if new data changes the communities
identified as at-risk due to improvements since the prior data was collected, removing services
from previously served communities could cause a regression in those communities. The reopening should include an allowance for continuing services at a reasonable level in
communities identified by the 2020 Needs Assessment update, in recognition that providing
resources is the exact reason for communities seeing improvements.
Kristi Hart
(She/ her/ hers)
Home Visiting Administrator
Maternal and Child Health Section
Division of Public Health Services
NH Department of Health & Human Services
29 Hazen Dr. Concord, NH 03301
Work Cell Phone: (603)491-5399
Fax: (603)271-4519
Email: kristi.hart@dhhs.nh.gov

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Ms. Maria Button, Director
Executive Secretariat, Office of Operations
Health Resources and Services Administration
Rockville, MD 20857
Agency Information Collection Activities: Proposed Collection: Public Comment Request;
Information Collection Request Title: The Maternal, Infant, and Early Childhood Home Visiting
Program Statewide Needs Assessment Update
July 22, 2024
Dear Ms. Button,
The Association of State and Tribal Home Visiting Initiatives (ASTHVI) appreciates the
opportunity to comment on the next update of the needs assessment under the Maternal,
Infant, and Early Childhood Home Visiting (MIECHV) program. ASTHVI understands there are no
changes proposed in this next needs assessment update, and that HRSA is seeking comment on
the administrative burden on states and Tribes wishing to update their assessment. However,
ASTHVI members would like to offer feedback on the assessment’s content and highlight
opportunities for further improvement in service of families in at-risk communities.
State administrators believe that the structure and rushed nature of the report’s submission
timeline does not allow adequate time for reflection and analysis given the complexity of
determining which communities are truly “in need.” Many counties that are impoverished
simply do not meet the determined threshold; other counties that perhaps have improved and
risen above the thresholds are, in many ways, being penalized for doing so, as their services are
subsequently revoked.
Administrators have also shared examples of communities in need identified based on
indicators that are not considered by the assessment, and their inability to designate

communities with legitimate need because of the limitations of the criteria outlined in the
assessment. For example, the criteria create difficulties serving populations experiencing
homelessness, who are unable to stay in the same geographic area long-term. These challenges
are compounded by the rush to submit the needs assessment update–this last round was due
the same month it was released–which left little time for states to do more than the bare
minimum of analysis. The lack of flexibility and rushed nature of the needs assessment
unintentionally contributes to inequities in provision of services.
ASTHVI members strongly recommend the immediate addition of a provision permitting
continued services in a community if a needs assessment update finds that community to be
marginally above the threshold. Every geographic area has some level of need, and allowance
should be made for the needs assessment to reflect this fact. ASTHVI members additionally
believe it imperative that a method of demonstrating need outside of a data threshold, and
measuring genuine community engagement, be quantified and implemented as soon as feasible
into the needs assessment, perhaps through additional opportunities for comment or listening
sessions. Equity means something different to every grantee, and the needs assessment could
be more equitable with more flexibility on what to emphasize and explore within the report.
ASTHVI shares HRSA’s understanding that the needs assessment is a critical and foundational
resource providing essential information to state and Tribal administrators in identifying and
serving families in need. We appreciate the opportunity to share the feedback that ASTHVI
members provided, in the spirit of improving this assessment and ensuring it continues to serve
all families in need.
Sincerely,
Catriona Macdonald
Catriona Macdonald, Executive Director

Commissioner
Stephanie Muth
July 23. 2024

HRSA Information Collection Clearance Officer
Room 14N39
5600 Fishers Lane
Rockville, Maryland 20857
RE: Information Collection Request Title: The Maternal, Infant, and Early Childhood Home Visiting
Program Statewide Needs Assessment Update—OMB No. 0906-0038—Revision
To Whom It May Concern:
The Texas Department of Family and Protective Services, as the MIECHV program awardee for the state
of Texas, submits the following comments for consideration to the request for information on the
MIECHV statewides needs assessment update.
1. Necessity and utility of the proposed data collection for the proper performance of the agency’s
functions.
DFPS supports the opportunity to update our MIECHV needs assessment to expand the number of at-risk
communities eligible to receive MIECHV-funded grants for evidence-based home visiting services. With
the increased funding from our most recent MIECHV award, in addition to an increase in state general
revenue for home visiting, Texas is now serving 47 out of 59 eligible at-risk communities. Should Texas
receive additional match funding in the next grant cycles, the Texas MIECHV program is prepared for
additional growth and expansion to address remaining gaps in home visiting availability, limited
saturation in larger communities, and limited reach in rural and remote areas of Texas. We intend to
update the statewide MIECHV needs assessment in 2025 to account for shifting demographics,
population growth, and changes in community context.
2. Accuracy of the estimated burden
Texas will continue to work with The University of Texas Health Science Center at Houston to update the
Texas MIECHV needs assessment, in conjunction with an update to Texas’ community maltreatment risk
maps (non-MIECHV funded). PEI produces the risk maps to identify and allocate resources across our
family support programs (MIECHV and others) to communities and families that could most benefit from
them. The risk maps provide zip code level data on risk factors related to child maltreatment such as
Family Poverty, Health & Disability, Child Safety & Health, Low Income, and Low Education. The risk
maps form the basis of the Texas MIECHV Needs Assessment, which also looks at the quality and
capacity of existing programming and unmet needs to identify priority communities for Texas MIECHV.
Our research partners estimate that the needs assessment update will require 500 hours.

4900 North Lamar Blvd. • P. O. Box 149030 • Austin, Texas 78714-9030 • 512-929-6900 • www.dfps.texas.gov

An Equal Opportunity Employer and Provider

RFI – MIECHV Needs Assessment
July 23. 2024
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3. Ways to enhance the quality, utility, and clarity of the information to be collected
Texas receives the largest MIECHV grant at almost $27 million. We currently support 25 MIECHV Local
Implementing Agencies (with an additional 21 subgrantees) and are implementing eight home visiting
models. We are a large state both geographically, with 254 counties, as well as in population. Our
recommendation to HRSA as it develops all requirements, opportunities, and guidance is to keep in mind
the challenges for larger states compared to smaller state programs. The amount of information gathering
and analysis required for a state of our size to effectively understand and represent the diverse needs of
children, families, agencies, and communities is significant.
4. Use of automated collection techniques or other forms of information technology to minimize the
information collection burden
We have longstanding relationships with research partners, such as the University of Texas, who are able
to assist us with evaluation efforts and the needs assessment and may not utilize other tools. Our
rcommendation would be that these be available, but not required, and allow states to conduct the needs
assessment to meet their own unique needs building on their existing resources and capacity, within
requirements.
Thank you for the opportunity to respond to this information request.
Respectfully,

Claire Hall
Claire Hall
MIECHV Project Director
Division of Prevention and Early Intervention
Claire.hall@dfps.texas.gov

July 23, 2024
Submitted via email to paperwork@hrsa.gov.
Re: Agency Information Collection Activities: Proposed Collection: Public Comment Request; Information
Collection Request Title: The Maternal, Infant, and Early Childhood Home Visiting Program Statewide
Needs Assessment Update (89 FR 45903)
To Whom It May Concern:
Start Early appreciates the opportunity to offer information in support of the U.S. Department of Health
and Human Services (HHS) Health Resources and Services Administration (HRSA) regarding its proposed
Statewide Needs Assessment Update for the Maternal, Infant, and Early Childhood Home Visiting
(MIECHV) program. Our comments focus on promoting both cross-system coordination and state
utilization of needs assessment data.
About Start Early
Start Early is a non-profit, public-private partnership that works to advance quality early learning for
families with children, before birth through their earliest years, to close the opportunity gap. Thousands
of young children, parents, and members of the early childhood workforce are reached each year
through our programs, training, evaluation, and advocacy efforts.
We do this work with a recognition that advancing equity in early childhood access, use, participation,
and outcomes for young children and their families is inextricably tied to advancing equity and justice
for people of color and communities that have been under-resourced and divested from. Our home
visiting priorities include ensuring adequate support and compensation for a diverse workforce,
centering family and provider voice in program and system improvement, and fully integrating home
visiting into the early learning system and continuum of supports for pregnant and parenting people.
Recommendations
Promoting Cross-System Coordination
We encourage HRSA to consider how the MIECHV Statewide Needs Assessment can support states in
cross-system coordination and collaboration efforts. For example, we encourage HRSA to ask states
about the specific strategies (e.g. relaxing program income guidelines) they use to encourage crossprogram and cross-system referrals for families. Additionally, while we recognize that states are
required by the MIECHV authorizing statute to leverage their Title V MCH Block Grant, Head Start, and
CAPTA needs assessments for identification of at-risk counties, we also encourage HRSA to list states’
PDG needs assessments as an additional, optional point of comparison that could promote collaboration
across programs and systems that serve the prenatal-5 population. Whereas other data sources (e.g.
the Head Start needs assessment) requires states to aggregate program- or local-level data before using
it to make decisions at the regional or state levels, using the state-level data in the PDG needs
assessment is unlikely to create significant burden for state leaders and is likely to complement the
other needs assessments already mentioned in statute.
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Supporting State Data Utilization & Decision-Making
We recognize the importance of gathering statewide needs assessments for the MIECHV program and
applaud HRSA’s efforts to use that data at both the state and national levels to articulate the ongoing
need for this critical work. We also encourage the agency to gather input from state leaders on how
they are actively using the data in their MIECHV statewide needs assessments and what changes or
guidance would allow the needs assessment data to be used more effectively. From our partners in
state systems across multiple states, Start Early has received the feedback that because states do not
have the capacity to update their state needs assessments frequently but are required to use the
assessment for decision-making purposes, they are sometimes unable to make decisions flexibly using
real-time data. For example, if many families served by MIECHV-funded programs move to another
county due to economic or other factors, the needs assessment may appear to indicate that one county
has unused MIECHV-funded program slots (which could be interpreted as a lack of need for
programming), while clients’ new home county does not appear on previous needs assessments at all.
We encourage HRSA to solicit additional feedback on these types of challenges and provide additional
guidance to states in order to ensure that the critical information included in the MIECHV state needs
assessments can be used to respond to the evolving needs of communities.
Conclusion
Thank you for consideration of the above comments. For additional information, please contact Nadia
Gronkowski, Policy Manager at Start Early, 33 W. Monroe Street, Suite 1200, Chicago, Illinois 60603,
ngronkowski@startearly.org.
Sincerely,

Yvette Sanchez Fuentes
Senior Vice President, National Policy
Start Early

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