This collection is disapproved at this time. Under the requirements of the Paperwork Reduction Act, a collection of information must serve an agency purpose, meet a specific need, have practical utility, and not unnecessarily duplicate available information.While the approval request demonstrates a clear need to collect information on efforts to provide effective health care services to patients of various ethnic/racial backgrounds, the collection fails to demonstrate that it serves an agency purpose and that it has practical utility. There are two reasons that the collection fails to meet the "purpose" criteria. First, OMB has serious concerns about the underlying purpose of the study. As stated in the approval request, the data gathered will "provide HRSA with an infromation base in making the future resource and staffing decisions realted to reducing the barriers to health care often faced by limited-Enlish speaking populations." This statement points to the central assumption underlyign this study: that cultural competence in health care is reflected in the ethnic/racial composition of the staff at health care centers. We seriously question the validity of this assumption. We are particularly concerned that HRSA would make staffin decisions based on this assumption, without providing any evidence that the ethnic/racial composition of providers should be used as a measure of culturally competent health care service. Second, the data gathered fromthe study will not inform on the stated purpose of the information collection. The states purpose is to assess the race/ethnicity of the staff and client of community healht care centers, and to assess teh provision of services to bi/mulitlingual populations in the community health centers. In addition, the survey seeks to "determine exisitng barriers that prevent patients of various ethnic/racial bckgrounds from receiving proper health care." This study is not structured to asssess the provision of services to the health centers; nor will it adequately identify existing barriers in the provision of health care services. The survey instrument does not include enough questions about services to adequately meet the stated goal of the collection. Similarly, it fails to adequately address several potential barriers to health care, including language, transportation, and child care servces. For example, while most questions aim to identify the ethnic/ racial composition of the health center clientele, none of the questions ask respondents to identify the langauges spoken by the clientele. This information would be a crucial first step in assessing the degree to which language acts as a barrier in the delivery of health care services. Because the collection does not gather data that informs on the stated purpose of the study, this colleciton fails to demonstrate that it has practical utility. However, OMB beieves that this is an important effort -- we see a clear need to identify the barriers in the provision of health care services to ethnic/racial minorities. For this reason, we strongly encourage HRSA to work to make the appropriate revisions.
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Inventory as of this Action
Requested
Previously Approved
10/31/2000
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The purpose of this study is to collect information on the racial/ethnic composition of health care center users and providers, as well as information on the composition and provision of bi/multilingual services. These data will provide information on efforts to provide effective health services for speakers of languages other than English.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.