OMB 3201-0011 Qualitative Supporting Statement A

SUPPORTING STATEMENT FOR OMB CLEARANCE

National Youth Anti-Drug Media Campaign

Qualitative Research – Supporting Statement A

OMB Control Number

3201-0011

Prepared by:

Draftfcb

100 West 33^rd Street

New York, New York 10001

On behalf of:

Office of National Drug Control Policy

Executive Office of the President

750 17^th St. NW

Washington, DC 20503

February 23, 2009

PAPERWORK REDUCTION ACT SUBMISSION

Please read the instructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 17th Street NW, Washington, DC 20503.
Agency/Subagency originating request: Office of National Drug Control Policy (ONDCP)	2. OMB control number: b. None a. 3201 --0011
3. Type of information collection (check one) a. New collection b. Revision of a currently approved collection c. Extension of a currently approved collection d. Reinstatement, without change, of a previously approved collection for which approval has expired e. Reinstatement, with change, of a previously approved collection for which approval has expired [X] f. Existing collection in use without an OMB control number For b.- f., note item A2 of Supporting Statement instructions	4. Type of review requested (check one) a. Regular [X] b. Emergency--Approval requested by: c. Delegated
	5. Small entities Will this information collection have a significant economic impact on a substantial number of small entities? Yes No [X]
	6. Requested expiration date a. Three years from approval date [X] b. Other--Specify: / /
7. Title [National Youth Anti-Drug Media Campaign (NYADMC)-Parent and Youth Qualitative Research]
8. Agency form number(s) (if applicable)
9. Keywords Drug Abuse Prevention, Youth, Parents, Communications
10. Abstract . The qualitative research described here is deployed throughout the communications development process- as a means of developing fundamental strategies, to provide initial feedback to new creative concepts and as a means of measuring message delivery against multicultural audiences.
11. Affected public (mark primary with "P" and all others that apply with "X") a. [X] Individuals or households d. Farms b. _ Business or other for-profit e. _ Federal Government c. _ Not-for-profit institutions f. _ State, Local,or Tribal govt.	12. Obligation to respond (mark primary with "P" and all others that apply with "X") a. Voluntary b. Required to obtain or retain benefits c. Mandatory
13. Annual reporting and recordkeeping hour burden a. Number of respondents: [1,248] b. Total annual responses: [1,248] 1. Percentage of those responses collected electronically: [0%] c. Total annual hours requested: [1,872] d. Current OMB inventory e. Difference f. Explanation of difference 1. Program change 2. Adjustment	14. Annual reporting and recordkeeping cost burden (in thousands of dollars) a. Total annualized capital/startup costs: [0] b. Total annual costs (O&M): [1,005,000] c. Total annualized cost requested: [1,005,000] d. Current OMB inventory e. Difference f. Explanation of difference 1. Program change 2. Adjustment
15. Purpose of information collection (mark primary with "P" and all others that apply with "X") a. Application for benefits e. _ Program planning or b. _ Program evaluation management c. General purpose statistics f. Research d. Audit g. _ Regulatory or compliance	16. Frequency of recordkeeping or reporting (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting [X] 1. On occasion [X] 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennially 8. Other (describe)
17. Statistical methods Does this information collection employ statistical methods? Yes No [X]	18. Agency contact (person who can best answer questions regarding the content of the submission) Name: [Mark Krawczyk] Phone: [202-395-6720]

SUPPORTING STATEMENT FOR OMB CLEARANCE

NATIONAL YOUTH ANTI-DRUG MEDIA CAMPAIGN

QUALITATIVE Research

TABLE OF CONTENTS

1. JUSTIFICATION

A.1 Circumstances making the collection of information necessary

A.2 Purpose and use of the information

A.3 Use of information technology and burden reduction

A.4 Efforts to identify duplication and use of similar information

A.5 Impact on small businesses or other small entities

A.6 Consequences of collecting the information less frequently

A.7 Special circumstances relating to the guidelines of 5 CFR 1320.5

A.8 Comments in response to the federal register notice and efforts to consult outside agency

A.9 Explanation of any payment or gift to respondents

A.10 Assurance of confidentiality provided to respondents

A.11 Justification for sensitive questions

A.12 Estimates of hour burden including annualized hourly costs

A.13 Estimate of other total annual cost burden to respondents or record keepers

A.14 Annualized cost to the federal government

A.15 Explanation for program changes or adjustments

A.16 Plans for tabulation and publication and project time schedule

A.17 Reason(s) display of OMB expiration date is inappropriate

A.18 Exceptions to certification for Paperwork Reduction Act submissions

A. Justification

1. Circumstances Making the Collection of Information Necessary

This submission for OMB clearance is one of three data collection instrument submissions currently up for renewal for the Office of National Drug Control Policy’s (ONDCP) National Youth Anti-Drug Media Campaign (NYADMC). The data collection instruments are used as part of the advertising development process as required by ONDCP’s 2006 Congressional Reauthorization (Public Law 109-469) that states ONDCP must “test all advertising prior to use in the national media campaign to ensure that the advertisements are effective and meet industry-accepted standards.”

All data collection instruments have been developed with input from subject matter experts in the fields of advertising and public health communication research and evaluation; have been reviewed by an Institutional Review Board (IRB) to ensure the research with human subjects is scientific, ethical, and meets Federal regulatory requirements; and are currently conducted by industry leading third-party vendors, such as Millward-Brown.

This application for OMB clearance is to cover a range of qualitative research programs intended to inform messages and strategies employed in Media Campaign communications. Since the inception of this campaign in 1999, qualitative research throughout the development of campaign communications has played a significant role in the success of the NYADMC. The qualitative research described here is deployed throughout the communications development process as a means of developing fundamental strategies, to provide initial feedback to new creative concepts and as a means of measuring message delivery against various audiences, including multicultural populations.

2. Purpose and Use of the Information

The National Youth Anti-Drug Media Campaign (the Campaign) is a social marketing effort designed to prevent and reduce youth illicit drug use by:

• Increasing awareness of the consequences of drug use

• Changing youth and adult attitudes and intentions to use drugs

• Using parenting skills to prevent youth from using drugs

• Motivating youth and adults to adopt and maintain anti-drug behaviors

To fulfill the Campaign objectives of decreasing illicit drug usage among youth, a logic model based on Social Cognitive Theory has been deployed. The role of advertising is to:

1. Raise Awareness: Parents and youth see, hear and comprehend anti-drug advertising messages.

2. Change Attitudes: After viewing the advertising, adults and youth evaluate the validity of its factual information, its social implications, and whether they believe they can effectively carry out the behaviors necessary to prevent youth/themselves from using drugs.

3. Change Intentions: Once adults and youth deem the anti-drug messages as valid, they adopt anti-drug attitudes and make a personal commitment to engage in simple anti-drug actions, or assume a drug-free lifestyle.

4. Change Behavior: Once parents and youth have committed to anti-drug behavior, they begin to adopt prevention behaviors featured in advertising, devise their own strategies and promote the behavior among peers.

To help ensure that the Media Campaign is successful in preventing illicit drug use among the nation’s youth, a variety of qualitative research programs are utilized throughout the formative stages of communications development. These include but are not limited to:

• Exploratory Research

This formative research is conducted with members of the target audience to explore experiences, attitudes, and beliefs related to campaign strategies and drug use, prior to the development of new Campaign ads. Exploratory research is conducted in focus groups each comprised of approximately eight tweens (youth ages 11-13 years), eight teens (youth ages 14-16 years), eight parents/guardians of youth ages 11-16 years, or other adults/demographics based on emerging drug threats. On an annual basis, an estimated 36 total exploratory research groups will be conducted. Findings are used to develop new Campaign ad approaches based on the most compelling arguments and information gathered from members of the target audience.

• Focus Groups Testing of Creative Concepts

In focus group testing of creative concepts, members of the target audience review Campaign ads in their conceptual stages (storyboards, scripts, etc.) to determine if ad concepts communicate intended messages in a credible, compelling way, and identify any potential communications issues. The study uses focus groups conducted throughout the year, as new ad concepts are developed, each comprised of approximately eight tweens (youth ages 11-13 years), eight teens (youth ages 14-16 years) or eight adults (parents of tweens or teens, or other adults). On an annual basis, an estimated 72 focus groups will be conducted. Findings are used to refine and finalize Campaign ads.

• Quali-Quant Evaluations

The purpose of this research is to gauge the effectiveness of new Campaign ads in terms of message communications and impact on relevant anti-drug beliefs and intentions with two hard-to-count (HTC) populations, such American Indians. The small size and limited geographic concentrations of these populations makes traditional copy testing recruitment problematic. As a result, this multicultural component of copy testing is carried out using a smaller qualitative focus group setting in conjunction with a quantitative survey typically used for larger groups. On an annual basis, an estimated 12 quali-quant focus groups will be conducted. Findings are used primarily to refine ads for regional airing.

3. Use of Information Technology and Burden Reduction

For qualitative research, as described above in A.2, there is no use of technology, given that this type of research is conducted in group discussion or interview format.

4. Efforts to Identify Duplication and Use of Similar Information

No duplicate data collections exist. The qualitative studies described here are the sole source of formative target information relative to the effective development of communications products and programs, as well as the optimization of Campaign messaging platforms and the overall strategic direction of the Campaign.

5. Impact On Small Businesses or Other Small Entities

The proposed research does not involve any small businesses or other small entities.

6. Consequences of Collecting the Information Less Frequently

To be able to effectively change attitudes, perceptions and behaviors about marijuana and other illicit drugs, the Campaign uses a wide variety of media (print, television, radio, interactive), a range of message strategies and numerous specific advertisements throughout the course of the year. Specific communications need to be regularly updated to maintain their effectiveness. Strategies need to be continually validated, and new advertising products and programs must be tested to ensure that they are properly communicating their intended messages. The proposed methodologies described here represent the minimum required to ensure ongoing campaign effectiveness against the range of target audiences.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances.

8. Comments In Response to the Federal Register Notice and Efforts to Consult Outside Agency

The ONDCP has established a network of research, behavioral science, communications and public health experts that serve as ongoing consultants to the campaign and are known as the Media Campaign Advisory Team (MCAT). Those who will be involved with shaping the campaign research include:

Social Marketing/Behavior Change Advisors

Elvira Elek, Ph. D. Prevention /Behavior Change/ Multicultural (Hispanic) target audience specialist

Kristen Holtz, Ph.D. Family/Parenting Dynamics/Youth Understanding/Drug Abuse Prevention

Leslie Snyder, Ph. D. Social Marketing and Mass Communication

Lisa Ulmer, Ph.D. Prevention and Behavior Change

Additional Core Advisors

David Brandt Practical Advertising Research, Interpretation of Quantitative Evaluation results

Philippe Cunningham, Ph.D. Family/Parenting Dynamics/Skills

Ivan Juzang Multicultural Understanding/Advertising/Branding

Larry Sheier, Ph.D Research Methodology and Theory

Peter Zollo Youth Understanding/Advertising/Branding

Ad Hoc Advisory Pool

In addition to MCAT, a pool of ad hoc advisors may participate in working groups and in special consultation on specific issues or topics. These ad hoc advisors have expertise in the range of areas described above, as well as specialized expertise in such areas as: approaches to advertising research, peer networks, mass culture, emerging media and technology, new drug threats (such as methamphetamine and abuse of prescription medications), and advertising and branding. The ad hoc advisors will supplement the MCAT as needed.

9. Explanation of Any Payment or Gift to Respondents

All respondents will be offered a monetary incentive to participate in the qualitative research described here. The amount of this incentive will typically be $50 – $75 depending on the market and youth vs. adult audience. Usually adults will receive more than youth to ensure participation, and urban participants will receive payment on the higher end of the range. Harder to recruit audiences may require incentives higher than $75. It is standard practice in commercial market research to offer recruited respondents an incentive to help assure their participation. Failure to provide a basic incentive is likely to decrease responses from individuals who are otherwise pre-disposed to be helpful. Given the anti-drug focus of the research, there is particular need for participants to be drawn from all walks of life, particularly those most likely to be at-risk for drug use.

10. Assurance of Confidentiality Provided to Respondents

Information provided by respondents will be treated in confidence and kept private. Respondents will be informed prior to participation that their responses are confidential. They will also be advised of the nature of the activity, the length of time it will require, and that participation is purely voluntary and can be terminated at will. For focus groups with youth, parents will provide written consent for their child’s participation in the focus group. Youth will provide verbal assent during screening and again before the group begins. For focus groups with adults, they will sign their own assent at the beginning of the focus group.

If the sessions are audiotaped or videotaped, the respondents will be informed. Video/audio tapes are kept in locked drawers, labeled only with the time and date of the research. Tapes will be used by the project team for reference only, and will be destroyed after use.

As a further guarantee of confidentiality, all presentation of data in reports will be in aggregate form, with no links to individuals being preserved. Although some personal information will be gathered (e.g. gender, age, race) no personal identifiers (e.g. full name, address or phone, social security number, etc.) will be collected or saved.

11. Justification for Sensitive Questions

By virtue of the focus on drug use, there will be sensitive questions for respondents. These specifically relate to the items inquiring about respondent attitudes about marijuana and other illicit drugs. These questions are necessary to determine the impact of advertising concepts and strategies on the attitudes and behaviors that the campaign is intended to change. To help ensure advertising effectiveness, it is essential to understand these reactions prior to the costly process of producing advertising and other communications programs. To protect the individual from any negative response to these questions or any fear of discovery, respondents are informed that they need not answer any question that makes them feel uncomfortable or which they simply do not wish to answer. The confidential nature of the research is stated and reinforced.

12. Estimates of Hour Burden Including Annualized Hourly Costs

Over the course of one year of qualitative research, the total hour burden is estimated at 1,368 hours as follows:

Table 1. Estimates of Annual Burden by Hours and Annualized Cost to Respondents

Audience	Number of Participants	Frequ-ency	Avg. Time Per Focus Group	Annual Burden (Hours)	Hourly Wage Rate	Annual Respondent Cost
Youth (age 11-16)	656	1	90 minutes	984	* $6.55	$6,445.20
Adults	592	1	90 minutes	888	** $14.96	$13,284.48
TOTAL	1,248	-	-	1,872		$19,729.68

* 2000 Child Labor Coalition- Current Population Survey: 26% of all 16 year-olds are employed in an average month. As a conservative estimate for this application, 50 % employment at minimum wage is assumed.

** Extrapolation based upon 2006 per capita income, 2006 Current Population Survey, U.S. Census Bureau, U.S. Department of Commerce

13. Estimate of Other Total Annual Cost Burden to Respondents or Record Keepers

There is no additional cost burden to respondents or record keepers.

14. Annualized Cost to the Federal Government

	# of Groups	Est. Cost per Group***	Total Cost
Exploratory Research	36	$11,250.00	$405000.00
Focus Groups Creative Concept Testing	72	$5,000.00	$360,000.00
Quali-Quant	12	$20,000.00	$240,000.00
TOTAL	-	-	$1,005,000.00

*** For Exploratory and Focus Groups research, the estimated cost per group is obtained by dividing the cost for recent Campaign research by the number of groups conducted. For Quali Quant, a campaign historical estimated cost per group has been used.

15. Explanation for Program Changes or Adjustments

There are no program changes or adjustments requested in this application

16. Plans for Tabulation and Publication and Project Time Schedule

While the primary purpose of Media Campaign qualitative research is to guide the development of advertising and communications programs, the ONDCP may make results available to its partners.

The data collection plan, schedule and analysis for each project will be tailored to the specific communications project and intended audience. Reporting typically takes place several weeks following the completion of the final focus group for any given project.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

The OMB Control Number and expiration date will be displayed on the consent form(s) for youth and adults.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

This submission complies with all requirements contained in 5 CFR 1320.9 and 5 CFR 1320.8(b)(3).