MOVE_Survey justification A(v3)[1]

MOVE! Weight Management Program for Veterans

Survey of Patient Experiences

VA FORM 10-0472

OMB 2900-XXXX

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

The legal authority for this data collection is found in 38 USC, Part I, Chapter 5, Section 527 that authorizes the collection of data that will allow measurement and evaluation of the Department of Veterans Affairs Programs, the goal of which is improved health care for veterans. The proposed data collection is part of a research study that is being conducted to evaluate the MOVE! Weight Management Program for Veterans. The data collection is necessary because not all data that is relevant to evaluating the program is collected within the patient medical record in a systematic way that allows for testing of research hypotheses in a valid and reliable fashion.

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

The Veteran Health Administration’s (VHA) national Program Office responsible for policy and oversight regarding weight management treatment (National Center for Health Promotion and Disease Prevention, Office of Patient Care Services, VHA) will use the information collected to study and evaluate the MOVE! Weight Management Program for Veterans. MOVE! is the VHA’s clinical weight management program in place at all 140 medical centers and health care systems, including many VHA community-based outpatient clinics. The MOVE! Weight Management Program for Veterans is a behaviorally-based, supported self-management program. Effectiveness of such programs is largely based on patient involvement and engagement, which makes obtaining information about patient program experiences directly from patients even more critical.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Improved information technology will not decrease the burden on the public. The information will be collected via a postal survey. Survey responses will be optically scanned using the Fast and Accurate Questionnaire Scanning System (FAQSS) designed by Optimum Solutions Corporation. We determined that a web-based data collection would not be appropriate for the proposed sample. This sample has widely varying levels of health and e-health literacy and access to the internet. Respondent burden has been minimized through rigorous selection of items, avoidance of items requiring “free text” responses, and targeted survey deployment.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

There are no data collection activities that currently collect information directly from patients about the MOVE! Program. Further much of the information proposed for collection is not regularly or systematically collected within the medical record, as it is not the kind of information that would typically be used to guide individual patient care.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

Since the proposed data collection is targeted to individual patients, it does not impact small business or other small entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

The data collection being proposed is a one-time collection as part of a research study. If not conducted, then VA will not be able to be responsive to the weight management needs of the patients it serves.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study and require the use of a statistical data classification that has not been reviewed and approved by OMB.

There are no such special circumstances.

8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The notice of Proposed Information Collection Activity was published in the Federal Register on July 16, 2009; (Volume 74, Number 135, Page 34640). We received no comments in response to this notice.

b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances which preclude consultation every three years with representatives of those from whom information is to be obtained.

Outside consultation is conducted with the public through the 60- and 30-day Federal Register notices.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift is provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Information on the form will become part of a system of records which complies with the Privacy Act of 1974. This system is identified as "Veteran, Patient, Employee and Volunteer Research and Development Project Records-VA (34VA11)" as set forth in the Compilation of Privacy Act Issuances via online GPO access at http://www.gpoaccess.gov/privacyact/index.html

11. Provide additional justification for any questions of a sensitive nature (Information that, with a reasonable degree of medical certainty, is likely to have a serious adverse effect on an individual's mental or physical health if revealed to him or her), such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

a. The number of respondents, frequency of responses, annual hour burden, and explanation for each form is reported as follows:

VA Form	No. of respondents	x No. of responses	x 15 min.	/ by 60	Number of Hours
10-0472	5,000	1	75000		1,250

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB 83-I.

This request covers only one form.

c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

The form does not require any additional recordkeeping. The cost to the respondents for completing these forms is $18,750 ($15 per hour x 1,250 burden hours).

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

a. There is no capital, start-up, operation or maintenance costs.

b. Cost estimates are not expected to vary widely. The only cost is that for the time of the respondent to complete the survey.

c. There is no anticipated recordkeeping burden.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The estimated one-time cost of this survey to the Federal Government is $77,000. This estimate is for the costs of printing, mailing, and processing returned surveys.

15. Explain the reason for any burden hour changes since the last submission.

This is a new collection and all burden hours are considered a program increase.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The results from this survey will be submitted for publication in the peer-reviewed medical literature. In addition, a final report will be disseminated within the Veterans Health Administration. The project will begin immediately upon receipt of OMB approval (anticipated by January 2010). Survey will be fielded over an approximately two-three months window. Results will be tabulated over the following four months with a final report expected no later than late fall 2010. The analytic plan includes descriptive statistics (frequencies, means, etc.), cross-tabulations, and generalized linear and logistic regression modeling. All analyses will be conducted with appropriate techniques for a multi-stage stratified cluster sampling design.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

VA requests not to display an expiration date. To display an expiration date would result in unnecessary waste of existing stock for forms. It is not cost effective for VA to pay for reprints of the form, just to change the expiration date. VA seeks to minimize its cost of collecting, processing and using the information by not displaying the expiration date.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

There are no exceptions.

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