Justification Memo

Memorandum

To: Julie Wise, OMB Desk Officer, Office of Management and Budget

Through: Rachelle Ragland-Greene, FNS Information Clearance Officer and

Ruth Brown, OCIO Desk Officer

From: Robert Post

Deputy Director

USDA, Center for Nutrition Policy and Promotion

Re: Under Approved Generic OMB Clearance No. 0584-0523

Request Approval to Conduct Focus Groups to Inform Public Communication about the 2010 Dietary Guidelines for Americans (DGA)

______________________________________________________________________________

The Center for Nutrition Policy and Promotion of the USDA is requesting approval for formative research under Approved Generic OMB Clearance No. 0584-0523.

Based on Departmental review and comment, this revised OMB submission is being completed as requested by the Office of the Secretary. The information provided reflects revisions to the method, content and images submitted in May 2010 under OMB Control Number 0584-0523 and information collection reference number 200910-0584-002.

The following revised content and information is provided for your review:

1. Title of Project: Formative Research to Inform Public Communication about the Dietary Guidelines Messages.

The research includes consumer in-person focus groups to explore Dietary Guidelines 2010 nutrition topics to be conducted in September 2010.

2. Control Number: 0584-0523, expiration date 12/31/2012.

3. Public affected by this Project:

• Focus Groups on Message Concepts and New Nutrition Images. Parents with at least one child 5-12 years old who reside in households in which the income falls between $15,000 and $100,000 will be asked to provide feedback on nutrition concepts based on the priority health recommendations from the 2010 Dietary Guidelines Advisory Committee report. A total of 12 focus groups will be conducted in Baltimore, MD, Dallas, TX and Sacramento, CA in June 2010. There will be 8 participants in each focus group for a total of 96 participants.

July – August Focus Group	Number of Focus Groups Per Location
Phase	Baltimore, MD		Dallas, TX	Sacramento, CA	Total
Message Concepts and New Nutrition Images with Adults	4		4	4	12
Total Number of Focus Groups					12
Total Number of Participants					96

4. Time needed per Response:

Consumer focus groups:

Screening: Based on the assumption that screening 15 people will yield one participant for the groups, the burden hours associated with screening for the focus groups is 240 hours (10 minutes x 1,440 = 14,400 minutes = 240 hours).

Focus Groups – Message Concepts and New Nutrition Images: Based on the assumption that the average length of the discussions will be 110 minutes per participant, plus an additional 10 minutes to complete the confidentiality form for a total of 2 hours per respondent, the burden hours associated with 96 focus group participants is 192 hours (120 minutes x 96 = 11,520 minutes = 192 hours).

Total burden hours associated with the data collection is 432 hours.

Background

As mandated by Congress, the Dietary Guidelines for Americans (DGA) are developed and released jointly by USDA and HHS every five years to assure the public that they receive the most current, scientifically sound nutrition advice available. [Public Law 101-445, Section 301 (7 U.S.C. 5341), the National Nutrition Monitoring and Related Research Act of 1990, Title III]. The Dietary Guidelines for Americans (DGA) are evidence-based Federal recommendations designed to prevent and reduce diet-related chronic diseases, while promoting good health and healthy weight among Americans ages two and older.

USDA’s Center for Nutrition Policy and Promotion (CNPP) is currently leading four concurrent and complementary tracks, many in cooperation with other key government agencies. These are outlined below.

TRACK I: 2010 Dietary Guidelines for Americans

The Dietary Guidelines form the basis for all federal nutrition policy and education. Sponsored by USDA and the Department of Health and Human Services (HHS), the Guidelines are updated every five years and offer the most current, science-based information about diet, physical activity, and other nutrition and food safety issues that affect the health and well-being of the American public. Primary target audiences for the Guidelines are those intermediaries that disseminate nutrition information to consumers including government agencies, health professionals, nutrition educators, researchers, and journalists. Activities under track one include:

• The 2010 Dietary Guidelines for Americans “policy document” scheduled to be released by December 2010, will be developed based on the Dietary Guidelines Advisory Committee (DGAC) Report released June 15, 1010.

• A consumer launch and campaign to showcase consumer-based tools, resources, and materials based on the 2010 Dietary Guidelines is planned for 2011. Products from tracks II (Guidelines messaging), III (next generation food pyramid), and IV (new online interactive tools) are likely to be featured.

TRACK II: Research on Dietary Guidelines Messaging

A robust research plan with consumer (parents and children) and health professional populations on communicating the new Guidelines is currently underway. Iterative in nature, this plan employs various qualitative and quantitative methodologies (i.e., literature review, environmental scan, surveys, focus groups, ethnographic online “immersion”, and stakeholder discussions and blog forums) to develop actionable messages that resonate with families and the message multipliers who communicate with them. Quantitative validation will be completed with 4,000 consumers (oversampling for low-income and low-literacy) and 600 health professionals. The research will inform message development to address priority areas presented in the 2010 DGAC Report:

1. Reducing overweight and obesity by decreasing calorie intake and increasing physical activity;

2. Shifting eating patterns to emphasize vegetables, cooked dry beans and peas, fruits, whole grains, nuts, seeds, seafood, fat-free and low-fat milk products, and moderate amounts of lean meats, poultry, and eggs;

3. Reducing intake of foods containing added sugars, solid fats, sodium, and refined grains;

4. Meeting the 2008 Physical Activity Guidelines for Americans.

TRACK III: Research on Food Guidance System (next generation food pyramid)

The Food Guidance System, an educational system designed to translate the Dietary Guidelines, is being revised to help consumers build overall healthy eating patterns by allowing them to select foods that meet their dietary needs through food groups. The Food Guidance System is just one important and widely-recognized tool in a diverse network of resources used by the Federal Government to help consumers implement healthy eating practices.

• Current system includes a food pyramid symbol to cue consumers to supporting educational resources, nutrition/physical activity messages and personalized tips, and extensive online interactive healthy eating tools.

• The focus groups will explore potential alternative images. This research is designed to identify the best national icon for healthy eating.

TRACK IV: Online Interactive Tool Modernization

CNPP is currently building an extensive online interactive application for personalized diet and physical activity planning, assessment, and analysis.

• The new suite of tools will serve as the Federal answer to the call for Americans to put the 2010 Guidelines into practice.

• The application will serve all audiences and broaden the user base with personalized functionality and use of up-to-date web and wireless technology.

Please see the table below for a detailed description of all qualitative and quantitative research activities.

Research Activity	Description	Timeline
STAKEHOLDERS MEETINGS (Track II)	Discussion of current and future dietary guidance messaging Federal Agencies MyPyramid Partners	September 2009 (completed)
TELEPHONE DISCUSSIONS (Tracks II & III)	Discussion of current and future dietary guidance messaging and MyPyramid Federal Agencies Education and Public Health Professionals Media Former DGAC Members Industry Competition	January 2010 –March 2010 (completed –final reports under review)
LITERATURE REVIEW (Track II)	Review of knowledge, understanding, use of dietary guidance concepts, as well as lessons learned and best practices to consider Market research Media Analysis Environmental Scan	January 2010- May 2010 (completed – final reports under review)
EXPLORATORY FOCUS GROUPS FOR ADULTS (Tracks II & III)	Testing of DGA concepts and messages relevant to adults Overarching NEW Graphic DGA Concepts Adult consumers – parents with children 5-12 years old is the key audience 3 Cities – Baltimore, Dallas, Sacramento Research intended to be iterative so that the messages/concepts/graphics tested later in this round of focus groups can be informed and “tweaked” based on earlier findings.	September 2010 (Subsequent timeline is highly influenced by OMB approval of this round of focus groups. The release of the Dietary Guidelines Policy Document is also highly contingent on an approval within the next 1 to 2 weeks.)
ONLINE IMMERSION W/ BREAK OUT FOCUS GROUPS (Tracks II & III)	Putting Dietary Guidelines and next generation food pyramid messages, tools, and resources into practice in a family setting Participants include: Families - Primary shoppers Women and Men 50/50 mix of w/ and w/o kids Geographic, Age, Socioeconomic mix Follow-up online focus groups	October 2010
QUANTITATIVE SURVEY (Tracks II & III)	Validating messages and images to project findings to US population 4000 Consumers (oversampling for low-income and low-literacy individuals) 600 Professionals 20 minute Web based Testing	November 2010

Methodology for Focus Groups (Tracks II and III)

Focus Group Objectives:

Consumer Messages

• Identify consumers’ knowledge and understanding of basic nutrition concepts and terms for the DGA.

• Understand consumers’ success and challenges in achieving behavior change and why:

  • Determine what lifestyle changes consumers are making/have made to improve their personal and family nutrition and physical activity, why they are making them, and how they remain successful in continuing these healthier behaviors.

  • Determine what it would take to get consumers to implement nutrition and PA changes if they have not already made changes.

• Identify nutrition messages that may motivate consumers to change their behavior

• Qualitatively explore new icon concepts as a cue to healthy eating to determine improvements toward greater consumer use and application.

• Inform subsequent phases of DGA formative research.

Methodology, Design and Data Analysis:

Screening: CNPP will conduct focus groups among 96 adults in three locations. In selecting locations and recruiting participants, we will ensure geographic diversity to represent a range of American communities, as well as socioeconomic and attitudinal diversity among consumers (e.g., consumers with varying knowledge- and interest-levels regarding nutrition). The focus group sessions will be conducted in-person. Each participant will be asked to attend a single session. Participants will be recruited in each of the three cities in which we will conduct research by local recruiting resources in those cities. Participant positions will be filled through use of opt-in databases of local residents that they maintain. Interested participants will be screened by professional recruiters to assure that they meet the specific target audience requirements required by the research.

Incentives for participants: Focus group participants are typically provided with an incentive – usually a cash or check payment at the close of their research session. The standard rate provided by commercial facilities begins at $75 for general consumers, plus, at times, additional reimbursement for parking and/or travel expenses. We anticipate the total incentive/travel reimbursement offered to each adult participant to be between $75 and $100.

Confidentiality: Participants are assured by the research facility, and always by the moderator at the beginning of each group, that their names and responses are kept confidential, and will not be disclosed to anyone but the individuals conducting research in this investigation, except as otherwise required by law. They are also assured that no one will try to sell them anything following this research.

Outcome:

The focus group data will be reviewed for recurring themes and report on those identified during the review. Preliminary and final summary reports will be provided for all research components. A final summary report of the surveys will be both descriptive and quantitative in nature. Findings will be used to modify messages and materials if necessary to respond to the needs of the CNPP constituencies. Differences across group location and audience will be noted when appropriate, but given the qualitative nature of this research, findings will be considered descriptive and directional but not definitive.

We also intend to develop an article for publication based on the results of the research components, as we believe the research will be of interest to nutrition and health professionals who read journals such as the Journal of Nutrition Education and Behavior.

5. Federal Costs: $100,000 for the focus groups

6. Requested Approval Date: July 2, 2010

7. Formative Research Tools:

   1. Screening questionnaire for parent focus groups (attachment A)

   2. Consumer Message Concepts parent focus group discussion guide (attachment B)

   3. Confidentiality Statement (attachment C)