Justification Statement

OMB Control # 0584-0524

04/30/2013

Memorandum

Date: January 16, 2011

To: Julie Wise, OMB Desk Officer, Food and Nutrition Service

Through: Rachelle Ragland Green, Food and Nutrition Service, Information Clearance Officer; Ruth Brown OCIO Desk Officer

From: Alicia White, Senior Nutritionist, Child Nutrition Division

USDA – Food and Nutrition Service

Re: Under Approved Generic OMB Clearance No. 0584-0524

Request Approval to Perform Formative Research –

FNS Team Nutrition Curriculum Messages

_______________________________________________________________________________

The Food and Nutrition Service (FNS) of the USDA Food, Nutrition and Consumer Services is requesting approval for formative research under Approved Generic OMB Clearance No. 0584-0524.

This request is to acquire clearance for the testing of messages for inclusion in a garden-related nutrition education curriculum.

The following information is provided for your review:

1. Title of Project: Formative Research about FNS Team Nutrition Curriculum Messages

2. Control Number: 0584-0524

3. Public affected by this Project: Individuals, and State, Local/Tribal Employees

• Third and fourth grade students in schools participating in the National School Lunch Program. One-third of students will reside in a household whose income falls at or below 185% of the Federal poverty line.

• Parents/caregivers of third and fourth grade students in schools participating in the National School Lunch Program. One-third of parents/caregivers will also reside in a household whose income falls at or below 185% of the Federal poverty line.

See section 7, Project Purpose, Methodology & Formative Research Design for a description of the number of focus groups for each audience, student and parent/caregiver. The formative research focus groups will be conducted only with English-speaking audiences. Although FNS notes that nutrition messages communicated in Spanish would be useful for parents and caregivers, currently resources are insufficient to develop and test messages and supporting content in both English and Spanish.

4. Number of respondents:

There will be a total of 735 respondents: 360 parents/caregivers, 360 students in grade three or grade four (who are children of the responding parents/caregivers), and 3 school administrators and 12 classroom teachers of students in grades 3 or 4. The participants in the focus groups will be represented by (1) a qualified parent/caregiver and (2) a child enrolled in the 3^rd or 4^th grade of the same parent/caregiver. Only a parent/caregiver will participate in the screening process.

The school’s principal (one school administrator per school site) will choose two 3^rd and two 4^th grade teachers from whose classes parent/caregiver and student dyads will be selected through the screening process to participate in the focus groups to be held at the school site. The principal will provide the teachers with the direction for distributing a letter and form to be sent home with their students. The classroom teacher will be responsible for (1) distributing to students enrolled in his or her class of third or fourth grade students, a letter of invitation and a response form to their parents/caregivers to participate in a focus group, and (2) then collecting the completed forms. The teachers will collect and return the parent/caregiver forms to the evaluation contractor; they will not complete a questionnaire nor participate in the screening process.

• Recruitment will be done in four classrooms (two 3^rd grade and two 4^th grade) in each of three schools: two without a school garden, one with a school garden, and at least one with 85% or more of the students eligible for free or reduced price lunch (FRL). Each classroom will be composed of approximately 30 students. The teachers (4 teachers representing 3 schools for a total [N] =12) at each school will be provided by the principal with a class set of letters with contact forms that they will distribute to their students (N=360) to take home to their parents/caregivers (See Attachment 4: Parent/Caregiver Response Form). The total number of parents/caregivers to receive the Parent/Caregiver Response Form will be approximately 360. Of these, it is anticipated that 20% (n=72) will complete and return the form to the classroom teacher, indicating that they and their child meet the minimum criteria, and are available and interested in participating in the focus group on the specified date and time. The teacher will mail the completed forms to the contractor in the pre-addressed and pre-paid envelope provided by the contractor.

• Once the completed Parent/Caregiver Response Forms have been received, the contractor will review them to determine which parents/caregivers meet the minimum criteria specified in the Parent/Caregiver Response Form. Those that meet the minimum criteria (approximately 80% or 58 parent/caregivers) will then be screened using the Screening Telephone Questionnaire (see Attachment 5: Protocol for Administration of Screener Guide). In order to seat 8 to 10 students and 8-10 parents/caregivers per focus group at each of the three sites (for at total of 24-30 students; 24-30 total parents/caregivers), 12 students and 12 parents/caregivers will be recruited. Only the parent/caregiver will be screened using the Screening Telephone Questionnaire for the purpose of establishing the student and parent/caregiver dyad, and only a dyad composed of one parent/caregiver and his/her child in 3^rd or 4^th grade will be allowed to participate in the focus groups at one school site. It is anticipated that the screening telephone questionnaire will take an average of 15 minutes to complete. This includes the time for non-responders who may terminate early.

Each focus group will consist of 8 to 10 participants, for a total of 48-60 participants. A description of the groups is provided in the table below.

Focus Groups

Target audience	Number of groups	Number of participants per group	Total number of participants
3rd-4th grade Student Participants	3	8-10	24-30
Parents/Caregivers	3	8-10	24-30
Total	6		48-60

5. Time needed per response:

In the table below, Time Needed Per Initial Parent/Caregiver Response Form, the time noted is an average of the response time for each target audience. Principal involvement includes inviting and giving direction to teachers to assist with distribution and collection of Parent/Caregiver Response Form. Teacher involvement includes distribution of the letter and Parent/Caregiver Response Form to students in his/her 3rd or 4th grade class, collection of the completed forms, inserting the completed forms in the pre-stamped, pre-addressed envelope, and placing the envelope in the outgoing mailbox at the school’s office. Student involvement includes only receiving the letter and form from the teacher, taking the letter and form home to a parent/caregiver, and returning (if completed by a parent/caregiver) the Parent/Caregiver Response Form to the teacher.

Time Needed Per Initial Parent/Caregiver Response Form

Target audience	Time (minutes)	Time (hours)
Principals (N=3)	10	0.16
Teachers (N=12)	15	0.25
Students (N=360)	10	0.16
Parents/Caregivers of Elementary School Students: Responders (N=72)	8	0.13
Parents/Caregivers of Elementary School Students: Non-Responders (N=288)	2	0.03

Time Needed Per Screening Telephone Questionnaire

Target audience	Time (minutes)	Time (hours)
Students	N/A	N/A
Parents/Caregivers of Elementary School Students (N=58)	15	0.25

Due to the young age of the student participants (8 to 10 years of age), no time is required of the students for the screening telephone questionnaire. Only a parent/caregiver will participate in the screening. This one screening telephone questionnaire will determine the attributes of the participants of each of the two focus groups.

Time Needed Per Focus Group

Target audience	Time (minutes)	Time (hours)
Student Participants (N= 24-30)	60	1.00
Parents/Caregivers (N=24-30)	60	1.00

6. Total Burden Hours on Public:

(a) Affected Public	Respondent Type		(b) Survey Instruments	(c) No. Respondents	(d) Frequency of Responses	(e) Est. Total Annual Responses per Respondent (c x d)	(f) Hours Per Response	(g) Total Burden Hours (e x f)
	Principals		Distribution of Parent/Caregiver Response Form to Classroom Teachers	3	1	3	0.16	0.48
	Classroom Teachers		Distribution & collection of Parent/Caregiver Response Form	12	1	12	0.25	3.0
Individuals & Households & and State, Local/Tribal Employees	Students		Distribution of Parent/Caregiver Response Form	360	1	360	0.16	57.6
		Student Responders	Focus Group (including Student Reaction Form)	(30)	1	30	1.00	30
	Parent/Caregiver Responders		Parent/Caregiver Response Form	72	1	72	0.13	9.36
			Screening Telephone Questionnaire*	(58)	1	58	.25	14.5
			Focus Group (Including Parent Reaction Form, Agreement on Security of Comments & Consent Agreement)	(30)	1	30	1.00	30
	Parent/Caregiver Non-Responders		Parent/Caregiver Response Form	288	1	288	0.03	8.64
Total				735		735		153.6

*Includes burden for those answering none or part of the questions.

6. Project Purpose, Methodology and Formative Research Design:

Background

FNS administers the nutrition assistance programs of the United States Department of Agriculture (USDA). The mission of FNS is to provide children and low resource families better access to food and a more healthful diet through its nutrition assistance programs. Among these programs are the Child Nutrition Programs, including the National School Lunch Program (NSLP), School Breakfast Program (SBP), Summer Food Service Program (SFSP), and the Child and Adult Care Food Program (CACFP). The Child Nutrition Programs provide nutritionally balanced, low-cost, or free meals and snacks. Team Nutrition is an FNS initiative that supports the Child Nutrition Programs through training and technical assistance for foodservice, nutrition education for children and their caregivers, and school and community support for healthy eating and physical activity.

Through the Team Nutrition Initiative, FNS develops curriculum and related resources that support Team Nutrition’s behavior-oriented strategy of “providing multifaceted, integrated nutrition education for children and their parents.” Such curricula are designed to build skills and motivation for children to make healthier food and physical activity choices as part of a healthy lifestyle.

FNS is currently developing garden-related nutrition education lessons that promote fruit and vegetable consumption while meeting education standards for academic course content in third and fourth grades. These lesson plans will fill a need for a national nutrition education curriculum that connects and reinforces farm-to-school, school garden, and school meal initiatives.

The lessons will specifically address key factors research has shown to be predictive of children’s fruit and vegetable intake: preference and taste, availability and accessibility of fruits and vegetables in the school and home environment, and food preparation skills. The lessons will support efforts designed to increase fruit and vegetable intake among children – particularly intake of dark green and orange vegetables and increase awareness of how fruits and vegetables are gown.

Purpose

The purpose of the proposed formative research is to obtain feedback from students in the third and fourth grades and their parents/caregivers on key messages that will be communicated through garden-related nutrition education lessons and featured in take-home parent/caregiver materials. The messages will focus on motivating children to consume fruits and vegetables featured in the lessons and encourage parents and caregivers to model healthy behaviors related to nutrition, specifically gardening and produce preparation and consumption.

Qualitative research will verify that the developed messages are behavior-focused, clear, credible, actionable, relevant, useful to the intended audience -- and ultimately, compel audiences to take action.

Methodology/Formative Research Design

The table below outlines the formative research design, and the subsequent sections outline the approach in more detail.

Target audience	Research Methodology
Students	3 focus groups (n=24-30)
Parents/Caregivers	3 focus groups (n=24-30)

The methodology applied will be a formative research design using focus groups to allow for in-depth exploration of three sample messages designed to motivate students to consume fruits and vegetables and three sample messages to encourage parents/caregivers to model healthy behaviors related to nutrition, specifically gardening and produce preparation and consumption. This approach also allows the Agency to capitalize on the small group dynamics to generate new insights regarding garden-related nutrition education activities. In-person focus groups will be the methodology used for parent/caregiver and student audiences.

A professionally trained moderator will guide participants through the discussion to glean information about the messages associated with this effort. The three messages will be presented in a poster format with written expressions and artwork/graphics (Attachment 8). The formative focus group Moderator’s Guides (Attachments 1 and 2) will serve as a tool to guide the group conversation during the focus group sessions. All focus group questions and probing follow-up inquiries (to clarify focus group participants understanding of questions and responses) will be standardized. For consistency across all school sites, the same questions and procedures for implementing both the parent and caregiver focus groups, and student focus groups will be applied.

The in-person research among students and parents/caregivers will span three communities in three different regions of the United States in order to maximize the geographic and ethnic diversity of participants. The communities are 1) Shreveport, LA; 2) Pittsburg, KS; and 3) Los Angeles County, CA. In each community, two focus groups will be conducted at one elementary school: one for eight to ten 3^rd and 4^th grade students, and one for eight to ten of the parents/caregivers of these students. A total of six focus groups will be implemented: three for students and three for parents/caregivers.

Design/Sampling Procedure

The sample will include two different audiences: students in the 3^rd and 4^th grades and their parents/caregivers, applying purposive and convenience sampling procedures. All participating schools will be participating in the National School Lunch Program, with one having at least 85% of the students eligible for the program to ensure representation from low resource communities. Two school sites will not have a school garden and one will have a school garden. The rationale for this design is to increase the rigor of the evaluation by comparing and contrasting the differing participants’ perspective of garden-related nutrition messages. Site selection of one school (Louisiana) that is >75% African American, and a second school (California) that is >75% Hispanic will ensure a high degree of racial and ethnic diversity across all schools selected. School data will be used to determine a balance of race/ethnicity of students across the schools.

Only students and parents/caregivers that speak and read English will be recruited. Although FNS notes that nutrition messages communicated in Spanish would be useful for parents and caregivers, currently resources are insufficient to develop and test messages and supporting content in both English and Spanish.

Participating parents/caregivers will have a child in the 3^rd or 4^th grade that attends the school and participates in the student focus group. Recruiting across the three parent/caregiver focus groups will ensure a balanced representation of grades (3^rd and 4^th), gender, and race/ethnicities. Parents/caregivers will also be screened for employment-related conflict of interest (employment with school district food services and/or USDA, market research company, produce farming, grocery or convenience store operation, diet and/or nutrition experts, health and fitness business), special dietary needs, age (minimum of 21 years), and child care/transportation needs, among other factors. Only one parent/caregiver per child will be allowed to participate.

Site Selection

The focus group sessions, scheduled for February 2011, will be conducted in three communities: Shreveport, LA, Pittsburg, KS, and Los Angeles County, CA. The sites for formative research testing were chosen because they represent three geographically different areas of the country and include both urban and more rural locations.

Recruitment of Participants

With approval from the school site principal, two classrooms of 3^rd grade students and two classrooms of 4^th grade students from each school will participate in the recruiting process. A memo will be provided to the classroom teacher (Attachment 3) along with the Letter of Invitation and Parent/Caregiver Response Form (Attachment 4). The teacher will send the letter and form home with the students to give to their parents/caregivers. This recruiting strategy will be used because schools typically will not release students’ telephone numbers and addresses due to privacy concerns addressed in the Family Educational Rights and Privacy Act (FERPA). The letter will include a description, purpose, length, time, location, amount of stipend, and other details of the activity. Interested parents/caregivers who both meet the initial criteria (specified in the letter) and are available to participate in the focus group will return the response form to the teachers. After the due date for returning the forms, the teachers will mail the completed forms to the contractor in a preaddressed, stamped envelope previously provided. The evaluation team will use this form to select parents/guardians to call and administer the screening telephone questionnaire. Selection will be done to ensure a balance of grades and gender of participating students. During this contact, evaluation staff will follow the Protocol for Administration of Screener Guide (Attachment 5) to confirm that the parent/guardian and student meet all the criteria for participation in the focus group. Through the screening process, a select group of parents/caregivers will be confirmed for participation in the focus groups. Note that a more detailed description of the recruitment process is provided in Section 4 above. As noted above, selection of one school (Louisiana) that is >75% African American, and a second school (California) that is >75% Hispanic will ensure a high degree of racial and ethnic diversity across all schools selected.

Confirmation of Participation. A follow-up letter of confirmation will be mailed to parents/caregivers who have agreed to participate in the focus group with their child who is a student in 3^rd or 4^th grade. The letter will thank the participant for being an important part of the focus group, remind them of the date, time, and location of the focus groups, and provide other information about scheduling, as needed. One day prior to the focus group the parents/caregivers will be contacted via phone, as indicated on the Parent/Caregiver Response Form, to remind them of the focus group date, time and location.

Incentives. Parent/caregiver participants will receive a cash stipend of $50.00 as reimbursement for expenses such as transportation and childcare costs (for other children not participating in the focus groups). Student participants will receive a token incentive worth $1.00 to $3.00 to enhance their participation and engage them in the focus group discussion. The tokens provided will not endorse a particular team or product. The selection of these amounts comes from the past experience of the evaluators in the recruitment of families for participation in an after-school focus group.

System of Record FNS-8, FNS Studies and Reports, published in the Federal Register on 4/25/1991 at 56 FR 19078, covers personal information collected under this study and identifies safeguards for the information collected.

Focus Group Sessions

Time. The parent/caregiver and student focus groups will last for a total of 60 minutes. The first 15 minutes of the focus group session, the parents/caregivers and their children will convene in one room for an introduction to the focus group process and ground rules. Then, the parents/caregivers will be taken to a different room for their focus group. The parent/caregiver focus groups (including the completion of a reaction form and focus group discussion) will last 45 minutes. The student focus group will last 30 minutes. It needs to be shorter in length because the young age of the participants (8 to 10 years) limits their ability to focus on the evaluation activity for any longer. Students will be held in their groups an additional 15 minutes while their parent/caregiver is completing their focus group. During this time, the students will be engaged in games provided by the contractor.

Materials. Each focus group will include three visual aids: posters with nutrition education messages (Attachment 8). In all sessions, a trained moderator will facilitate discussion as described in the Moderator’s Guide: Student Focus Group and Moderator’s Guide: Parent/Caregiver Focus Group (Attachments 1 and 2).

Consent. Included in the parent/caregiver focus group is time for completing the Agreement on Security of Comments Form (Attachment 6) and Parent/Caregiver Consent Form (Attachment 7). These forms were previously approved by OMB under FNS Core Nutrition Messages Concept Testing ICR Reference No: 200709-0584-003 (OMB control number: 0584-0524). They have been modified here only to reflect the content of the focus groups.

Data Analysis

Focus groups will be audio-recorded using professional equipment and the information collected will be used to inform the final nutrition education messages. The key findings will be presented in a report for future reference.  Respondents will be informed that the sessions are recorded. Recordings will be transcribed, with no names being associated with individual respondents' comments. Notes taken while watching all focus group sessions and transcripts of audio recordings will serve as the primary methods of data collection.  Focus group transcripts will be reviewed for recurring themes stated across multiple focus groups and respondents.

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.  No names will be associated with individual respondents’ comments in the final report.
No attempt will be made to generalize the findings to be nationally representative or statistically valid.

Outcome

Information and formative input gathered from the specific target audiences through the formative research will help to understand which messages are most effective at motivating the target audience to take action. FNS may decide to publish summary findings of the focus group research either electronically or in print, but such documents will not include information that personally identifies focus group participants.

6. Confidentiality: Using the Agreement on Security of Comments Form (Attachment 6), participants will be informed of confidentiality and privacy act provisions before responding to the screener. System of Record FNS-8, FNS Studies and Reports, published in the Federal Register on 4/25/1991 at 56 FR 19078, covers personal information collected under this study and identifies safeguards for the information collected.

6. Federal Costs: Contract costs: $41,734.00

6. Research Tools/Instruments:

Attachments

1. Moderator’s Guide: Parent/Caregiver Focus Group

A. Parent/Caregiver Reaction Form (Attachment 1.A)

B. Moderator Reporting Form: Parent/Caregiver Focus Group (Attachment 1.B)

2. Moderator’s Guide: Student Focus Group

A. Student Reaction Form (Attachment 2.A)

B. Moderator Reporting Form: Student Focus Group (Attachment 2.B)

3. Memorandum to Principals and Classroom Teachers

A. Memorandum to Principals (Attachment 3.A)

B. Memorandum to Classroom Teachers (Attachment 3.B)

4. Parent/Caregiver Response Form

5. Protocol for Administration of Screener Guide

6. Agreement on Security of Comments Form

7. Parent/Caregiver Consent Form

8. Visual Aids for Focus Groups

10