UNITED STATES DEPARTMENT OF AGRICULTURE
INDEPENDENT ASSESSMENT OF THE DELIVERY OF
TECHNICAL AND FINANCIAL ASSISTANCE
PART B
CONTRACT AG-3142-C-09-0030
OMB CONTROL NUMBER 0503-NEW
Customer Focus Groups; Community Based Organizations; and Approved Insurance Providers and Brokers/Agents
Table of Contents
Page
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
B.1 Respondent Universe and Sampling Methods 1
B.2 Procedures for the Collection of Information 7
B.3 Methods to Maximize Response Rates 8
B.4 Tests of Procedures or Methods 8
B.5 Consultations on Statistical Aspects of the Design 9
List of Tables
Page
Table 2 States to be Included in the Focus Groups 6
Table 3 Estimated Number of Focus Group Participants 7
COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
1. DESCRIBE (INCLUDING A NUMERICAL ESTIMATE) THE POTENTIAL RESPONDENT UNIVERSE AND ANY SAMPLING OR OTHER RESPONDENT SELECTION METHOD TO BE USED. DATA ON THE NUMBER OF ENTITIES (E.G., ESTABLISHMENTS, STATE AND LOCAL GOVERNMENT UNITS, HOUSEHOLDS, OR PERSONS) IN THE UNIVERSE COVERED BY THE COLLECTION AND IN THE CORRESPONDING SAMPLE ARE TO BE PROVIDED IN TABULAR FORM FOR THE UNIVERSE AS A WHOLE AND FOR EACH OF THE STRATA IN THE PROPOSED SAMPLE. INDICATE EXPECTED RESPONSE RATES FOR THE COLLECTION AS A WHOLE. IF THE COLLECTION HAD BEEN CONDUCTED PREVIOUSLY, INCLUDE THE ACTUAL RESPONSE RATE ACHIEVED DURING THE LAST COLLECTION.
NOTE: This Information Collection is not a statistical sampling or analysis; per OMB guidelines, this section supplements Part A with further description of the methodology.
Respondent Universe
The data required for sampling include state, county, and basic demographic information about the potential customers (who are predominantly women and/or minorities), CBOs, and/or AIPs that includes contact details, such as an address and telephone number. In the final report, we will observe and comment on the potential limits on the findings in these information collections arising from the non-responsiveness of non-participant ranchers and farmers, and those customers, potential customers, and individuals who applied for, but were denied technical or financial assistance, and those who declined to participate.
Neither the focus groups nor the CBO or AIP interviews will produce, or are intended to produce, results that are quantitative or representative in nature. Rather, they will produce qualitative, anecdotal information. As explained more fully below, the States covered by this Assessment were selected for a variety of reasons including that they had high concentrations of women and minority farmers and ranchers, and historically high rates of civil rights complaints. This selection process was not intended to result in a sampling representative of the farmer/rancher population as a whole. Instead, it was intended to collect anecdotal information, primarily from women and minority farmers and ranchers so that the Assessment Team will have experiential information to provide it with a better understanding of how the various USDA programs operate from some customers’ perspectives, and complaints, issues, positive experiences, and the like within the relevant State. An inter-agency team consisting of high-level officials participated in a source selection process that recommended to the Secretary their choice of the responsive contractor for this task. On September 30, 2009, Secretary Vilsack announced the award of a competitive contract to the Jackson Lewis Corporate Diversity Counseling Group (JL Team) for an independent, 12-month assessment of program delivery by FSA, RD, NRCS, and RMA in 14 states. The 14 states initially selected by USDA were California, Washington, New Mexico, Georgia, Arizona, Montana, Michigan, Oklahoma, North Dakota, Pennsylvania, Florida, Louisiana, North Carolina, and Vermont. The states were selected by an interagency USDA Team applying the following criteria: (1) several States from each Region; (2) highest concentrations of African-American, Hispanic, Asian, Native American, and women customers; and (3) historic rates of civil rights complaints. Geographic locations of Focus Group States range from California to North Carolina, and North Dakota (and Vermont) to Louisiana. The Contract was recently modified to include Mississippi and South Carolina – States with high concentration of African-American farmers and historically high numbers of civil rights complaints – and eliminate Montana (for budgetary reasons) from the Assessment. Thus, the Assessment now covers 15 USDA-selected States.
For each of the USDA-selected states, USDA identified six counties within each State to be included in the Assessment (“selected counties”). The following data were used by USDA to choose which counties in each State would be most beneficial in terms of meeting the objectives of the Civil Rights Independent Assessment: income levels, male to female ratio, disability, race, cross-section of races, location and production of farms to ensure a variety of small, medium, and large farms, and the median household income of the county. Data about the number of discrimination complaints were also utilized. The counties were reviewed and approved by USDA leadership. In the final report, Jackson Lewis will observe and comment on the potential limits on the findings in these information collections arising from including only six counties within fifteen States in the Assessment and limiting, as discussed below, the focus group participants to six counties within ten States of the fifteen USDA-selected States. This information, along with USDA employee interviews; reviews of USDA policies, procedures and methodologies; review of internal and external complaints and lawsuits; USDA documents and information; regulations; and, statutes, will provide Jackson Lewis with information that will be useful to anecdotally characterize the effectiveness of USDA functioning and identify recommendations and methodologies to assist in ensuring that programs are delivered equitably and that access is afforded to all constituents, with particular emphasis on women and minority farmers, ranchers, and other constituents. The Team will produce a final comprehensive report, including a thorough written analysis of their findings and applicable law, and will conclude with specific recommendations to assist the USDA Secretary in making the appropriate changes.
Focus Groups
Because of budgetary constraints, USDA determined that focus groups could be conducted in only 10 of the 15 selected States. Data used to select the 10 focus group States included data from the 2007 Census of Agriculture Report (“2007 Ag Census”), posted on the USDA website, and from a spreadsheet USDA developed detailing the number of Title VI discrimination charges filed in the 15 States between 2008 and 2010 against the applicable USDA Agencies (FSA, RD, NRCS, and RMA).
The percentages of farmers/ranchers by protected category (African-American, Hispanic/Latino, Native American, Asian, and women) were calculated separately for each State, using Ag Census “principal operators” data. The number of principal operators for a given State was divided into the number of principal operators for a protected category to determine the percentage the protected category constituted of all principal operators in the State.
Using Louisiana as an example, Louisiana’s Ag Census “Table 54. Selected Farm Characteristics by Race of Principal Operator: 2007 and 2002” (“Table 54”) was used. The number of African-American principal operators listed in Table 54 for 2007 (1,914) was divided by the number of principal operators for 2007 (30,106) resulting in the percentage of African-American principal operators in Louisiana of 6.4%. The same calculations for each of the States were performed and then ranked from 1 to 15, with 1 being the State with the highest percentage of African-American principal operators and 15 the lowest.
In determining the Average Annual Civil Rights Complaints per 100,000 Customers, a similar process was followed. The number of complaints for a State was divided by 3 (the number of years covered). The result was divided by the number of principal operators in the State; to arrive at the percentage of complaints per 100,000, the product was multiplied by 100,000. The States were ranked from 1 to 15, that is, high percentage to low percentage.
In calculating the Total Score Rankings, the States’ ranking numbers for each of the six categories (4 races/ethnicity, 1 gender, 1 civil rights complaint). The States were then ranked from the highest total to the lowest. The highest scores represented the lowest cumulative ranking and, therefore, the least relevance to the Assessment. These calculations were used as a starting point for discussions with USDA on the Focus Group State selection process. Additional anecdotal input was obtained by USDA. The focus group States were then jointly selected by Jackson Lewis and USDA from among the 15 total States, based on highest concentrations of minorities and/or women, and geography (so that there would be States in the four geographic regions of the United States).
The respondent universe for the focus groups will predominantly1 include women and minority customers, within the 10 focus group States, who were customers, or submitted applications during the past three years for technical and/or financial assistance programs administered by USDA through the Farm Service Agency (FSA), Natural Resources Conservation Service (NRCS), Rural Development (RD), and/or Risk Management Agency (RMA). These USDA women and minority customers, including those that have been denied service in the past, will be eligible to participate in the focus groups. The states the participants will be chosen from are listed in Table 2. The number of total participants for the 30 focus groups ranges from 300 to 450 and is shown in Table 3A.
The respondent universe will be determined by separate lists, produced by each of the four Agencies, of individuals and organizations. These lists will be composed of customers and potential customers who, in the past three years, either applied for or received technical or financial assistance from the applicable Agency. The lists provided by the Agencies are a compilation of information collected in the ordinary course of doing business. Included in the lists are all individuals who, within the past three years, were unsuccessful applicants, or are customers, or potential customers.
The lists will be limited to the USDA customers who live within the 10 focus group states and, further, the six counties within those focus group states. The separate customer lists provided by USDA for each Agency will include demographics such as race/ethnicity and gender, program information, dates of participation, and addresses/contact information.
The individual lists will be sorted by sex and minority status. An attempt will be made to have two white male farmers/ranchers participate in each focus group. This is so their views are provided as to whether they appear to be treated in the same manner, or differently, as women and minority farmers/ranchers. They will be randomly selected. The remaining individuals for each focus group will be randomly selected in proportion to approximate their percentage of representation in the women and minority farmers/ranchers within a state. For example, assume the number of women and minority farmers/ranchers in a state constituted 10% of all of the state’s farmers/ranchers; further, assume that women constituted 80% of the women and minority, farmers/ranchers in the state. The goal would be for 80% of the focus group members, not including the two white males, to be women. Within each protected category the participants will be selected randomly. Random selection will be conducted in a standard manner whereby a computer program takes the applicable classification e.g., African-American, and produces a random list of African-Americans who reside in the six counties of the applicable focus group State.
Recruiting Goals:
Recruitment will be for 15 members for each group (assuming up to a 20% no-show rate, allowing for at least 12 participants per group).
Groups will have a mix of race/ethnicity and be reflective of the minority and female farming/ranching population in the region.
Through the random selection process, as described above, it is anticipated that the Groups will have a mix of loan/program participation from each of the 4 Agency offerings.
Participants will be paid $50 for their participation.
To the extent possible, Community-Based Organizations will be accessed to identify members who do not participate in USDA programs because of perceived unfairness or discrimination, and several such members may be included in each group.
Moderators
Most of the moderators will be senior Jackson Lewis attorneys2, all of whom are USDA Civil Rights Assessment Team members and are thus well-educated on the tasks and issues involved in this Assessment. The moderators are exceptionally diverse in both race/ethnicity and gender, including two African-American males, an African-American female, a Hispanic male, an Asian female, a Native American female, and two white males. This diversity will be critical to effective dialogue with diverse customers regarding issues of discrimination, equity, and fairness. The team is highly-experienced in public speaking, including jury “focus groups,” trials, group training, and moderating. Additionally, all moderators will participate in a training session/refresher course in focus group moderation, offered by an experienced consultant. Their knowledge of the basic issues will be important to effective management of the Focus Group participants. As one example: If a farmer begins describing a complex interaction he had with a County Committee regarding a loan, the moderator will know that this experience happened well before the three-year period preceding the focus group (as required by the Focus Group Questions Document (“Questions Document”), because County Committees have not been involved in loan processing for the past decade. Thus, the moderator can get the discussion back on focus and avoid wasting time. There will be other instances where knowledge of the organization of USDA, its programs and history, and the issues in this Assessment will be helpful to directing the discussion—within the confines of the Questions Document—most effectively. We have no concerns about moderators’ knowledge and expertise diverting them from the questions contained in the Questions Document because they only will ask questions included in the Questions Document.
CBO Interviews
The respondent universe for the CBO interviews will include CBOs in the 15 USDA-selected Assessment States whose members are predominantly women and/or minorities. USDA State/local offices for each Agency provided a list of CBOs with whom they had contact within the past three years. We are ranking CBOs by subpopulations of interests (women and minority) and state in which they operate and selecting the top 270. CBOs will be recruited to reflect minority/female status of their organizations, locations near large concentrations of women and minority customers, and based further on recommendations of USDA State and County representatives. The goal is to have the CBOs distributed evenly among the 15 States; however, because of the higher number of farmers and ranchers in Assessment States such as California, it is possible that CBOs in the States with higher concentrations of ranchers and farmers may constitute proportionally more of the CBO pool than smaller Assessment States. The aim is to conduct 90 interviews. Only one person from each of the selected CBOs will be interviewed. The CBO will be asked to designate for interview an officer or member who the CBO determines would be most knowledgeable in terms of answering questions on behalf of the CBO’s members. The range of 60 to 90 interviews is given because it may become clear at some point during the selection process, or during actual interviews, that particular CBOs cannot provide any information that could be useful to the Assessment. Also it is expected that some CBOs that commit to be interviewed will not actually be available/willing to be interviewed.
It is estimated that only one-third or 33% of the CBOs contacted will agree to participate in the interviews. Thus, to secure a maximum of 90 interviews, that number was multiplied by three (90 X 3). From the list of 270, CBOs will be selected based on their proportion within the women and minority farmers and ranchers within the applicable state. For example, if in a given state women constitute 80% of the women and minority farmers/ranchers, the target would be to recruit, from the list of 270, which has been sorted by focus, CBOs whose focus is on women’s issues for 80% of the CBOs to be interviewed for that state. In the final report, when discussing comments made during the CBO interviews, we will disclose the approximate (so as to maintain confidentiality) number of members of the CBO that made the comment.
AIP Interviews
There will be two types of AIP interviews. The first type will be the AIP itself (“AIP Company Interview”). The second type will be agents/brokers (“Agent Interviews”) from each of the four to six selected AIPs. The respondent universe for the AIP Company Interviews will include all 16 AIPs who sell and service RMA policies and their agents/brokers. Lists of the 16 AIPs and individual information about the AIPs are public and readily available on the USDA/RMA website. The target is to conduct six AIP Company Interviews. If, because of lack of cooperation of the AIPs, we are unable to secure six AIP Company Interviews, we intend to conduct a minimum of four such interviews Selection of AIPs will be based on geographic location of office(s) and the AIPs’ customer base (large concentrations of women and minority producers).
With respect to the AIP Company Interviews, a corporate officer of each selected AIP will be asked to designate an individual to be interviewed who is the most knowledgeable about the actual AIP’s outreach and marketing efforts aimed at women and minority farmers and ranchers. The purpose of the AIP Company Interviews is to collect direct, qualitative information from the AIPs about the AIP programs and services, how AIPs identify and market to potential customers, and AIP practices with respect to women and minority customers and potential customers..
The second set of interviews (Agent Interviews) will focus on what programs and services the individual agents/brokers provide, how they identify and market to potential customers and the agents’/brokers’ practices with respect to women and minority customers and potential customers. (. With respect to the Agent Interviews, several agents/brokers from each selected AIP will be interviewed. They will be selected on geographic location of office(s) and the agents’/brokers’ customer base (large concentrations of women and minority producers) from a list supplied by USDA of the AIP’s agents/brokers who service one or more of the six counties within each of the fifteen Assessment States. A comprehensive list of agents/brokers and the states and counties each serve is posted on the USDA/RMA website. The number of total participants for the Agent Interviews ranges from 14 to 56, with 56 being the target number; however, the range provided is to account for the possibility that fewer than the desired number of agents/brokers will agree to be interviewed.
Table 2. States to be included in the Focus Groups
STATE |
Arizona |
California |
South Carolina |
Georgia |
Louisiana |
Mississippi |
New Mexico |
North Carolina |
North Dakota |
Oklahoma |
Table 3. Estimated number of Focus Group participants
Number of states |
Number of focus groups per state |
Number of participants per group |
Total number of participants |
10 |
3 |
10 |
300 |
10 |
3 |
11 |
330 |
10 |
3 |
12 |
360 |
10 |
3 |
13 |
390 |
10 |
3 |
14 |
420 |
10 |
3 |
15 |
450 |
2. DESCRIBE THE PROCEDURES FOR THE COLLECTION OF INFORMATION INCLUDING:
- STATISTICAL METHODOLOGY FOR STRATIFICATION AND SAMPLE SELECTION;
- ESTIMATION PROCEDURE;
- DEGREE OF ACCURACY NEEDED FOR THE PURPOSE DESCRIBED IN THE JUSTIFICATION;
- UNUSUAL PROBLEMS REQUIRING SPECIALIZED SAMPLING PROCEDURES, AND
- ANY USE OF PERIODIC (LESS FREQUENT THAN ANNUAL) DATA COLLECTION CYCLES TO REDUCE BURDEN.
Procedures for Collection of Information
Using the lists comprising primarily women and minority customers; CBOs whose members are primarily women, or minority, or dissuaded individuals, and AIPs provided by each of the four USDA agencies, a smaller group of up to 2250 potential participants will be drawn for the focus groups3, 270 for CBO interviews and 60 for AIP interviews respectively. Factoring in the expected lower response rate for focus groups, the potential participants selected for recruitment will be designed to ultimately yield 300 to 450 participants. The potential participants selected for CBO interview recruitment will be designed to yield 60 to 90 participants. The potential participants selected for AIP interview recruitment will be designed to yield 20 to 60 participants.
3. DESCRIBE METHODS TO MAXIMIZE RESPONSE RATES AND TO DEAL WITH ISSUES OF NON-RESPONSE. THE ACCURACY AND RELIABILITY OF INFORMATION COLLECTED MUST BE SHOWN TO BE ADEQUATE FOR INTENDED USES. FOR COLLECTIONS BASED ON SAMPLING, A SPECIAL JUSTIFICATION MUST BE PROVIDED FOR ANY COLLECTION THAT WILL NOT YIELD "RELIABLE" DATA THAT CAN BE GENERALIZED TO THE UNIVERSE STUDIED.
Achieving a high response rate involves locating the sample members and securing participation. Below we describe procedures to be followed to maximize the number of sample members who agree to participate in the focus groups, CBO interviews, and AIP interviews:
An advance letter will be mailed followed by a telephone call within 3 days of the mailing.
Prior to the scheduled focus group and/or interview we will call each respondent to remind them to attend.
The following procedures will be used to maximize the attendance of focus group and interview participants.
Schedule calls at different times of the day and week, to improve the chances of finding a respondent at home or office.
Leave a message on answering machines in order to let the respondent know the call was not a marketing effort but a research study and to accommodate customers who prefer to call back.
Provide a toll-free number for respondents to call to verify the study’s legitimacy or to ask other questions about the study. Those without telephones in their homes can also call this number from any location.
Require many unsuccessful call attempts
to a number without reaching someone before considering whether to
treat the case as “unable to contact.”
4. DESCRIBE ANY TESTS OF PROCEDURES OR METHODS TO BE UNDERTAKEN. TESTING IS ENCOURAGED AS AN EFFECTIVE MEANS OF REFINING COLLECTIONS OF INFORMATION TO MINIMIZE BURDEN AND IMPROVE UTILITY. TESTS MUST BE APPROVED IF THEY CALL FOR ANSWERS TO IDENTICAL QUESTIONS FROM 10 OR MORE RESPONDENTS. A PROPOSED TEST OR SET OF TESTS MAY BE SUBMITTED FOR APPROVAL SEPARATELY OR IN COMBINATION WITH THE MAIN COLLECTION OF INFORMATION.
No tests will be conducted.
PROVIDE THE NAME AND TELEPHONE NUMBER OF INDIVIDUALS CONSULTED ON STATISTICAL ASPECTS OF THE DESIGN AND THE NAME OF THE AGENCY UNIT, CONTRACTOR(S), GRANTEE(S), OR OTHER PERSON(S) WHO WILL ACTUALLY COLLECT AND/OR ANALYZE THE INFORMATION FOR THE AGENCY.
Because this is a qualitative information collection, there were no statistical aspects of the design.
Contractor Jackson Lewis LLP will actually collect and/or analyze the information for USDA. The contact person for Jackson Lewis is Deputy Project Manager John M. Bryson, II and his contact telephone number is 703-483-8318.
1 As discussed below, two white male farmers/ranchers will be included in each of the focus groups. They will be selected randomly, as defined above, from the lists provided by each Agency.
2 The non-attorney is Karen Atkinson, a Native American female and the President of Tribal Strategies, Inc., a subcontractor to JL.
3 The individuals contacted and selected will be roughly in proportion to their representation among women and minority customers in the USDA-selected States and counties.
| File Type | application/msword |
| File Modified | 2010-09-24 |
| File Created | 2010-09-24 |