Justification for Change

0920-0017 Justification 10 17 10 PIF History.docx

Application for Training

Justification for Change

OMB: 0920-0017

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Justification for the modification of 0920-0017, “Application for Training”


Justification: CDC is requesting a non-substantive change to the currently approved information collection titled Participant Information Form (PIF) in order to minimize the paperwork burden for those individuals who currently attend our collaborative training events and have to fill-out more than one collection instrument. Also, see the "PIF History" section below for an explanation of when the PIF was added to OMB Control number 0920-0017.


CDC funds a group of regional centers that provides training in the diagnosis, treatment, and prevention of STDs and HIV for health care professionals and prevention specialists (e.g., clinicians, disease intervention specialists, counselors, health educators, etc.). They also partner with other federal training centers to provide collaborative training events; and during these collaborative training events, participants are required to complete more than one collection instrument.


The proposed information collection will, 1) minimize the paperwork burden for individuals attending our collaborative training events that are hosted by more than one federal agency, 2) minimize the cost to CDC of collecting, maintaining, using, and disseminating data collected during collaborative training events, and 3) maximize the usefulness of information collected by CDC during collaborative training events. Also, the proposed collection instrument will collect information to determine whether the program is providing training to the intended health professionals and prevention specialists. This information is necessary for internal CDC planning.


CDC is requesting the proposed information collection’s changes/additions be accepted as a non-substantive change to our already OMB-approved PIF information collection (0920-0017).


Changes/additions to the PIF (0920-0017).

  1. The unique ID number has increased from eight to 12

  2. Question one, two and three are now question 13, 11, and 12 respectfully

  3. Eight additional questions have been added to ensure other federal agencies’ data collection requirements are met and to minimize the paperwork burden during collaborative training events.

  4. Number of respondents: 8,975

  5. Time to complete the form: 5 minutes.



PIF History


CDC notes the following steps it took (in 2005) to add the information collection (PIF) to OMB control number 0920-0017. This is necessary because CDC has been notified that the information collection (PIF) is not one of the three information collections associated with this OMB control number despite NCHSTP's request to add it in 2005.

According to documentation from the OMB PRA - Information Collection Request (ICR) Tracking System, email correspondence, and notice of actions to and from key CDC and OMB staff (see attachments 1-6), the request to add the PIF to OMB control number 0920-0017 was received and processed by OMB in 2005-2006. In addition, CDC has been using the PIF information collection since 1) it received its notice of action on 03/02/2006 stating that the PIF has been added to OMB control number 0920-0017 and 2) since it received its notice of action extending the PIF without change on 03/02/2010.


CDC notes the history of the already OMB approved collection instrument titled Participant Information Form (PIF).

According to the OMB PRA - Information Collection Request (ICR) Tracking System:

  1. On November 16, 2005, NCHSTP requests OMB approval to add the collection instrument titled “Participant Information Form” (PIF) to OMB control No. 0920-0017; increasing the number of respondents to 45,525 from 35,525 (see attachment 1 and notation in ICR Tracking System).

  2. On 02/14/2006, change to increase the total number of respondents to 45,525 from 35,525 (as originally requested by NCHSTP on November 16, 2005) was granted by OMB (see attachment 2 and notation in ICR Tracking System).

  3. On 02/15/2006, conference call conducted to clarify the purpose of the additional form. OMB requested additional information. Additional information was sent and CDC waited for approval (see notation in ICR Tracking System).

  4. On 02/21/2006, OMB notice of approval email sent (see notation in ICR Tracking System).

  5. On 03/10/2006, Seleda Perryman emails Notice of Action adding the PIF to OMB control number 0920-0017 to key staff (see attachment 3).

  6. On 03/10/2006, program staff notified additional collection instrument (PIF) has been added to OMB 0920-0017.

  7. On 10/27/2009, NCHSTP submits request to extend collection instrument titled PIF (see notation in ICR Tracking System).

  8. On 02/04/2010, Approval Granted. PIF approved without change (see notation in ICR Tracking System and attachment 4).


In spite of the previously stated history, it is unclear why the information collection PIF cannot be downloaded from the Reginfo.gov website. CDC has attached a copy of the already OMB approved PIF (see attachment 5) and is requesting a non-substantive change to it; the proposed collection instrument (also titled Participant Information Form) that contains the proposed changes is also attached as attachment 6.


CDC notes that OMB approval for the already approved PIF (0920-0017) expires in 03/31/2013.  CDC will include the proposed information collection when it submits its next request for approval.

 


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