Supporting Statement A

Assessment of Characteristics of State Crash Outcome Data Evaluation Systems

OSTLTS Generic Information Collection Request

OMB No. 0920-0879

Supporting Statement – Section A

Submitted: November 9, 2012

Program Official/Project Officer

Angela Salazar

Public Health Advisor

Transportation Safety Team

Division of Unintentional Injury Prevention

National Center of Injury Prevention Control

Centers for Disease Control and Prevention

Phone number: 770.488.3949

Fax number: 770.488.1371

Email: [email protected]

Section A – Justification

1. Circumstances Making the Collection of Information Necessary

Background

This data collection is being conducted using the Generic Information Collection mechanism of the Office for State, Tribal, Local and Territorial Support (OSTLTS) Survey Center (OSC) – OMB No. 0920-0879. The respondent universe for this data collection aligns with that of the OSC. Data will be collected from state health departments acting in their official capacities.

This data collection is authorized by Section 301 of the Public Health Service Act (42 U.S.C. 241). Motor vehicle crashes are a leading cause of death in the U.S. accounting for over 30,000 deaths a year. According to the National Highway Traffic Administration’s (NHTSA) Traffic Safety Facts, in 2010, there were an estimated 32,885 people killed in motor vehicle crashes. An average of 90 people died each day in motor vehicle crashes in 2010—one every 16 minutes. (Attachment A). These data are gathered using NHTSA’s Fatality Analysis Reporting System (FARS) and National Automotive Sampling System General Estimates System (NASS GES). FARS provides a census of detailed information on all qualifying fatal traffic crashes. NASS GES is a nationally representative sample, drawn and collected from police accident reports, that provides estimates on non-fatal crashes but does not link to medical injury information. Therefore, for motor vehicle crash injuries that do not result in a death but do cause an injury, there is no source of data that provides complete information. While police crash reports (Attachment B) are available at the state level and give information on the crash and factors related to the cause of the crash, these reports do not give important medical details of the injury. Medical records (Attachments C and D) give details of injury but do not have data on factors leading to the crash such as speeding or factors contributing to more severe injury such as lack of restraint use. Data from both of these types of records is needed to give a complete picture of the crash. Additionally, there is no complete, easily available source of either of these records at the national level and, availability at the state level varies. Attachments B, C, and D are included to give reviewers background information so that they may understand the project; none of the data included in these attachments will be analyzed as a part of this current project.

To keep pace with emerging public health challenges and to address the leading causes of death and disability, the Centers for Disease Control and Prevention (CDC) initiated an effort to achieve measurable impact quickly in a few targeted areas. CDC's Winnable Battles are public health priorities with large-scale impact on health and with known, effective strategies to address them. The current Winnable Battles have been chosen based on the magnitude of the health problems and our ability to make significant progress in improving outcomes. The Centers for Disease Control and Prevention identified motor vehicle crash injury as one of its six Winnable Battles (Attachment E). Also, the CDC has priorities of strengthening surveillance and epidemiology; and providing state and local support; providing analysis of state and national level data on motor vehicle crash injury fits these priorities.

NHTSA created the Crash Outcome Data Evaluation System (CODES) to quantify and report on the benefits of safety equipment and legislation in terms of mortality, morbidity, injury severity and health care costs by linking the police crash report for a crash to medical records for the occupants who were in that crash. Leading to this goal, in 1992 NHTSA sought grant applications with existing statewide crash and injury data systems that were capable of generating medical and financial outcome information if linked together (Attachment F). Any State agency, non-profit organization, or educational institution was eligible to develop and coordinate a coalition of data owners and users to perform the desired linkages. Applicants were required to demonstrate the existence and accessibility of computerized State crash, EMS, emergency department, hospital, outpatient, rehabilitative, long-term care and insurance claims data, and to work with NHTSA to implement the probabilistic linkage algorithm and ensure transfer of their linked data to NHTSA for use in preparing a report to Congress. Entities in 20 states responded to the solicitation. Hawaii, Maine, Missouri, New York, Pennsylvania, Utah, and Wisconsin were awarded grants effective October 1, 1992, to establish CODES. A NHTSA report was created using linked data from six of these original States (Attachment G). CODES became institutionalized in the awarded States based on a series of partnerships between traffic safety and public health agencies (those which own the State data) and NHTSA (who provided the software and training resources to establish linkages). Since then, States that have been able to successfully link at least two years of crash and injury outcome data have had the opportunity to apply to join the CODES Data Network, affording a unique and substantive opportunity to analyze data that would otherwise not be available. Many CODES programs are managed in the state Department of Health and those that are not have a relationship with the Department of Health through data acquisition and the CODES Board of Directors.

Since NHTSA started funding CODES, states have had varying success in linking the data and conducting useful analyses with the resulting data. Many states have produced linked data on a regular and reliable basis while others have only managed to produce data for a subset of the years they have been part of CODES. Similarly, some states have produced multiple products including journal publications and fact sheets using CODES data each year while other states tend to put out fewer products over the course of the project. NHTSA completed a white paper in 2010 describing the products created using CODES data (Attachment H). Other major products include a NHTSA sponsored analysis combining data from 18 CODES states using 2003-2005 data for a report on motorcycle helmet use and associated head and facial injuries (Attachment I). NHTSA has continued to award grants as the original States were joined by new States. Most states are now working with 2009 or 2010 data, and analyses are underway employing certain states’ combined data through 2008. In addition, some states have started conducting data linkage without being a part of the CODES program.

Since the CODES Program was initiated, grantees have been encouraged to secure in-kind funding to help support and institutionalize the CODES program in their State. Still, as of 2012 each CODES Grantee is at least partially dependent on NHTSA designated CODES funding. The fifteen CODES grantees in 2012 are in Connecticut, Delaware, Georgia, Illinois, Kentucky, Maine, Maryland, Minnesota, Missouri, Nebraska, New York, Ohio, South Carolina, Utah, and Virginia. In 2012, NHTSA made the decision to transition CODES to state level responsibility, including cessation of CODES cooperative agreements after the current agreements expire, or, in some cases, earlier than the original expiration date. NHTSA remains in favor of linkage and is encouraging expiring grantees to secure other funding sources, including possible NHTSA grants through the State Highway Safety Offices, so that the states would continue to have the advantage of linked data.

In 2010, the CDC entered into an Interagency Agreement with NHTSA with the purpose of exploring and testing the feasibility and benefits to CDC of an ongoing partnership and stake in the CODES program. This Interagency Agreement was renewed for 2011 and 2012. The CDC determined that motor vehicle crash data linked to medical records are of value in preventing injuries. Given the importance of this type of data to CDC priorities and the decisions that NHTSA has made in terms of continued funding of CODES, the current data collection was developed to identify characteristics of state programs that are associated with successful linkage and analysis, and characteristics for sustainability of programs without having the NHTSA CODES program of funded cooperative agreements.

Privacy Impact Assessment

Overview of the Data Collection System

The data collection system will be a survey using a web-based questionnaire. The MS Word version of the questionnaire is in Attachment J and a screen print of the same questionnaire in Survey Monkey, which is how it will actually be administered, is in Attachment K. The CDC and NHTSA developed questions with support from the University of Maryland School of Medicine Charles McMathias National Study Center for Trauma and Emergency Medical Services, hereafter referred to as the National Study Center, under their CODES cooperative agreement with NHTSA.

The questionnaire will be administered as a web-based data collection using Survey Monkey. The questionnaire will collect state specific information from each contact for each state that conducts data linkage. Survey Monkey is a tool that allows users to easily develop web-based surveys. With Survey Monkey, users create individual accounts that are password protected. Passwords are sent over secure, encrypted SSL connections. The questionnaire will be available for a period of two weeks. The data will then be extracted and the questionnaire closed and removed from Survey Monkey. All data will be stored at the National Study Center. All data will be available only to members of the research team, will be password protected, and will be stored on computers located behind closed locked doors. In addition, the building in which the data will be stored has security guards and requires official employee identification to enter. CDC, NHTSA, and the National Study Center will collaborate in analysis of the data.

Items of Information to be Collected –

A brief data collection of states will be conducted to collect state specific information from each state that conducts data linkage of motor vehicle crash records to medical records. The questionnaire will consist of 30 questions with 22 of the questions being close-ended and the remainder open-ended. The content categories for the questions include:

• Administration of CODES in the state including responsible boards and committees, their membership, and the member’s specific duties

• Meeting frequency of committees

• State experience in conducting linkage and analysis of CODES and similar data

• Funding sources for programs

• Involvement of CODES program with other motor vehicle and traffic agencies in the state

• Use and frequency of use of CODES data in the states

• Software packages used for CODES and proficiency in packages

• Challenges in implementing CODES

• Technical assistance related to CODES

• Data availability for CODES

2. Purpose and Use of the Information Collection

As the infrastructure of CODES will be changing due to the decision to transition CODES to state level responsibility, it is important to examine state CODES programs to evaluate how certain program characteristics relate to the state’s success in linking data and in analyzing data to produce useful products. The specific objectives of this project are to identify:

• The characteristics of state programs that have been successful in linking data.

• The characteristics of state programs that have been successful in disseminating the linked data through various products.

• The characteristics of sustainable state linkage programs.

This information can be used in the future for other motor vehicle data linkage projects to determine what characteristics are needed for a successful project. The final products for this project will include an internal report, and potentially, a journal publication and/or best practices document for a state to reference when implementing a motor vehicle linkage system. No identifiable information for any of the states, aside from the list of states participating in the project, will be published in any document.

Privacy Impact Assessment

Employees of state and local public health agencies will be speaking from their official roles and will not be asked, nor will they provide individually identifiable information other than the contact information (name, email address, phone number, mailing address) for the individual completing the questionnaire. The contact information will be associated with the data only during the time of data collection in case it is necessary to clarify questionnaire responses. Once the results begin to be analyzed; only the name of the state will be associated with the outputs. CDC, NHTSA, and the National Study Center will collaborate in analysis of the data. All data collection results will be stored and maintained at the National Study Center. Attachments C and D contain personally identifiable data – these data are used to create the CODES system and are maintained in secured storage at the state level. These data will not be used in this data collection. Any data the CDC analyzes will be in aggregate form and will not contain personally identifiable information.

No sensitive information is being collected. No individually identifiable information is being collected. No data from Attachments C and D which do contain personally identifiable information will be used in this data collection. The proposed data collection will have little or no effect on respondent privacy. Respondents are participating in their official capacity as health officials in state (District or territory) departments of health.

3. Use of Improved Information Technology and Burden Reduction

Data will be collected via Survey Monkey, a web-based questionnaire allowing respondents to complete and submit their responses electronically. Survey Monkey is a tool that allows users to easily develop web-based surveys. With Survey Monkey, users create individual accounts that are password protected. Passwords are sent over secure, encrypted SSL connections. This method was chosen to reduce the overall burden on respondents. The request to participate in the data collection will be emailed directly to the identified contact for each state with a link to the questionnaire. The questionnaire was designed to collect the minimum information necessary for the purposes of this project (i.e., limited to 30 survey questions).

4. Efforts to Identify Duplication and Use of Similar Information

In designing this data collection, we identified the information needed and then searched websites and existing CODES records such as previous presentations and reports from the states to determine if any of the information identified could be obtained from secondary sources. The information that could be obtained from secondary sources was not included on the questionnaire. We consulted with the National Highway Traffic Safety Administration (NHTSA) and determined that the remaining information had either not been collected in the past, or had not been collected recently enough to be useful for this data analysis.

5. Impact on Small Businesses or Other Small Entities

No small businesses will be involved in this data collection.

6. Consequences of Collecting the Information Less Frequently

The purpose of this request is to ensure collection of data that is not otherwise available in current, time sensitive or relevant formats to specific or emergent priorities of CDC. Specifically, without this data there would be:

• No timely feedback on the characteristics of effective state programs for linked motor vehicle crash and medical data.

• Incomplete understanding of the barriers to successful linkage of data and analysis of the same data.

• No opportunity to inform potential future data linkage projects so that successful methods can be retained and less successful methods can be recognized

• Reduced ability to fully promote state motor vehicle linkage programs which have the ability to provide information that will save lives.

This request is for a one time data collection. There are no legal obstacles to reduce the burden.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances with this information collection package. This request fully complies with the regulation 5 CFR 1320.5 and will be voluntary.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

This data collection is being conducted using the Generic Information Collection mechanism of the OSTLTS Survey Center (OSC) – OMB No. 0920-0879. A 60-day Federal Register Notice was published in the Federal Register on October 22, 2010, Vol. 75, No. 204; pp. 65353-54. Two comments were received from the Association of State and Territorial Health Officials (ASTHO), and the National Association of County and City Health Officials (NACCHO).

CDC partners with professional STLT organizations, such as the Association of State and Territorial Health Officials (ASTHO), the National Association of County and City Health Officials (NACCHO), and the National Association of Local Boards of Health (NALBOH) along with the National Center for Health Statistics (NCHS) to ensure that the collection requests under individual ICs are not in conflict with collections they have or will have in the field within the same timeframe.

9. Explanation of Any Payment or Gift to Respondents

CDC will not provide payments or gifts to respondents.

10. Assurance of Confidentiality Provided to Respondents

The Privacy Act does not apply to this data collection.

This data collection is not research involving human subjects.

11. Justification for Sensitive Questions

No information will be collected that are of personal or sensitive nature.

12. Estimates of Annualized Burden Hours and Cost

The estimate for burden hours is based on a pilot test of the questionnaire. CDC, the National Highway Traffic Safety Administration, and the National Study Center administered the pilot test by asking three personnel from these organizations that have worked with CODES, and two state CODES administrators for a total of five pilot testers to pilot test the questionnaire and keep track of how long it took to complete it. The estimated time to complete the questionnaire, including time for reviewing instructions, gathering needed information and filling out the questionnaire, was 30 minutes. A maximum of one individual in each of 35 states will participate in the data collection resulting in a total of 35 individuals.

Estimates for the average hourly wage for respondents are based on the Department of Labor (DOL) National Compensation Survey estimate for management occupations – medical and health services managers in state government (http://www.bls.gov/ncs/ocs/sp/nctb1349.pdf). Based on DOL data, an average hourly wage of $48 is estimated for all respondents. Table A-12 shows estimated burden and cost information. Eligible respondents who will be responsible for completing the questionnaire include the National Highway Traffic Safety Administration CODES grantee for CODES projects or the designated Injury Prevention Partner for non-CODES linkage project in either a state health department or a state department or university serving as a proxy for the state health department.

Table A-12: Estimated Annualized Burden Hours and Costs to Respondents – CODES Questionnaire

Type of Respondent	No. of Respondents	No. of Responses per Respondent	Average Burden per Response (in hours)	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
State Public Health Department Director of the Injury Section	35	1	30/60	18	48.00	$864
TOTALS	35	1	30/60	18	$48.00	$864

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There will be no direct costs to the respondents other than their time to participate in each data collection.

14. Annualized Cost to the Government

There are no equipment or overhead costs. An Interagency Agreement with the National Highway Traffic Safety Administration is in place and will be used to oversee the data collection and analysis. The National Study Center will provide support in developing the questionnaire with input, review, and final approval by NHTSA and CDC. There will be no additional cost above the money transferred to NHTSA in the interagency agreement Statement of Work for projects including the on-line questionnaire that includes web page development, instrument design and implementation, the data collection, data analysis and reporting. The web page development, instrument design data analysis and reporting will be implemented by the National Study Center and will be overseen by NHTSA and CDC. The costs to the government include the cost of the Interagency Agreement, the CDC Technical Monitor and the CDC Project Officer, both of whom will oversee the tasks in partnership with NHTSA. The estimated costs reflect the costs outlined in the Statement of Work and 220 hours of a CDC FTE GS-13 for oversight of the data collection development and analysis.

Table A-14: Estimated Annualized Cost to the Federal Government

Staff (FTE)	Average Hours per Collection	Average Hourly Rate	Average Cost
Technical Monitor-CDC GS-13	120	50.00	6000.00
Project Officer –CDC GS-13	60	50.00	3000.00
Technical Monitor-NHTSA GS-13	40	50.00	2000.00
Estimated Total Cost of Information Collection			11,000.00

15. Explanation for Program Changes or Adjustments

This is a new data collection.

16. Plan s for Tabulation and Publication and Project Time Schedule

Analysis will be conducted using State results from the secondary data collection and questionnaire responses. A set of constructs has been outlined and will serve as a means to identify and quantify the characteristics necessary to conduct data linkage in a self-sufficient, successful manner. The constructs will be compared to outcomes for each state of relative success in linking and in analysis to determine which constructs are related to successful outcomes. Ultimately a set of characteristics and a means for comparison to that list will be developed providing the knowledge of what is needed to implement a data linkage program before the information is lost.

√ Design data collection questionnaire (COMPLETE)

√ Develop data collection protocol, instructions and analysis plan (COMPLETE)

√

√ Prepare OMB package (COMPLETE)

√ Submit OMB package (COMPLETE)

□ OMB approval (TBD)

□ Administer questionnaire _____(Survey open 2 weeks)

□ Analyze data (2 months)

□ Prepare report (2 months)

17. Display of OMB Approval Date

We are requesting no exemption.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification. These activities comply with the requirements in 5 CFR 1320.9

LIST OF ATTACHMENTS – Section A

Note: Attachments are included as separate files as instructed.

Attachment A. NHTSA Fatality Analysis Reporting System example

Attachment B. Police crash report example

Attachment C. Sample Emergency Department record

Attachment D. Sample Inpatient record

Attachment E. Motor Vehicle Winnable Battle letter

Attachment F. Sample RFP for CODES

Attachment G. Original NHTSA CODES report

Attachment H. Catalog of CODES projects

Attachment I. Motorcycle Helmet Use CODES report

Attachment J. State Questionnaire WORD version

Attachment K. Screen print of Questionnaire