OMB Justification Memo

Memorandum

Date: June 22, 2015

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: Jessica Larson, Senior Nutritionist, Center for Nutrition Policy and Promotion (CNPP)

USDA – Food, Nutrition and Consumer Services

Re: Under Approved Generic OMB Clearance No. 0584-0523 Request for Approval to Perform Formative Research to Develop Communication Strategies to Promote Healthy Eating Among Americans

Center for Nutrition Policy and Promotion (CNPP) of the USDA Food, Nutrition, and Consumer Services is requesting approval for formative research under Approved Generic OMB Clearance No. 0584-0523.

This request is to acquire clearance to conduct formative research in order to develop communication strategies for future CNPP efforts to promote healthy eating among Americans based on the upcoming Dietary Guidelines for Americans 2015.

The following information is provided for your review:

1. Title of the Project: CNPP Journaling and Focus Groups

2. OMB Control Number and Expiration Date: 0584-0523, Expiration Date: 1/31/2016

3. Public Affected by this Project: Americans between the ages of 18 and 49 (Generational cohorts X and Y) with a BMI of less than 35. Participants will include both English- and Spanish-speaking individuals, and a mix of gender, race and income. See section 7, Project Purpose, Methodology & Formative Research Design for a description of the number of participants necessary for the research methodology. The definitions of the public affected by this project are identified in the screening instruments (see Attachments A.1 and A.2 and E.1 and E.2). The definitions of the audiences are identical for the journaling and focus group phases of the research.

4. Number of Respondents:

CNPP will contact 1,536 individuals and households. Out of those, approximately 432 will participate. Responder estimates per activity are based on anticipated response rates of 50% for Journaling and 25% for In-Person Focus Groups. We estimate that 48 participants will participate in Journaling. Of these, 18 participants will participate in the homework assignment and 12 will participate in Journaling follow-up groups (75%). One hundred and ninety-two (192) individuals will be recruited to participate in in-person mini focus groups and will be asked to complete the homework assignment. Of these, 144 (75%) will participate in focus group discussions. CNPP estimates there will be a total 3,102 responses annually from 1,536 individuals contacted by CNPP (1,924 responses + 1,178 unsuccessful responses from 1,104 non responders).

Table 1: Number of respondents

CNPP, along with our contractors, will contact approximately 1,536 individuals and households to recruit:

• 24 participants for the journaling exercise in English

• 24 participants for the journaling exercise in Spanish

• 12 participants for three follow-up groups with journaling participants (in English only) with four participants each, with six recruited for each group

• 96 participants for 12 mini-focus groups (English) with six participants each with eight recruited for each group to assure quorum

• 96 participants for 12 mini-focus groups (Spanish) with six participants each with eight recruited for each group to assure quorum

For all mini-focus groups, 8 participants will be recruited for each of the 12 groups to seat a quorum of six. Recruitment criteria and methodology are discussed in the Recruitment section below. Since all recruited participants will be asked to complete the pre-discussion assignment (homework), the burden estimate for homework is based on the number of participants recruited, whereas the burden for focus group participation is based on the number of participants seated (72). Similarly, six participants will be recruited for the three journaling follow-up groups, seating four in each group. Thus, the burden hours for pre-discussion activity is based on the number of individuals recruited (18 total), whereas the participation hours in post-journaling groups is based on the number of participants seated (12).

The journaling exercise and follow up discussion groups with journaling participants will be conducted online using existing technologies suited for these purposes. The journaling exercise will employ an online discussion platform (QualBoard®) which includes a mobile app, allowing respondents to access and answer questions at their convenience via computer, tablet, or smart phone. It also includes a mobile journaling tool called LifeNotes which allows respondents to provide open-ended posts in response to research team questions. The use of journaling tools will allow the research team to recruit participants from different geographic areas (see Section 7, Recruitment Strategy). Electronic records provide an efficient way to capture qualitative data for further analyses. Respondents can access this online discussion at a website that has not yet been developed. CNPP will provide this information once it has been developed. We estimate that the development of the site will take one week before data collection.

Virtual journaling tools also reduce respondents’ burden compared to traditional journaling in several ways:

• Participants make entries to specific discussion questions rather than keeping an ongoing diary.

• Participants can more easily make these entries at their convenience, as opposed to having to submit responses via a desktop computer alone.

• Participants can skip questions that are not applicable to their situation (e.g., not describing a social situation if they are eating alone).

• Any clarifying probes by research staff are targeted based on specific responses by respondents.

Virtual focus groups with journaling participants will be conducted using existing virtual meeting platforms such as GoToMeeting® or Adobe Connect® (see Attachment D.1, Moderator Guide). Follow-up focus groups will be conducted only with respondents who completed the journaling task in English. Since we expect the journaling participants to be recruited from different geographic regions, virtual focus groups are the only feasible methodology to engage them in an in-depth discussion. Respondents will need a web camera (valued at $40) to participate in this discussion group. The camera will be provided at no cost to respondents who do not own one, and will be theirs to keep. Provision of the camera is essential to assuring participation of lower income participants. Asking participants to return the camera will place additional burden on the respondents. Furthermore, the cost of shipping the camera back and labor costs associated with recovery will further increase the cost of the study and the overall shipping and processing costs may in fact be higher than the cost of the camera itself. Therefore, participants will not be asked to return the camera.

5. Time Needed Per Response:

Journaling: Using guides presented in Attachments B.1 (English) and B.2 (Spanish), journaling participants will participate for 14 calendar days for 15 to 20 minutes per day for two weeks.

Journaling follow-up homework assignment: Prior to the follow up groups, participants will be asked to complete the homework assignment outlined in Attachment C.1.A.1 The homework will take 30 minutes to complete and will be an essential part of the discussion.

Journaling follow-up focus groups: Individuals participating in follow-up discussion groups will spend approximately 120 minutes responding following the discussion guide presented in Attachment D.1.

In-person focus group homework assignment: The homework assignment is an essential component of the discussion and will take participants about 30 minutes to complete. The homework assignment is similar to that for the journaling focus groups and is presented in Attachments E.1.A and E.2.A

In-person focus groups: Participants will engage in a 90-minute in-person group discussion addressing topics outlined in the moderator guide (Attachments F.1 and F.2).

The table summary of estimated burden hours is presented below.

Table 2: Burden Hours

6. Total Burden Hours on Public: 779

7. Project Purpose, Methodology, and Formative Research Design:

Background

This year, the U.S. Departments of Agriculture and of Health and Human Services will release the Dietary Guidelines for Americans 2015 policy document, which is the cornerstone of Federal nutrition programs. Updated every five years, the Dietary Guidelines for Americans (DGA) serve as the nation’s authoritative recommendations regarding recommended calorie consumption, making informed food choices, and being physically active to attain and maintain a healthy weight, reduce risk of chronic disease, and promote overall health. Recommendations from the DGA are intended for Americans ages 2 years and older, including those at increased risk of chronic disease.

The USDA Center for Nutritional Policy and Promotion (CNPP) is collaborating with HHS’s Office of Disease Prevention and Health Promotion (ODPHP) to develop communication strategies to promote healthy eating among Americans based on the DGA. Specifically, CNPP is tasked with developing communication strategies for the general population to encourage dietary practices recommended by the DGA, as well as physical activity.

To date, much is known about dietary choices of Americans, and the USDA and HHS have conducted previous audience segmentation efforts to determine how to separate the US population based on their nutrition knowledge, attitudes, and self-reported behaviors. Despite these data and the communication efforts they have informed, there has been little success when it comes to behavior change in this arena.

New developments in the fields of consumer decision theory and marketing suggest that more sophisticated ways of understanding audiences and the decisions they make when it comes to health (in general) and nutrition may foster different intervention and communication strategies to yield the more desired outcomes that USDA and HHS desire. These new approaches, however, necessitate additional understanding of the target audiences not addressed by previous research. Specifically, to develop successful communication strategies, including effective audience segmentation frameworks, additional information is needed about structural, cognitive, cultural, and affective factors influencing food consumption, as well as how these factors relate to overall dietary patterns. In addition, it is important to understand how food behavior corresponds to the audiences’ overall perceptions of health and wellbeing, since consumers do not view these as independent constructs.

The approval of this information collection is necessary for USDA to develop a communications and audience outreach strategy that consumers not only find relevant, but are also designed to accurately reflect the everyday decisions today’s consumers face when making choices about nutrition and health. Following best practices of consumer research, the first, qualitative phase of this research plan will seek to expand the understanding of Americans’ food choice behavior. The specific qualitative techniques proposed include the following:

• Journaling: an anthropological approach which asks participants to record certain aspects of their daily experiences over a period two weeks, with intermittent probes or questions posed by the researchers based on the respondent’s diary;

• Small, in-depth follow-up discussions with a subset of participants completing the journaling exercise to better understand their mindsets during the journaling assignment; and

• Focus groups among individuals recruited from different populations to ascertain the extent to which their overarching perspectives of health and wellness are reflected in the everyday decisions they make regarding nutrition.

It is important to note that the research detailed in this submission represents only the first part of the overall research program. This research compliments the already approved message testing qualitative research by helping to develop communication strategies to more effectively disseminate consumer-facing messages. Later this year, our plans are to build on the findings of this research, and we will submit a quantitative research protocol to OMB for approval that will provide the audience segmentation USDA desires and will uncover the Key Performance Indicators (KPIs) that influence likely behavior change opportunities among consumer audiences.

Purpose

This qualitative data will provide in-depth insights into how audiences talk and think about the issues pertinent to nutrition, food choices, and wellbeing that are necessary for the development of effective communication strategies. The qualitative data collection is also a vital first phase in the development of follow up formative research protocols intended to inform future USDA outreach strategies among consumer audiences. These research activities directly meet the Secretary of Agriculture’s directive to develop innovative approaches to inform Americans about 2015 Dietary Guidelines and ultimately positively impact the health of all Americans.

The information collected during this initial qualitative phase of the research will provide the research and communication teams with initial understanding of:

• The structural, cultural, cognitive, and affective factors influencing food choices and food behavior;

• Dietary patterns; and

• Perceptions of wellbeing and audiences’ priorities.

This information about the audiences will be contextualized within individuals’ daily routines and habits.

The information will be essential to the formative research by:

• Identifying key factors pertinent to food decisions;

• Suggesting different ways to segment consumers based on their ability to consistently implement healthful behaviors;

• Allowing the research staff to generate additional research questions that could be explored in follow up research; and

• Providing descriptive information about how individuals talk about issues pertinent to food choices and wellness that aids in the development of follow up research protocols.

In addition, the qualitative research will provide initial insights to the communication team regarding the target audiences (see below) that will be used in developing future communication strategies. An especially important insight will be the language and terminology used by the audiences in reference to food choices, cognitive and affective factors influencing food decisions, personal routines, and their personal wellness and wellbeing priorities.

Methodology/Research Design

Recruitment

The target population for this study is defined in terms of generational cohorts: Generation Y (18 to 32 year olds) and Generation X (33 to 49 year olds). Furthermore, all screening criteria will exclude individuals with a BMI over 34.9. We will recruit both English-speaking and Spanish-speaking participants for journaling and mini-focus group tasks.

For the mini-focus groups, we estimate that 672 individuals will be screened to recruit 192 individuals for the Spanish-language groups. In addition, 672 individuals will be screened to recruit 192 participants for the English-language groups. We plan to recruit 96 English-speaking participants and 96 Spanish-speaking participants. Thus, eight participants will be recruited for each mini group (24 mini groups in total) to seat six. Therefore out of 192 participants recruited for the focus group phase of the study:

• All 192 will be asked to complete the at-home exercise

• 144 will participate in the focus group discussion.

The Spanish-speaking participants will be segmented by region of origin (Mexican, Central American and Caribbean or South American), income and BMI index (normal range vs. overweight/obese). The English-language focus groups will be segmented by generational cohort, race (Black/African American vs. other), income, and BMI. To meet the segmentation requirements, the recruitment will oversample African American individuals.

A multi method strategy will be used to recruit participants. This will involve the use of randomly selected household lists in the target geographic areas, use of databases of individuals available from focus group facilities, and outreach to community and faith-based organizations. The outreach activities are especially vital for recruitment of lower income and Hispanic monolingual participants. All potential respondents will be contacted and screened by phone. The screening instruments (English and Spanish) are included in Attachments E.1 and E.2.

Individuals who express interest in participating in the research project and meet the eligibility criteria in terms of generational cohort will be further screened and assigned to groups based on their race/ethnicity, income, and BMI. During the screening process we will obtain verbal consent and verbal commitment to participate in the assigned focus groups and participants will complete consent forms prior to any follow up research activities (see Attachments G.1 and G.2).

For the journaling task, we plan to screen 168 individuals (84 English speakers and 84 Spanish speakers) to recruit 24 individuals who will participate in English and 24 individuals who will participate in Spanish. A similar multi-method strategy as described for the mini-focus groups will be utilized. All screening will be done by phone.

Recruitment for the journaling follow up focus groups will be conducted among participants who completed the journaling exercise in English. Only those who participated will be eligible, and as such, all 24 participants will be invited to participate in the follow up groups. An invitation e-mail and screener is presented in Attachments A.1 and B.1, respectively. For the three follow up virtual group, we will recruit 18 participants (six each) to seat 12 (four each).

Confirmation of Participation

A follow-up letter of confirmation will be mailed and/or emailed to individuals who have agreed to participate in each phase of research. The letter will thank the participant for agreeing to be part of the focus group and reiterate privacy statements. The follow up e-mails for the journaling activity (Attachments A.1.A [English] and A.1.B [Spanish]) will provide a URL linking to the consent form (Attachments G.1 [English] and G.2 [Spanish]) and unique ID and password. Similarly, reminders for journaling follow up groups (Attachment C.1.A) will link to an electronic consent form (Attachment G.1 [English]), and remind participants about the homework assignment. The confirmation letters for in person focus groups (Attachments E.3 [English] and E.4 [Spanish]) will remind participants of the date, time and location of the groups, as well as provide other information about scheduling, directions, etc., as needed. They will also restate the instructions for the homework assignment. All confirmation forms will include contact information for the contractor.

Incentives

CNPP will provide various incentive amounts based on the participants level of involvement. Incentive amounts will depend on the qualitative task. We understand that the OMB guidance about incentives for participation in research is based on the principles of the 2006 memo: Guidance on Agency Survey and Statistical Information Collections (hereby referred to as the 2006 memo). The 2006 memo explicitly states its purpose as “to improve the quality of Federal surveys and statistical information.” The research proposed here is exclusively qualitative. Participation in focus groups and journaling requires substantial commitment on the part of the respondents. For the proposed focus groups, both virtual and in-person, participants must make a commitment to attend the discussion at certain time on a specific date. And, incentives have been considered a standard practice in conducting qualitative research (see, for instance, the CDC General Guidelines for Focus Groups)¹. The justifications for the incentive amounts proposed for this research are based on the circumstances mentioned in the 2006 memo when an agency may provide survey participants with incentives. These circumstances apply to the qualitative research proposed here and are detailed as appropriate for each data collection activity proposed here.

Journaling: Journaling participants will participate for 14 calendar days. An incentive of $250 is in line with industry standards and is a fair compensation for a substantial commitment of 15 to 20 minutes per day for two weeks.

• Data Quality: The purpose of the research described here is to offer guidance to CNPP to develop communication strategies pertinent to the 2015 Dietary Guidelines and future USDA outreach efforts as per the Secretary’s directive. The 2015 Dietary Guidelines will serve as a framework to improve the nutrition and ultimately the health of all Americans, including those who do not show a strong interest in the topic of nutrition. It is therefore imperative that the qualitative insights are gleaned by hearing the opinions of a diverse range of the American public. The proposed incentive is comparable to incentives offered by commercial vendors for the same commitment.

Limiting incentives would do an irreparable harm to this objective by increasing non-response bias. Journaling is a “longitudinal” data collection activity that spans 2 weeks. Items asked in the second week of the data collection build upon information garnered in the first week. In order to draw insights about nutrition choices, it is vital that participants remain engaged over the full effort. Smaller incentives are likely to lead to some respondents dropping out prior to the conclusion of the data collection period, leading to incomplete data and further contributing to non-response bias.

In addition, offering no incentive or a small incentive, especially for a more labor-intensive data collection that has a longer “commitment,” will limit participation to individuals with personal or vested interest in the topic matter, thus limiting the range of opinions expressed in the journaling discussions to those who likely lie outside of CNPP’s primary target audiences (see Data Quality, under In-person focus groups, below for more information about audience limitations).

• Complex study design: In qualitative research, the complexity of the research “design” is best translated as the specificity of the recruitment criteria. The study employs highly restrictive criteria for participation: English-language groups are segmented by income, race, generational cohort and Body Mass Index (BMI). Spanish-language groups are segmented by country of origin, income and BMI. Proposed incentives are more likely to secure the participation of individuals meeting the screening requirements, making recruitment more effective and thus saving government money in recruitment costs.

Journaling follow-up focus groups: Individuals participating in the follow-up discussion groups among those who participated in the journaling exercise will receive an incentive of $50. These participants will be offered $25 to complete a mandatory “homework” assignment prior to group participation. The homework assignment is an essential component of the discussion. Since the virtual focus groups require web cameras to participate, participants who do not own one will be provided with one at no cost. The camera (valued at $40) will be theirs to keep.

• Improved coverage of specialized respondents, rare groups, or minority populations Journaling follow up focus groups will be conducted only among the English-speaking participants in the journaling task. Therefore, there is a very limited pool of potential respondents. Furthermore, it is imperative that participants from lower income groups participate in this phase of research. The pool of potential lower income respondents who participated in the journaling exercise adds to the recruiting limitations. Incentives must be set at a level that will encourage participation from these select groups.

• Although on-line focus groups do not require travel, they do require individuals’ full commitment to participating in the discussion. Therefore, we assume that some respondents will need child care during the participation. Furthermore, as discussed below, many low participants may skip participation if there opportunities to earn money by working additional hours at their jobs or taking side work. Based on the average cost of child care in research location (see table 3) we estimate the child care cost at $30. Furthermore, based on the average minimum hourly wage at research locations of $7.88 (see table 4), we recommend that $ 16 of the incentive amount cover competitive labor wages for two hours.

• For the homework assignment, respondents will be asked to collect 7 to 10 pictures representing their thoughts about wellness. The incentive of $25 for the “homework” assignment is based on the assumption that respondents will have to purchase magazines at newsstand prices in order to collect these pictures. The incentive will thus cover the cost at least 5 magazines, assumes the newsstand price of approximately $5.

In-Person Focus groups: CNPP participants will receive a $75 incentive after participating in a 90-minute focus group and $25 after completing a pre-discussion assignment (estimated at 30 minutes).

• Data Quality: As noted above, the purpose of the research described here is to offer guidance to CNPP to develop communication strategies pertinent to the 2015 Dietary Guidelines and future USDA outreach efforts as per the Secretary’s directive to improve the nutrition and ultimately the health of all Americans, including those who do not show a strong interest in the topic of nutrition. It is therefore imperative that the qualitative insights are gleaned by hearing the opinions of a diverse range of the American public. Limiting incentives would do an irreparable harm to this objective by increasing non-response bias. Offering no incentive or a small incentive, will limit participation to individuals with personal or vested interest in the topic matter, thus limiting the range of opinions expressed in qualitative discussions. In addition, this would also potentially exclude sections of the population who cannot afford to attend the focus groups, either due to the cost of childcare or the cost of missing work (see below). This, in turn, would limit the qualitative insights gathered the opinions of the very select individuals willing to participate in the research without or with very low incentives, severely biasing the information needed to develop strategic efforts to inform future outreach. The suggested incentive amounts will assure participation by the broader spectrum of American public and thus decrease non-response bias.

• Complex study design: As is the case in the Journaling phase, the in-person focus groups employ highly restrictive criteria for participation: English-language groups are segmented by income, race, generational cohort and Body Mass Index (BMI). Spanish-language groups are segmented by country of origin, income and BMI. Proposed incentives are more likely to secure the participation of individuals meeting the screening requirements, making recruitment more effective and thus saving government money in recruitment costs.

• Improved coverage of specialized respondents, rare groups, or minority populations: All of the research phases associated with this project (including both English-language and Spanish-language elements) will include low-income participants. The research team for this effort was selected largely due to their vast experience in conducting research among low-income populations. In the similar work they have conducted among this audience, low-income participants have been burdened with additional transportation and child care costs which have prevented them from participating in focus groups or led to high no-show rates.

For the focus groups, we anticipate that most of our low-income participants will be parents of young children. Although the participant burden for focus groups is 90 minutes, a typical participant may spend an additional half-hour at the facility (e.g., arriving earlier to check in and waiting for incentives after the group). Furthermore, a participant may have to commit an hour to travel to and from the facility. In all, the actual time commitment for the focus group participation is closer to three hours. In order to ensure the participation of lower-income participants in similar, previous research efforts, incentives were necessary to cover the childcare and transportation costs as well as the cost of competing job opportunities.

For this effort, the childcare costs are estimated at $15 per hour. This estimate is based on the estimated cost for babysitting services for 1-2 children in proposed research locations suggested by Care.com (http://www.care.com/babysitting-rates) presented in Table 3. This estimate is slightly less than the average suggested rate across locations for the care of two children, and slightly more than the average suggested rate for the care of one child. In total, we recommend that $45.00 of the incentive amount cover childcare costs.

Table 3: Estimated costs for childcare

Location	Hourly Cost: 1 Child	Hourly Cost: 2 Children
Baltimore, MD	14.50	15.50
Birmingham, AL	13.50	15.00
Los Angeles, CA	15.00	16.50
Dallas, TX	14.00	15.00
Average Cost	14.25	15.50

We also recommended a transportation allowance of $10. This incentive will fully cover cost of public transportation fares in proposed locations, and any incidental expenses such as parking at public transportation hubs (e.g., Park and Ride).

Furthermore, the show rates among low-income participants are often affected by available opportunities to earn additional income (e.g., extra hours at work or side jobs) that pay more than the typical incentive. The groups to be conducted during this effort will be held in the evening, during such times where many participants have the option to earn extra income (e.g., obtaining additional shift work, going to their second job). Therefore, incentives must make economic sense to the participants in order to be effective in securing their attendance and participation.

The average hourly wages for this group of participants is estimated to be $7.88 per hour. This estimate is based on the minimum wages as stated by the United States Department of Labor (http://www.dol.gov/whd/minwage/america.htm) in the proposed research locations (see Table 4).

Table 4: Minimum wages per location

Location	Hourly Minimum Wage
Baltimore, MD	8.00
Birmingham, AL	7.25
Los Angeles, CA	9.00
Dallas, TX	7.25
Average Cost	7.88

In total, we recommend that $ 24 of the incentive amount cover competitive labor wages. This total is based off of a participant spending an hour-and-a-half at the focus group, a half-an-hour checking in and waiting afterwards for incentives and one hour commuting time (half an hour each way), for the total of 3 and half hours.

For the homework assignment, respondents will be asked to collect 7 to 10 pictures representing their thoughts about wellness. The incentive of $25 for the “homework” assignment is based on the assumption that respondents will have to purchase magazines at newsstand prices in order to collect these pictures. The incentive will thus cover the cost at least 5 magazines, assumes the newsstand price of approximately $5. There is no additional incentive needed for travel time to purchase the magazines.  Previous language explained the incentive for completing the homework. 

Focus Group and Journaling Content

A trained moderator will facilitate the interviews/discussions as described in the Moderator's Guide for Journaling Virtual Group Follow-Up and Mini-focus Groups. (Attachments D.1, F.1 [English] and F.2 [Spanish]) appropriate to the audience. The journaling task will be self-directed: participants will respond to questions for each day of the task (Attachments B.1 [English] and B.2 [Spanish]).

Consent

Consent forms will be collected at the outset of the study, after the recruitment process. Consent forms will be obtained during the recruitment process and reflect the content of the focus groups. Consent materials will be made available in Spanish for Spanish-speaking parents and are included in this submission. Consent forms are appended in Attachments G.1 and G.2. Because the journaling task and journaling follow up groups will be conducted electronically, the participants will acknowledge consent electronically.

Data Analysis

Focus Groups: Both in-person and virtual focus groups will be audio-recorded (with respondent permission), and the information collected will be used to inform the main informational objectives of the study: understanding of wellness priorities, and factors that influence food choices among Americans. Focus group respondents will be informed that the sessions are recorded. Notes taken while observing the focus group sessions and the transcripts of the recordings will be the primary methods of data collection for qualitative data. Transcripts and notes will be reviewed for recurring themes stated across multiple groups and respondents. Differences will be assessed across groups, locations, and audiences will be noted as appropriate. Findings will be considered descriptive and directional, but not definitive. No attempt will be made to generalize findings as nationally-representative or statistically valid.

Journaling: The analyses of journaling data will use the electronic records of participants’ entries. The analyses will look at the relationship between food choices and social, emotional and other triggers and situational factors such as availability of time, activities participants engaged in and so forth. The goal of the analyses will be descriptively summarize these relationships across the participants and to identify common associations between food choices and emotional, social and other factors.

Outcomes/Findings

Information and formative input gathered from specific target audiences through the research will help identify messages and content that is most effective at motivating target audiences to take action. It will also uncover new ways to identify key target audiences. CNPP may decide to publish summary research findings either electronically or in print, but such documents will not include information that personally identifies any of the research participants. Our Contractors will submit a final report will be submitted to CNPP. The report will be based on qualitative approaches to summarizing verbatim data. No statistical summaries or analyses will be conducted.

8. Confidentiality:

CNPP and contractors will follow procedures for maintaining safeguards consistent with the Privacy Act during all stages of data collection. A system of record notice (SORN) titled FNS-8 USDA/FNS Studies and Reports in the Federal Register on March 31, 2000, Volume 65, Number 63, and is located on pages 17251-17252 discusses the terms of protections that will be provided to respondents.

Using forms in Attachments G.1 and G.2 all participants will receive a privacy statement along with the consent form. The confidentially statement will inform the participants that all opinions they provide will be private and none of their responses will be associated with personally identifiable information (PII). Participants will also be informed that findings will be presented as a summary. If representative quotes are used in the summaries, the authors of the quote will be identified only by gender and age cohort.

Additional steps employed to notify the respondents about their privacy are as follows:

• As part of the conditions of employment, all trained staff working on the project have signed a non-disclosure agreement (NDA) (Attachment H.1) prohibiting them from discussing any information about the research studies they work on with anyone not involved with the project, especially discussing or releasing personally identifiable information (PII).

9. Federal Costs: $235,169.61

The breakdown of the contractor cost for this specific research activity is presented in Table 3. These are funds obligated to this phase of the research project. The cost does not include labor cost of Federal employees, as supervision and contribution to this research is part of their customary job activities.

Table 3: Contractually obligated funds

Contractor Cost (labor &ODC)			$202,920
Incentives	N	Incentive	Total
Journaling (Spanish)	24	$250	$6,000
Journaling (English)	24	$250	$6,000
Virtual focus groups
Homework	18	$25	$450
Group participation	12	$50	$600
In person focus groups
Homework (Spanish)	96	$25	$2,400
Homework (English)	96	$25	$2,400
FG discussion (Spanish)	96	$75	$7,200
FG discussion (English)	96	$75	$7,200
Total Incentives			$32,250
Total cost			$235,169.61

10. Research Tools/Instruments:

• Attachment A.1: USDA JOURNALING SCREENER - ENGLISH

• Attachment A.2: USDA JOURNALING SCREENER - SPANISH

• Attachment A.1 A: USDA JOURNALING INVITATION- ENGLISH

• Attachment A.2.A: USDA JOURNALING INVITATION- SPANISH

• Attachment B.1 USDA JOURNALING GUIDE: ENGLISH

• Attachment B.2: USDA JOURNALING GUIDE: SPANISH

• Attachment C.1.A: USDA JOURNALING FOCUS GROUP FOLLOW UP E-MAIL (English only)

• Attachment C.1.A.1: USDA JOURNALING FOCUS GROUP HOMEWORK ASSIGNMENT(English only)

• Attachment C.1.B: USDA WEB CAMERA INTRUCTIONS (English only)

• Attachment D.1: USDA JOURNAL FOLLOW-UP MODERATOR GUIDE – ENGLISH

• Attachment E.1: USDA FOCUS GROUP SCREENER GUIDE – ENGLISH

• Attachment E.1.A: HOMEWORK INSTRUCTIONS-ENGLISH

• Attachment E.2: USDA FOCUS GROUP SCREENER GUIDE – SPANISH

• Attachment E.2.A: HOMEWORK INSTRUCTIONS-SPANISH

• Attachment E.3: CONFIRMATION AND FOLLOW UP LETTER-ENGLISH

• Attachment E.4: CONFIRMATION AND FOLLOW UP LETTER-SPANISH

• Attachment F.1: MODERATOR GUIDE FOCUS GROUP ENGLISH

• Attachment F.2: MODERATOR GUIDE FOCUS GROUP SPANISH

• Attachment G.1: CONFIDENTIALLY AND CONSENT FORMS ENGLISH

• Attachment G.2: CONFIDENTIALLY AND CONSENT FORMS SPANISH

• Attachment H.1: PII CONFIDENTIALITY AND NON DISCLOSURE AGREEMENT

1 http://www.cdc.gov/nccdphp/dnpa/socialmarketing/training/pdf/focusgroupguidelines.pdf

3