Justification for Change

Using Traditional Foods and Sustainable Ecological Approaches for

Health Promotion and Diabetes Prevention in AI/AN Communities

(OMB no. 0920-0889, exp. date 6/30/2014)

Change Request

October 24, 2012

Summary

CDC is currently approved to collect information semi-annually from 17 AI/AN tribes funded under the cooperative agreement “Using Traditional Foods and Sustainable Ecological Approaches for Health Promotion and Diabetes Prevention in American Indian/Alaska Native Communities.” The web-based information collection instrument is called the Traditional Foods Shared Data Elements. Based on experience with the instrument since its approval in 2011, CDC proposes two clarifications in wording, as well as restructuring/reformatting the instrument to improve usability and respondent satisfaction.

Effect of Proposed Changes on Currently Approved Instruments and Attachments

Changes requested

Two clarifications in wording:

(1) Questions about gardening will explicitly include composting, soil amendment, irrigation methods, canning and preserving foods, and types of gardens, such as community, school, box, raised beds.

(2) The term “health policy” will be changed to “health practice.”

Formatting:

(3) Questions that were repeated across evaluation domains will be consolidated, thus reducing duplication of questions and the length of the instrument. However, data generated by the revised MDE instrument will be comparable to data generated by the original MDE instrument.

No other changes are proposed to the content of the shared data elements, the number of respondents, the estimated burden per response, the semi-annual frequency of data collection, or the electronic method of data collection. We will monitor feedback from respondents to determine whether the revised format results in reduced burden per response.

The revised instrument is included as Att 4a (rev). Traditional Foods SDE Oct 2012.

Background and Justification

CDC is currently collecting information from 17 AI/AN tribal awardees concerning activities that support the availability and use of traditional foods or alternative healthy foods, such as community/individual gardens and farmers’ markets; storytelling, media and outreach activities; availability of places, equipment and educational programs that promote physical activity; social support for healthy lifestyles; collaboration with other agencies and programs; policy-level changes in communities; and program outcomes. The Shared Data Elements are based on an evaluation construct that employs three domains: Traditional Local Healthy Foods, Physical Activity, and Social Support for Healthy Lifestyle Change and Maintenance. The original SDE instrument was organized by the three domains. Respondents were asked to answer similar questions for each domain, resulting in duplication of questions across domains. A number of grantees expressed concern about the length of the instrument.

We prepared a streamlined instrument that presents each question once (instead of three times), and allows the respondent to identify the domain(s) associated with the response. We have consulted with grantees about this approach and have received favorable feedback. Grantees indicate that the new approach will make data entry easier for them.

Other concerns noted by grantees since the initial OMB approval include use of the term “health policy” (they suggested the change to “health practice” – see below) and the concern that questions about gardening did not include the full complement of activities or types of gardens across seasons. These concerns have been addressed in the revised instrument.

• The term “health policy” has been changed to “health practice.” Grantees noted that “health practice” in local communities makes more sense to community members, in that “this is how we do things.” Health policy, on the other hand, may be viewed as “top down” prescription from outside the community. In the revised instrument, information about health policy is subsumed under health practice.

• The existing gardening questions are being expanded to include: composting, soil amendment, irrigation methods, canning and preserving foods, and types of gardens, such as community, school, box, raised beds.

CDC requests OMB approval of the revised instrument, effective immediately. We plan to field the revised instrument for the Fall 2012 data collection.  The next report to CDC is due by December 10, 2012.

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