Justification Memo MIHOPE NonSub Change

To: Brenda Aguilar; Office of Information and Regulatory Affairs (OIRA)

From: Office of Planning, Research and Evaluation (OPRE); Administration for Children and Families (ACF)

Date: October 2, 2012

Subject: Nonsubstantive Change – Maternal and Infant Home Visiting Program Evaluation (MIHOPE)

This request is for a nonsubstantive change to incorporate suggested changes to materials, based on experiences in the field since clearance. The requested changes are outlined below and referenced materials uploaded into ROCIS.

1. Consent and streamlined home visitor/supervisor survey

In July 2012, OMB approved a data collection package for the Mother and Infant Home Visiting Program Evaluation (MIHOPE) that included separate informed consent forms for home visitors and for home visiting supervisors. Both groups of staff are being asked to complete a 75-minute survey at two points in time, and home visitors are being asked to be video-recorded during home visits with some of the families they serve.  Since OMB approval of the data collection package, the team has learned that some home visiting program staff serve as both home visitors and supervisors. Rather than asking these staff to complete two 75-minute surveys, one 105-minute survey has been developed that combines elements of the two surveys while removing redundancies. A new consent form has therefore been developed that describes this new survey more accurately than either of the previously approved consent forms, and that explains that the staff person might be asked to be video-recorded during some home visits.  The hybrid survey and consent forms were developed to reduce burden on staff. Without these changes, these home visiting program staff would have been asked to consent twice and to complete two 75-minute surveys at two points in time. With the change, they will provide consent once and answer one 105-minute survey at two points in time.  The revised consent form and streamlined survey are titled “Hybrid HV-SP Consent Form”. In the streamlined survey the black text is the original supervisor survey and red text is added from the HV survey. This new version of the survey has been uploaded and is titled “MIHOPE Combo Survey”.

2.  Incentive for those who are both HV and supervisors

As the package is currently written, staff who are employed as supervisors but also serve as home visitors for families in the study have the potential to receive $60 in payments ($30 for each survey). We are requesting to provide these individuals $40 for completing a streamlined survey discussed in #1 above. If approved, we will update the supporting statement accordingly and upload to ROCIS.

3. Revised state administrator survey with track changes

Since the OMB approved the data collection package, the team has discovered that the state administrator survey can be streamlined if the team provides the state administrator a list of possible stakeholders in their state to look at while they are being interviewed. The administrator is asked questions about the agencies on the list that are actively involved in different aspects of MIECHV decision-making. The use of this list has not been found to change the data we will get but improves efficiency. The flow of some of the questions in the interview has also changed from the approved instrument to correspond to the more efficient interview. The revised instruments have been uploaded and are titled “State_Administrator_Interview_Baseline_Version” and “State Administrator Interview 12 Month” . No questions have changed and no new questions have been added.

4. State consent changes we agree to discuss case by case

The team has learned from past evaluations that states or individual implementing agencies may request slight changes to the approved informed consent to allow for the collection of administrative records. For example, in a past study, New York has required us to use a specific consent form and to have forms notarized in order to receive state administrative data such as unemployment insurance data. In another study, Oklahoma required changes in language on how a family could withdraw from the study. A second set of changes may be requested by local or state institutional review boards. We are hoping that most IRBs will defer to the MDRC’s IRB, but there may be some cases where a local IRB requires a change in consent language.  Since site recruitment is occurring on a rolling basis over a year period we cannot submit all changes at once. Instead, we will raise any proposed changes with OMB as individual cases are identified.