Change Justification HIPAA Incentive Memo

DATE:
TO:

THROUGH:

April 10, 2014
Julie Wise, OMB Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget
Ruth Brown, Desk Officer
United States Department of Agriculture
Office of Chief Information Office

FROM: Lynnette Thomas
Branch Chief, Planning & Regulatory Affairs
Food and Nutrition Service
SUBJECT:

Justification for Survey and Incentive to Determine if Respondents Will
Return Medical Release Form to OMB Control No: 0584-0580
WIC Infant and Toddler Feeding Practices Study-2

Through this memorandum, we are requesting a non-substantive change to the burden
estimates and incentives for the WIC Infant and Toddler Feeding Practices Study-2, under the
Information Collection Request (ICR), OMB Control No. 0584-0580, which was approved on
May 30, 2013.
The WIC Infant and Toddler Feeding Practices Study-2 is intended to examine what mothers
feed their infants and toddlers and how they make those decisions; the study also collects
information from hospital records about the baby’s health, height and weight at birth and
information on baby’s height and weight from medical providers.
The Food and Nutrition Service (FNS) is requesting OMB approval to add an incentive of $5
for return of Attachment YY HIPPA Letter. This letter will add approximately .017 hours per
respondent to the current approved burden hours. This letter will ascertain whether
respondents will agree to return or are refusing to return the study HIPAA form authorizing
release of birth records and records on height and weight from medical providers.
The HIPAA form and post-birth letter are sent to respondents after the birth of the baby.
Respondents are asked to sign the form and return it in a postage paid envelope. The response
rate for the return of the HIPAA forms has been low. Of the 2,514 HIPAA forms sent to
active study participants to date, only 1,098 have been returned (43.7%), despite 2nd mailings
and telephone followup. Few respondents (19) have explicitly refused to sign the form.
Research on incentives has established that even modest incentives increase the rate of return
of paper surveys.1 We believe a $5 incentive will encourage respondents to return the form or
explicitly refuse without enticing. As a token of our appreciation, our contractors will provide
the incentive of $5.00 given to the respondent’s Payoneer incentive card for the return of either
the signed HIPAA form or a statement that they do not want to sign the HIPAA form.

1

Mercer, A., Caporaso, A., Cantor, D. and R. Townsend (2014) “Monetary incentives and response rates in
household surveys.” Paper to be presented at the annual meeting of the American Association for Public
Opinion Research, Anaheim, CA, May 15-18, 2014.
AN EQUAL OPPORTUNITY EMPLOYER

The HIPAA remail form will be an additional mailing sent to respondent when we receive no
response to the Post-Birth HIPAA letter and form (Appendix H1/H2). A copy of the letter is
attached.

Request for
approval
Post Birth
HIPAA letter
& Form

Burden
Currently
Approved
Additional
Requested
New Total

YY1,2

1,888

1

Responses
34,220

Hours
5,098

1,888

31.52

36,108

5,129.52

1,888

0.0167

Total Annual
Burden

Average
Hours per
Response

Total Annual
Responses

Frequency of
Response
(annual)

Number of
Respondents

Type of
Survey
Instrument

Affected
Public

Individuals/
Households

Appendices

Reading, signing and returning the HIPAA form will add approximately1 minute. Having the
respondent’s permission to obtain medical records will allow FNS to obtain valuable information
on the child’s height and weight from medical records.

31.5296

If you have any questions regarding this request, please contact Lynnette Thomas, Branch Chief
for the Food and Nutrition Service, Planning & Regulatory Affairs Branch at (703) 605-4782.

AN EQUAL OPPORTUNITY EMPLOYER