Form 2 comments

Finalized by Data Work Group 6/19/12

Home Visiting Form 2
60-day Federal Register Notice Public Comments
Comment
Date

Commenter

Comment

Response

3/21/2012

Yvonne Goldsmith (AK)
[email protected]
Unit Manager
AK Dept. of Health & Social Services
| MCH-Epidemiology

I estimate the following amount of time will be required, on
an annual basis, to fill out:
Form 2 - 70 hours

4/5/2012

Cynthia Suire, DNP, MSN, RN
MIECHV Program Manager
Louisiana DHH-OPH-MCH
[[email protected]]

The burden estimate is underestimated, as each construct
will need several hours of completion of the forms, analysis
and reporting. In addition, there will need to be state
established data collection processes instituted for those
constructs not collected within model (i.e. Benchmark 6).
MIECHV state staff and the state’s Department of Children
and Family Services will use man hours for requesting,
compiling and exchange data regarding child maltreatment
data. Louisiana estimate is closer to 774 annual hours,

The estimation of data collection burden for respondents is based on
the additional effort involved in data collection (e.g., at the local
implementing agency), data entry and transfer (e.g., to state program),
analysis, and uploading into the Discretionary Grant Information
System (DGIS) required of grantees. Data collection activities that are
part of home visiting model or program requirements are excluded
from the calculation. Of the two parties who commented on the
reporting burden for this proposed data collection form, one estimated
the burden would be 70 hours annually per respondent and the other
estimated it at 774 hours. The estimate we put forth in the FRN for this
form fell within these values, i.e., 313 hours annually per respondent.
In light of the uncertainty involved in estimating with accuracy the
collection burden of these activities separately from other existing
programmatic data collection requirements, we will reassess the
burden estimate once actual data collection is underway (e.g., after
two years of experience since the burden is likely to be higher during
the first year).
The estimation of data collection burden for respondents is based on
the additional effort involved in data collection (e.g., at the local
implementing agency), data entry and transfer (e.g., to state program),
analysis, and uploading into DGIS required of grantees. Data collection
activities that are part of home visiting model or program requirements
are excluded from the calculation. Of the two parties who commented
on the reporting burden for this form, one estimated the burden would
be 70 hours annually per respondent and the other estimated it at 774
hours. The estimate we put forth in the FRN for this form fell within
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rather than the 313 hours cited in the federal register.

3/12/2012

April 16

3/12/2012

CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
[email protected]

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
[email protected]

Request that the Grantee be allowed to make revisions in
their Benchmark document to add columns for additional
information not already captured in the document.
Connecticut’s Benchmark document already includes most
of the information requested, with the exception of the
data. It would be unnecessarily burdensome to complete a
separate page for each construct which would be 35
separate pages.

Benchmark Area: There is no space to indicate the
Benchmark Area such as Maternal and Infant Health or
Economic Self-Sufficiency, which is important given the
insurance status, is listed in both benchmark areas.

Request that the Data Collection Plan- OTHER be reported
overall or for all measures,
i.e. across programs or by
model rather than per construct. Data Collection – OTHERby construct could present a significant reporting burden.

these values, i.e., 313 hours annually per respondent. In light of the
uncertainty involved in estimating with accuracy the collection burden
of these activities separately from other existing programmatic data
collection requirements, we will reassess the burden estimate once
actual data collection is underway (e.g., after two years of experience
since the burden is likely to be higher during the first year).
The proposed data collection form is distinct from the Benchmark Plan
developed by the grantee. Grantees may revise their benchmark plans
as needed based on discussions with their Regional Project Officer.
The proposed form is designed to collect information electronically
into the DGIS for the duration of the MIECHV program for data
aggregation, reporting and other accountability purposes at the federal
level.
The DGIS will have the capability to automatically populate fields that
remain unchanged from year to year (e.g., name and type of
performance measure) or to provide a “drop down menu” when the
number of choices is discrete (e.g., tools utilized)
[NOTE: need to clarify the distinction between benchmark plan and
DGIS in 30-day FRN; may want to add language in form instructions]
We concur and added a line to specify the benchmark area in the first
section of the proposed form.

The process of data collection may vary by construct (e.g., parties
involved, frequency of collection, etc.) and therefore cannot be
reported for all measures. For those instances in which the data
collection process is the same from year to year, we will design the
DGIS to automatically pre-populate this field from prior periods. We
added language to the instructions to clarify the purpose of this
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April 16

3/12/2012

April 16

April 13

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]
CT Dept of Public HealthMargie Hudson, Carol Stone
Jennifer Morin, Mary Emerling
MIECHV Team
[email protected]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]

Data Collection Plan – Other: It may be clearer to rename
this “How” or equivalent given the instructions “How the
data will be collected…and reported…”

Thomas R. Jenkins, Jr.
President & CEO
Nurse-Family Partnership
Tom.Jenkins@nursefamilypartnershi
p.org

HRSA should define how states detect improvements in
benchmark areas.
Draft Form 2 is intended to demonstrate improvements by
state in benchmark areas; however, the form does not
appear to include baseline information from which a state
can assess improvements in the benchmarks.

Please - Remove/omit/delete – Rationale For The Measure.
The Measures are required.

Rationale for the Measures: It is unclear why this element
is necessary for the Performance Measures, as the
justification for all the measures were approved with the
grantee benchmarks plans.

We recommend that the form be revised to include
baseline information and to specify how states assess
progress toward the benchmark areas.

section. Grantees could utilize the “Other” field to report any changes
from one year to another.
We added language to the instructions to clarify the purpose of this
section.

Selection of a performance measure per construct is required. The
measure can be selected by the grantee, therefore the rationale for
selection is informative. Grantees have discretion in selecting from a
variety of possible indicators that capture the given construct in
accordance with individual grantee’s goals and constraints.
Grantees have not universally provided the rationale for indicator
selection in their measurement plans. Also, the proposed form is
designed to collect information electronically into the DGIS for the
duration of the MIECHV program for data aggregation, reporting and
other accountability purposes at the federal level, and is distinct from
the approved benchmark plans. We will design the DGIS to prepopulate this field from prior periods since the rationale for an
indicator is not likely to change from year to year.
Grantees will collect baseline information as specified in their
approved benchmark plans, which includes specification of baseline
and comparison periods under their definition of improvement. We
have added language to clarify the concepts of baseline and
comparison periods in the proposed form instructions under the
“Definition of Improvement” section.
o

o
We recommend that the following questions be addressed:

Grantees have already identified baseline period data and how to
track progress of participating families in their approved
benchmark plans.
Grantees have also identified in their benchmark plans their data
collection plans, including frequency of collection by the state or
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April 16

April 16

April 16

April 16

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]
Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]

o How will states identify baseline data and track progress
of participating families in the benchmarks?
o How often will data be collected on the benchmarks?
o Will any of the data be used for the national evaluation of
the MIECHV Program? If so, how?
Form 2: Grantee Performance Measures
1. Relevant Construct: Is this the same as the “Construct”
listed as the first definition in the instructions page? Please
clarify and ensure consistency between the form and the
form instructions.

o

territorial program.
The proposed form is designed to collect information on
performance indicators and is not part of the MIHOPE national
evaluation.

We removed the word “Relevant” and made the titles in the proposed
form sections consistent with those of the instructions.

Value for Annual Reporting Year – Data (N): Please be
The “n” is the count of the number of individuals who provided data
clearer in the instructions, as stated it is not clear how the N for a given indicator value calculation. We added clarifying language to
for each construct is to be calculated.
the instructions and distinguished n1 (number of program participants
involved in creating the value of the performance measure for the
baseline period) from n2 (number of program participants involved in
creating the value of the measure for the comparison period.)
Data Considerations: Grantees may need more space (#
allowed characters) in the data considerations than
currently appear on the draft form 2.

We will ensure that the DGIS allows adequate space for narrative (i.e.,
number of characters) in this section.

Data Considerations Three-Year Improvement (Yes/No):
Please provide further clarification that there should be no
response to this is element until the third reporting year.

We added language to the instructions specifying the purpose of this
item. Also, the function to provide this information will be disabled in
DGIS until the third year, when improvement should be reported.

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April 16

Laura DeBoer, MPH
Idaho Department of Health and
Welfare
Maternal and Child Health Program
Maternal, Infant, and Early
Childhood Home Visiting Program
[[email protected]]

General Comment: Will this form only be relevant through
reporting year 3 or will states continue to complete this
form through reporting years 4 and 5?

We expect that this proposed form will be utilized throughout the 5year period defined in legislation. OMB grants approval for a three-year
period which can be renewed.

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