FAHV OMB Part A - response to 2nd passback_final

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Home Visiting: Approaches to Father Engagement and Fathers' Experiences

OMB: 0970-0448

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Home Visiting: Approaches to Father Engagement and Fathers’ Experiences


OMB Information Collection Request

New Collection




Supporting Statement

Part A

April 2014


Submitted By:

Office of Planning, Research and Evaluation

Administration for Children and Families

U.S. Department of Health and Human Services


7th Floor, West Aerospace Building

370 L’Enfant Promenade, SW

Washington, D.C. 20447


Project Officer:


Lauren Supplee










Contents


JUSTIFICATION


APPENDICES


Appendix A: Program Recruitment and Data Collection Instruments

Appendix A-1: Program Recruitment Letter and Project Summary

Appendix A-2: Guide for Selecting Parents for Interviews

Appendix A-3: Staff Consent Form

Appendix A-4a: Parent Consent Form (English)

Appendix A-4b: Parent Consent Form (Spanish)

Appendix A-5a: Parent Flyer (English)

Appendix A-5b: Parent Flyer (Spanish)


Appendix B: Federal Register 60-Day Notice


Appendix C: Urban Institute Staff Confidentiality Pledge


Appendix D: Certificate of Approval from the Institutional Review Board (IRB) of the Urban Institute


Appendix E: References

A1. Necessity for the Data Collection

The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services (HHS) seeks approval to collect proposed information in support of a study of approaches used by selected home visiting programs to actively engage fathers in their program services. ACF is interested in obtaining information to disseminate lessons from these home visiting programs to other home visiting programs as well as to individuals who provide program oversight and assistance.


Through the proposed information collection, the researchers will obtain information about the strategies used by the home visiting programs to actively engage fathers in home visiting services, the perspectives and experiences of staff in these programs, and the experiences and views of fathers who have participated in the selected programs as well as the views of the mothers. The study will include site visits to five selected home visiting programs that vary in their service delivery models, the populations they serve, and geographic location. Information will be collected through small group and one-on-one discussions with program directors, supervisors/coordinators, home visitors, and participating fathers and mothers.


Study Background

Having an involved father is an asset for children. Father involvement during infancy and early childhood is linked to stronger attachment security (Grossman et al 2002; Hossain et al. 1994), better cognitive outcomes for children (Roggman et al. 2004), social competence (Pettit et al 1998), lower levels of externalizing behavior for boys and higher levels of mental health for girls (Sarkadi et al. 2008). The association between father involvement and positive outcomes actually begins before children are born as pregnant women with involved partners are more likely to exhibit positive ante-natal health behaviors (Alio et al. 2010). These associations are above and beyond the benefits to children from their fathers’ economic contributions (McLanahan and Percheski 2008). Finally, there is some evidence to suggest that father involvement may be particularly valuable for children whose mothers are in some way vulnerable, for example depressed mothers (Elder 1992; Fagan et al 2009).


For these reasons there have been increased efforts to encourage greater father involvement, especially for low income men who often face significant barriers to being/staying involved with their children. Although home visiting programs have traditionally targeted mothers and their children, the increasing recognition of the importance of fathers has led some of these programs to include fathers. Though there may be challenges to engaging fathers in home visiting programs, some programs have developed strategies to engage fathers and maintain their involvement. Given the importance of father involvement beginning prenatally and continuing through childhood for a range of child development outcomes, it is important to learn about the ways in which home visiting programs include fathers.


In 2013, the Office of Planning, Research and Evaluation (OPRE) contracted with the Urban Institute to conduct an exploratory study to learn about father engagement and fathers’ experiences in early childhood home visiting programs. These programs historically have been directed towards moms andlittle systematic information exists on the methods and approaches that home visiting programs utilize to engage fathers. Therefore, this study will explore these issues and offer unique lessons learned on what engagement strategies are being used with at least some perceived success and where there are perceived barriers to reaching and involving particular types of fathers.


The information from this study can benefit a diverse group of stakeholders including home visitors, model developers, program administrators, and federal policy makers. Indeed, while some administrators and staff of the U.S. Department of Health and Human Services-funded Maternal, Infant, and Early Childhood Home Visiting (MIECHV) program and other home visiting programs have made a concerted effort to engage fathers of the children they serve and report success in doing so, other programs have been less successful. The reports and other products from this study will document the lessons learned from the perspective of program staff and fathers about how to most effectively engage and serve fathers, and provide insight into the fathers’ own experiences, perceptions, and opinions about the programs. Both the MIECHV grantees and other home visiting program operators could benefit from these findings and use them to guide their work with fathers.


In addition, responsible fatherhood is a priority area for the current Administration, and several of the Administration for Children and Families’ offices, such as the Office of Head Start (OHS), Children’s Bureau (CB), and Office of Family Assistance (OFA), are attempting to tackle the complex issue of father engagement in program services. CB has been compling resources through their Child Welfare Information Gateway on fathers and home visiting but few resources focus on strategies for father engagement in early childhood home visiting models. OHS has a rich history of encouraging Early Head Start programs to include fathers but anecdotally programs report challenges in effectively engaging fathers in services. Finally, through the Healthy Marriage and Responsible Fatherhood funding in OFA, one of the three goals of the responsible fatherhood work is to engage fathers with their children and build co-parenting skills, an outcome of interest in home visiting broadly. Information on how home visiting programs engage fathers in early childhood services could have implications beyond home visiting to disseminating innovative strategies of father engagement to other ACF programs that serve fathers, such as the Early Head Start center-based and family child-care program options as well as programs providing responsible fatherhood activities for dads.


None of the current research and evaluation work conducted by ACF or in partnership with HRSA under MIECHV specifically addresses this need. For example, the Mother and Infant Home Visiting Evaluation (MIHOPE) includes an impact analysis to measure the difference home visiting programs make for the at-risk families they serve. MIHOPE is primarily focused on mothers and collects minimal information on father involvement, the relationship between the father and mother, and material support provided.The study does not include an indepth examination of father engagement in home visiting services or how programs engage fathers. Taken all together, the current information collection fills a gap in the current knowledge base..





Legal or Administrative Requirements that Necessitate the Collection

There are no legal or administrative requirements that necessitate the collection. ACF is undertaking the collection at the discretion of the agency.

A2. Purpose of Survey and Data Collection Procedures



Overview of Purpose and Approach

This study will be exploratory in nature, designed to learn more about how selected programs engage fathers, perceived challenges to father engagement, and perceived benefits. The goal of this information collection is to provide information that will be of use to other home visiting programs regarding how home visiting program staff engage fathers in home visiting, staff perspectives towards and experiences with engaging fathers, fathers’ experiences participating in home visiting services, and mothers' views of fathers' involvement.


The study approach will include site visits to five purposively selected home visiting programs determined to be implementing strategies to actively engage fathers. The five will be selected from among programs identified by federal staff and a small group of national experts who were consulted about the study (n= 9). The list of programs have been narrowed to nine that will be further screened to identify program characteristics, the population served, and the level of father engagement in the program, to narrow the final list of sites to five.


Multiple perspectives on the issue of father engagement in home visiting will be obtained during the site visits. Site visit respondents will include program directors, supervisors/coordinators, home visitors, and participating mothers and fathers. Staff positions and titles are expected to vary by site. In addition, the researchers will also shadow home visitors and observe the activities and interactions that occur during two home visits per site in which fathers are participating. The observations will likely be done with different fathers from those that are interviewed.



Upon OMB approval of the proposed information collection instruments, the site visits will be conducted in the fall of 2014 (October-November). In late spring of 2015, a final report and a research brief will be released, drawing upon and synthesizing the information collected to present key findings and lessons.



Research Questions

The study will explore the following research questions:


  1. What methods and approaches do program staff use to encourage father engagement?


  1. What supports—including program philosophies/models of family engagement, specialized training, and program resources—are perceived as most useful to staff recruiting, engaging, and serving fathers in their programs?


  1. Which program recruitment and engagement strategies are perceived to work better for different types of fathers (e.g., residential/non-residential; married, cohabiting, un-partnered, partnered with someone other than the child’s mother; first-time or experienced fathers; teen/young fathers; fathers of different racial/ethnic backgrounds), and why? What types of fathers are perceived as harder to engage, and why?


  1. What are the experiences of fathers in these programs and what are their motivations for participating?


  1. What are the perceived benefits of program participation for fathers, mothers, and their children, according to both fathers and program staff?


  1. What role do mothers play in facilitating or preventing or discouraging father engagement in home visits?


Study Design

The study design is based on methods suitable for exploratory research, in which the primary purpose is to gather information about the lay of the land, rather than to test hypotheses or evaluate outcomes. Plans for data collection include 5-day site visits to five home visiting programs that vary in program model (e.g., Early Head Start, Parents as Teachers, Healthy Families America, Nurse Family Partnership, and Healthy Start) and the demographics of the populations served. During the planning phase of this project, the contractor contacted program experts in the field and leaders from national associations for model home visiting programs (n=9) to gather input into the study design and to collect recommendations for potential site visit locations. Approximately twenty-five programs were identified based on various fatherhood engagement strategies being implemented (e.g., hiring a male fatherhood coordinator, hiring male home visitors, conducting home visits specifically for fathers, organizing fatherhood workshops). The contractor reviewed these programs in consultation with OPRE and selected nine potential programs that were implementing different father engagement strategies, while considering variation in populations served and home visiting program model. These nine programs will be screened to examine the level of father engagement in each program and to narrow down the list of potential sites to five that offer good opportunities for learning about father engagement in diverse home visiting programs. Upon OMB approval of the information collection instruments, each of these five potential programs will be sent a recruitment letter (see Appendix A-1) to explain the study and invite the program to participate. Once a program consents to participate, the research team will provide the program staff with the Guide for Selecting Parents for Interviews (see Appendix A-2). This guide will provide detailed instructions and support to home visting program staff on selecting and inviting fathers and mothers to participate to ensure a variety of parents are selected.


During the on-site visit to each program, the researchers will obtain multiple perspectives on the ways fathers are involved in or being served by home visiting programs. For each selected program, they will conduct:

  • an in-depth interview with the program director and additionally with up to two senior level staff (e.g., supervisor/coordinator) involved with father engagement; interviews with up to five home visitors, conducted individually or in small groups of two or three respondents.

  • in-depth interviews with eight fathers who have participated in a home visit or been engaged in the home visiting program in some meaningful way.

  • separate in-depth interviews with two mothers receiving home visiting services who are matched to fathers selected for interviews.

  • brief information collection with the home visitor for each of the two home visit observations.


Interviewing program leaders individually will provide detail on the program’s history, philosophy, structure, and components to better understand how decisions were made to involve fathers in home visiting activities. Supervisors/coordinators will be asked to discuss their experiences training and working with home visiting staff on how to engage fathers, and where there have been challenges and successes. Interviews with home visitors individually or in small groups will provide information about their direct experience working with fathers and their perceptions and views.


Individual in-depth interviews with fathers will address a range of topics related to their participation and individual circumstances including their relationships with their children’s mothers, their involvement with their children, their unique struggles being a father, and what supports have helped or could help them to be better engaged in their children’s development. Interviews with a small number of mothers provides the opportunity for collecting data on multiple perspectives on fathers' engagement in home visiting programs.


A team of two experienced, qualitative researchers (one senior researcher and one research assistant) will conduct each visit. The senior researcher will lead the interviews and obtain consent, and with the permission of the respondent, we will audio record the interviews. With home visiting staff, we will use a laptop to record close to verbatim interview responses and later create targeted transcripts capturing the key information provided. The parent interviews will be audio recorded and then fully transcribed. If permission to record is not provided, both researchers will take more detailed notes.


All hard and electronic copies of documents containing sensitive information or personal identifiers will be stored in accordance with a data security plan, as approved by the Urban Institute’s Institutional Review Board.



Universe of Data Collection Efforts

The research approach calls for the development of customized interview protocols for each type of respondent. The instruments to be used for collecting data and the research questions (RQ) the data address are as follows:

  • Interview Guide for Program Administrators (RQ 1, 2, 3, 5, 6): To collect information during individual interviews with program directors and relevant senior-level staff (e.g., supervisors/coordinators) to gather information about the program history and structure, the characteristics of the population served, the program’s philosophy toward father engagement in home visits, and perceived successes and challenges with engaging fathers.

  • Interview Guide for Home Visitors (RQ 1, 2, 3, 4, 5, 6): To collect information from home visiting staff about their experiences and perspectives towards engaging fathers, their training on father engagement, and the perceived successes and challenges with engaging fathers.

  • Interview Guide for Fathers-English (RQ 3, 4, 5, 6): To collect information during individual interviews with English-speaking fathers about their relationships with their children and their children’s mothers, their experiences with the home visiting program and other fatherhood activities offered, and the perceived benefits and challenges of program participation.

  • Interview Guide for Fathers-Spanish (RQ 3, 4, 5, 6): To collect information during individual interviews with Spanish-speaking fathers about their relationships with their children and their children’s mothers, their experiences with the home visiting program and other related fatherhood activities, and the perceived benefits and challenges of program participation.

  • Interview Guide for Mothers-English (RQ 3, 4, 5, 6): To collect information during individual interviews with English-speaking mothers about their relationship with their children’s fathers, ways fathers support and engage with their children, their perspectives on their children’s father’s involvement in home visiting services, and the perceived benefits and challenges of fathers’ program participation.

  • Interview Guide for Mothers-Spanish (RQ 3, 4,5, 6): To collect information during individual interviews with Spanish-speaking mothers about their relationship with their children’s fathers, ways fathers support and engage with their children, their perspectives on their children’s father’s involvement in home visiting services, and the perceived benefits and challenges of fathers’ program participation.

  • Home Visit Observation Sheet (RQ 4): To collect observational notes before and after the home visits on the structure and demographics of the families as well as home visitors’ impressions of the visit.



Parent interviews will be conducted in English or Spanish, as preferred by the respondent. The research team includes investigators who are fluent in Spanish and can accommodate Spanish-speaking parents with limited English proficiency.

A3. Improved Information Technology to Reduce Burden


In-depth interviews of the type proposed for this study do not lend themselves to the use of technology to reduce burden. Audio recording of individual interviews, with permission, will be used to facilitate interviewer-participant dialogue without extensive note taking and lap-top note taking in small group discussions will increase accuracy of documentation of all points raised during the discussions.


A4. Efforts to Identify Duplication


The data requirements for this study have been carefully reviewed to determine whether the needed information is already available. Efforts to identify duplication included a review of the current literature and discussions with knowledgeable experts. Limited information is available about home visiting models that make efforts to include fathers, and the few existing studies generally focus on a single model. Moreover, little information has been published about fathers’ personal experiences in home visiting programs and how mothers perceive father engagement in home visiting services. In contrast, this study will include data from different home visiting models offering a range of experiences and perspectives from a variety of respondents, including father, mothers, and home visiting providers. We concluded that no existing data source can provide the data needed to answer the study’s research questions.

A5. Involvement of Small Organizations


We expect all five organizations that will be included in the study will be small, non-profit organizations.


Burden will be minimized for respondents by restricting the interview length to the minimum required, by conducting on-site visits and interviews at times convenient for the respondents, and by requiring no record-keeping or written responses. Further, the total number of fathers and mothers that program staff will be asked to identify for the interviews is small.

A6. Consequences of Less Frequent Data Collection

This is a one-time data collection. Not collecting information as proposed would limit the government’s ability to identify and document valuable lessons about strategies to engage fathers and disseminate the information broadly.

A7. Special Circumstances

There are no special circumstances for the proposed data collection efforts.

A8. Federal Register Notice and Consultation


Federal Register Notice and Comments

In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on August 9, 2013, Volume 78, Number 154, page 48689 and provided a 60-day period for public comment. A copy of this notice is attached as Appendix B. During the notice and comment period, one comment and three requests for the instruments were received. The one comment noted objection to the information collection but did not include any suggestions for changes.

The instruments were sent to the three who requested them; no suggestions for change were received.

Phone consultations were conducted with seven non-federal experts in the field, primarily leaders from home visiting program national associations. They were asked to comment on the proposed study design and to share information about how their home visiting programs have approached the issue of father engagement. The recommendations received from experts helped shape the final study design.

A9. Incentives for Respondents


As a token of appreciation, a box of children’s books will be provided to programs for their efforts in identifying and recruiting parent participants, coordinating home visit observations, and assisting with scheduling and organizing the visit. Books will be valued at no more than $5 a book. The actual number of books purchased will be based on the particular program’s caseload of families, but will not exceed a total cost of $100 in children’s books per program. Additionally, each father and mother will receive $40 as a token of appreciation. This approach expresses gratitude for the respondents’ participation but will not be an excessive amount that could be coercive. Respondents who withdraw from the study during an interview will still be offered the indicated amount.

The amount indicated for respondents ($40 per parent respondent) is similar to those offered in association with recent OMB-approved information collections conducted by the Urban Institute. In Understanding the Dynamics of Disconnection from Employment and Assistance (0970-0434), researchers offered low-income mothers $40 for participation in an in-person qualitative interview in their homes lasting 75 minutes in length on average. The amounts have been successful in these other, similar information collections, and are appropriate in size to thank respondents for their participation given the study requirements.

A10. Privacy of Respondents


Prior to the start of each interview, the researchers will assure the respondents that the information provided will be kept private to the extent permitted by law. Specifically, none of the information obtained during the course of the study will be disclosed in such a way that individuals can be identified by anyone outside the research team, and the respondents will not be quoted by name in dissemination activities, such as the final research report, research briefs, federal briefings, and conference presentations. The organizations participating in the study will not be identified by name in any reports or other dissemination activities and descriptive information that would allow the organization to be identified will be limited. However, it is possible that the whole of the information would allow the identity of organizations to be discerned. Program administrators will be advised of this possibility. Other information will not be shared with anyone other than the research staff assigned to the study, all of whom will be required to sign the Urban Institute’s Staff Confidentiality Pledge. See Appendix C.

All respondents will be given and asked to sign informed consent forms before the start of the interview. See Appendices A-3, A-4a, and A-4b for copies of the consent forms for staff and parents, respectively.


This study is also under the purview of the Urban Institute’s Institutional Review Board (IRB), which is registered under Federalwide Assurance number 00000189, indicating it adheres to the requirements in the HHS Protection of Human Subjects regulations at 45 CFR Part 46. All data collection and security procedures described in this package have been approved by the IRB. See Appendix D for a copy of the IRB Notice of Approval. To receive IRB approval for this study, the data collection effort must adhere to the following principles:


  • Subjects are informed of the nature of the research and how it will be used, and their consent either obtained or explicitly waived, where risks to them are determined to be minimal.

  • Adequate provision is made to protect the privacy of subjects and to maintain privacy of data, where promised and as appropriate.

  • Risks to subjects are minimized to the extent possible within research designs.

  • Risks to subjects (from the research) are reasonable in relation to anticipated benefits (of the research).

  • The selection of subjects is as equitable as possible (the burdens and benefits of the research are fairly distributed) and particular attention is paid to research involving vulnerable populations and protected health information.

A11. Sensitive Questions


The interview guides contain some topic areas that could be considered sensitive but indivduals need not provide any information that they are uncomfortable sharing. Individuals will be told that they can choose to not answer any question and may stop the interview at any time. For example, topics with fathers include their relationships with their children and their children’s mothers, and whether they provide child support. In discussions about their circumstances information may also be shared about personal challenges. Fathers may disclose challenges related to sensitive areas (e.g., mental health problems or a history of delinquency, incarceration, or domestic violence), however, the interview guides do not directly ask about these issues.


Likewise, topics discussed with mothers will include their relationships with their children’s fathers, how fathers support their children, and how the home visiting program has helped the mother, her children, and her children’s father. However, individuals need not provide any information that they are uncomfortable sharing. Individuals will be told that they can choose to not answer any question and may stop the interview at any time. During discussion about interations during home visits or how home visitors have helped them, some women may disclose sensitive information (e.g., a history of domestic violence, depression) however, the interview guides do not directly ask about these issues. The interview guides for fathers and mothers also ask about country of origin and length of time in the United States. These questions have been asked in OMB approved instruments used in other contracts supported by OPRE, such as Parents and Children Together (0970-0403), and no issues have been identified.


A12. Estimation of Information Collection Burden


Exhibit A-1 shows estimated burden of the information collection, which will take place within a one-year period.

  • Guide for Selecting Parents for Interviews: Home visiting program staff are asked to follow this guide to identify and select parents for interviews and send contact information for each parent to the reseach team through secure procedures.

  • Interview Guide for Program Administrators: Interviews with 15 program administrators (i.e., program directors, supervisors/coordinators), up to three from each of the five sites, at an average length of 90 minutes.

  • Interview Guide for Home Visitors: Interviews with 25 home visitors, up to five in each of the five sites, at an average length of 75 minutes.

  • Interview Guide for Fathers-English: Interviews with 30 English-speaking fathers, approximately six in each of the five sites, at an average length of 75 minutes.

  • Interview Guide for Fathers-Spanish: Interviews with 10 Spanish-speaking fathers, approximately two in each of the five sites, at an average length of 75 minutes.

  • Interview Guide for Mothers-English: Interviews with 8 English-speaking mothers, 1-2 in each of the five sites, at an average length of 60 minutes.

  • Interview Guide for Mothers-Spanish: Interviews with 2 Spanish-speaking mothers in one or two sites, at an average length of 60 minutes.

  • Home Visit Observation Sheet: Protocol used to collect brief information from home visitors before and after 10 home visits, 2 per site. No burden will be placed on clients receiving the home visit.


Exhibit A-1: Estimated Burden in Annualized Hours and Costs

Instrument

Total Number of Respondents

Number of Responses Per Respondent

Average Burden Hours Per Response

Total Burden Hours

Annual Burden Hours (rounded)

Average Hourly Wage ($)

Total Annual Cost ($)

Guide for Selecting Parents for Interviews

5

1

10

50

50

$30.99

$1,549.50

Interview Guide for Program Administrators

15

1

1.5

22.5

23

$30.99

$697.27

Interview Guide for Home Visitors

25

1

1.25

31.25

31

$18.02

$563.12

Interview Guide for Fathers-English and Spanish versions

40

1

1.27

50.8

51

$10.00

$508.00

Interview Guide for Mothers-English and Spanish versions

10

1

1.02

10.2

10

$10.00

$102.00

Home Visit Observation Sheet

10

1

0.17

1.7

2

$18.02

$30.63

Estimated Annual Burden Sub-total

 

 

 

 

167


$3,450.53



Total Annual Cost

The estimated total annualized cost burden to respondents is based on the burden hours and estimated hourly wage rates for each data collection instrument, as shown in the two right-most columns of Exhibit A-1. These estimates are based on:

  • an assumed hourly wages of $30.99 for program administrators, based on mean hourly wage for “Social and Community Service Managers”, as reported in the May 2012 U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wage Estimates, http://www.bls.gov/oes/current/oes119151.htm).

  • an assumed hourly wages of $18.02 for home visitors, based on mean hourly wage for “Community Health Workers,” as reported in the May 2012 U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wage Estimates, http://www.bls.gov/oes/current/oes211094.htm).

  • an assumed hourly rate of $10.00 for fathers and mothers. This equates to annual earnings of $20,800 for a worker employed full-time year-round. For reference, this assumed wage rate is more than the federal minimum wage of $7.25 per hour.

A13. Cost Burden to Respondents or Record Keepers

There are no additional costs to respondents or record keepers.

A14. Estimate of Cost to the Federal Government

The total cost to the federal government of implementing the information collection activity, analyzing the information is $226,993. This amount includes all costs related to study design and development, information collection, and analyses of data. This is a one year information collection request.

A15. Change in Burden

This is a new data collection.

A16. Plan and Time Schedule for Information Collection, Tabulation and Publication


Upon OMB approval of proposed instruments, data collection will be completed by January 2015. Findings from analysis of the information collected through on-site interviews will be presented by the research contractor in a final research report, expected in May 2015. This report will be publically disseminated through OPRE and the Urban Institute, and analyses will likely be submitted for publication in peer-reviewed professional journals. Findings will also be presented at research and practitioner conferences.


Timing

Activity

September – January 2015

DATA COLLECTION

Interview Guide for Program Administrators

Interview Guide for Home Visitors

Interview Guide for Mothers-English and Interview Guide for Mothers-Spanish

Interview Guide for Fathers-English and Interview Guide for Fathers-Spanish

Home Visit Observation Sheet

Fall/Spring 2015

DATA ANALYSIS


May 2015

FINAL REPORT AND RESEARCH BRIEFS


A17. Reasons Not to Display OMB Expiration Date

All instruments will display the expiration date for OMB approval.

A18. Exceptions to Certification for Paperwork Reduction Act Submissions

No exceptions are necessary for this information collection.




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