OMB Memo - NSWP III

Memorandum
Date:

July 18, 2016

To:

Stephanie Tatham, OMB Desk Officer

Through:

Ruth Brown, United States Department of Agriculture, Office of Chief
Information Office

From:

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

Re:

Generic OMB Clearance No. 0584-0606 – Pretesting for the Third National
Survey of WIC Participants (NSWP-III)

The Food and Nutrition Service (FNS) of the United States Department of Agriculture (USDA)
is requesting approval for pretesting of data collection instruments under Approved Generic
OMB Clearance No. 0584-0606.
This request is to acquire clearance to conduct pretesting with the Special Supplemental
Nutrition Program for Women, Infants, and Children (WIC)’s State agencies (SAs), local
agencies (LAs), current and former WIC participants, and denied WIC applicants with the
purpose of identifying potential data quality problems, such as high item nonresponse rates, and
modification of flow, order, and timing of questions, as well as participant understanding of
questions asked. The following information is provided for review:
1. Title of the Project: Pretesting for the Third National Survey of WIC Participants (NSWPIII)
2. Control Number: 0584-0606, Expires 03/31/2019
3. Public Affected by this Project:
State, Local, Tribal Governments:
• State WIC Agency Directors
• Local WIC Agency Directors
Individuals/Households:
• Current WIC Participants
• Former WIC Participants
• Denied WIC Applicants

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4. Number of Respondents & Research Activities:
Table 1. Research Activities Target Audience
Respondent Type
State WIC Agency Director

Research Activity
State Agency Survey

Local WIC Agency Directory

Local WIC Agency Survey

9

WIC Participants

WIC Participant Certification Survey

9

Program Experiences Survey

9

Former WIC Participants Case Study

9

Denied Applicant Survey

9

Denied WIC Applicants

# of Participants
9

Total

54

5. Time Needed Per Response:
Table 2. Estimated Time Needed Per Response by Research Activity
Respondent Type
State WIC Director

Research Activity
State Agency Survey

Local WIC Agency Directory

Local WIC Agency Survey

0.72

WIC Participants

WIC Participant Certification Survey

0.50

Program Experiences Survey

0.50

Former WIC Participants Case Study

0.67

Denied Applicant Survey

0.58

Denied WIC Applicants

Time (Hours)
1.15

See the enclosed excel burden table for the detailed burden estimate.

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6. Project Purpose, Methodology, and Formative Research Design:
Background
A primary objective of the Third National Survey of WIC Participants (NSWP-III) is to provide
FNS with nationally representative estimates of improper payments from the WIC program
arising from errors in the certification or denial of WIC applicants, in order to fulfill the
requirements of the Improper Payment Elimination and Recovery Act (IPERIA) of 2012. In
addition, the study will investigate potential SA and LA characteristics that may correlate with
these errors, and will assess WIC participants’ reasons for satisfaction or dissatisfaction with the
program. NSWP-III builds on three previous studies and reports that span several decades.
To accomplish study objectives, the following data collections are planned for the full data
collection: (1) a Certification Survey with up to 2,000 recently certified WIC participants; (2) a
Denied Applicant Survey with up to 240 WIC applicants who did not qualify for the program;
(3) a Program Experiences Survey with up to 2,500 current WIC program participants; (4) a
Former Participant Case Study with 125 inactive WIC program participants who have stopped
redeeming WIC benefits; (5) a State Agency Survey with 90 agencies, including 50 States and
the District of Columbia, 34 Indian Tribal Organizations (ITOs), and 5 U.S. Territories; and (6) a
Local WIC Agency Survey with 1,500 local WIC agency directors.
Purpose
The purpose of each data collection activity is described below.
State Agency Survey
Federal guidelines grant SAs substantial authority to determine the State’s WIC Program
operations and procedures, including providing guidance to LAs on implementing procedures to
determine an applicant’s eligibility, negotiating and determining food options, establishing
application and payment procedures, and establishing program data management systems and
procedures. The State Agency Survey is designed to identify policies and practices that each
WIC SA has established under these discretionary powers, and to enable comparisons of their
potential effects. The State Agency Survey was created by incorporating and modifying
questions from NSWP-II. Some questions are new to the NSWP-III survey, some NSWP-II
questions have been dropped due to changes in the program since the prior study was conducted,
and other questions have been dropped because they were outside the scope of research questions
detailed in the Performance Work Statement (PWS).
Local Agency Survey
The Local Agency Survey will focus on the services the LA provides to WIC participants, as
well as the infrastructure of the WIC agency itself, including structure of the agency, clinics and
sites under the LA, income eligibility procedures, certification procedures, and food instrument
or food distribution procedures. LAs will also be asked about the policies and practices at their
sites. These questions will characterize heterogeneity in site-level policies and practices across
the nation. The Local Agency Survey was created by incorporating and modifying questions
from NSWP-II. Some questions are new to the NSWP-III survey, some NSWP-II questions have

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been dropped due to changes in the program since the prior study was conducted, and other
questions have been dropped because they were outside the scope of research questions detailed
in the PWS.
Certification Survey
The Certification Survey’s purpose is to meet the objective of calculating improper payment
rates due to certification error in the WIC program. Data from the survey, combined with State
administrative data on WIC participants and redemptions of food instruments, will allow the
research team to estimate rates of case error and improper payments in a nationally
representative sample, as well as for each of the five certification categories (pregnant women,
breastfeeding women, non-breastfeeding postpartum women, infants, and children), by asking
respondents questions related to their eligibility for WIC. The Certification Survey has been
adapted from NSWP-II’s Certification Survey to maintain as much comparability as possible,
while balancing the need to reflect current certification regulations.
Denied Applicant Survey
The purpose of the Denied Applicant Survey is to determine whether WIC applicants who were
deemed ineligible were correctly or erroneously denied WIC benefits. The survey data will
inform the estimation of the rate and associated dollar cost of underpayments due to erroneous
denials. An additional purpose is to describe the reasons why applicants were correctly or
erroneously denied WIC benefits. To answer the study objectives, the Denied Applicant Survey
differs from that used in NSWP-II. The prior study’s Denied Applicant Survey did not ask
requisite questions needed to determine whether the denial was made correctly or erroneously. In
order to know if an applicant was correctly or erroneously denied, the study must confirm the
applicant’s residence, certification category, and income at the time of application. To achieve
these objectives, the NSWP-III Denied Applicant Survey, in large part, mirrors the Certification
Survey, with appropriate modifications to introductory language and question stems—for
example, referring to the applicant’s “date of application” rather than “date of certification.”
Program Experiences Survey
The Program Experiences Survey will collect data on WIC participants’ program experiences,
participation in other programs, food security, and other characteristics not available from
administrative data. The Program Experiences Survey was created by incorporating and
modifying questions from NSWP-II. Some questions are new to the NSWP-III survey.
Former WIC Participants Case Study
The Former WIC Participants Case Study consists of qualitative interviews designed to examine
the barriers and facilitators to WIC program retention. The instrument also seeks to determine
reasons why a participant stopped redeeming benefits within their period of eligibility. The
research team will select former participants from the previously identified sampling units of
LAs for this qualitative study, using administrative data provided by the SAs.
Methodology/Research Design
State Agency Survey
A paper-and-pencil, self-administered survey will be administered to selected SAs.

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FNS will aid the research team in contacting the Regional Offices of three selected regions. Each
of the three Regional Offices will be provided a list of four States selected for participation in the
pretest of the State Agency Survey. The Regional Offices will be asked to alert the selected SAs
to expect an invitation to participate in the pretest and to confirm contact information of the
person who will be responsible for completing the survey.
The research team will mail a hard copy of the invitation letter and two hard copies of the
questionnaire (one to keep and one to return) to nine of the selected SA directors. The remaining
three SAs will be kept as potential back-up participants, if the research team is having difficulty
gaining participation from an SA during the data collection period. The mail package will be sent
using FedEx priority mail; this will allow for the package to stand out among the other mail
items the official may receive, and it allows for the package to be tracked. The package will
include a prepaid FedEx envelope to return the completed survey to the research team.
The research team will follow up with a telephone call 2 days after the package should have been
received. The purpose of this call will be to answer any questions, identify the point of contact,
and emphasize the timing of the pretest. For some of the SAs, this telephone call will also be
used to obtain recommendations and contact information for LAs to include in the pretest. For
the two SAs selected to provide contact data for participants who will be contacted for other
surveys, this call will be used to answer any questions they may have for that procedure.
Reminder emails will be sent each week of the data collection period. No more than four
reminder emails will be sent. If the State WIC Agency Director does not return the survey within
2 weeks after the invitation letter and survey are sent, the research team will place a follow-up
reminder telephone call.
Once the research team receives each survey response, a trained interviewer will contact the SA
director to schedule a debriefing telephone interview. During the debriefing telephone interview,
the interviewer will ask pretest participants to estimate how long it took them to complete the
survey, and to identify any survey questions that were confusing or difficult to answer. After the
pretest data collection period has ended, the research team will send a thank-you email (or letter)
to all SA directors who participated in the pretest. Feedback provided during the pretest will be
used to revise the State Agency Survey. The survey will be programmed into the web-based
survey software program, Qualtrics, for use with the full study sample.
Local Agency Survey
A paper-and-pencil, self-administered survey will be sent to selected LAs with contact
information provided by the SAs.
The research team will email an invitation to selected LAs and mail a hard copy of the invitation
letter with two hard copies of the questionnaire (one to keep and one to return). The mail
package will be sent using FedEx priority mail; this will allow for the package to stand out
among the other mail items the official may receive, and it allows for the package to be tracked.
The package will include a prepaid FedEx envelope to return the completed survey to the
research team.

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The research team will follow up with a telephone call 2 days after the package should have been
received. The purpose of this call will be to answer any questions, identify the point of contact,
and emphasize the timing of the pretest. For some of the LAs, this telephone call will also be
used to start the process of obtaining a sample of participants to pretest other instruments (if
necessary).
Reminder emails will be sent each week of the data collection period. No more than four
reminder emails will be sent. If the LA director does not return the survey within 2 weeks after
the invitation letter and survey are sent, the research team will make a follow-up reminder
telephone call.
Once the research team receives each survey response, a trained interviewer will contact the LA
director to schedule a debriefing telephone interview. During the debriefing telephone interview,
the interviewer will ask pretest participants to estimate how long it took them to complete the
survey, and to identify any survey questions that were confusing or difficult to answer. After the
pretest data collection period has ended, the research team will send a thank-you email (or letter)
to all LA directors who participated in the pretest. Feedback provided during the pretest will be
used to revise the Local Agency Survey. The survey will be programmed into the web-based
survey software program, Qualtrics, for use with the full study sample.
Certification Survey
In-person survey interviews will be conducted with nine selected current WIC participants (e.g.,
with five interviews in English and four in Spanish). Participants will be recruited as described in
the Recruiting and Consent section.
Selected participants will be scheduled for an interview which will take place at their home.
After obtaining informed consent in person, the Field Interviewer (FI) will administer the survey
from a paper questionnaire, reading each question aloud, following interviewer instructions, and
writing down the responses indicated by the WIC participant. As specified in the questionnaire,
the FI will obtain and review documentation of income and other determinants of eligibility, and
then return the documentation to the respondent. The FI will use a stopwatch to record the total
duration needed for the survey. The FI will debrief the respondent immediately following the
completion of the Certification Survey and identify any questions that were confusing or difficult
to answer. After completing the survey and debriefing, the FIs will thank each pretest participant
and provide a $25 gift card. After incorporating changes needed to improve item response rates,
the flow and timing of questions, and/or clarity of questions asked, the survey will be
programmed for computer assisted personal interviewing (CAPI) for use with the full study
sample.
Denied Applicant Survey
In-person survey interviews in either English and Spanish will be conducted with a total of nine
selected denied WIC applicants (e.g., with five interviews in English and four in Spanish).
Data collection protocols are identical to that for the Certification Survey. Selected participants
will be scheduled for an interview which will take place at their home. After obtaining informed
consent in person, the FI will administer the survey from a paper questionnaire, reading each

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question aloud, following interviewer instructions, and writing down the responses indicated by
the survey participant. As specified in the questionnaire, the FI will obtain and review
documentation of income and other determinants of eligibility, and then return the
documentation to the respondent. The FI will use a stopwatch to record the total duration needed
for the survey. The FI will debrief the respondent immediately following the completion of the
Denied Applicant Survey and identify any questions that were confusing or difficult to answer.
After completing the survey and debriefing, the FIs will thank each pretest participant and
provide a $25 gift card. After incorporating changes needed to improve item response rates, the
flow and timing of questions, and/or clarity of questions asked, the survey will be programmed
for CAPI for use with the full study sample.
Program Experiences Survey
Interviews with a total of nine current WIC participants will be conducted by telephone (e.g.,
with five interviews in English and four in Spanish). Participants will be recruited as described in
the Recruiting and Consent section.
Trained telephone interviewers (TI) will administer the survey using paper copies that will have
the same questions, response options, and prompts as the questionnaires that will be programmed
for use with the full study sample. After verbally obtaining informed consent by telephone, the
TI will administer the survey, reading each question aloud, following interviewer instructions,
and writing down the responses indicated by the WIC participant. The TI will use a stopwatch to
record the total duration needed for the survey.
The TI will debrief the respondent immediately following the completion of the Program
Experiences Survey and identify any questions that were confusing or difficult to answer. After
completing the survey and debriefing, the TIs will thank each pretest participant and obtain a
delivery address for sending a $25 gift card. After incorporating changes needed to improve item
response rates, the flow and timing of questions, and/or clarity of questions asked, the survey
will be programmed for computer assisted telephone interviewing (CATI) for use with the full
study sample.
Former WIC Participant Case Study
Telephone-based interviews will be conducted with nine selected former WIC participants (e.g.,
with five interviews in English and four in Spanish). Participants will be recruited as described in
the Recruiting and Consent section.
The Former WIC Participant Case Study interviews are qualitative in nature and the interview
guide will be available on paper for interviewers to conduct by telephone. After verbally
obtaining informed consent by telephone, the TI will administer the survey, reading each
question aloud, following interviewer instructions, and audio recording the interview, if
recording is permitted by the respondent. If permission is not given to audio-record the
interview, an additional TI will be asked to take notes. The TI will use a stopwatch to record the
total duration needed for the survey.
The TI will debrief the respondent immediately following the completion of the Former WIC
Participant Survey and identify any questions that were confusing or difficult to answer. After

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completing the survey and debriefing, the TIs will thank each pretest participant and obtain a
delivery address for sending a $25 gift card. After incorporating changes needed to improve item
response rates, the flow and timing of questions, and/or clarity of questions asked, the survey
will be programmed for CATI for use with the full study sample.
Design/Sampling Procedures
State Agency Survey
The research team will select three FNS Regional Offices and nine SAs under the jurisdiction of
those offices as the primary SA sample. An additional SA will also be identified in each region
to serve as a back-up if the research team is having difficulty gaining participation from an SA
during the data collection period. The research team will present a list of SAs recommended for
the pretest to FNS for review. The research team will seek a mix of urbanized and rural States
from each of three regions. The team also will seek to include an ITO or territory among the nine
responding agencies, if possible.
Local Agency Survey
SAs that have agreed to participate in the pretest of the State Agency Survey will be asked to
help the research team identify one or two LAs that could participate in this pretest. The
overriding criterion for selection would be to select LAs that the SA believes would be most
cooperative in the short timeframe of the pretest. Again, following a convenience sample study
design, the research team will continue to recruit LAs to pretest the instrument until up to nine
LA directors agree to participate.
Certification Survey
A subsample of two SAs (and LAs within these two States, if necessary) that participate in the
pretest will be asked to provide the names of 50 English-speaking participants and 50 Spanishspeaking participants, who were certified up to 4 weeks prior to the start of pretesting, who may
be invited to participate in the pretest. These State or local agencies will be selected such that inperson pretesting can occur in one or two geographic areas where trained interviewers are
available, to minimize travel costs and to facilitate efficient data collection during the short
pretesting period. The selected participants will be invited to take part in the pretest until nine
current participants have responded to the survey (e.g., with five interviews in English and four
in Spanish). Both versions of the instrument—that is, the instrument for use with adult WIC
participants themselves, and the version for parents or legal guardians of infant or child WIC
participants—will be pretested. Therefore, each version of the survey (English Version A for
adult WIC participants; Spanish Version A for adult WIC participants; English Version B for
infant/child WIC participants; and Spanish Version B for infant/child WIC participants) will be
pretested with two to three people, for a total of nine pretest respondents.
Denied Applicant Survey
A subsample of SAs (and LAs within these SAs, if necessary) that participate in the pretest will
be asked to provide the names of 50 English-speaking applicants who were denied WIC
assistance and benefits no more than 6 months prior to the onset of pretesting, and 50 Spanishspeaking applicants who were denied WIC assistance and benefits no more than 6 months prior
to the onset of pretesting, who could be contacted for the pretest. These SAs or LAs will be

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selected based on geographic proximity to facilitate efficient data collection during the short
pretesting period. The selected participants will be contacted until nine denied WIC applicants
have responded to the survey. The research team will pretest the instrument in English and
Spanish with a total of nine respondents selected from a list of denied WIC applicants. Both the
adult and child versions of the instrument will be pretested. Therefore, each version of the survey
(English Version A for adult WIC applicants; Spanish Version A for adult WIC applicants;
English Version B for infant/child WIC applicants; and Spanish Version B for infant/child WIC
applicants) will be pretested with two to three people, for a total of nine pretest respondents.
Program Experiences Survey
A subsample of the SAs (and LAs within these SAs, if necessary) that participate in the pretest
will be asked to provide the names of a total of 50 English-speaking participants and 50 Spanishspeaking participants who could be contacted for the pretest. The research team will pretest the
instrument with a total of nine respondents selected from a list of WIC participants (e.g., with
five interviews in English and four in Spanish). Both the adult and child versions of the
instrument will be pretested. Therefore, each version of the survey (English Version A for adult
WIC participants; Spanish Version A for adult WIC participants; English Version B for
infant/child WIC participants; and Spanish Version B for infant/child WIC participants) will be
pretested with two to three people, for a total of nine pretest respondents.
Former WIC Participant Case Study
A subsample of the SAs (and LAs within these SAs, if necessary) that participate in the pretest
will be asked to provide the names of 50 English-speaking former participants and 50 Spanishspeaking former participants who could be contacted for the pretest. Depending on the
capabilities of the SA’s management information system (MIS), the Study Plan refers to two
methods that would be used for selecting samples of former participants. The preferred method
for the pretest is to select those States where the MIS is capable of identifying former
participants who stopped redeeming benefits before the end of their certification period as target
participants for the survey.
The research team will pretest the instrument in English and Spanish with a total of nine
respondents selected from a list of former WIC participants. Both the English and Spanish
versions will be tested (e.g., with five interviews in English and four in Spanish).
Recruitment and Consent
Using the sampling plan detailed above, recruitment will follow the procedure(s) described
below:
State Agency Survey
FNS will aid the research team in contacting the Regional Offices of three selected regions. Each
Regional Office will be provided a list of three SAs selected for participation in the State Agency
Survey pretest. The research team will identify a fourth SA as a back-up if it is having difficulty
gaining participation from an SA during the data collection period.

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The research team will use current contact information to send an email invitation letter to the
nine State WIC Agency Directors to request their participation in the study and remind them of
their obligation to participate in these types of studies. The research team will mail a hard copy
of the invitation letter and two hard copies of the questionnaire (one to keep and one to return) to
the selected State WIC Agency Directors. The research team will follow up with a phone call 2
days after the package should have been received. The purpose of the call will be to answer any
questions, confirm the point of contact, and emphasize the timing of the pretest.
Reminder emails will be sent each week of the pretest period, and up to two reminder telephone
calls will be made, until a SA completes its survey.
Local Agency Survey
The research team will email an invitation letter to selected Local WIC Agency Directors in the
sample to request their participation in the study and remind them of their obligation to
participate in these types of studies.
The research team will mail a hard copy of the invitation letter and two hard copies of the
questionnaire (one to keep and one to return) to the selected LA directors. The research team will
follow up with a telephone call 2 days after the package should have been received. The purpose
of the call will be to answer any questions, confirm the point of contact, and emphasize the
timing of the pretest.
Reminder emails will be sent each week of the data collection period. If the LA director does not
return the survey within 2 weeks after the invitation letter and survey are sent, the research team
will make up to two follow-up reminder telephone calls.
Certification Survey
Prior to conducting the in-person interviews, trained recruiters will contact potential respondents
to participate in the pretest of the Certification Survey by telephone. Trained FIs will then
schedule in-person interviews by telephone with those who have agreed to participate. FIs will
schedule a time that is convenient for the participant and follow up with a confirmation and
reminder phone call 1 day prior to the scheduled interview time. If a participant gives the FI
permission to send text messages, then text messages will be used to confirm a scheduled
interview. Prior to administering the Certification Survey, the FI will thoroughly review the
study consent form. Consent will be obtained in writing, and a copy of the signed consent form
will be provided to the respondent (one copy kept by the FI). In the event of non-consent, the FI
will thank the sampled participant, conclude the visit and leave their home.
Denied Applicant Survey
Recruitment protocols will be identical to that for the Certification Survey. Prior to conducting
the in-person interviews, trained FIs will schedule in-person interviews by telephone. FIs will
schedule a time that is convenient for the participant and follow up with a confirmation and
reminder phone call 1 day prior to the scheduled interview time. If a participant gives the FI
permission to send text messages, then text messages will be used to confirm a scheduled
interview. Prior to administering the Denied Applicant Survey, the FI will thoroughly review the
study consent form. Consent will be obtained in writing and a copy of the signed consent form
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will be provided to the respondent (one copy kept by the FI). In the event of non-consent, the FI
will thank the sampled participant, conclude the visit and leave their home.
Program Experiences Survey
TI will use current contact information to call the WIC participants selected for the telephone
Program Experiences Survey. No more than five attempts (telephone calls) will be made to
contact the respondent. Prior to administering the telephone Program Experiences Survey, the TI
will read the study consent form; consent will be obtained verbally.
Former WIC Participant Case Study
TI will call the sample selected for interview for the Former WIC Participant Case Study. No
more than five attempts (telephone calls) will be made to contact the respondent. Prior to
administering the Former WIC Participant Case Study, the TI will read the study consent form;
consent will be obtained verbally.
Incentives
Accurate estimation of certification errors and improper payments in WIC depends on
participation in the Certification and Denied Applicant Surveys. The validity of responses to the
Program Experiences Surveys, and to a lesser extent, the Former WIC Participant Case Study,
depend on a sufficient response rate. While pretesting will take place on a small number of
respondents, the quality of pretesting based on participation will allow the survey instruments to
be refined to modify the flow, order and timing of questions, clarify questions asked, and revise
or omit items that yield high item nonresponse rates. Incentives will be used for the following
instruments during pretesting (no incentives will be provided for SAs or LAs):
Certification Survey
To maximize response rates, the research team proposes an incentive of $25 in the form of a gift
card for completing the Certification Survey. The justification for providing this level of
incentive is to help mitigate the potential for nonresponse bias and to enhance the quality of the
data collected. There is burden on the respondent to provide sensitive information and
documentation about their income and other eligibility factors. The incentive will be used to
compensate the respondent for this unusual reporting burden. The incentive will also mitigate
some expenses related to child care or travel (in the event that the interview cannot be conducted
at the participant’s home).
Program Experiences Survey
To maximize response rates, the research team proposes an incentive of $25 in the form of a gift
card for completing the Program Experience Survey. The justification for providing this level of
incentive is to help mitigate the impact of nonresponse bias and to enhance the quality of the data
collected. There is burden on the respondent to respond to this survey. The incentive will be used
to compensate the respondent for this reporting burden.
Former WIC Participant Case Study
To maximize response rates, the research team proposes an incentive of $25 in the form of a gift
card for completing the Former WIC Participant Case Study interview. The justification for
providing this level of incentive is to help mitigate the impact of nonresponse bias and to

11

enhance the quality of the data collected. There is burden on the respondent to identify sensitive
information about their experiences. The incentive will be used to compensate the respondent for
this unusual reporting burden.
Data Analysis
Analyses of the pretest data will include calculation of the average, median, and maximum
duration of each survey (to provide an empirical estimate of burden); identification of items with
high nonresponse and/or frequent indications by respondents during debriefing of questions
being unclear; and qualitative review of suggestions received during debriefing for modifying the
order, flow, or wording of items. Data collection instruments will be revised as needed based on
these sources of data.
7. Confidentiality:
FNS complies with the Privacy Act of 1974. All information gathered from SA and LA directors,
current and former WIC participants, and denied applicants who participate in this study, is for
research purposes only and will be kept private to the full extent allowed by law. Data from the
data collection efforts will be presented in aggregate form, and therefore cannot be linked back to
the response of any individual. All respondents will be given consent forms that state their
personal information will be kept private, and that their responses will only be used for summary
tabulations and statements of best practices. FNS published a system of record notice (SORN)
titled FNS-8 USDA/FNS Studies and Reports in the Federal Register on April 25, 1991, volume
56, pages 19078–19080, that discusses the terms of protections that will be provided to
respondents. To ensure that personal information remains private, the contract executed between
FNS and Capital Consulting Corporation (CCC) requires that CCC create and keep data on
secure networks, and utilize data collectors who sign confidentiality agreements binding them to
protect private information. The Contractor will assign a unique ID number to each respondent.
A data file (called the “master key file”) will contain each respondent’s ID number, name, and
contact information. This file will be encrypted and retained by CCC and its subcontractors, Abt
Associates Inc., Abt SRBI, and 2M Research Services separate from data files containing
respondent responses to data collection. Data files used to analyze pretesting of the instruments
will not include the name or other personally identifiable information (PII) of any respondent.
Such PII will be replaced with the respondent ID number in analysis data files. Once the contract
is over, the Contractor will destroy the master key file with private information.
8. Federal Costs:
The total cost to the Federal Government is $157,998.01, which includes the total cost for
Contractor and Federal Staff costs for the abbreviated supporting statement, developing the
instruments, and the collection of pretesting information. The Contractor cost is estimated at
$157,044.97. This is based on an estimate of 1005 hours, with a salary range of $54.33–
$220.75/hour, and includes overhead costs. This information collection also assumes a total of 22
hours of Federal employee time: for GS-12, step 6 at $43.32 per hour, for a total of $953.04 on
an annual basis. Federal employee pay rates are based on the General Schedule of the Office of
Personnel Management (OPM) for 2016.

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9. Research Tools/Instruments:
All instruments being pretested in the field and recruitment materials being pretested in the
research lab are listed below. Instruments are included as appendices and listed by Appendix ID
in the enclosed burden table.

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