Part_A_Generic_Clearance_Cognitive_Pilot_and_Field_Studies_final

Part_A_Generic_Clearance_Cognitive_Pilot_and_Field_Studies_final.docx

Generic Clearance for Cognitive, Pilot and Field Studies for Bureau of Justice Statistics Data Collection Activities

OMB: 1121-0339

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  1. JUSTIFICATION


1. Importance of Information


This is a request for a 3-year generic clearance for the Bureau of Justice Statistics (BJS) that will allow it to develop, test, and improve its survey and data collection instruments and methodologies. The procedures utilized to this effect include, but are not limited to, tests of various types of survey and data collection operations, focus groups, cognitive laboratory activities, pilot testing, field testing, exploratory interviews, experiments with questionnaire design, and usability testing of electronic data collection instruments.


BJS is requesting the generic clearance in order to test new methodologies for surveys and data collection activities. In addition to the self-report surveys BJS conducts, such as the National Crime Victimization Survey and the Prison and Jail Inmate Surveys, BJS is expanding or enhancing its data collection efforts in the areas of establishment surveys, for instance through development of supplements to the Annual Probation Survey and Annual Parole Survey and the new National Survey of Victim Service Organizations, and by exploring the use of administrative data collected by other agencies that can enhance our understanding of the functioning of the justice system, such as BJS’ efforts to redesign the National Judicial Reporting Program and to collect data on elder abuse via the Assessment of Administrative Data on Elder Abuse, Mistreatment and Neglect. We believe the generic clearance will be a helpful vehicle for evaluating questionnaires/assessments and various other data collection procedures related to these new or changing data collections.


In the past, BJS has approached design and testing either through redesign projects that obtained full OMB clearance for data collection, such as BJS’ efforts under PREA; or BJS has relied on convenience samples of 9 or fewer persons to provide input and feedback on survey design and data collection methodologies. Neither of these approaches meets BJS’ needs to develop and implement more rigorous testing procedures. Seeking full OMB clearance prior to testing instruments causes delays to BJS achieving its timeliness objectives for collections. Reliance on 9 or fewer persons does not provide a basis for conducting any type of test and the data from 9 or fewer have no generalizability. The information collected via these mechanisms, while still helpful, was nonetheless somewhat limited in its ability to detect and diagnose problems with the instruments and the procedures being tested. The generic testing clearance will allow BJS to take advantage of a variety of methods that are useful for identifying questionnaire/assessment and procedural problems, suggesting solutions, and measuring the relative effectiveness of alternative solutions. Through the use of these techniques, when employed routinely in the testing phase of BJS data collections, questionnaires and assessments can be simplified for respondents, respondent burden can be reduced, procedures for the collection of administrative data can be streamlined, and the quality of the questionnaires and assessments used in continuing and one-time surveys and assessments can be improved. Thus an increase in the quality of the data collected can be achieved as well.


BJS is requesting a three-year generic clearance for pretesting, during which BJS will provide periodic reports on pretesting activities. The pretesting activities conducted under this generic clearance will be for development work only. These development activities will include such things as investigation of item types, research on the availability and quality of administrative data from state and local justice agencies, small scale tests to test appropriate access and retrieval methods for various types of administrative data, research about mode of administration (telephone, paper and pencil, computer-based, mail-out and mail-in, etc.), methodology of questionnaires and assessments, and testing of items. Activities covered under this generic clearance will not include field testing of a full-scale program implementation protocol.


This clearance package is intended to serve as a request for generic clearance. In this document we have provided a description of the scope of possible activities that might be covered under this clearance. The requested clearance is important to BJS’ use of pretesting activities, because of the length of time required to plan the activities. This generic clearance will go through the usual two Federal Register Review periods. Subsequent to these review periods, BJS requests that OMB review then comment on or clear proposed studies in a two-week period with no 30-day Federal Register Notice period required under the Generic clearance. This clearance is similar to the testing clearances held by the Census Bureau, the Bureau of Labor Statistics, the National Center for Education Statistics, and the National Center for Science and Engineering Statistics.


The specific methods proposed for coverage by this clearance are described below. Also outlined are the procedures BJS plans to put in place for keeping OMB informed about the identity of the surveys and the nature of the research activities being conducted.


The methods proposed for use in questionnaire and assessment development are as follows:


Pilot testing. For the purposes of this clearance, we are defining pilot tests as data collection efforts conducted among either purposive or statistically representative samples, for which evaluation of the questionnaire and/or procedures is the main objective. BJS will only publish research and development (R&D) and methodological reports on the results of these pilot tests, but will not publish statistical reports or data sets based on the findings. Pilot tests are an essential component of this clearance package because they serve as the vehicle for investigating basic item properties for new or redesigned data collection efforts, such as reliability, validity, and difficulty, as well as feasibility of methods for standardized administration of forms. Under this clearance a variety of surveys will be pretested, and the exact nature of the surveys and the samples is undetermined at present. However, due to the smaller nature of the tests, we expect that some will not involve representative samples. In these cases, samples will basically be convenience samples, which could be limited to specific geographic locations, may involve expired rotation groups of a current survey, are known to have specific aggregate demographic characteristics, etc. The needs of the particular sample will vary based on the content of the survey being tested, but the selection of sample cases will not be completely arbitrary in any instance. Where applicable, pilot testing may also include collecting sample administrative data, which will allow BJS to test procedures regarding data procurement as well as comparability of data across sites.


Behavior coding. This method involves applying a standardized coding scheme to the completion of an interview or questionnaire, either by a coder using a tape-recording of the interview or by an in-person observer at the time of the interview. The coding scheme is designed to identify situations that occur during the interview that reflect problems with the questionnaire. For example, if respondents frequently interrupt the interviewer before the question is completed, the question may be too long. If respondents frequently give inadequate answers, this suggests there are some other problems with the question. Quantitative data derived from this type of standardized coding scheme can provide valuable information to identify problem areas in a questionnaire, and can be used as a substitute for or as a complement to the traditional interviewer debriefing.


Interviewer debriefing. This method employs the knowledge of the employees who have the closest contact with the respondents. In conjunction with other methods, we plan to use this method in our field tests to collect information about how interviewers react to the survey instruments, as well as understand problems and pitfalls encountered by interviewers during the interview.


Exploratory interviews. These may be conducted with individuals to understand a topical area and may be used in the very early stages of developing a new survey. It may cover discussions related to administrative records (e.g. what types of records, where, and in what format), subject matter, definitions, etc. Exploratory interviews may also be used to investigate whether sufficient issues are present related to an existing data collection to consider a redesign.


Respondent debriefing questionnaire. In this method, standardized debriefing questionnaires are administered to respondents who have participated in a field test. The debriefing form is administered at the end of the questionnaire being tested, and contains questions that probe to determine how respondents interpret the questions and whether they have problems in completing the survey/questionnaire. This structured approach to debriefing enables quantitative analysis of data from a representative sample of respondents, to learn whether respondents can answer the questions, and whether they interpret them in the manner intended by the questionnaire designers.


Follow-up interviews or re-interviews. This involves re-interviewing or re-assessing a sample of respondents after the completion of a survey or assessment. Responses given in the re-interview are compared with the respondents’ initial responses for consistency between responses. In this way, re-interviews provide data for studies of test–re-test reliability and other measures of data quality. In turn, this information aids in the development of improved, more reliable measures.


Split sample experiments. This involves testing alternative versions of questionnaires, and other collection methods, at least some of which have been designed to address problems identified in draft questionnaires or questionnaires from previous surveys. The use of multiple questionnaires, randomly assigned to permit statistical comparisons, is the critical component here; data collection can include mail, telephone, Internet, or personal visit interviews or group sessions at which self-administered questionnaires are completed. Comparison of revised questionnaires against a control version, preferably, or against each other, facilitates statistical evaluation of the performance of alternative versions of the questionnaire. Split sample tests that incorporate questionnaire design experiments are likely to have a larger maximum sample size than field tests using other methodologies. Larger sample sizes will enable the detection of statistically significant differences and facilitate methodological experiments that can extend questionnaire design knowledge more generally for use in a variety of BJS data collection instruments.

Cognitive and usability interviews. This method involves intensive, one-on-one interviews in which the respondent is typically asked to "think aloud" as he or she answers survey questions. A number of different techniques may be involved, including asking respondents to paraphrase questions, probing questions asked to determine how respondents came up with their answers, and so on. The objective is to identify problems of ambiguity or misunderstanding, or other difficulties respondents have answering questions. This is frequently one of the early stages of revising a questionnaire.


Focus groups. This method involves group sessions guided by a moderator, who follows a topical outline containing questions or topics focused on a particular issue, rather than adhering to a standardized questionnaire. Focus groups are useful for surfacing and exploring issues (e.g., confidentiality concerns) which people may feel some hesitation about discussing.


Procedures for Clearance


Before testing activity is undertaken, BJS will provide OMB with a memo describing the study to be conducted and a copy of instrumentation and debriefing materials that will be used. Depending on the stage of instrumentation development, this may be a printed questionnaire, a set of prototype items showing each item type to be used and the range of topics to be covered by the questionnaire, or an interview script. When split sample experiments are conducted, either in small group sessions or as part of a field test, the different versions of the questionnaires to be used will be provided. For a test of alternative procedures, the description and rationale for the procedures will be submitted. A brief description of the planned field activity will also be provided. BJS requests that OMB raise comments on substantive issues within 10 working days of receipt.


Data collection for this project is permitted under the authorizing legislation for the questionnaire being tested. In most cases, data collection activities conducted by BJS will be authorized under the BJS enabling legislation, 42 USC, Section 3731, Chapter 46, Subchapter III. At this time, it is not known whether other titles will be referenced for specific projects, as we do not know all of the survey questionnaires or data collection protocols that will be pretested during the course of the clearance. The authorizing statute will be specified in each information clearance.


2. Needs and Uses


The information collected in this program of developing and testing questionnaires and other data collection protocols will be used by staff from BJS to evaluate and improve the quality of the data in the surveys and assessments that are ultimately conducted. None of the data collected under this clearance will be published for its own sake.


Because the questionnaires being tested under this clearance are still in the process of development, the data that result from these collections are not considered official statistics of BJS or other Federal agencies. Data will not be made public, except it can be included in research reports prepared for sponsors inside and outside of BJS. The results may also be prepared for presentations related to survey methodology at professional meetings or publications in professional journals.


Information quality is an integral part of the pre‑dissemination review of the information disseminated by BJS (described in BJS’s Data Quality Guidelines, which can be found at http://www.bjs.gov/content/dataquality/dataquality.cfm). Information quality is also integral to the information collections conducted by BJS and is incorporated into the clearance process required by the Paperwork Reduction Act.


BJS anticipates conducting testing work under this Generic IC for a number of projects, including but not limited to the following:


  1. Survey of Prison Inmates (SPI): BJS will pursue development work for the SPI study under the generic clearance in order to test the survey administration prior to seeking full clearance. A memorandum detailing the testing activities will be submitted to OMB for approval. BJS will pilot test the SPI instrument to ensure the questions and response options do not cause any significant comprehension or recall problems for inmates, as well as to test the mode of survey administration (i.e., CAPI with PAPI as the back-up mode) to: 1) ensure the instrument is performing appropriately and the skip logic is programmed accurately; 2) test the length of the survey to ensure it is running within specific time constraints; and 3) test sampling and interviewing protocols to ensure the procedures developed do not cause any significant burden to the facilities or staff.


  1. Probation and Parole Survey Supplements: BJS aims to create supplements to its Annual Probation Survey and Annual Parole Survey for the purpose of gathering data to use to describe and categorize probation and parole agencies on the legal frameworks under which they operate (e.g., sentencing rules), supervision practices, organizational structure, and other factors that help to explain changes in probation and parole populations over time. In order to develop these annual supplements, BJS will conduct pilot studies of the content of the instruments in order to: 1) identify the best respondents for each of the varied survey instrument sections; 2) assess the cognitive burden to respondents and their understanding of survey items (potentially through cognitive interviewing or respondent debriefing); 3) determine respondent capacity to report on survey items; and 4) estimate the burden associated with fielding the supplemental instruments. 


  1. Census of Adult Probation Supervising Agencies (CAPSA): BJS will pursue development work for the CAPSA study under the generic clearance in two ways. Each of the different activities will be requested in separate memoranda submitted to OMB for approval. First, BJS will pilot test the full data collection instrument in a limited and select number of probation agencies to determine: 1) if probation agencies within different branches of government and/or at different levels of government have any significant comprehension problems related to definitional issues, terminology, and question content; 2) to assess usability of the web mode of administration of the survey; and 3) to determine how well the screener portion of the data collection instrument correctly identifies entities as adult probation supervising agencies for the purposes of developing a national frame of all adult probation supervising agencies in the the U.S. Second, BJS will employ semi-structured telephone interviews with contacts in each state to confirm BJS's understanding of the organization of the probation function in their states, as one method to validate the current frame of adult probation supervising agencies and to review the final "fact sheet" describing the organization of probation in their state and provide additional input if necessary.


  1. National Prison Statistics (NPS) supplements to the NPS:  BJS’ goal is to expand the substantive content of the NPS to gather and report data on factors related to the changes in states and federal prison populations, such as sentencing and release practices, procedures affecting “good-time” calculations, and the use of “life without parole” and other types of relatively rare but severe sanctions. In addition, to improve the timeliness of statistics on annual changes in the prison population, BJS is interested in implementing a separate NPS “short” form that would be limited in scope and collected shortly after the end of a calendar year in order to provide a March/April release on the change in the prison population. To accomplish these efforts, BJS will pursue development work for the NPS supplements under the generic clearance. Different methodological development activities will be requested in separate memoranda submitted to OMB for approval. BJS will conduct pilot studies to test the content of the various draft survey instruments to assess: 1) respondent burden; 2) cognitive understanding of items by respondents; 3) capacity to report on the survey items; and 4) methods to identify the best respondent(s) for the varied content. 


  1. Redesign of the National Judicial Reporting Program (NJRP):  One goal of the NJRP redesign is to assess the capacity of each state to provide automated information on criminal cases handled in the state’s trial court system. Ideally, each state would have a statewide criminal court case management information system that contains key case-level attributes (e.g., date of referral, defendant demographics, offenses charged, court disposition, and date of disposition). To accomplish this goal, BJS plans to conduct development work for the NJRP redesign under the generic clearance in several ways. Each of the different activities will be requested in separate memoranda submitted to OMB for approval. First, BJS will employ semi-structured interviews with key court personnel in each state to determine: 1) whether the needed data exist in an automated form; 2) the mechanisms by which BJS may obtain these automated data, including information on formal approvals needed, data sharing agreement requirements, IRB requirements, etc.; 3) the technical process by which the needed data can be extracted from the management information system; 4) the burden and cost to respondents of harvesting these administrative data; and 5) the nature of available data documentation. Second, BJS will collect administrative data from a limited and select number of states, chosen based on information obtained during the semi-structured interview process, in order to assess the comparability of these data across sites and the ability to produce a database with common elements.


  1. Assessment of Administrative Data on Elder Abuse, Mistreatment and Neglect (EAMN): The EAMN data collection project is a new data collection established to examine the problem of elder abuse, mistreatment and neglect by collecting data on cases of suspected elder abuse referred to Adult Protective Services agencies. The study will pursue development work under the generic clearance in two different ways. Each of these different activities will be requested in two separate memoranda submitted to OMB for approval. First, the EAMN project will use semi-structured exploratory telephone interviews with APS personnel in each state to determine: 1) whether any APS case management system is state based or county based; 2) in what form the needed data exist (automated, paper, hybrid); 3) in jurisdictions and/or states with automated data, the mechanisms by which BJS may obtain these automated data, including information on formal approvals needed, data sharing agreement requirements, and IRB requirements; 4) the technical process by which the needed data can be extracted from the case management system; 5) the burden and cost to respondents of harvesting these administrative data; and 6) the nature of available data documentation. Second, the EAMN project will collect administrative data from a selected subset of states and/or jurisdictions (depending on information obtained during the exploratory interviews) in order to assess the comparability of these data across sites and the ability to produce a database with common elements.


  1. NICS Estimates Methodology Development: This project is intended to strengthen communication between state and federal criminal justice agencies and result in an improved understanding of underlying issues pertaining to making criminal history and related records identifiable and ensure records of persons prohibited from purchasing or possessing a firearm are available at the national level. Under separate submissions for approval for development activities under the generic IC, BJS may employ semi-structured interviewing of key stakeholders in state and federal criminal justice agencies, as well as pilot testing of survey instruments.


  1. Criminal Victimization of Persons with Disabilities Residing in Group Quarters (CVGQ): This BJS data collection will assess the feasibility of collecting self-report victimization data from persons with cognitive and/or physical disabilities residing in group quarters. Part of the CVGQ feasibility assessment with focus on methods to interview resident-respondents across different types of group quarters, including the development of an ACASI version of the National Crime Victimization Survey. During the development of a self-report victimization instrument that is accessible to persons with disabilities, particularly those with cognitive impairments, BJS will likely need to employ several of the development and testing methodologies delineated in this generic IC, such as cognitive interviewing, behavior coding, and split sample experiments. Requests for distinct development and testing activities will be submitted to OMB for approval separately.


  1. National Survey of Victim Service Organizations (NSVSO): This is a new BJS data collection designed to assess the feasibility of collecting national data on the types of services offered by victim service organizations, as well as the feasibility of collecting client-level administrative data from these organizations. The NSVSO will seek to utilize the development activities under this generic IC for two purposes. Each of these different activities will be requested in two separate memoranda submitted to OMB for approval. First, BJS must pretest the NSVSO survey instrument in order to assess burden to and cognitive understanding of items by respondents, capacity to report on the items, and methods to identify the best respondent within a given organization (for the varied content covered by the survey). Second, BJS would like to conduct exploratory interviews with key staff in a limited and select number of victim service organizations to determine the availability of client-level administrative data and the mechanisms by which BJS may obtain those data, including any confidentiality, legislative, or other legal restrictions on access.


3. Use of Information Technology


When the survey or assessment being pretested employs automated methods for its data collection, the research conducted under this submission will also use automated data collection techniques. This clearance offers BJS the opportunity to try innovative technologies that can reduce burden, improve data quality and reliability, and increase the use of information technology.


4. Efforts to Identify Duplication


This research does not duplicate any other questionnaire design work being done by BJS or other Federal agencies. The purpose of this clearance is to stimulate additional research, which would not be done under other circumstances due to time constraints. This research will involve collaboration with staff from other agencies that are sponsoring surveys conducted by BJS, when applicable. The research may also involve joint efforts with staff from other Federal laboratory facilities. All efforts would be collaborative in nature, and no duplication in this area is anticipated.


To the maximum extent possible, we will make use of previous information, reviewing results of previous evaluations of survey data before we attempt to revise questionnaires. However, this information is not sufficient to refine our survey questionnaires and assessments without conducting additional research.


5. Minimizing Burden


This research will be designed as relatively small-scale data collection efforts. This will minimize the amount of burden required to improve questionnaires, data collection instruments, and procedures, to test new ideas, and refine or improve upon positive or unclear results from other tests. The results of the research conducted under this clearance are expected to improve the methods and instruments utilized in full scale studies and thereby improve information quality while minimizing burden to respondents.


6. Consequences of Less Frequent Collection


This clearance involves one-time questionnaire and data collection research and development activities for each survey or data collection connected with the clearance. If this project were not carried out, the quality of the data collected would suffer. In addition, activities covered under this clearance will allow for more specific and precise calculation of burden hours and costs associated with survey and data collection efforts conducted by BJS.


7. Special Circumstances


All the guidelines listed in the OMB guidelines are met. There are no special circumstances.


8. Consultations Outside the Agency


The 60-day Federal Register notice was published on September 14, 2012 (77 FR, No. 179, p. 56865). No public comments have been received in response to this notice.


Consultation with staff from other Federal agencies that sponsor surveys conducted by BJS will occur in conjunction with the testing program for the individual survey. Consultation with staff from other Federal laboratory facilities may also occur as part of joint research efforts. These consultations will include discussions concerning potential response problems, clarity of questions and instructions, and other aspects of respondent burden. Additional efforts to consult with potential respondents to obtain their views on the availability of data, clarity of instructions, etc., may be undertaken as part of the testing that is conducted under this clearance.


9. Paying Respondents


While no currently proposed projects involve the use of incentives, BJS may develop other projects where incentives could be used. BJS may offer up to $40 for any cognitive labs and up to $75 for focus group participation. We also may propose incentive experiments in limited cases.


10. Assurance of Confidentiality


According to 42 U.S.C. Section 3735, the information gathered under this clearance shall be used only for statistical or research purposes, and shall be gathered in a manner that precludes their use for law enforcement or any purpose relating to a particular individual other than statistical or research purposes. All respondents who participate in research under this clearance will be informed that the information they provide may be used only for statistical purposes and may not be disclosed, or used, in identifiable form and that their participation is voluntary. For personal visit and telephone interviews, this information will be conveyed verbally by the interviewer. For personal visit interviews, respondents will also be notified in writing to give them something they can keep and read. For self-administered questionnaires, the information will be included in the mailing package, recruitment communications and materials, either on the questionnaire, or the instructions. For Internet-based data collections, this information will be displayed prominently, and in a format that allows the respondent to print it out. All participants in cognitive research will be required to sign written notification concerning the voluntary and confidential nature of their participation. We will also inform respondents in writing of the need to have an OMB number. No participant direct identifiers will be maintained. The Generic Information Clearance will specify the particular authority for the data collection.


11. Justification for Sensitive Questions


It is possible that some potentially sensitive questions may be included in questionnaires that are tested under this clearance. One of the purposes of the testing is to identify such questions, determine sources of sensitivity, and address concerns related to those questions, insofar as possible, before the actual survey is administered. Justification for any sensitive questions included in a project covered by this generic IC will be included in the individual project submissions.


12. Estimate of Hour Burden


We estimate that the number of people involved in our exploratory, field test, pilot, cognitive, and focus group work will average about 1,450 respondents per year, although a larger number of testing activities is projected to occur during the first year of the generic IC. We estimate the average annual burden hours across all proposed project activities will be 4,700 hours. The total estimated respondent burden is approximately 14,100 hours for the period from January 2013 through December 2015. These projected burden hours and number of respondents will be distributed as follows:


Time Period Respondents Respondent burden (hours)


January 2013 – December 2013 2,300 7,500

January 2014 – December 2014 1,025 3,300

January 2015 – December 2015 1,025 3,300



A variety of forms will be used in conducting the research under this clearance, and the exact number of different forms, length of each form, and number of subjects/respondents per form are not thoroughly known at this time. However, we can project that our activities will likely include testing items and data collection modes, and conducting pilot tests, cognitive labs or interviews, exploratory interviews, re-interviews, behavior coding and focus groups.


13. Estimate of Cost Burden


There is typically no cost to respondents for participating in the research being conducted under this clearance, except for their time to complete the questionnaire or participate in an interview or focus group.


14. Cost to Federal Government


It is very difficult to anticipate the actual number of participants, length of interview, and/or mode of data collection for the work to be conducted under this clearance over the entire 3-year clearance period. Without that information, it is not possible to estimate in advance the cost of the work under this IC to the Federal Government. Costs associated with each individual project will be covered by the statistical unit conducting the research and will come from their data collection budgets. We will include information about costs in the individual submissions.


15. Reason for Change in Burden


There is no change in burden, as this is an initial request for a generic information clearance.


16. Project Schedule


This research program is for questionnaire and procedure development purposes. Data tabulations will be used to evaluate the results of questionnaire testing. The information collected in this effort will not be the subject of estimates or other statistics in BJS reports; however, it may be published in research and development reports or be included as a methodological appendix or footnote in a report containing data from a larger data collection effort. The results of this research may be prepared for presentation at professional meetings or publication in professional journals. Due to the nature of this clearance, there is no definite or tentative time schedule at this point. We expect work to be conducted more or less continuously throughout the duration of the clearance.


17. Request to Not Display Expiration Date


No exemption is requested.


18. Exceptions to the Certification


There are no exceptions to the certification.

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