Non-sub change justification memo

TO: Jennifer Park, Office of Management and Budget

Statistical and Science Policy,

Office of Information and Regulatory Affairs

FROM: John Pender DATE: 8/24/15

Economic Research Service

SUBJECT: OMB CONTROL NUMBER: 0536-0072

Request for Non-substantive changes to procedure for increasing the response rate in the health care provider survey component of the Survey on Rural Community Wealth and Health Care Provision (SRCWHCP)

We have completed the survey of health care providers in all 150 communities for the Survey on Rural Community Wealth and Health Care Provision. The mean response rate found in the survey was 23.3%, and was substantially lower in some regions and for some provider types (see attached “Proposal for Provider Survey Non-Response Follow-Up Activities”, hereinafter referred to as the “proposal”). This response rate is much less than the 80% response rate predicted in the Information Collection Request (ICR) for this survey, despite our efforts to maximize the response rate using virtually all of the applicable suggestions provided by OMB’s Guidance on Agency Survey and Statistical Information Collections (dated January, 2006), and despite additional efforts to increase the response rate that were approved by OMB after we completed the pilot phase of the survey (see my non-substantive change request dated February 6, 2015). The lower than anticipated response rate in the survey raises concerns about the statistical power and possible non-response bias of the results of the full survey.

To address these concerns, we request the following non-substantive changes to the recruitment protocol for potential respondents in the survey:

• One final contact will be made to non-respondents of all three provider types in all three regions.

• As much as time allows, telephone calls will be made to the clinics of those providers to verify that the providers are still at that address. This could slightly reduce the number of non-respondents who will receive the survey and gift.

• The survey will be sent with a personalized letter and a $40 unconditional cash incentive payment to non-respondents via Priority U.S. Mail, using a flat rate envelope that is tracked and insured.

• Return envelopes will use postage stamps rather than business reply envelopes.

• The 366 respondents who completed the survey earlier this year will be sent a “thank you” letter with a $40 cash gift enclosed.

There will be no changes to the mail/web survey questions. Copies of the cover letter to non-respondents and the thank you letter to earlier respondents are attached.

The rationale for these proposed changes is provided in the attached proposal. We estimate that 25% of the 1186 non-respondents contacted in this manner may complete the survey. This would provide another 296 completed surveys, bringing the total to 662 (approximately 42% of the eligible sample of 1570). While still well below the OMB goal of 80%, this would increase the power for overall analysis and contribute valuable information for the analysis of non-response bias.

Revised Burden Estimate

The estimated burden to date on sampled providers to date is shown in Table 1, which includes the total number of primary health care providers contacted for the mail/web survey, the outcomes, and the burden in minutes. The estimate allows 15 minutes for each sampled provider to read and review the survey materials and decide whether or not to participate and an additional 15 minutes to complete the survey, either online or on paper. The resulting total burden to date for the Health Care Provider Survey is 546.75 hours.

Table 1. Health Care Provider Survey Outcome Totals and Burden to Date

Outcomes	Number	Average Minutes per Case	Total Minutes	Total Hours
Not Eligible	251	15	3765	62.75
Refused	18	15	270	4.5
No Response	1186	15	17,790	296.5
Completed Surveys	366	301	10,980	183.0
TOTAL	1821		32,805	546.75

¹The 30 minute time allocation for each Completed Survey includes 15 minutes for reviewing the request and reading enclosed materials and 15 minutes for completing the survey.

The estimated burden on sampled providers after incorporating the non-response follow-up is shown in Table 2. This estimate adds 3 minutes for each of the 366 Completed Surveys (Spring) group for receiving the “thank you” letter with a gift card. Because the non-respondents have already been contacted twice in the past, the burden estimate includes an additional 5 minutes to open the mailing and review the materials, both for those who do not respond and for those who do complete the survey. Completing the survey is still estimated as 15 minutes. The resulting total burden to complete the Health Care Provider Survey, including the proposed non-response follow-up, is 735.38 hours. This is 60 hours more than the total burden initially estimated in the ICR for the health care provider surveys (675 hours). However, the ICR also estimated 547.5 hours of burden for the Phase 3 component. Due to timeline constraints, Phase 3 activities will be much more limited than originally planned; so the overall project burden will be less than the ICR estimate. Revised Phase 3 activities will be proposed in a subsequent document.

Table 2. Health Care Provider Survey Outcome Totals and Burden with Non-Response Follow-up

Outcomes	Number	Average Minutes per Case	Total Minutes	Total Hours
Not Eligible	251	15	3,765	62.75
Refused (Spring)	18	15	270	4.5
Refused (Fall)	10	5	50	0.8
No Response (Spring & Fall)	880	20	17,600	293.3
Completed Surveys (Spring)	366	33	12,078	201.3
Completed Surveys (Fall)	296	35	10,360	172.7
TOTAL	1821		44,123	735.38

4