Support Statement A

OMB Control Number: 0990-0281

ODPHP Generic Information Collection Request: Prevention Communication and Formative Research

Audience Research to Inform Physical Activity Guidelines Strategic Communication

Supporting Statement — Section A

June 21, 2017

Submitted to:

Sherrette Funn

Office of the Chief Information Officer

U.S. Department of Health and Human Services

Submitted by:

Frances Bevington

Strategic Communication and Public Affairs Advisor

Office of Disease Prevention and Health Promotion

U.S. Department of Health and Human Services

Section A — Justification

1. Circumstances Making the Collection of Information Necessary

In the United States, more than one-third of adults¹ and 17% of children² are obese. Obesity is related to many serious health conditions, including heart disease, stroke, type 2 diabetes and certain types of cancer. In 2008, the estimated annual medical cost of obesity in the United States was $147 billion.

According to the Centers for Disease Control and Prevention (CDC), a combination of factors — including behaviors like physical activity — are critical to preventing and treating obesity.³

The Office of Disease Prevention and Health Promotion (ODPHP) will be releasing the second

edition of the Physical Activity Guidelines in 2018. Based on the latest science, the Physical Activity Guidelines provides guidance on how children and adults can improve their health through physical activity.

The success of the second edition of the Physical Activity Guidelines — in other words, the extent to which these recommendations affect Americans’ physical activity knowledge, attitudes, and behaviors — depends in part on the effectiveness of Physical Activity Guidelines outreach and communication.

In preparation for the release of the new guidance, ODPHP seeks to test consumer messages and graphics that will be used to promote the Physical Activity Guidelines recommendations and encourage consumers to be more physically active.

In 2012, ODPHP submitted a request to renew its Generic Clearance (0990-0281). In this submission, ODPHP described plans for research to evaluate the Ad Council’s Childhood Obesity Prevention communications campaign. ODPHP never conducted this childhood obesity research. Therefore, the childhood obesity research that ODPHP proposed in 2012 has no impact on this request to conduct research related to the Physical Activity Guidelines.

Furthermore, the childhood obesity research proposed in 2012 had a distinct purpose and audience that differ dramatically from the purpose and audience of the research proposed in this submission. In 2012, ODPHP proposed researching how moms and kids receive, understand and respond to childhood obesity-related advertising materials. In contrast, this submission requests approval to conduct research with adults 35 to 64 — including, but not limited to, parents — to test draft graphics and messages designed to raise awareness of Physical Activity Guidelines recommendations and encourage adults to get the recommended amount of physical activity for themselves and their families.

2. Purpose and Use of the Information Collection

To support these efforts, ODPHP has developed preliminary messages and graphics that promote the guidelines. This research is intended to serve as a process check and gauge whether consumers understand the messages and find the graphics relatable and persuasive.

In order to obtain this feedback, ODPHP proposes conducting focus groups with consumers. Focus groups are the most efficient way to collect in-depth feedback on these audiences’ preferences and information needs.

Consumer Focus Groups

ODPHP is seeking approval to conduct 9 in-person, 90-minute consumer focus groups with adults ages 35–64. The groups will be conducted in 3 metropolitan areas: Baltimore, MD; Chicago, IL and Las Vegas, NV, which represent 3 HHS regions. At least one group per location will be conducted with parents of adolescents (ages 12-17).

ODPHP will recruit up to 8 participants for each group (72 participants total). Focus groups will be conducted in English and Spanish, and audiences will be segmented as follows:

	Baltimore, MD	Chicago, IL	Las Vegas, NV	Total
Adults (General)
English	1	1	2	4
Spanish	1	1		2
Parents of Adolescents
English	1	1	1	1
Total FG	3	3	3	9

All participation is strictly voluntary.

ODPHP will seek insight into the following research questions:

• What are consumers’ perceptions and opinions of PAG graphics?

• To what extent do consumers understand the messages?

• What messages and visuals do consumers find appealing?

• What messages and visuals do consumers find persuasive, motivating, and doable?

• What factors influence the effectiveness and acceptability of messages and graphics?

Information Use

Following the focus groups, ODPHP will develop a summary report that details key findings. ODPHP will present findings in aggregate and will not collect or report information that identifies individual participants.

Focus groups with consumers will provide critical insights that will inform strategic communication for the second edition of the Physical Activity Guidelines. ODPHP will use these findings to develop graphics and targeted messages that promote physical activity and motivate consumers to achieve the recommendations in the Physical Activity Guidelines.

3. Use of Improved Information Technology and Burden Reduction

Focus groups will be conducted in person. To reduce participant burden, ODPHP will make every effort to plan focus groups at times and in locations convenient for participants (for example, accessible by public transportation).

Participants for all focus groups will be drawn from convenience samples. For all focus groups, ODPHP will use a laptop to take notes to save transcription time. To ensure that key themes and quotations are captured accurately, ODPHP will also audiotape all focus groups.

4. Efforts to Identify Duplication and Use of Similar Information

To our knowledge, there is no information of a similar nature that has been or is currently being collected. The graphics and messages to be tested have just been developed and this is the first opportunity to gather consumer feedback and reactions.

5. Impact on Small Businesses or Other Small Entities

No small businesses will be impacted or involved in this data collection.

6. Consequences of Collecting the Information Less Frequently

This request is for one-time data collection. These data have not previously been collected elsewhere.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances with this information collection package. This request fully complies with the regulation 5 CFR 1320.5 and will be voluntary.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

This data collection is being conducted using the Generic Information Collection mechanism through ODPHP — OMB No. 0990-0281.

9. Explanation of Any Payment or Gift to Respondents

Incentives

Participants will be offered a cash incentive of $75 for a 90-minute focus group as a token of appreciation for their participation.

Justification for Incentives

The proposed incentive amount ($75) has been shown to be the minimum required incentive to offset the challenges for this audience to participate in a focus group. These challenges may include lost wages, transportation, and childcare, among others. Incentives ensure timely recruitment and decrease no-show rates.

The recruitment company will use incentives in order to recruit a diverse set of participants (ODPHP will retain copies of the incentive receipt forms on a secure server). The proposed amount is consistent with standard practice for qualitative data collection efforts and experience with this population on previous projects.

ODPHP has consulted with several recruitment firms in locations where focus groups will be held. These firms noted the minimum amounts necessary, based on their experience, to successfully recruit consumer research participants — see below.

In Baltimore, MD, recruitment firms Observation Baltimore and L&E Research suggested:

• $75–100

In Las Vegas, NV, recruitment firm Consumer Opinion Services suggested:

• $75–80

In February 2017, ODPHP partnered with recruitment firm Market-Ease and used a $75 incentive to successfully recruit consumer research participants for 90-minute Physical Activity Guidelines-related focus groups in Chicago, IL.

In the recent past, incentives lower than the proposed amount ($75) have made it difficult to recruit consumers and have had significant consequences. Examples include:

• OMB Control Number: 0923-0047. In Spring 2016, consumer focus groups for the CDC were compromised because of an incentive that was too low ($75). Before beginning recruitment, the recruitment firm noted that this amount would be too low to successfully recruit consumers for a 90-minute focus group. In order to ensure the recruit was successful, the focus groups were shortened to 60 minutes, which cost the researchers a total 90 minutes of data collection time. Ultimately, 5 recruits (out of a goal of 27 total participants) were “no-shows,” which further compromised researchers’ ability to collect valuable data.

• OMB Control Number: 0920-0572. In Spring 2015, a recruit for another HHS agency was unable to be completed using a lower incentive ($40). The recruitment firm contacted over 1,600 individuals for a 24-person focus group study. The recruitment firm could not complete the recruit at a $40 incentive and the study had to be canceled.

If ODPHP is unable to successfully recruit consumer focus group participants in a timely manner, the consequences will be significant:

• ODPHP will be unable to communicate effectively about the Physical Activity Guidelines — critical guidance with the potential to impact physical activity nationwide and, ultimately, related chronic diseases such as obesity, heart disease, and diabetes

• ODPHP will waste funds either preparing for research that it cannot complete or contacting far more prospective participants than anticipated

• Consumers will receive communication about physical activity recommendations that may not reflect their behaviors, attitudes, or preferences, thereby imposing an undue burden and/or limiting their opportunities to see, understand, or act on this important information

10. Assurance of Confidentiality Provided to Respondents

The Privacy Act does not apply to this data collection. ODPHP will not collect any personally identifiable information from focus group participants. The focus group moderator’s guides and the participant information sheet — included in the consumer focus group protocols [see Attachment B (English) and Attachment E (Spanish)] — include confidentiality information for participants. Participants will also be instructed that they can stop their participation at any time.

11. Justification for Sensitive Questions

ODPHP does not anticipate that research participants will perceive questions as sensitive in nature. ODPHP will focus on collecting information that can inform physical activity-related information and tools that help consumers. However, this information is key to understanding how to communicate with consumers about physical activity recommendations. Prior to the discussion, the moderator will inform participants that they may decline to respond if they are uncomfortable answering any question.

12. Estimates of Annualized Burden Hours and Costs

The estimate for burden hours is based on:

• Emails sent to and phone calls conducted with 216 prospective consumer participants, to recruit 72 consumer focus group participants. We estimate that each prospective consumer participant will spend a total of 10 minutes reading and responding to the recruitment email and answering screening questions over the phone. See the phone screener in Attachment A (English) and Attachment D (Spanish), and the recruitment email in Attachment B (English) and Attachment E (Spanish).

• Nine 90-minute focus group discussions with a total of 72 consumer participants (up to 8 participants in each group). See protocol in Attachment B (English) and Attachment E (Spanish).

Estimates for hourly burden are calculated using the mean hourly wage for all occupations ($23.23), because ODPHP aims to recruit diverse adults for consumer focus groups.⁴ Estimates do not adjust for the fact that some participants will not be employed, assuming that their time is of comparable value.

Table A-12: Estimated Annualized Burden Hours and Costs to Participants

Research Steps	No. of Participants	Average Burden per Response	Total Burden Hours	Hourly Wage Rate	Total Participant Costs
Consumer Recruitment	216	10/60	36	$23.23	$836.28
Consumer Focus Groups	72	1.5	108	$23.23	$2,508.84
Totals	432		168		$3,345.12

13. Estimates of Annualized Burden Hours and Costs

Participants may incur costs related to transportation or childcare, which ODPHP intends to offset with an adequate incentive.

14. Annualized Cost to the Government

Table A-14: Estimated Annualized Cost to the Federal Government

Expense	Number/ Amount	Cost/Hourly Wage Rate	Average Cost
Communication Researchers	180	$123.64	$22,255.20
Spanish Translator/Moderator	51	$96.80	$4,936.80
Support Staff	75	$66.52	$4,989.00
Consumer Recruitment Fee	90	$150.00	$13,500.00
Consumer Participant Incentives	90	$75.00	$6,750.00
Travel (2 Staff)	2	$3,333.00	$6,666.00
Estimated Total Cost of Data Collection			$59,097.00

The estimated annual cost to the Federal government is $59,097.00.

15. Explanation for Program Changes or Adjustments

This is new data collection.

16. Plans for Tabulation and Publication and Project Time Schedule

The qualitative information shared by focus group participants will be collected via typed notes and audio recording. After each focus group is complete, contractor staff will review the written notes within 24 hours, and audiotapes will be transcribed. Contractor staff will analyze the data qualitatively by reviewing the session notes and pulling out the main themes from each set of discussions. These themes will be summarized. No names or other personal information will be reported in the summaries.

Proposed Timeline

Completion Date	Major Tasks/Milestones
May 2017	Develop focus group protocols and screening instruments
June 2017	Translate focus group protocols and screening instruments Submit request for OMB approval under existing generic clearance Plan for recruitment Plan for focus groups
July 2017	Recruit participants Finalize focus group logistics Begin conducting focus groups
August 2017	Finish conducting focus groups
September 2017	Analyze focus group data Draft summary report of findings and recommendations

17. Reason(s) Display of OMB Expiration Data is Inappropriate

We are requesting no exemption.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification. These activities comply with the requirements in 5 CFR 1320.9.

Section A — List of Attachments

[IN SEPARATE FILES]

• Attachment A: Phone Screener for Focus Groups (English) — Research Instrument

• Attachment B: Focus Group Protocol (English) — Research Instrument

• Attachment C: Rating Exercise (English) — Research Instrument

• Attachment D: Phone Screener for Focus Groups (Spanish) — Research Instrument

• Attachment E: Focus Group Protocol (Spanish) — Research Instrument

• Attachment F: Rating Exercise (Spanish) — Research Instrument

• Attachment G: Graphics and Taglines (English) — Stimulus Material

• Attachment H: Messages (English) — Stimulus Material

• Attachment I: Graphics and Taglines (Spanish) — Stimulus Material

• Attachment J: Messages (Spanish) — Stimulus Material

1 Adult Obesity Facts. Centers for Disease Control and Prevention. Retrieved from https://www.cdc.gov/obesity/data/adult.html

2 Childhood Obesity Facts. Centers for Disease Control and Prevention. Retrieved from https://www.cdc.gov/obesity/data/childhood.html

3 Adult Obesity Causes & Consequences. Centers for Disease Control and Prevention. Retrieved from https://www.cdc.gov/obesity/adult/causes.html

4 May 2015 National Occupational Employment and Wage Estimates, United States. Bureau of Labor Statistics. United States Department of Labor. Retrieved at http://www.bls.gov/oes/current/oes_nat.htm.