Generic OMB Memo Aug 21 2018

Memorandum

Date: August 21, 2018

To: Stephanie Tatham, OMB Desk Officer

Through: Ruth Brown, USDA- OCIO Desk Officer

From: Rachelle Ragland-Greene, Information Collection Officer

Food and Nutrition Service, Acting Branch Chief, Planning & Regulatory Affairs

Re: Under Approved Generic OMB Clearance No. 0584-0523 Request for Approval for SNAP-Eligible Qualitative Research

The Food and Nutrition Service (FNS) of the United States Department of Agriculture (USDA) is requesting approval for formative research under Approved Generic OMB Clearance No. 0584-0523.

This request is to acquire clearance to conduct formative research with SNAP-eligible adults (18 to 75 years old) in order to inform the development of SNAP-Educator tools. The purpose of this research is to gather data about the SNAP-eligible audience that will help SNAP-Ed providers better reach the SNAP-eligible audience through free digital platforms, like social media and online. The insights from this research will help identify more effective forms of communications to virtually disseminate nutrition education while increasing cost efficiencies.

The following information is provided for your review:

1. Title of the Project: SNAP-Eligible Qualitative Research

2. Control Number: 0584-0523, Expires 09/30/2019

3. Public Affected by this Project: Individuals/Housesholds: Respondent type: Americans between the ages of 18 and 75 who are eligible for SNAP benefits, specifically:

• SNAP-eligible 18-29 year olds, non-married/do not have children

• SNAP-eligible 18-44 year olds, with children

• SNAP-eligible 45-75 year old empty nesters or adults who do not have children

Participants will include both English- and Spanish-speaking individuals, a mix of gender, ethnicity and race.

See section 7, Project Purpose, Methodology, and Formative Research Design, for a description of the number of participants for each audience by research methodology (focus group interviews). The definitions of the public affected by this project are identified in the screening instruments English and Spanish (see Attachments C-1 and C-2).

4. Number of Respondents:

USDA, along with our contractors, will contact approximately 840 individuals to recruit, oversampling will be conducted to achieve show rates for this data collections and non-respondent burden estimates are included in Section 6:

• 150 participants for 15 focus groups in English. Each group will have six participants, with 10 recruited for each group to assure quorum of six.

• 60 participants for six focus groups in Spanish. Each group will have six participants, with ten recruited for each group to assure quorum of six.

A total of 840 people will be contacted to determine eligibility for the research (see table 4.1). These individuals will be contacted via phone and will be asked a series of questions from a screener (see Attachment C-1 and C-2) to determine eligibility. Those who make it through the entire screener will qualify for the study.

Of the total 840 individuals contacted, an estimated 210 individuals (25%) will make it through the entire screener and will qualify for the study (see table 4.2). Of the total 840 individuals contacted, an estimated 630 individuals (75%) will not make it through the entire screener and will not qualify for the study.

As stated above, 210 individuals will qualify for the study and will express intent to participate. An estimated 126 individuals (60% of individuals who qualify) will show for the research (see table 4.2). An estimated 84 individuals (40% of individuals who qualify) will either not be available during the time of the focus group or not show up to the focus group.

Table 4.1 – Screen for Focus Groups*
Audience	# of Participants
English-language groups	600
Spanish-language groups	240
Total	840
*Includes non-qualified and those choosing not to participate.

Table 4.2 – Research Activities by Audience

Target Audience	Research Activity	# of Participants
English-language groups	Confirmation and follow-up	150
	Group discussion	90
Spanish-language groups	Confirmation and follow-up	60
	Group discussion	36

5. Time Needed Per Response:

Those who make it through the entire screener will qualify for the study. The estimated average time to complete the entire screener is 15 minutes (see table 5.1). Those who terminate during the screener will not qualify for the study. The estimated average time to make it through part of the screening document is 10 minutes for those who chose not to participate further.

Of the total 840 individuals contacted, an estimated 210 individuals (25%) will make it through the entire screener and will qualify for the study (see table 4.2). As stated above, each of these individuals will spend an estimated average of 15 minutes to complete the entire screener. Of the total 840 individuals contacted, an estimated 630 individuals (75%) will not make it through the entire screener and will not qualify for the study. As stated above, each of these individuals will spend an estimated average of 10 minutes to go through part of the screener before opting out.

As stated above, 210 individuals will qualify for the study and will express intent to participate. An estimated 126 individuals (60% of those who qualify) will participate in the research (see table 4.2). Each of these individuals will commit the additional 2.5 hours necessary for the focus group discussions (see table 5.2). An estimated 84 individuals (40% of those who qualify) will either not be available during the time of the focus group or not show up to the focus group and will thus, not commit any more time to the project.

Recruitment criteria and methodology are discussed in the Project Purpose, Methodology, and Formative Research Design section, below. The burden for focus group participation is based on the number of participants seated (126). See Section 6 for a summary of estimated burden hours.

Table 5.1 - Time Needed per Consent*
Target Audience	Time (minutes)	Time (hours)
English-language groups	15	0.25
Spanish-language groups	15	0.25
*The time is an average response per respondent.

Table 5.2 - Time Needed for Research Activities by Audience

Target Audience	Research Activity	Time (minutes)	Time (hours)
English-language groups	Confirmation and follow-up	2.28	0.038
	Group discussion	150	2.5
Spanish-language groups	Confirmation and follow-up	2.28	0.038
	Group discussion	150	2.5

6. Total Burden Hours on Public:

		Respondents					Non-Respondents
Event	Sample Size	# of Respondents	Frequency of data collection	Total Respondents	Time per Response (hours)	Total Estimated Burden (hours)	# of Non-Respondents	Frequency of data collection	Total Non-Respondents	Time per Response (hours)	Total Estimated Burden (hours)	Grand Total Burden Hour Estimate
Screening for Focus Groups
English-language groups	600	150	1	150	0.25	37.50	450	1	450	0.167	75.15	112.65
Spanish-language groups	240	60	1	60	0.25	15.00	180	1	180	0.167	30.06	45.06
Focus Groups
Confirmation and follow-up	210	210	1	210	0.0835	17.53	0	n/a	0	0	0	17.53
Group Discussion (English)	150	90	1	90	2.5	225.00	60	1	60	0.0835	5.01	230.01
Group Discussion (Spanish)	60	36	1	36	2.5	90.00	24	1	24	0.0835	2.00	92.00
Individual/Household Subtotal	840	210		210		385.03	630		630		112.22	497.25

Total burden hours on public: 497.25 hours and 840 total annual responses.

7. Project Purpose, Methodology, and Formative Research Design:

Background

The Agricultural Act of 2014 indicates that promotion of nutritious food choices must be informed by a data-driven needs assessment of the target population and their barriers to accessing nutritious food. As such, the Food and Nutrition Service (FNS) is working to ensure that SNAP-Ed programs implement interventions which include multiple nutrition education approaches which include social marketing and policy, systems and environmental approaches as outlined in the Supplemental Nutrition Assistance Program Education Plan Guidance (SNAP-Ed Guidance see Attachment N). The purpose of this research is to gather data about the SNAP-eligible audience to inform how SNAP-Ed providers can better reach the SNAP-eligible audience on digital platforms. Social marketing is one of the levels of interventions that can be used to deliver community and public health information. The findings from this research will help FNS to provide customer service to SNAP-Ed program providers about how to maximize the effectiveness of their social marketing to better reach SNAP-eligible audiences with community and public health information about nutritious eating.

FNS is exploring how SNAP-Educators can better reach and communicate with SNAP-eligible adults. Given the proliferation of social media and digital usage among SNAP-eligible audiences, FNS seeks to understand how to utilize these channels to more successfully communicate with these important audiences. This research will help inform SNAP-Ed educators with how to more successfully communicate with their audience by using free and effective online platforms.

In recent years, social media has become an increasingly effective and cost-efficient tool for reaching Americans, including those among lower incomes. According to Pew Research Center’s Internet/Broadband Fact Sheet¹, 81% of Americans with household incomes of $30,000 or less use the internet. And, Pew Research’s Social Media Fact Sheet² reports that, 69% of the general American adult population and 63% of low-income Americans use at least one social media site. This adoption of social media, even among low-income audiences, allows the potential for wide dissemination of information on social media platforms.

These data are promising; however, they do not exactly replicate or reflect the social media usage habits of SNAP-eligible adults. SNAP-eligible information regarding how SNAP-eligible audiences tend to use social media/digital channels in the context of nutrition information represents a vital question for USDA. Social media is a cost-effective way for SNAP-Ed practitioners to reach their target audiences where they live, work, and play in an effort to positively affect behavior change. Because of these reasons, USDA has chosen to conduct a research study that addresses these questions.

Purpose

Understanding how to better reach SNAP-eligible audiences on social media and related digital channels is imperative for SNAP-Educators to establish multi-level interventions and community health approaches. With this need in mind, this effort has the following research objectives:

• Identify what and when SNAP-eligible adults use digital channels (i.e. Google keywords, frequently visited websites, Facebook, Twitter, Instagram, YouTube, Pinterest)

• Uncover any usage parameters or boundaries to social media consumptions (e.g. access to internet, data plan limitations, prioritization of information they read and/or share).

• Explore where nutritional information fits into the consumption of online materials.

• Explore trusted sources and willingness to act on or share nutrition information.

• Explore how SNAP-Ed strategies and MyPlate³ consumer nutrition materials, in various formats, could be best seen, used, and potentially shared, given target audiences and their social media habits.

• Explore reactions to existing concepts and message (borrowed from SNAP-Ed and MyPlate materials).

• Determine how SNAP-Educators can position content to better engage SNAP-eligible adults.

• Develop a set of recommendations and practical tips for SNAP-Educators to leverage digital and social media in future outreach and social marketing campaigns.

Focus groups are the ideal data collection method for this project. This approach will allow FNS to directly interact with eligible audiences to determine how to better engage them in state and community based approaches. Such in-person research allows individuals to share their standard habits and practices, upon which we overlay research stimuli. We will test six pieces of stimuli across the focus groups, including print and video examples (see Stimuli in Attachments G-1, G-2, H-1, H-2, I-1, I-2, J-1, and J-2).  Participants will rate each example individually using a written handout [see Attachment K-1 and K-2 Focus Group Handout #1], and then discuss the example as a group.  After all the examples are shown, and all ratings collected, participants will identify one example they are most likely to use.  At the end of the focus group, participants will have a final opportunity to give written feedback and share their ideas for social media see [Attachment L-1 and L-2 Focus Group Handout #2]. That way, we can explore realistic means of digital information dissemination and further develop ways to support SNAP-Ed providers in implementing evidence-based nutrition education approaches. Through these in-person discussions about what social media/digital outlets our audiences use, for what purposes, and when, we can then explore how nutrition information falls into the mix. We can also probe how the target audience deems certain types of materials as conducive for a specific outreach method.

Convening small groups of individuals from a common background allows for these individuals to share information about and discuss shared experiences. This social aspect is imperative when studying the natural dissemination of information. Additionally, focus groups are a more efficient method of data collection than individual interviews among a similar number of respondents.

Methodology/Research Design

The targeted sample population of this research are those who are eligible for Supplemental Nutrition Assistance Program (SNAP) benefits, otherwise referred to as SNAP-eligible. The research divides this sample population into three cohorts at ordinal life stages: (1) SNAP-eligible 18-29 year olds not married/without children (2) SNAP-eligible 18-44 year olds with children living at home (3) SNAP-eligible 45-75 year olds without children living at home.

The universe of this research is the estimated 44.3 million American adults that are SNAP-eligible. SNAP-eligibility is dependent on income, assets, and household size. Generally, households at or below 185% of the poverty line are eligible for SNAP benefits. This constitutes an estimated 30% of the adult population, a total of about 83.1 million American adults.⁴

The research team has chosen six focus group locations to ensure extensive representation of the target population: Baltimore, MD; Chicago, IL; Phoenix, AZ; Farmington, NM; Miami, FL; and outside of Seattle, WA. These locations were chosen to represent geographic, racial/ethnic, language, and cultural diversity of target population. Table 7.1 shows a breakdown of the focus groups in each location.

Table 7.1: Focus Group Locations

Specifications:	English-language					Spanish-language
	Baltimore, MD	Chicago, IL	Phoenix, AZ	Farmington, NM	Outside Seattle, WA	Chicago, IL	Miami, FL
SNAP-Eligible, 18-29-year-old adults, non-married/do not have children	1 group	1 group	1 group	1 group	1 group	1 group	1 group
SNAP-Eligible, 18-44-year-old adults, with children	1 group	1 group	1 group	1 group	1 group	1 group	1 group
SNAP-Eligible, 45-75-year-old empty nesters or adults in that age range who do not have children	1 group	1 group	1 group	1 group	1 group	1 group	1 group

Design/Recruitment Procedures

Respondents will be recruited based on highly restrictive criteria for participation. All the participants will be SNAP-eligible adults. “SNAP-eligible” is defined according to annual household income (HHI) and number of people living in the household. For this effort, the following combinations of income and household size qualify as SNAP-eligible:

• HHI < $25,000, one person living at home

• HHI < $35,000, two people living at home

• HHI < $40,000, three people living at home

• HHI < $45,000, four people living at home

• HHI < $55,000, five people living at home

• HHI < $65,000 six people living at home

• HHI < $75,000, seven people living at home

• HHI < $85,000, eight or more people living at home

In addition to income and number of people in the household, additional screening criteria include marital status, age, and number/age of children living at home. Groups will also be conducted in Spanish and English. In addition to the geographic diversity noted above, the locations selected for the research will also allow for participation among SNAP-eligible individuals who live in rural, suburban, and urban settings, as indicated in Table 7.2.

Table 7.2: Location Selections

Cities/Towns	Region	Locale Description	Focus Group Languages
Chicago, IL	Midwest	Urban, Suburban	English, Spanish
Miami, FL	South	Urban	English, Spanish
Baltimore, MD	North East	Urban	English
Phoenix, AZ	West	Suburban	English
Farmington, NM	West	Rural	English
Outside Seattle, WA	West	Suburban, Rural	English

The research team for this effort was selected largely due to their vast experience in conducting groups among low-income populations, including similar efforts for USDA. Researchers do not anticipate any unusual problems, with the exception of unique challenges associated with recruiting low-income participants and ensuring strong show/participation rates. Specifically, low-income participants, especially those with children, can be disproportionately burdened with additional transportation and child care costs which have prevented them from participating in focus groups or led to high no-show rates. (See “Compensation” section for more information.)

Participants will travel to engage in a two-hour, in-person group discussion at a professional focus group facility or comparable location. Discussion will address topics outlined in the moderator guide (see Attachments F-1 and F-2).

This is a qualitative research effort that will be conducted at one point in time, in part, to reduce participant burden.

Although this research will be conducted in-person, it involves the use of techniques to reduce respondent burden and minimize overall federal cost. First, a multi-method strategy will be used to recruit participants. We will be working with professional recruiting partners in target locations who have proprietary “opt-in” databases of potential research participants. These databases contain general demographic information for each individual. Only individuals whose demographic profiles fall within the project’s general parameters will receive a short recruitment phone call to determine if they meet all project criteria. All individuals must meet the criteria listed in the screening questionnaire and provide consent to participate before any research can take place (see Attachments C-1 and C-2).

Participant Confirmation and Consent

During the screening process, we will obtain verbal consent and verbal commitment to participate in the assigned focus groups, and participants will complete consent forms with contact information prior to any follow up research activities (see Appendices D-1 and D-2).

To ensure participation and avoid no-shows among in-person focus group respondents, a follow-up confirmation letter (see Appendices E-1 and E-2) will be mailed and/or emailed to individuals who have agreed to participate in each phase of research. The letter will notify participants the focus group is voluntary, it will also thank the participant for agreeing to be part of the focus group and reiterate privacy statements (see Appendices A-1 and A-2). It will also remind participants of the date, time, and location of the groups, as well as provide other information about scheduling, directions, etc., as needed. All confirmation letters will include contact information for the contractor.

Incentives or Gifts

Incentives have been considered a standard practice in conducting qualitative research (see, for instance, the CDC General Guidelines for Focus Groups), helping to maximize participation, manage recruitment hours, and reduce no-show rates. The justifications for the incentive amounts proposed for this research are based on the circumstances mentioned in the 2006 memo: Guidance on Agency Survey and Statistical Information Collections. In our opinion these circumstances apply to the qualitative research proposed here. In addition, more recent experimental evidence regarding effective incentives also plays a role in determining the incentive rate for this effort.

The participant burden for focus groups is 120 minutes (two hours), but a typical participant may spend an additional half hour at the facility (e.g., arriving earlier to check in and waiting for incentives after the group) that is not included in travel time. In all, the actual time commitment for the focus group participation is closer to 2.5 hours, as included in the burden hours estimate.

FNS will provide an incentive of $75 for participating in this research. Incentives are more likely to secure the participation of individuals meeting the screening requirements, making recruitment more effective and thus saving government money in recruitment costs. In addition, the study employs highly restrictive criteria for participation. Each group is segmented by income, generational cohort, and if the individual has children at home. Both English-language and Spanish-language groups will consist of low-income participants.

As discussed below, the planned $75 incentive level is consistent with OMB’s considerations and guidance for incentive levels. This incentive can be used to offset any travel or childcare cost incurred as a result of participating in a focus group.

Experimental Evidence

New experimental evidence and recent OMB-approved incentive rates provide helpful guidance for the $75 incentive level. First, Cognitive Labs research as part of government agencies have recently conducted studies with successful participation rates that provided $40 incentive for one-hour, one-on-one interviews, and $75 for focus groups of a 90-120-minute duration, the same duration of this research program.

In addition, the Food and Nutrition Service recently completed a study called Nutrition Assistance in Farmers Markets: Understanding the Shopping Patterns of SNAP Participants⁵ illustrating that higher incentive rates foster higher response and show rates for SNAP participants.

Childcare Costs

Several research participants will be parents of young children who require childcare. The recruiting facilities selected for this effort, in part due to their previous experience efficiently recruiting low-income audiences, do not provide on-site childcare due to liability issues. As a result, we have reviewed childcare costs in each location. To maintain equity throughout the project, the highest rate of the six cities was used for estimated compensation for all cities. The highest cost for care between the six cities was $17.50 per hour for one child and $19.00 per hour for two children. This estimate is based on estimated cost for babysitting services in proposed research locations suggested by Care.com (http://www.care.com/babysitting-rates) presented in Table 1. To calculate the cost of care, we averaged the cost of care for one child and for two children for an average rate of $18.25. In total, we recommend that $54.75 of the incentive amount cover childcare costs. This total is based off a participant spending two hours at the focus group, a half an hour checking in and waiting afterwards for incentives, and a total of a half an hour for travel time.

Given the estimated 3.0 hours necessary to participate in the groups (including check-in, check-out, and transportation time), the total childcare estimate comes to $54.75.

Table 1: Estimated costs for childcare

Location	Hourly Cost: 1 Child	Hourly Cost: 2 Children
Baltimore, MD	$15.50	$17.00
Chicago, IL	$15.00	$16.50
Phoenix, AZ	$14.50	$16.00
Farmington, NM	$13.50	$14.50
Seattle, WA	$17.50	$19.00
Miami, FL	$15.50	$17.00
Average Cost	$15.25	$16.67

Transportation Allowance

We also recommend a transportation allowance of $20. This portion of the incentive will fully cover cost of public transportation fares in proposed locations, and any incidental expenses such as parking (in some location) at public transportation hubs (e.g., Park and Ride).

Equity

Finally, it is important to address equity as well. As noted in the 2006 OMB memo, if incentives are used, these should apply to all participants in research. Therefore, the recommended incentives must be applied to all participant segments, regardless of the incidence and research location. This rule also applies to both SNAP program participants and non-program participants. Specifically, if SNAP participants feel more compelled to participate in this research because of their connection to the program, they should not be unfarily penalized from an incentives perspective and receive less than their eligible, yet non-participating counterparts. As a result, all participants will receive the same incentive rate.

Table 3 illustrates the total estimated incentive amounts stemming from the aforementioned calculations.

Table 3: Incentive Estimate Summary

Incentive Component	Estimate
Childcare Costs	$54.75
Transportation Allowance	$20.00
TOTAL INCENTIVE ESTIMATE	$74.75

For the reasons explained in this memo, we set the incentive rates to $75 for respondents who participate in these focus group sessions.

Data Analysis

Qualitative Data. The focus groups will be video-recorded (with respondent permission), and the information collected will be used to inform the main informational objectives of the study, as noted above. Focus group respondents will be informed that the sessions are recorded. Notes taken while observing the focus group sessions and the transcripts of the recordings will be the primary methods of data collection for qualitative data. Transcripts and notes will be reviewed for recurring themes stated across multiple groups and respondents. This analysis will initially be conducted using the computer software NVIVO. NVIVO employs a combination of machine learning and manual input to help analyze qualitative information. Differences will be assessed across groups, locations, and audiences and will be noted, as appropriate. Since this work is qualitative, findings will be considered descriptive and directional, but not definitive. No attempt will be made to generalize findings as nationally-representative or statistically valid. After focus groups have concluded, key findings will be summarized and FNS will draw strategic implications and recommendations.

Outcomes/Findings

Information and formative input gathered from specific target audiences through the research will help inform final products that are relevant, meaningful, and easy-to-use. Research summary findings may be published either electronically or in print, but such documents will not include information that personally identifies any of the research participants. Contractors will submit a final report to FNS. The report will be based on qualitative approaches to summarizing verbatim data. No statistical summaries or analyses will be conducted.

8. Confidentiality:

FNS and contractors will follow procedures for maintaining safeguards consistent with the Privacy Act during all stages of data collection. A system of record notice (SORN) titled FNS-8 USDA/FNS Studies and Reports in the Federal Register on March 31, 2000, Volume 65, Number 63, and is located on pages 17251-17252 discusses the terms of protections that will be provided to respondents.

Using forms in Attachments A-1 and A-2, all participants will receive a privacy statement along with the consent form. The privacy statement will inform the participants that all opinions they provide will be private and none of their responses will be associated with personally identifiable information (PII). Participants will also be informed that findings will be presented as a summary. If representative quotes are used in the summaries, the authors of the quote will be identified only by gender and age cohort.

As part of the conditions of employment, all trained staff working on the project have signed a non-disclosure agreement (NDA) (Attachment B-1) prohibiting them from discussing any information about the research studies they work on with anyone not involved with the project, especially discussing or releasing personally identifiable information (PII).

In addition, IT security procedures will be implemented to protect data during and after administration of the qualitative research. Specifically:

1. Data will be held using secure servers.

2. Once data are collected, any meta-data associated with data collection will be stripped from the files (e.g. e-mail address and phone number, operating system used by the device to complete the system).

3. Both Contractors and USDA will follow the prescribed security protocols including:

   1. Secure access to physical facilities.

   2. Use of network security software.

   3. Strong password requirements to access networks and password policies requiring frequent changes in passwords.

   4. No administrative privileges for users of work stations.

   5. Disaster recovery plans.

Once data are collected, only the staff working on the project will have access to the data.

Federal Costs: $246,035

9. Research Tools/Instruments:

• Attachment A-1 Privacy Act Statement (English)

• Attachment A-2 Privacy Act Statement (Spanish)

• Attachment B-1 Confidentiality Agreement

• Attachment C-1 Screener (English)

• Attachment C-2 Screener (Spanish)

• Attachment D-1 Consent Form (English)

• Attachment D-2 Consent Form (Spanish)

• Attachment E-1 Focus Group Confirmation Form (English)

• Attachment E-2 Focus Group Confirmation Form (Spanish)

• Attachment F-1 Focus Group Guide (English)

• Attachment F-2 Focus Group Guide (Spanish)

• Attachment G-1 Focus Group Stimuli Email Newsletter (English)

• Attachment G-2 Focus Group Stimuli Email Newsletter (Spanish)

• Attachment H-1 Focus Group Stimuli Social Media (English)

• Attachment H-2 Focus Group Stimuli Social Media (Spanish)

• Attachment I-1 Focus Group Stimuli Apple and Peanut Butter Wrap (English)

• Attachment 1-2 Focus Group Stimuli Apple and Peanut Butter Wrap (Spanish)

• Attachment J-1 Focus Group Stimuli Frozen Fruit Cups (English)

• Attachment J-2 Focus Group Stimuli Frozen Fruit Cups (Spanish)

• Attachment K-1 Focus Group Handout #1 (English)

• Attachment K-2 Focus Group Handout #1 (Spanish)

• Attachment L-1 Focus Group Handout #2 (English)

• Attachment L-2 Focus Group Handout #2 (Spanish)

• Attachment M-1 Burden Hours Table

• Attachment N Social Marketing and PSE Descriptions from SNAP Plan Guidance FY 2018

1 http://www.pewinternet.org/fact-sheet/

2 http://www.pewinternet.org/fact-sheet/social-media/

3 OMB Control Number: 0584-0523 Expiration Date September 2019.

4 https://www.census.gov/

5 OMB Control Number 0584-0564 Expiration Date 10/31/2015.