Attachment 3 60-day comment submission from ALA

December 21, 2015
David Sharlip
Office of Administrative and Management Analysis Services
National Library of Medicine, Building 38A, Room B2N12
8600 Rockville Pike, Bethesda, MD 20894
[email protected]
Re: Proposed Collection; 60-Day Comment Request Consumer Health Information in Public Libraries
User Needs Survey (NLM), October 30, 2015, 80 FR 66914
Dear Mr. Sharlip:
The American Library Association (ALA) thanks you for the opportunity to comment on the proposed
collection for the Consumer Health Information in Public Libraries User Needs Survey.
First, the ALA values the leadership provided and resources and training enabled through the National
Library of Medicine (NLM). From PubMed/MEDLINE to health information outreach and training for
librarians to partnering with ALA on educational exhibitions, our members and the communities we
serve significantly benefit from the work of the NLM and National Network of Libraries of Medicine.
The ALA applauds the efforts of the NLM and its partners to continue to inform and improve its services
to public libraries and to increase its understanding of library workers’ resource and education needs.
Programming and services related to consumer health and wellness make up an important area of
engagement for America’s roughly 16,700 public libraries. The most recent Digital Inclusion Survey
research from the ALA and the University of Maryland Information Policy & Access Center, in fact, finds
that a significant majority (greater than 56%) of public libraries provide programming to help library
users locate and use reputable health information and help identifying health insurance resources (such
as those available through the Affordable Care Act).
We believe this data collection could have practical utility, and we appreciate the opportunity to provide
input on ways to enhance the utility, quality and clarity of the efforts, as well as reduce respondent
burden. Our comments first seek clarity related to the effort’s Supporting Statement, then provide more
detailed feedback on proposed survey questions. These comments reflect significant contributions from
Dr. John Carlo Bertot, professor and co-director of the Information Policy & Access Center at the
University of Maryland; and Kendra Morgan, senior program manager for WebJunction at OCLC. Their
contact information is provided at the end of this letter.
Response to Supporting Statement
Sections A.1 – A.3 (Circumstances Making the Collection of Information Necessary; Purpose and Use of
the Information Collection; Use of Information Technology and Burden Reduction)
The ALA seeks clarification on how the researchers have defined “highest impact libraries.” For example,
does this category refer to libraries with large service populations, libraries in communities with high
rates of uninsured persons, or another determinant of “high impact?” Relatedly, it would be useful to
know which datasets and/or formulas have been used to determine the impact level.

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It is similarly unclear how the researchers arrived at the number of library workers (1,558) in the sample.
Is this number derived from a subset of workers at central libraries, as the survey instrument screen
shot indicates, or from workers across various branches of library systems? Importantly, this issue raises
the larger question of how the researchers have identified the appropriate library workers to respond to
the survey. Specifically, are there targeted named recipients or job titles that are specifically targeted;
and, if so, who (or what) are these? Mailed invitations alone are likely not sufficient for ensuring the
desired response rate of 50 percent. Is there additional outreach planned?
ALA appreciates the effort to minimize the burden of the collection of information on library workers
who are to respond, and believes that the question of how respondents are identified and notified will
have a significant effect on both the estimated burden hours and response rate. In addition, the quality
and number of the survey questions largely determines the accuracy and validity of the findings. On this
matter, we believe that several questions, as stated, could be improved. Please see the below
paragraphs, Response to Survey Questions as well as Sections A.4, A.6, & A.8, for more feedback on the
proposed questions and their potential impact on survey burden.
Lastly, we would like to know how the survey results will be shared with the broader Library and
Information Studies community beyond the investigators’ home institutions (University of WisconsinMadison and the National Library of Medicine). ALA strongly recommends that any datasets and/or
reports produced from this survey should be made publicly available within 30 days of research
completion.
Sections A.4, A.6, & A.8 (Efforts to Identify Duplication and Use of Similar Information; Consequences of
Collecting the Information Less Frequently; Comments in Response to the Federal Register Notice and
Efforts to Consult Outside the Agency)
A.4 and A.6: ALA is unaware of any similar national study of consumer health information in public
libraries, and believes this research would be a valuable addition to our body of knowledge in this
important area of library service. We note in comments below, however, that some of the questions
asked would duplicate or be similar to existing data available (e.g., urbanicity and number of paid staff
at a given location). Requiring use of the standard library identification number (LIBID) used by the
Institute of Museum and Library Services (IMLS) will allow researchers to cross-walk basic library
information already reported and publicly available. In relation to A.6, ALA requests clarification on how
often these data will be collected over the three-year period.
A.8: ALA disagrees that consultation was not possible. While it is true there is no single representative
organization for every library worker, the ALA is the oldest and largest library association in the world,
and we consult regularly and frequently with the Chief Officers of State Library Agencies, researchers
such as those at the University of Maryland Information Policy & Access Center, with IMLS, and with
other library organizations. Each and all of us have direct experience with national surveys of this kind
that we believe would be valuable to advise this data collection. Additionally, OCLC and IMLS have direct
knowledge of consumer health information in libraries from the Health Happens in Libraries initiative.
We urge engagement with these highly informed and interested agencies.
A.10 Assurance of Confidentiality Provided to Respondents

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ALA highlights the need to clarify that responses to this proposed survey may indeed be confidential, but
perhaps not anonymous. In order to contact the appropriate library staff member to complete the
survey, some level of identification likely would need to take place. This observation is subject to greater
detail forthcoming about the sampling and analysis plans.
A.12 Estimated Annualized Burden Hours
The cost and burden estimates are presented as annualized costs, with a three-year annualized cost
estimate provided for the respondents. It is unclear whether this three-year estimate suggests that the
investigators are proposing a single stand-alone survey, or whether it will serve as a baseline for future
surveys over the three-year period.
Response to Survey Questions
Overall, the survey questions contain a high proportion of open-ended questions that would be useful in
gathering qualitative data, but the amount of writing required may affect both the response rate and
the ability to conduct useful analysis. To minimize the burden on respondents and to enhance the
quality, utility, and clarity of the information to be collected, we recommend that collection be
streamlined through the reduction of potentially unnecessary questions as well as by providing
additional guidance to the respondent on the open-ended questions. Where necessary, corrections for
question accuracy have also been provided (e.g., Q.16).
Q2: What activities has your library been involved with pertaining to the Affordable Care Act?
We recommend reformulating this as a multiple choice question that allows the respondent to select all
that apply, perhaps with an “other” text box. This change would allow the results to be presented
quantitatively. For question suggestions, see the 2014 Digital Inclusion Survey, Appendix C.
Q.4: What training about the Affordable Care Act focused on public libraries did your library staff
participate in?
We believe more response options would provide higher-quality information in this case. We
recommend listing general webinars or training provided by the following as response options: the
Centers for Medicare & Medicaid Services; the state library or other state administrative entities;
specialized training for official consumer assistance roles (e.g., Navigators), certified application
counselors, or in-person assistance. Again, an “other” text box could be used to sweep in options not
anticipated by the researchers, while the additional options would reflect training sources we believe
are commonly used.
Also, this question requires a correction to the representation of “Health Happens in Libraries.” The
response option should be changed to read "WebJunction's Health Happens in Libraries project." Also
important to note is that branding did not exist in the first few months of this project and many
participants who attended the earliest webinars would not necessarily report having participated, as
they may have forgotten (or never originally known) who was responsible for the session. It is important
to note that WebJunction did not frame any of the webinars as "training," but rather were connecting
library staff to resources and information about the insurance rollout portion of the ACA and the
questions that library staff could hear from patrons in their libraries. This effort later expanded to
include examples of what libraries were doing to meet local needs.

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Q.5: Which of the following online resources do you use to answer patrons’ health information questions
[Please check all that apply]?
This question transitions sharply away from previous questions on the ACA to questions about health
information in general. It would likely make more sense to group questions into appropriate sections so
as to clarify what kind of information is being sought. So, for instance the current Q.9 would be moved
up with other ACA questions). Also, the answer option for "Google" could likely be expanded to include
"search engines" in general (i.e. Google, Yahoo, Bing, etc.). Consider also adding a response option that
includes library subscription access to health databases (e.g., EBSCO Consumer Health Complete, Salem
Health, Gale Health & Wellness Resource Center), as was done in the Digital Inclusion Survey. Another
response option might be state or local health departments.
Q.6: Have you had any training in health information resources in your current or in any previous library
positions?
As in Q.4, the use of the term "training" may not be helpful as many library staff might consider an
informational webinar to be a continuing education activity rather than a training session. Consider
including examples such as webinars, courses, workshops, etc. after or in place of the word "training."
Q.7: What kind of health information training have you had?
Another potential response option to include is the CHIS (Consumer Health Information Specialization)
program, available from the Medical Library Association) (http://www.mlanet.org/p/cm/ld/fid=329)
Q.8: Do you refer health-related questions to someone else in your library who has training in health
information resources?
Consider adding, “If yes, please describe who typically receives these referrals?”
Q.9: Did your State Library collaborate with your library’s librarians regarding the Affordable Care Act?
Individual libraries may be unable to answer this question accurately. In cases where state libraries did
collaborate with local libraries, library workers may be unaware of this collaboration or may not have
utilized the resources. As a substitute, consider asking whether the library accessed or utilized resources
from the state library regarding the ACA, such as webinars, face-to-face trainings, LibGuides, or
reference resources. Note, again, that this question returns to the ACA after the preceding questions
dealt with health information more generally. Please see Q.5 comments for suggestions about question
grouping.
Q.11. Did your library collaborate with other local or state partners, such as health agencies and public
health departments, on the Affordable Care Act effort?
Consider clarifying and expanding "collaboration" to include "outreach, education, or enrollment
assistance" regarding enrollment in the health insurance marketplaces established as part of the ACA.
Q.12: Please share any comments you may have about collaborations pertaining to the Affordable Care
Act.

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This type of open-ended question will likely be difficult to analyze, and could use more guidance. This
question could be improved by soliciting information more directly about challenges and barriers to
collaboration, or about what has worked well in the collaboration process. In general, it seems that this
survey would benefit from at least one question asking about past successes as well as challenges.
Q.14: Did your library use any resources from the National Library of Medicine to help answer questions
about the Affordable Care Act?
Consider combining this question with the open-ended question in Q.15. This could be in the form of a
check list question listing all NLM resources, with the option to respond with “never used,” “rarely
used,” or “use regularly.” This change would allow the results to be presented quantitatively (e.g., by
percentage)
Q.16: Did your library implement the “Health Happens in Libraries” Affordable Care Act information
campaign sponsored by the American Library Association (ALA)?
This question contains an inaccurate statement. The “Health Happens in Libraries” campaign was not
sponsored by the ALA, but was in fact an IMLS-supported program by OCLC and ZeroDivide. Also, the
project was not positioned as a "campaign" to libraries or library staff. Libraries were not encouraged to
implement anything, but were provided with examples of what was happening with colleagues around
the country, and asked to consider what role the library can and should play to support community
health needs.
Q.17: What challenges, if any, were presented by the implementation of the “Health Happens in
Libraries” Affordable Care Act information campaign in your library?
Again, this is a misrepresentation of the “Health Happens in Libraries” project and activities. Libraries
were not asked to implement a “campaign.” The question also seems overly narrow to be useful to NLM
or other agencies. As stated in Q.12, a question (or questions) related to challenges and successes would
seem more useful in improving information and services available.
Q.20: The Affordable Care Act enrollment period and Medicare are topics that directly involve the federal
government. Do libraries and librarians have a role to play in helping people who need health
information related to government programs?
Consider adding Medicaid and using “library staff” instead of “librarians.”
Q.21a & Q21b: Why do you think libraries and librarians (do not) have a role to play in helping people
who need health information related to government programs?
These questions may require greater clarification in order to solicit meaningful input. Does it ask about
federal government programs specifically, or state and local government programs, as well? Also,

consider reframing the question to ask, “What roles do you think libraries and librarians should (should
not) play in helping people who need health information related to government programs?” Also,
because it is possible that staff classified as paraprofessional will be responding to the survey, it would be
more inclusive to use "library staff" instead of "librarians."

Q.22: Please use the space below to share anything else related to your library’s experience with the
Affordable Care Act.

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Rather than soliciting an open-ended response, this question could be refined to explore the demand for
health information services in public libraries. For example, “What is your perception of patron demand
for ACA enrollment information or support at your library?" and/or "What is your perception of patron
demand for health information support more generally at your library?" More information is needed
about staff perception of public demand for these services, and this survey could help address the issue.
Q.23: In what state is your library located?
This question could be avoided if libraries were previously identified through the use of IMLS datasets,
available here: https://www.imls.gov/research-evaluation/data-collection/public-libraries-united-statessurvey. See also Q.24.
Q.24: In what type of setting is your library located?
This question could also potentially be avoided through the use of existing IMLS datasets. Another
potential complication with this question is related to the lack of definition for “highest impact
libraries.” For example, if this term includes central libraries as well as branches, it is possible that some
branches in a given library system would be designated as urban/suburban while others may be
designated as rural.
Q.25. How many paid staff, professional and paraprofessional, does your library have?
This information is available in IMLS datasets and is more likely to be accurate than in these survey
responses.
Q.26. Do you have a Master’s degree in Library Science?
It may be useful to expand this question to include other advanced degrees besides the MLS. Many
libraries, for example, hire staff members with advanced degrees in public health, education, social
work, and other areas. Consider including multiple degrees with instructions to “check all that apply.”
Q.27-Q.28 (Demographic Questions)
The usefulness of collecting demographic information from the respondents is unclear. The ethnicity of
the library worker may not be relevant to the services offered by that library.
Q.29: Would you like more information regarding the National Network of Libraries of Medicine (NN/LM)
and/or the National Library of Medicine (NLM)?
The NN/LM has not been mentioned prior to this question, and it is not differentiated from NLM. The
survey introduction might want to include more information about the NN/LM as well as information
about the benefits of NLM services and resources.
Q.31-35 (Contact Information from Survey Instrument Screen Shot)
These questions may also be redundant if existing datasets are used.
Recommendations for Additional Questions
In addition to the suggestions to the existing questions provided above, we encourage you to consider
adding multiple-choice response questions of the following nature:
1. How would you describe the current staffing level of your library (e.g., too many staff, adequate
number of staff, inadequate number of staff, etc.) to meet patron demand related to consumer
health information?

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2. What role(s) do you currently play in your library (e.g., Management/Administration, Reference
Services, Children’s Services, Adult Programming, Young Adult Programming, Children’s
Programming, Circulation)? Check all that apply.
Related Studies and Datasets to Consider
We also encourage you to consider the following studies, which contain recent survey results on health
and wellness programs in public libraries and patron use of public access technology for health
information seeking:
 Digital Inclusion Survey of Public Libraries, 2013 – 2014: http://digitalinclusion.umd.edu/
 The U.S. IMPACT Study, 2013 – 2015, University of Washington Information School:
http://impact.ischool.washington.edu/index.html
As we have indicated in our comments, we believe strongly in the value of public library research,
especially as it relates to key service areas such as health and wellness. Libraries are indeed a “key
resource” for public information about the Affordable Care Act, as the investigators have stated, and we
encourage all efforts to understand the challenges and successes of information provision in public
libraries since its implementation.
Thank you again for this opportunity to comment on this proposed survey. We look forward to your
responses, and we also offer contact information for Dr. John Carlo Bertot and Kendra Morgan, as well:
John Carlo Bertot, Ph.D.
Professor and Co-Director
Information Policy & Access Center
College of Information Studies
University of Maryland
4105 Hornbake Building, South Wing
College Park, MD 20742
Email: [email protected]
Phone: 301.405.3267

Kendra Morgan
OCLC
Senior Program Manager, WebJunction
220 W. Mercer St., Ste 200
Seattle, WA 98119
Email: [email protected]
Phone: 206.336.9211

Sincerely,

Emily Sheketoff, Executive Director
American Library Association
Washington Office
About the American Library Association
The American Library Association is the oldest and largest library association in the world, with more
than 58,000 members in academic, public, school, government, and special libraries. The mission of the
American Library Association is to provide leadership for the development, promotion and improvement
of library and information services and the profession of librarianship in order to enhance learning and
ensure access to information for all.

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