Title VI Supporting Statement Part A Indian Nutrition 12.12.17

Evaluation of the Administration for Community Living’s (ACL) American Indian, Alaska Natives, and Native Hawaiian Programs (OAA Title VI) – NEW

Administration for Community Living/Administration on Aging

Supporting Statement Parts A and B

June 9, 2017

Project Officer

Kristen Hudgins, PhD, Social Scientist

Office of Performance and Evaluation

Center for Policy and Evaluation

Administration for Community Living

Mary E Switzer Building

330 C Street, SW, Rm 1229A

Washington DC 20201

Telephone: 202-795-7732

Email: [email protected]

Table of Contents

A. Justification 1

1. Circumstances Making the Collection of Information Necessary 1

2. Purpose and Use of the Information Collection 3

3. Use of Improved Information Technology and Burden Reduction 5

4. Efforts to Identify Duplication and Use of Similar Information 5

5. Impact on Small Businesses or Other Small Entities 6

6. Consequences of Collecting the Information Less Frequently 6

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5 6

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency 6

9. Explanation of Any Payment or Gift to Respondents 7

10. Assurance of Confidentiality Provided to Participants 7

11. Justification for Sensitive Questions 8

12. Estimates of Annualized Burden Hours and Costs 8

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers 9

14. Annualized Cost to the Federal Government 9

15. Explanation for Program Changes or Adjustments 10

16. Plans for Tabulation and Publication and Project Time Schedule 10

17. Reason(s) Display of OMB Expiration Date is Inappropriate 11

18. Exceptions to the Certification for Paperwork Reduction Act Submissions 11

B. Statistical Methods 11

19. Respondent Universe and Sampling Methods 11

20. Procedures for the Collection of Information 13

21. Methods to Maximize Response Rates and Deal with Nonresponse 16

22. Tests of Procedures or Methods to be Undertaken 17

23. Individuals Consulted on Statistical Aspects and Individuals Consulted and/or Analyzing Data 17

List of Attachments

1. Authorizing Legislation

2. Title VI Logic Model

3. Title VI Medicine Wheel

4. Title VI Evaluation Questions and Data Sources

5. Title VI Program Staff Interview Guide

6. Title VI Program Staff Focus Group Moderator Guide

7. Title VI Tribal Elder Focus Group Moderator Guide

8. Title VI Tribal Elder Interview Guide

9. Title VI Tribal Caregiver Focus Group Moderator Guide

10. Title VI Tribal Caregiver Survey

11. Title VI Program Staff Interview Consent Form

12. Title VI Program Staff Focus Group Consent Form

13. Title VI Tribal Elders Focus Group Consent Form

14. Title VI Tribal Elders Interview Consent Form

15. Title VI Tribal Caregivers Focus Group Consent Form

16. Title VI Caregiver Survey Consent Form

17. Title VI Evaluation 60-Day Federal Register Notice

18. Title VI ICF IRB Approval Letter

1. Justification

The Administration for Community Living (ACL) is requesting approval for data collection associated with the Evaluation of the Administration for Community Living’s (ACL) American Indian, Alaska Natives, and Native Hawaiian Programs (Older Americans Act [OAA] Title VI; short title: Evaluation of the Title VI Programs). OAA Title VI establishes grants to Native Americans for nutrition services, supportive services, and family caregiver support services. The purpose of Title VI is “to promote the delivery of supportive services, including nutrition services, to American Indians, Alaskan Natives, and Native Hawaiians that are comparable to services provided under Title III” (42 U.S.C. 3057), which provides nutrition, caregiver and supportive services to the broader U.S. population. Title VI is comprised of three parts; Part A provides nutrition and supportive services to American Indians and Alaska Natives, Part B provides nutrition and supportive services to Native Hawaiians, and Part C provides caregiver services to any programs that have Part A/B.

The evaluation will consist of six data collection activities: (1) tribal program staff interviews; (2) tribal program staff focus groups, (3) tribal elder focus groups, (4) tribal elder interviews, (5) tribal caregiver focus groups, and (6) tribal caregiver survey.

To facilitate stakeholder engagement, the ACL Title VI Advisory Group, which began meeting in November of 2014 to support the Evaluability Assessment (EA) of the Administration on Aging’s Title VI Tribal Grant Programs, will be reconvened as the ACL Title VI Program Steering Committee (Steering Committee). Additional representatives identified by ACL will be recruited to join the current 20-member Steering Committee. Steering Committee members, who will represent Federal, State and local partners, including Title VI grantees, will provide guidance to the Evaluation of the ACL Title VI Programs. They will review the evaluation design, data collection tools, and protocol testing and refinement, as well as review analytic plans (Title VI evaluation grantee plans), dissemination activities, and evaluation training and technical assistance plans and implementation.

1. Circumstances Making the Collection of Information Necessary

American Indian, Alaska Native, and Native Hawaiian (AI/AN/NH) populations experience significant health and socioeconomic disparities compared to the rest of the U.S. population. The AI/AN population has the highest rate of disabilities and the lowest life expectancy compared to the averages for the overall population (Centers for Disease Control and Prevention [CDC], 2008; Goins, Moss, Buchwald, & Guralnik, 2007). While 18% of the non-Hispanic white population is 65 years or older, just 8% of Native Hawaiians and 10% of the AI/AN population is 65 years or older (AoA, 2015). However, as overall life expectancy increases, the proportion of older AI/AN adults is expected to increase. By 2050, the percentage of non-Hispanic white adults is expected to decrease by 20%, while the population of older minority population adults, including AI/AN/NH, is expected to increase by 110% (AoA, 2015; CDC, 2013). For AI/AN, this translates to a 93% increase in the number of older adults. In addition, the population aged 75 and older needing long-term care is expected to double by the year 2030 (AoA, 2015; CDC 2013; Goins et al., 2007).

In fiscal year 2017, ACL awarded 270 Title VI three-year grants to tribes/tribal organizations and one organization serving Native Hawaiian elders for the provision of nutrition and supportive services, as well as 236 three-year grants for the Native American Caregiver Support Program. This information collection will be with the 2017 grantees. ACL expects to conduct the evaluation with 30 Title VI grantees representing programs that are Part A, B, and C fund recipients. The Evaluation of the Title VI Programs will examine the effects of the program on:

1. Older Indians, their families and caregivers

2. Tribal communities

3. Intergenerational connections in tribal communities

4. Management of the Title VI program

The Need for Evaluation

The Evaluation of the Title VI Programs is authorized under Section 206(a, c) of Title II of the OAA (see Attachment A), which directs ACL/AoA to “…measure and evaluate the impact of all programs authorized by this Act, their effectiveness in achieving stated goals in general, and in relation to their cost, their impact on related programs, their effectiveness in targeting for services under this Act unserved older individuals with greatest economic need (including low-income minority individuals and older individuals residing in rural areas) and unserved older individuals with greatest social need (including low-income minority individuals and older individuals residing in rural areas), and their structure and mechanisms for delivery of services, including, where appropriate, comparisons with appropriate control groups composed of persons who have not participated in such programs.”

ACL previously funded a contract to conduct EAs of the Title VI Program that resulted in the Title VI Programs logic model (see Attachment B) and medicine wheel (see Attachment C) on which the Evaluation of the Title VI Programs is based. Up to 30 Title VI grantees will participate in the Evaluation of the ACL Title VI Programs. In May 2017, the contractor hired to support the Title VI Evaluation will release a funding opportunity announcement (FOA) emphasizing the participatory nature of the evaluation to all Title VI program grantees. Interested program grantees will complete a grant application along with a tribal resolution and/or letter of intent signifying their commitment to participate in the evaluation. Title VI Evaluation grantees will receive a small amount of funding from the contractor as part of their grants to offset the cost of their participation in the evaluation. Evaluation activities include traveling to trainings and engaging in data collection. Grantees selected for this project will receive funding based on bands related to the size of the program and whether or not they provide Part A/B programs, or if they also have Part C programs. Title VI Evaluation funds provided to grantees from the contractor will average $15,000 in total ($5,000 per year) per grantee over the course of a three year period, which will be paid out in yearly installments.

Consistent with requirements of the Government Performance Results Modernization Act (GPRMA), ACL’s Administration on Aging (AoA) integrates its strategic priorities and plans with performance measurement criteria. The AoA has three major performance measures: improve program efficiency, improve client outcomes, and improve effective targeting of vulnerable elders. However, simply measuring performance at a macro level does not provide the level of detail required to understand emerging trends, systems issues and program innovation at the community level. Through program evaluations, ACL/AoA seeks a better understanding of key programs, such as the programs under Title VI of the OAA for AI/AN/NH.

2. Purpose and Use of the Information Collection

The Evaluation of the Title VI Programs will document the value of the Title VI Programs for individuals, families, communities, and tribes/tribal organizations and determine the extent to which the program is achieving its objectives. Additionally, the data gathered from this evaluation will support a deeper understanding the GPRA performance measures for the Title VI program. Specifically, the evaluation will explore the inputs, outputs, and outcomes from the logic model and medicine wheel to address three key questions. (See Attachment D for a full list of evaluation questions and data sources.)

1. What is the context of the Title VI Programs at the national and tribal levels? How are the Title VI Programs implemented at the national and tribal levels?

2. What are the outcomes and impact of Title VI Programs, nationally and by tribe or tribal groups?

3. What are the Title VI Programs outcomes for programs that rely solely or primarily on Title VI funds, compared to cost-shared programs that receive a significant proportion of their resources from other programs/agencies?

The guiding logic model and medicine wheel domains ensure evaluation questions accurately reflect planned and achieved Title VI Program outcomes and are culturally-grounded in the four quadrants of indigenous practice. The evaluation is guided by a participatory action research (PAR) framework centered on empowerment and community participation. The PAR framework supports community partnership in research, brings focus to critical problems, helps identify relevant research questions, and provides perspectives on culturally-based mechanisms of development and dissemination informed by community values and systems.

The evaluation design involves two interconnected studies—implementation and outcomes. The implementation study is designed to understand the extent of implementation of the Title VI Programs at the national and tribal levels, contextual factors that affect implementation, and the barriers and facilitators to program implementation.

The outcomes study is designed to assess the impact of program implementation, assessing the proximal and distal program outcomes outlined in the logic model. Primary and secondary data collection and analysis approaches are designed to describe and demonstrate the implementation of Title VI Programs and outcomes across nutrition services, supportive services, and caregiver support services.

Exhibit 1 provides an overview of the Evaluation of the Title VI Program data collection activities, relevant studies, and respondents.

Exhibit 1. Data Collection Activities

Activity	Purpose, Respondents, Method, and Relevant Study
Tribal Program Staff Interviews	The Program Staff Interviews will assess the nature, context, implementation, and management of Title VI Programs; document challenges and barriers to program implementation; and gather detailed information about the funding of activities (e.g., sole, blended, and how funds are leveraged). Data will include Title VI Program structure, resources, and activities; Title VI management structure; perceptions of met and unmet needs across Title VI service areas; barriers to Title VI services provision; and strengths and resources of the Title VI Program. Up to 2 local staff (e.g., program director and evaluation staff person) will participate in each interview. The interviews will be conducted via telephone in Year 1 with up to 30 evaluation grantees, for a maximum of 60 participants, and will take 60 minutes to complete. See Attachments E (Title VI Program Staff Interview Guide) and K (Consent Form).
Title VI Program Staff Focus Groups	The Program Staff Focus Groups will assess the nature, context, implementation, and management of Title VI Programs; document challenges and barriers to program implementation; and gather detailed information about the funding of activities (e.g., sole, blended, and how funds are leveraged). Data will include Title VI Program structure, resources, and activities; Title VI management structure; perceptions of met and unmet needs across Title VI service areas; barriers to Title VI services provision; and strengths and resources of the Title VI Program. The Program Staff Focus Groups will be conducted with up to 2 local Title VI program staff (e.g., program director and evaluation staff person) from each of the up to 30 evaluation grantees, for a maximum of 60 program staff participants. The focus groups will be conducted in-person at the Annual Title VI Conference in Year 3 of the evaluation and take 120 minutes to complete. See Attachment F (Title VI Program Staff Focus Group Moderator Guide) and L (Consent Form).
Title VI Tribal Elder Focus Groups	The Tribal Elder Focus Groups will assess tribal elders’ experiences and satisfaction with service delivery and program experience, as well as Title VI Programs outcomes from elders’ perspectives. Data will include met and unmet spiritual needs; social connectedness and isolation; physical, mental, emotional, and spiritual health and wellness; independence and quality of life; and experiences with and perceptions of services. The focus groups will be conducted in person in Year 2 with approximately 10 tribal elders from each of the 30 grantees and will take 120 minutes to complete. Grantees will recommend the best recruitment methods and location for the focus groups. See Attachment G (Title VI Tribal Elder Focus Group Moderator Guide) and M (Consent Form).
Title VI Tribal Elder Interviews	The Tribal Elder Interviews contain the same items as the Tribal Elder Focus Group Guides. The interviews will be conducted with elders who cannot participate in focus groups because they are homebound, but who receive Title VI services such as home-delivered meals. The interviews will assess tribal elders’ experiences and satisfaction with service delivery and program experience, as well as Title VI Programs outcomes from elders’ perspectives. Data will include met and unmet spiritual needs; social connectedness and isolation; physical, mental, emotional, and spiritual health and wellness; independence and quality of life; and experiences with and perceptions of services. The interviews will be conducted over the telephone in Year 2 with approximately 2 tribal elders from each of the 30 grantees and will take 60 minutes to complete. Grantees will recommend the best recruitment methods for the interviews. See Attachment H (Title VI Tribal Elder Interview Guide) and N (Consent Form).
Title VI Tribal Caregiver Focus Groups	The Tribal Caregiver Focus Groups will assess tribal caregivers’ experiences and satisfaction with service delivery and program experience, as well as Title VI Program outcomes from caregivers’ perspectives. Data will include linkage to needed services, ability to provide care, caregiver well-being (physical, mental, emotional, spiritual, quality of life, independence), community integration and social connectedness, and experiences with and perceptions of services. Evaluation grantees implementing caregiver support services as part of their Title VI Programs will participate. The Tribal Caregiver Focus Groups will be conducted in person using recruitment methods and at a location recommended by the grantees. The Tribal Caregiver Focus Groups will be administered once during Year 2 with approximately 10 tribal caregivers from each grantee providing caregiver services (approximately 26) under the Title VI Programs. The focus group will take 120 minutes to complete. See Attachment I (Title VI Tribal Caregiver Focus Group Moderator Guide) and O (Consent Form).
Title VI Tribal Caregiver Survey	The Caregiver Survey will assess the physical, emotional, mental and spiritual outcomes of the Title VI Programs and whether there are differences in outcomes by grantees characteristics and management models. Data will include linkage to needed services, ability to provide care, caregiver well-being (physical, mental, emotional, spiritual, and quality of life), and community integration and social connectedness. Evaluation grantees implementing caregiver support services as part of their Title VI Programs will administer the survey via paper and pencil. Grantees will recommend the best method for recruiting participants. The Caregiver Survey will be administered once in Year 3 to a total of 295 tribal caregivers from the 26 grantees providing caregiver services and will take 25 minutes to complete. See Attachment J (Title VI Tribal Caregiver Survey) and P (Consent Form).

Use of Information Collected

AoA’s strategic priorities are to empower older people and their families to (1) make informed decisions about, and easily access, health and long-term care options and (2) enable seniors to remain in their own homes through the provision of home and community-based services. Central to these priorities is the pursuit of consistent and effective approaches to support older adults in their own homes and communities, and to coordinate the provision of supportive services to seniors and their caregivers in an integrated system of long-term care.

Information gathered through the Evaluation of the Title VI Programs will inform ACL and its partners, other Federal agencies and administrators, current grantees, policymakers, and the field about ways to improve service delivery for elders and their caregivers and helping them to remain in their homes for as long as possible. For example, information gathered through the evaluation will be used to identify gaps and challenges in service delivery, as well as areas of further need.

This is the first comprehensive evaluation of the Title VI Program. Without this evaluation, Federal and local officials will not be able to determine whether the Title VI Programs are having the intended impact on AI/AN/NH elders and whether the grantees are meeting the individual goals of the programs.

3. Use of Improved Information Technology and Burden Reduction

Where possible, the evaluation uses secondary data sources to answer evaluation questions and minimize burden on respondents. Every effort has been taken to limit burden on individual respondents who participate in data collection activities. All instruments have been reviewed by members of the Title VI Steering Committee to ensure they do not place undue burden on participants. To improve efficiency, all instruments have been tailored to the respondent type and reviewed for cultural appropriateness. Interviews will be conducted via telephone to allow respondents flexibility in location. Given that not all respondents will have access to the internet, online surveys and focus groups are not possible. However, ACL and the contractor responsible for conducting the evaluation will collaborate with evaluation grantee staff to determine the best strategies for recruiting local respondents, methods for administering instruments, and/or locations of administration.

4. Efforts to Identify Duplication and Use of Similar Information

To date, there has been no formal evaluation of the Title VI Programs for Native Americans. ACL previously conducted EAs of the Title VI Program that examined the program characteristics of grantees’ nutritional, supportive, and caregiver support services to assess the feasibility of, and best approaches for, further evaluation of the program. Results of the EAs were used to develop the Title VI Programs logic model and medicine wheel that define the categories of program inputs, outputs, and outcomes included in the Evaluation of the Title VI Programs.

Where possible, ACL sought to avoid duplication of the design and data collection efforts by trying to identify existing instruments and data sets relevant to the study. As a result, several items on the tribal caregiver focus group moderator guide and caregiver survey were pulled for use from existing caregiver surveys, reviewed by cultural experts, and tailored to the target population and Title VI Programs. Further, ACL has identified the following sources of secondary data that, combined with the primary data collected through the evaluation, will help to reduce burden and answer the evaluation questions: (1) Identifying Our Needs: A Survey of Elders, (2) National Association of Area Agencies on Aging Title VI Survey, (3) Title VI grant applications, and (4) Title VI Program Performance Reports.

5. Impact on Small Businesses or Other Small Entities

No small businesses will be involved in this effort.

6. Consequences of Collecting the Information Less Frequently

The Tribal Program Staff Interviews and Tribal Program Staff Focus Groups will use the same basic questions to assess the nature, context, implementation, and management of Title VI programs; document challenges and barriers to program implementation; and gather detailed information about the funding of activities. Conducting interviews rather than focus groups in Year 1 reduces the time burden on participants; interviews will take 60 minutes whereas focus groups will take 120 minutes. In turn, conducting focus groups in Year 3 offers participants an opportunity to collaborate/learn from other programs. Collecting these data less frequently would not allow for this collaboration or for an assessment of change over time from Year 1 to Year 3. All other activities involve a one-time information collection.

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

This data collection request is fully consistent with the guidelines in 5 CFR 1320.8(d). There are no special circumstances required for the collection of information in this data collection.

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

A 60-day Federal Register Notice was published in the Federal Register on February 23, 2017, vol. 82, No. 35; pp. 11472-11473 (see Attachment Q). No public comments to the evaluation materials were received; however, in an effort to maintain consistency between evaluation instruments, ACL has decided to change some of the wording and response options to Question 37 in the Tribal caregiver survey. This is in keeping with ACL’s National Family Caregiver Support Program Evaluation Caregiver Survey as well as the National Evaluation of the Title III-C Services Client Outcomes Survey CAPI Questionnaire and does not substantively change the information being collected.

During the EA of the Title VI Programs, a 20-member stakeholder advisory group, consisting of representatives from the National Indian Council on Aging, the National Resources Center on Native American Aging, and Title VI program grantees, provided input and guidance on the Evaluation of the Title VI Programs logic model, medicine wheel of proximal and distal outcomes within the traditional quadrants of indigenous practice (spiritual, mental, emotional, and physical), and evaluation questions. This advisory group has since been reconvened as an evaluation steering committee that provided guidance on data collection instruments, protocol testing, and refinement.

9. Explanation of Any Payment or Gift to Respondents

The Evaluation of the Title VI Programs is grounded in the PAR framework, which is based on “reflection, data collection, and action to improve health and reduce health inequities through involving the people who, in turn, take actions to improve their own health participatory action” (Baum, MacDougall, & Smith, 2006). This approach requires the participation of individuals beyond grantee program staff, specifically elders and caregivers who are receiving Title VI services. Consequently, remuneration is suggested for these respondents, who will participate in the Tribal Elder Focus Groups, Tribal Elder Interviews, Tribal Caregiver Focus Groups, and Tribal Caregiver Survey. For many tribal communities it is customary to thank elders and participants with a nominal non-monetary gift of appreciation for their time. Based on this, as well as feedback from the Steering Committee and cultural competence experts, the contractor will work with individual grantees to determine an appropriate gift of appreciation (e.g., complimentary congregate meal, gift of food or coffee, etc.) for tribal elder focus group participants and tribal caregiver focus group and survey participants in deference to local customs and traditions.

Respondents to the tribal program staff interviews and focus groups will be grantee staff. Therefore, no remuneration is planned for those activities.

10. Assurance of Confidentiality Provided to Participants

To ensure the privacy of data compiled for the protection of human subjects, the data collection protocol and instruments for the Evaluation of the Title VI Program will be reviewed through the contractor’s institutional review board (IRB) prior to the collection of covered or protected data. The contractor’s IRB holds a Federal wide Assurance (FWA00000845; Expiration, April 13, 2019) from the HHS Office for Human Research Protections (OHRP). This review ensures compliance with the spirit and letter of HHS regulations governing such projects. All protected data will be stored on the contractor’s secure servers in the manner described in the IT Plan and IT Data Security Plan that was submitted to ACL on April 6, 2017.

Personally identifying information (PII) (e.g., name, address, e-mail address) will be collected to facilitate the administration of interviews, focus groups, and surveys, but PII will not be stored with or linked to responses as all data will be reported in the aggregate. All hard copy forms with PII will be stored in locked cabinets; contact information will be entered into a password-protected database accessible to a limited number of individuals who require access (e.g., selected contractor staff, such as data analysts). These individuals have signed privacy, data access, and data use agreements. Once final data collection is complete and incentives have been distributed (as appropriate), participant contact information will be deleted from the database and the hard copy forms will be destroyed.

11. Justification for Sensitive Questions

The caregiver survey asks respondents to self-identify their health status using questions from the AoA Performance Outcome Measurement Project. These questions are necessary to conduct subgroup analyses and to understand the characteristics of tribal caregivers. No other questions of a sensitive nature will be asked. The subject matter will be limited to perceptions of the ACL Title VI Programs’ services and activities. ACL’s information contractor obtained IRB approval for conduct of this assessment (see Attachment R).

12. Estimates of Annualized Burden Hours and Costs

Clearance is being requested for three years of data collection for the Evaluation of the Title VI Programs for 30 grantees. Exhibit 2 describes the estimated hourly burden associated with data collection activities while Exhibit 3 describes the estimated annualized costs associated with data collection activities. The cost was calculated based on the hourly wage rates for appropriate wage rate categories using data collected as part of the National Compensation Survey (BLS, 2015) and from the U.S. Department of Labor Federal Minimum Wage Standards.

The data collection timeframes are long, this is due to the cultural importance of establishing relationships in the communities where we will be gathering information and thus necessitates a different pace for data collection (LaVeaux and Christopher, 2009).

Exhibit 2. Annualized Burden Hours

Respondent Type	Form Name	No. of Annual Respondents	No. of Responses per Respondent	Average Burden (in hours) per Response	Annual Burden Hours1
Program director	Program staff interview guide	10	1	1	10
Program director	Program staff focus group moderator guide	10	1	2	20
Other Program Staff	Tribal program staff interview guide	10	1	1	10
Other Program Staff	Tribal program staff focus group moderator guide	10	1	2	20
Tribal elder	Tribal elder focus group moderator guide	100	1	2	200
Tribal elder	Tribal elder interview guide	20	1	1	20
Caregiver	Tribal caregiver focus group moderator guide	87	1	2	174
Caregiver	Tribal caregiver survey	98	1	0.42	41
Total		345			495

Exhibit 3. Estimated Annualized Cost to Respondents

Respondent Type	Form Name	No. of Annual Respondents	No. of Responses per Respondent	Average Burden (in hours) per Response	Hourly Wage Rate	Annual Respondent Cost
Program director	Tribal program staff interview guide	10	1	1	$33.382	$334
Program director	Tribal program staff focus moderator group guide	10	1	2	$33.382	$668
Other Program Staff	Tribal program staff interview guide	10	1	1	$22.003	$220
Other Program Staff	Tribal program staff focus group moderator guide	10	1	2	$22.003	$440
Tribal elder	Tribal elder focus group moderator guide	100	1	2	$7.254	$1,450
Tribal elder	Tribal elder interview guide	20	1	1	$7.254	$145
Caregiver	Tribal caregiver focus group moderator guide	87	1	2	$10.485	$1,824
Caregiver	Tribal caregiver survey	98	1	0.42	$10.485	$431
Total		345				$5,512

The estimated aggregated costs to respondents over the three-year period is $16, 536.

13. Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers

There will be no direct costs to the respondents other than their time to participate in each information collection.

14. Annualized Cost to the Federal Government

Governmental costs for this project include personnel costs for federal staff involved in the plan and data collection design, funding to 30 Title VI grantees who apply for grants to participate in the evaluation, development of data collection instruments and OMB materials, data collection and analysis, and reporting. There are no equipment or overhead costs. The project covers four years, the annual cost to the government is $223,639, and the total cost to the government is $894,557. The cost breakdown is described below.

This information collection includes approximately 30 percent level of effort of a GS-14 behavioral scientist’s time assuming a $112,021 annual salary. The estimated annualized cost to the Federal Government for oversight by this individual is $33,606.

Up to 30 grantees will be selected to participate in the evaluation. The contractor intends to award an average of $15,000 to each of the selected grantees to participate in the evaluation, for a total cost of $450,000. The $15,000 per grantee will be used to offset the cost of Title VI Program grantees to travel to meetings required in the evaluation, as well as to support the work of Title VI Programs to recruit participants and collect data. Additionally, the contractor is being compensated for the development of the instruments, as well as to collect and analyze participant data. The contract amount for the data collection is $310,133.

15. Explanation for Program Changes or Adjustments

This is a new data collection.

16. Plans for Tabulation and Publication and Project Time Schedule

Plans for Tabulation

Data collected through the evaluation will be analyzed to address key evaluation questions. The contractor will clean data, impute, and create variables as needed; prepare all data documentation, including quantitative codebooks; generate frequencies, means, and other descriptive analyses; and conduct the appropriate inferential statistics. The contractor will also perform statistical tests (t-test, chi-square, and regression) to assess the relationship between tribal characteristics and Title VI process measures (from the implementation study) to outcomes of the Title VI Programs. More specific information on the statistical methods to be used for this project are included in Part B of this document.

Analysis of interview and focus group data for the implementation and outcomes studies will involve the development of qualitative codebooks and include inductively-oriented and exploratory-analytic techniques aimed at identifying relevant stories emerging from the data. The analyses also will involve systematically integrating the quantitative findings with themes that emerge from focus group analysis with elders, caregivers, and program staff.

Publication

The contractor will produce one interim report per year and one final project report. The focus of the interim reports will be contingent on the project activities during the reporting year, as well as available data. The final report will include a comprehensive analysis and synthesis of findings related to all evaluation questions, describe the methods used to obtain data, data completeness and any data deficiencies, lessons learned, and relevant recommendations. Findings also will be presented in up to four briefings with stakeholders to facilitate discussion on evaluation outcomes. There also are plans to submit one manuscript of the evaluation findings to a peer-reviewed journal, such as the Journal of Aging and Health, American Journal of Evaluation, and American Journal of Public Health.

Project Timeline

Exhibit 4 provides the reporting schedule for the Title VI Programs evaluation.

Exhibit 4. Timeline

Activity	Timeline
OMB approval	Estimated October 2017
Issue Evaluation FOA	May 2017
Finalize selection of evaluation grantees	July 2017
Data collection	Begins 1 month after OMB approval
Conduct Tribal Program Staff Interviews	Estimated November 2017 to July 2018
Conduct Tribal Elder Focus Groups, Tribal Elder Interviews, and Tribal Caregiver Focus Groups	Estimated November 2017 to May 2019
Conduct Tribal Program Staff Focus Groups	Estimated August 2019 to April 2020
Administer Tribal Caregiver Survey	Estimated June 2019 to April 2020
Interim reports	August 2017, 2018, and 2019
Stakeholder briefings	Estimated September 2020-December 2020
Final project report	March 2021

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

All data collection instruments will display the expiration date of OMB approval.

18. Exceptions to the Certification for Paperwork Reduction Act Submissions

This collection of information involves no exceptions to the Certification for Paperwork Reduction Act Submissions.

1 Rounded to the nearest whole number

2 Mean hourly wage for social and community service managers; https://www.bls.gov/oes/2015/may/oes_nat.htm#31-0000

3 Mean hourly wage for social science research assistants; https://www.bls.gov/oes/2015/may/oes_nat.htm#31-0000

4 Federal minimum wage as of January 2017

5 Mean hourly wage for personal care aides; https://www.bls.gov/oes/2015/may/oes_nat.htm#39-0000