Justification of non-substantive change

Non-Substantive Change Request to CMS 0938-1275

April 29, 2020

This is a non-substantive change request to the CMS Generic Clearance (OMB No. 0938-1275, expiration 05/31/2021) for the Medicare Current Beneficiary Survey (MCBS). The current generic clearance includes approval for 558 burden hours to cover seven types of potential research and testing activities, including a field test. An increase in 2,737 hours is being requested to accommodate standalone supplemental field testing conducted outside of the production environment for the MCBS questionnaires (MCBS production is conducted under clearance 0938-0568, expiration 08/31/2022). This request would bring the total estimated burden for the CMS Generic Clearance to 3,295 hours.

With the emergence of the COVID-19 pandemic in the U.S., CMS is uniquely positioned to quickly collect vital information on how the pandemic is impacting the Medicare population by utilizing the MCBS. MCBS beneficiaries, by definition, are most at risk for underlying conditions that may lead to more severe COVID-19 complications. CMS requests an increase to the number of hours covered by this generic clearance to conduct testing of a MCBS COVID-19 Rapid Response Supplement to be administered by telephone in June 2020. The generic clearance is the most appropriate vehicle by which to test these questions and assess their performance.

The current burden for the generic clearance is 558 hours. The MCBS COVID-19 Rapid Response Supplement will require a total of 2,737 hours which results in an increased burden to the generic clearance. In the current generic clearance, it was assumed that field tests would be conducted as part of production and therefore not incurring additional burden. However, in order to field test the MCBS COVID-19 Rapid Response Supplement in a timely manner, we must program it independently from the MCBS production questionnaire and administer it as a separate supplement. Therefore, we are requesting this non-substantive change to increase the burden by 2,737 hours, bringing the total burden for this clearance to 3,295.

Projects	Number of Participants	Number of Responses/ Participant	Average hours per response	Response Burden
MCBS COVID-19 Rapid Response Supplement	10,949	1	0.25	2,737

To put this test into the field in a timely manner, telephone data collection for the MCBS COVID-19 Rapid Response Supplement field test must begin by early June 2020. To meet this timeline, programming of the questionnaire is scheduled to begin by May 4, 2020. OMB approval of the MCBS COVID-19 Rapid Response Supplement will be submitted under a GEN IC once this non-substantive request to 0938-1275 is approved.