OMB Letter

Generic Information Collection Request Addendum on study: Usability testing of the Supplemental Nutrition Assistance Program

Request: The purpose of this letter is to request a few modifications to an existing OMB submission based on impact of COVID social distancing restrictions as well as to add in language about the authority under which the data is collected and protected. As indicated in the original OMB submission titled, “Usability testing of the Supplemental Nutrition Assistance Program” and approved on October 18, 2019, the Census Bureau plans to conduct additional survey work under the Generic Clearance for Internet Nonprobability Panel Pretesting (OMB number 0607-0978). Relevant documents for the original submission are also enclosed in this present request.

Purpose of the Study

The purpose of the original study (to understand user-interface design issues and cognitive issues with the online forms that different states use when people apply for the Supplemental Nutrition Assistance Program SNAP (formerly known as food stamps) remains the same.

In the original study we identified five states that we would focus on. Those were Maryland, Virginia, Massachusetts, Oklahoma and Indiana. The states were chosen by the staff at SNAP and based on diversity of area, online form usage rates, and the ability to accommodate testing in the state area. We were able to complete only one of the five states (Maryland) before COVID social distancing restrictions went into effect. We still have four additional state SNAP online user interfaces to study. Depending on other ongoing projects that impact state selections, staff at SNAP headquarters may make some modifications in which of the states’ SNAP application will be evaluated. It is possible the four remaining states will remain the same, it is also possible there may be some slight modifications to which states are selected.

Still, the key research questions being examined remain the same, and that is to:

1) find usability problems which interfere with a respondent’s ability to answer the online SNAP form accurately, efficiently and with satisfaction while they are using a smartphone or laptop.

2) find cognitive issues with the instructions, questions, and response categories of the online form.

Methodology

• Population of Interest: No change. Participants will be those who are eligible to receive SNAP benefits.

• Timeline: The addendum requests a change in the timeline. Originally, we said that testing would be completed from October 2019 to October 2020. Due to social distancing COVID restrictions, we ask to extend the period of conducting the studies beginning again in January 2022 through June 2023.

• Language: No change. Usability testing will be conducted in English and Spanish where relevant.

• Devices: No change. Usability studies will be conducted on desktop/laptop or mobile devices.

• Sample: No change. Participants will be low-income individuals who are likely to be eligible to receive SNAP benefits but who have not yet filled out the form for benefits.

• Respondent recruitment: Slight change. As in the original study, participants will be recruited using a combination of word-of-mouth, flyers, online and paper advertisements. We have also added one additional question to the recruitment screener question. See enclosure 7.

• Interviews: No substantive change. The interviews will be conducted in-person or remotely using Census Bureau approved screensharing software (currently Microsoft Teams), as conditions permit.

• Location of interviews: Sessions were planned to take place at Census Bureau Headquarters or at local community centers and libraries. These are still possible locations, but we are adding in the ability to also conduct usability sessions remotely with the interviewers located in their home and the interviewees also located in their homes.

• Recordings: No change. Sessions will continue to be audio and screen recorded.

• Informed Consent: There is a slight change in the informed consent. We plan to explain to participants how this study is authorized by two collection authorities: Title 13 and Title 29 Section 3141. The protections offered by the Census Bureau and Title 13 only extend to the data that we collect on our devices, such as the audio and video recordings, the demographic information we collect during the recruiting phase and the background questionnaire and the questions about their internet use and experience. When respondents are answering survey questions on the state SNAP application, those answers are protected by the state privacy policies that govern their collection systems. We will cite those protections as well. For the state of Virginia, information entered into their online system is protected by the privacy policy of the Virginia Department of Social Services (VDSS). The Virginia Department of Social Services (VDSS) creates, collects, uses, maintains, and discloses Personally Identifiable Information (PII) in compliance with 45 CFR §155.260.

We will inform participants that their response is voluntary and that the information they provide is confidential and will be accessed only by employees involved in the research project. We will use a slightly modified consent form that indicates this protection. See enclosure 9. This consent form indicates that the respondent agrees that the interview can be recorded to facilitate analysis of the results. Participants who do not consent to be video or audio-taped will still be allowed to participate.

• Incentive: For remote sessions participants there is no change in the amount. However, the mode of getting the money to the participant is to use USPS priority mail. The current incentive approval amount for in-person sessions is $50.

• Burden: We were previously approved for 100 participants and 183 burden hours. We are not requesting any additional participants or burden hours.

Attachments

1. OMB original request (Previously approved by original OMB clearance – enclosure 1)

2. Protocol (Previously approved by original OMB clearance – enclosure 2)

3. Paper questionnaire, from MD, VA, MA, OK, ID (Previously approved by original OMB clearance – enclosure 3)

4. Demographic questionnaire (Previously approved by original OMB clearance – enclosure 4)

5. Mobile experience questionnaire (Previously approved by original OMB clearance – enclosure 5)

6. Satisfaction questionnaire (Previously approved by original OMB clearance – enclosure 6)

7. Additional screener questions for SNAP eligible recipients (Previously approved by original OMB clearance – enclosure 7)

8. FNS test plan (Previously approved by original OMB clearance – enclosure 8)

9. FNS consent form (With slightly new language for this addendum – enclosure 9)

For further information about this study, please contact Erica Olmsted-Hawala at 301-763-4893 or [email protected].