0059 Title VI SS v.2

Evaluation of the Administration for
Community Living’s (ACL) American Indian,
Alaskan Native, and Native Hawaiian
Programs (OAA Title VI) – Revision
Administration for Community
Living/Administration on Aging
Supporting Statement Part A
September 2020

A. 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 previous data collection for this project entailed a series of
interviews and focus groups with Title VI program staff, elders, and caregivers. This data collection
revision is requesting to collect information via a new follow-up tribal program staff interview.
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 populations, 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. 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

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The Need for Evaluation
The Evaluation of the Title VI Programs is authorized under Section 206(a, c) of Title II of the OAA, which
directs ACL 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.”
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. Through program
evaluations, ACL 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
Having completed most of the data collection, the Evaluation of the Title VI Programs has an interest in
adding a data collection activity to do a follow-up interview with evaluation grantees after they have
completed the current evaluation cycle to understand which components of the technical assistance
they have received have been the most useful for them.
Exhibit 1 provides an overview of the new Evaluation of the Title VI Program data collection activity.
Exhibit 1. Data Collection Activities
Activity
Title VI Program Staff
Follow-up Interviews

Purpose, Respondents, Method, and Relevant Study
The Program Staff Follow-up Interviews will assess how the Title VI Programs
have been utilizing and implementing the Technical Assistance they have
received from the contractor around the practice of evaluation. Data will
include how evaluation practice is being implemented and on what
occurring basis, as well as perceptions of met and unmet needs around
evaluation; and barriers to using evaluation. 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 4 with up to 12
evaluation grantees, for a maximum of 24 participants, and will take 60
minutes to complete. See Attachment A (Title VI Program Staff Consent Form
and Interview Guide).

Use of Information Collected
ACL’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.
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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.
The new proposed data collection with further allow ACL to understand how successful the training and
technical assistance provided to Title VI evaluation grantees was for their practice of data collection and
use.
3. Use of Improved Information Technology and Burden Reduction
Where possible, the evaluation has used 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. Staff follow-up interviews will be conducted via telephone to
allow respondents flexibility in location.
4. Efforts to Identify Duplication and Use of Similar Information
Where possible, ACL has sought to avoid duplication of the design and data collection efforts by trying to
identify existing instruments and data sets relevant to the study. However, there is no other way to
collect information on the effectiveness of the training and technical assistance provided to Title VI
grantees regarding data collection and usage.
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 Follow-up Interviews will gather detailed information about how programs are
continuing to strengthen their data and evaluation capacity. Conducting interviews minimizes burden as
interviews will take 60 minutes.
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 May 19, 2020, vol. 85, No.
397; pp. 22948-29949. No public comments to the evaluation materials were received during the 60-day
public comment period. A 30-day Federal Register Notice published in the Federal Register on August
18, 2020, vol. 85, No. 160; pp. 50826-50827.
9. Explanation of Any Payment or Gift to Respondents
Respondents to the tribal program staff follow-up interviews will be grantee staff. Therefore, no
remuneration is planned for those activities.
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10. Assurance of Confidentiality Provided to Participants

There are no assurances of confidentiality, we will be taking notes during the interview, contact
information and answers will be kept secure to the extent permitted by law.
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 (FWA00002349; Expiration, July 12, 2023 – Attachment
C) 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.
In order to facilitate the administration of interviews, the contractor will collect names, addresses and email contact information. This information will not be stored with or linked to responses, as all data will
be reported in aggregate. All hard copy forms with this information 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). Once final data
collection is complete, participant contact information will be deleted from the database and the hard
copy forms will be destroyed.
11. Justification for Sensitive Questions
There are no expectation that any questions of a sensitive nature will be asked.
12. Estimates of Annualized Burden Hours and Costs
Clearance is being requested an additional point of data collection for the Evaluation of the Title VI
Programs for 12 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

Program director

1

Form Name
Program staff follow-up
interview guide

No. of Annual
Respondents

No. of
Responses per
Respondent

Average
Burden (in
hours) per
Response

Annual
Burden
Hours1

12

1

1

12

Rounded to the nearest whole number

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Respondent Type

No. of Annual
Respondents

Form Name

Total

No. of
Responses per
Respondent

Average
Burden (in
hours) per
Response

12

Annual
Burden
Hours1
12

Exhibit 3. Estimated Annualized Cost to Respondents

Respondent
Type

Program
director

Form Name

Program staff
follow-up interview
guide

Total

Average
No. of
Burden
No. of
Responses
(in
Hourly Wage
Annual
per
hours)
Rate
Respondents
Respondent
per
Response
12

1

1

$33.382

12

Annual
Respondent
Cost

$400.56
$400.56

The estimated aggregated costs to respondents over the three-year period is $400.56.
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, data collection and analysis, and reporting. There are no equipment or overhead
costs. The project covers an additional 6 months, the annual cost to the government is $27,672, and the
total cost to the government is $61,278. 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.
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 $27,672.
15. Explanation for Program Changes or Adjustments
There is a program change decrease of -875 annual burden hours with a program change decrease of 495 annual number of responses.
16. Plans for Tabulation and Publication and Project Time Schedule
Plans for Tabulation
2

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

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Data collected through the evaluation will be analyzed to address key evaluation questions. The data
collection will be qualitative so analysis for the interview data 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 previous data collection for this evaluation.
Publication
The contractor has produced one interim report per year and will include the findings from the program
staff follow0up interviews in the final project report. 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.
Project Timeline
Exhibit 4 provides the reporting schedule for the Title VI Programs evaluation.
Exhibit 4. Timeline

Activity
OMB approval
Data collection
 Conduct Tribal Program Staff Follow-up
Interview
Final project report

Timeline
Estimated August 2020
Begins 1 month after OMB approval
 Estimated March 2021
September 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.

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References
Administration on Aging. (2015). A profile of older Americans: 2015. Retrieved from
http://www.aoa.acl.gov/Aging_Statistics/Profile/2015/docs/2015-Profile.pdf
Baum, F., MacDougall, C., & Smith, D. (2006). Participatory action research. Journal Of Epidemiology And
Community Health, 60(10), 854-857.
U.S. Bureau of Labor Statistics. (2015). National Compensation Survey. Office of Compensation and
Working Conditions. Washington, D.C. Retrieved from https://www.bls.gov/ncs/
Centers for Disease Control and Prevention. (2013). The state of aging and health in America 2013.
Atlanta, GA: Centers for Disease Control and Prevention. Retrieved from
http://www.cdc.gov/features/agingandhealth/state_of_aging_and_health_in_america_2013.pdf
Centers for Disease Control and Prevention. (2008). Racial/ethnic disparities in self-rated health status
among adults with and without disabilities—United States, 2004–2006. Morbidity and Mortality Weekly
Report, 57, 1069–1073.
Goins, R. T., Moss, M., Buchwald, D., & Guralnik, J. M. (2007). Disability among older American Indians
and Alaska Natives: An analysis of the 2000 Census public use microdata sample. The Gerontologist, 47,
690–696.

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