Appendix A: Responses to Federal Register Notice Comments

Appendix A1: Responses to Federal Register Notice Comments

Organization	Comment	Response
Rebecca Schueller Training & Consulting, LLC	I would like to encourage you to include human services programs located in both metro-adjacent and non-metro adjacent counties in this study.  Rural programs in non-metro adjacent counties face significant challenges not always captured by the experience of those programs located in metro-adjacent areas.  Transportation is just one example of the many challenges.  I would also like to see a recommendation that funding take this into account.  It is costly to support services over a wide geographical area, and yet most federal programs do not support full costs for organization, including flexible funding that allows for multiple types of transportation needed, including gas vouchers, bus tokens, cab and uber vouchers, paying for agency vehicles and paying for staff mileage reimbursement.  This flexibility is essential to help vulnerable and low-income rural clients access services in rural areas where there is not a strong transportation infrastructure, and particularly for nightshifts and weekend work.	The study team recognizes the importance of looking at a diverse set of rural communities within this study and has included both metro-adjacent and non-metro adjacent counties in our study using data from the U.S. Department of Agriculture’s Rural-Urban Continuum Codes. The study team is also using American Community Survey (ACS) data on the percentage of households in a county without a vehicle, which will allow the study team to examine the transportation challenges that residents within rural counties are likely to encounter.
Rebecca Schueller Training & Consulting, LLC	It would also help if DHHS would influence Federal Dept. of Transportation to change the way public transportation formula funding is made available to support flexible use.	This recommendation is outside the scope of the project.
Hogg Foundation for Mental Health	In your methodology, we question whether an “N of 1” (In-person site visit planning template) for each of the 12 sites proposed is robust enough to give you a picture of community conditions if you only have one person you are relying on to provide you a comprehensive picture of the community. It seems that you would want to survey/focus group/town hall many participants, including historically excluded community members to provide you the input you seek. So, our opinion is that surveying one person limits the true picture of the community you are wanting to learn more about.	The site visit planning templates are used to organize the various interviews that the study team will conduct during the site visits, which will now be virtual due to the ongoing COVID-19 pandemic. During these site visits, the study team is hoping to interview up to 20 members from each rural community, with a preference for interviewing 1 program director/main point of contact, 5 other program directors from human services programs, 9 staff members from human services organizations in the community, and 6 staff from nonprofit or partner organizations. Unfortunately, focus groups and town hall meetings, will not be possible due to COVID-19 restrictions.
Hogg Foundation for Mental Health	In light of COVID-19, having alternate ways versus just the in-person process to collect data (virtual platforms such as zoom, web-ex, etc.) or conference calls will be important so that community members feel safe during this engagement process.	The study team will be conducting these site visits virtually using WebEx (if the respondents have access to internet capabilities) or by telephone (if respondents do not have access to internet capabilities).
Hogg Foundation for Mental Health	We recommend that you include a hyperlink to the agency making the request. For example, in order to make a comment/opinion on (a) …whether the proposed collection of information is necessary for the proper performance of the agency's functions… one will need to review your mission/vision/purpose. This is not posted on the Federal Registry posting. Including a hyperlink would be most helpful to persons reviewing the posting. EX: whether the proposed collection of information is necessary for the proper performance of the agency's functions…	Thank you for your comment. The Office of Planning, Research, and Evaluation will consider updating its template to incorporate this feedback.
Hogg Foundation for Mental Health	In order to receive the input, you seek, we recommend you include hyperlinks to the actual survey instruments you proport to use. Without access to the instruments, it is impossible to make a valued comment/opinion on the estimated time to validate or refute the time it will take to complete this proposed process.	Per the Notice, you can request the instruments by emailing [email protected] and asking for the instruments to be emailed to you. As these are draft documents, they are not posted publicly at this time. In response to this comment, the ACF PRA Lead sent copies of these documents to the requester on January 15, 2021.
California Department of Social Services	This is a request for copies of the proposed collection of information for the Human Services Programs in Rural Contexts Study.	The ACF PRA Lead sent copies of these documents to the requestor on December 18, 2020.
Human Rights Campaign (HRC)	HRC urges ACF to design study methodologies that gather data on the unique challenges facing LGBTQ people and potential solutions in this study as well as future ones.	Thank you for the comment. While the study team is not talking directly with program participants during the site visits, inequities will be an area of focus in the interviews with program directors, staff members from human services organizations in the community, and staff from nonprofit or partner organizations. The study’s semi-structured interview instruments include questions about specific needs and gaps within communities, as well as unique characteristics about a site, which will provide the study team with an opportunity to explore challenges facing the LGBTQ community and other communities within rural contexts.

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