HPS_Emergency Clearance for Collection_Phase 3.1_SupportingStatementA_clean

HPS_Emergency Clearance for Collection_Phase 3.1_SupportingStatementA_clean.docx

Household Pulse Survey

OMB: 0607-1013

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OMB Information Collection Request

Supporting Statement A

U.S. Department of Commerce

U.S. Census Bureau

Household Pulse Survey

OMB Control Number 0607-1013

A. JUSTIFICATION

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Starting in March 2020, the Covid-19 pandemic has introduced extraordinary social and economic changes for American households. Since its rapid launch in April, 2020, the Household Pulse Survey has collected near real-time data on the experiences of American households as the coronavirus pandemic prompted business and school closures, and widespread stay-at-home orders. These data are released every two weeks, guiding the response and recovery from the pandemic.

One of the features of the Household Pulse Survey is its ability to respond to evolving information needs. Nonetheless, the Census Bureau has consulted closely throughout with the Office of Management and Budget (OMB) to ensure that the survey complies with the Paperwork Reduction Act and that the Census Bureau manage the public burden associated with the collection of data. This Request for a Revision to an Existing Collection is submitted in keeping with the principles of government transparency and the processes for Information Collection Requests (ICRs) approval.

The launch of new content will be considered a new data collection cycle under Phase 3 as approved by OMB (e.g., Phase 3.1, Phase 3.2, etc.). Each data collection cycle will consist of approximately six data collection periods. The Census Bureau will monitor the trajectory of the pandemic and continue its engagement with OMB, other agencies, and stakeholders to determine when additional collection cycles make sense to remain responsive to evolving data needs. It is anticipated that the Household Pulse Survey content will be reviewed quarterly or as the need and relevance of the existing content changes. To facilitate the introduction of new content and a new data collection cycle, the Census Bureau may take a break in data collection. Such breaks will be anticipated and communicated via the Census Bureau’s website. See below for a sample content review schedule. Actual dates would be dependent on the continuation of each data collection cycle of the Household Pulse Survey.

Household Pulse Survey Content Review and Revision Schedule
Data Collection Cycle	Content Review and Revision	Data Collection Start	Data Collection End
Phase 3.1	12/2020 - 3/2021	4/2021	7/2021
Phase 3.2	5/2021 - 6/2021	7/2021	9/2021
Phase 3.3	8/2021 - 9/2021	10/2021	1/2022

If the coronavirus pandemic and/or its effects continue into FY 2022, and it continues to be prudent to administer the Household Pulse Survey, the Census Bureau will submit a request to receive approval to continue the data collection for the Household Pulse Survey beyond one year past the clearance date. The Census Bureau commits to continuous evaluation of the need for the continuation of the survey in response to the coronavirus pandemic in consultation with OMB. Depending on the pandemic and the degree to which the Household Pulse Survey data continue to be useful in response and recovery efforts, the Census Bureau may conclude data collection activities prior to the clearance expiration date.

In circumstances that meet the requirements for Emergency Clearance under 5 CFR 1320.13, Census may request OMB approval to receive public comment concurrent with the collection of new or revised items or methods.

History of Household Pulse ICRs

Initial emergency clearance to conduct the Household Pulse Survey was approved by OMB on April 19, 2020 for a period through July 31, 2020. OMB subsequently approved an extension of the emergency clearance for the balance of the 180 days authorized under 5 CFR Section 1320, Paperwork Reduction Act, specifically 1320.13, Emergency Processing. This extension was granted in light of the continuing pandemic and recognition that the Household Pulse Survey data were widely used and valued by government officials and others managing response and recovery efforts. This extension of emergency clearance expired October 31, 2020.

In the interim, the Census Bureau put forward a regular (non-emergency) Information Collection Request (ICR) for OMB review on September 17, 2020. OMB approved this ICR on October 30, 2020 for three years (OMB No. 0607-1013; expiration October 31, 2023).

For the purposes of referencing prior ICRs, we refer to the ICR approvals to conduct the Household Pulse Survey as follows:

Phase 1 – Emergency clearance granted by OMB for the data collection period April – July, 2020
Phase 2 – Extended emergency clearance granted for the data collection period August – October 2020
Phase 3 – Normal clearance granted starting October 30, 2020 through October 30, 2023. Subsequent revisions to the questionnaire, once cleared by OMB, will be referred to as “Phase 3.1,” Phase 3.2,” etc.

The regular clearance for Phase 3 was initially conditioned upon the Census Bureau taking a temporary hiatus in data collection at the end of December, 2020 to evaluate the continued efficacy of the survey, and to make revisions as needed. However, given information about the trajectory of the pandemic in early December, it seemed imprudent to take the hiatus as planned at the end of that month. Doing so would mean that Household Pulse Survey would not be collecting data in the months of January or February, 2021 when the pandemic is still in an acute stage – and when the data produced by the Household Pulse continued to be useful to the public in understanding how American households would be faring during this period.

The Census Bureau therefore submitted a non-substantive request to OMB on December 22, 2020 to request approval for continuing collection of the current Phase 3 instrument through January and February 2021. Additionally, the Census Bureau proposed adding questions to the Phase 3 instrument immediately regarding individuals’ intention to receive the Covid-19 vaccine, and to release pre-approved questions on the economic stimulus payments given the payments were being issued. Given that time was of the essence for these items, we requested approval to include them effective the data collection cycle starting January 6, 2021. To maintain balance with regard to the estimated burden to the public, we also proposed removing questions from the current survey for which we find utility has declined over time to accommodate the addition of the intent to vaccinate questions.

As the survey continued without hiatus, the Census Bureau submitted a Request for Revision to an Existing Collection for a revised, Phase 3.1 questionnaire. To keep the participant burden low and encourage response, the Bureau has reviewed the Household Pulse Survey instrument to identify questions for which relevancy or utility is declining, and to address requests for new information emanating from previous public comment and consultation with other Federal agencies. Additional questions address the following new topics: disability, child health access, telehealth and childcare. The revised questionnaire can be found in Attachment A.

The Census Bureau published a notice in the Federal Register on February 1, 2021 with 30 days of public comment. OMB granted clearance for Phase 3.1 on March 18, 2021. The Census Bureau will deploy the revised questionnaire on or about April 14, 2021.

This Emergency Revision Request covers the proposed addition of content to the Household Pulse Survey not included in the Request for Revision for Phase 3.1. The content under consideration includes demographic screener questions from the Department of Defense (DOD) to identify Service members and military spouses (Q8a), and from the National Institute for Occupational Safety and Health (NIOSH) of the Centers for Disease Control and Prevention (CDC) to classify respondents employed in “essential” worker groups (Q13c and Q13d). The Household Pulse Survey is designed to collect and disseminate data on a near real-time basis to inform on the social and economic impacts of the Covid‐19 Pandemic. Data from the Household Pulse Survey will allow DOD to enhance services and target resources to help alleviate the impact of the pandemic on Service members and their families. The CDC would benefit from the data to respond to ongoing impacts of the pandemic and target outreach efforts to promote vaccine access and uptake among essential worker groups.

Lastly, an additional condition of the October 30, 2020 clearance was to complete a non-response bias analysis of the Household Pulse Survey data, to increase understanding with regard to the quality of the data as a new, experimental product. This work is underway and initial results will be released on the Census Bureau’s Experimental Data Products site (https://www.census.gov/data/experimental-data-products.html) on April 7, 2021. Ongoing information with regard to the quality of the Household Pulse Survey data is available in the Source & Accuracy Statements associated with each bi-weekly data release (see Attachment B for example).

The proposed revised questionnaire can be reviewed in Attachment A. The statement to respondents related to the Privacy Act and Paper Reduction Act is included in Attachment C. The language we propose to use to contact respondents, including invitations to participate via email and SMS text, is in Attachment D.

The collection is authorized under Title 13 United States Code, Sections 8(b), 182 and 196.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Phase 3.1 of the Household Pulse Survey will continue as an experimental endeavor in cooperation with other federal agencies to produce near real-time data to understand how individuals are experiencing business curtailment and closures, stay-at-home orders, school closures, access to health care, and other dimensions of daily living that may have been changed by the pandemic.

Questionnaire content for Phase 3.1 the Household Pulse Survey has been developed in close consult with the following agencies: the Census Bureau (Census); the U.S. Department of Agriculture’s Economic Research Service (USDA/ERS); the Bureau of Labor Statistics (BLS); the Centers for Disease Control and Prevention (CDC) and the National Center for Health Statistics (NCHS); the Health Resources and Services Administration’s Maternal and Child Health Bureau (HRSA/MCHB); the National Center for Education Statistics (NCES); the Department of Housing and Urban Development (HUD); the Social Security Administration (SSA); the Bureau of Transportation Statistics (BTS); and the Department of Defense (DOD). Domains include employment status, capacity to telework, income loss, consumer spending, application and receipt of benefits, food and housing security, education disruptions (K-12 and post-secondary), intent to be vaccinated, travel practices, dimensions of physical and mental wellness, access to care, disability, child health access, telehealth and childcare.

Data collected in Phases 1, 2 and 3 of the Household Pulse Survey have been in high demand and widely praised as a demonstration of the Federal statistical system’s ability to respond quickly to collect and disseminate high-frequency data products that inform response and recovery efforts in urgent circumstances like the pandemic. Some of the ways in which the data have been put to use include:

Federal, State and Local Agencies

National Center for Health Statistics

https://www.cdc.gov/nchs/covid19/pulse/mental-health.htm

Dept of Housing & Urban Development

https://www.huduser.gov/portal/pdredge/pdr-edge-spotlight-article-092820.html

National Center for Education Statistics

https://nces.ed.gov/blogs/nces/post/new-education-data-from-the-household-pulse-survey

USDA Economic Research Service

https://www.ers.usda.gov/data-products/chart-gallery/gallery/chart-detail/?chartId=98778

North Carolina Triangle J Council of Governments

https://www.tjcog.org/data-resources-2020-census/2020-household-pulse-survey

Academics and NGOs

University of Utah Gardner Policy Institute

https://gardner.utah.edu/covid-19/household-pulse-data-tool/

Annie E. Casey Foundation

https://www.youtube.com/watch?v=bl6OD0JwpQw; data incorporated into AEC's KIDS COUNT Data Center

Brookings Institution

https://www.brookings.edu/blog/education-plus-development/2020/06/22/unequally-disconnected-access-to-online-learning-in-the-us/

Harvard University Joint Center for Housing Studies

https://www.jchs.harvard.edu/blog/using-the-census-bureaus-household-pulse-survey-to-assess-the-economic-impacts-of-covid-19-on-americas-households

Media

https://www.washingtonpost.com/local/social-issues/census-surveys-pandemic-impact/2020/05/27/b7b55854-a027-11ea-9590-1858a893bd59_story.html

https://fivethirtyeight.com/features/yes-unemployment-fell-but-the-recovery-seems-to-be-slowing-down/

https://www.latimes.com/politics/story/2020-05-20/one-fifth-of-americans-couldnt-pay-may-rent-or-mortgage-government-survey-finds

All results from the Household Pulse Survey will continue to be disseminated from the U.S. Census Bureau’s Experimental Data Products Series (https://www.census.gov/data/experimental-data-products.html. This and additional information on the Household Pulse Survey available on to the public on census.gov can be found in Attachment E.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection technique s or forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

The Census Bureau will conduct this information collection online using Qualtrics as the data collection platform. Qualtrics is currently used at the Census Bureau for research and development surveys and provides the necessary agility to deploy the Household Pulse Survey quickly and securely. It operates in the Gov Cloud, is FedRAMP authorized at the moderate level, and has an Authority to Operate from the Census Bureau to collect personally identifiable and Title 13-protected data.

Qualtrics is an online data collection platform that allows survey invitations to be distributed electronically via email and/or SMS. All survey initiations for the Household Pulse Survey will be distributed to sampled participants via email and SMS, and data collection will occur entirely on the web. The data collection platform is optimized for use on a mobile device, so may be used via any type of internet access.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use of the purposes described in Item 2 above.

The Census Bureau and its sponsoring survey partners have initiated efforts to incorporate pandemic response-related questions into the existing benchmark surveys, but those efforts are longer term. Other polls and surveys fielded to track the pandemic and its effect have been well-cataloged by the Societal Experts Action Network (SEAN) at https://covid-19.parc.us.com/client/index.html#/.

The Household Pulse Survey does not duplicate these efforts. First, the sample of the Household Pulse Survey is very large relative to these other efforts, sufficient in size to produce estimates at the state level as well as for 15 Metropolitan Statistical Areas (MSAs). Secondly, the sample frame is the Master Address File (MAF), which is the gold standard frame for U.S. statistics and provides sampled respondents all of the strict confidentiality protections afforded them under Title 13 U.S.C. The statistical infrastructure at the Census Bureau, and within the federal statistical system, enables the use of the MAF coupled with auxiliary and administrative data to allow for extensive procedures to ensure the ability to understand and improve the representativeness of the survey results. Thirdly, the questionnaire has been designed with input from multiple federal agencies, including BLS; USDA/ERS; HUD; CDC and NCHS; HRSA/MCHB; NCES; SSA; BTS; and the Census Bureau. As such, it is a comprehensive, omnibus instrument that efficiently produces data on multiple sectors impacted by the coronavirus pandemic and associated response. Lastly, the data will carry the imprimatur of the federal statistical system and its standards for data stewardship, objectivity and transparency.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The collection of this information does not involve small businesses or other small entities.

We designed the survey questions to obtain the required information with minimal respondent burden. Further, there are no legal issues that influence respondent burden.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Continuing this collection helps track changes since the early days of the pandemic in the U.S. (April 2020) and inform recovery from this unprecedented experience for our country. The Household Pulse Survey is designed to address these particular data needs. As the nation is beginning its vaccination program, the Census Bureau commits to continuous evaluation of the need for the continuation of the survey in response to the coronavirus pandemic in consultation with OMB, other agencies, and stakeholders. Depending on the pandemic and the degree to which the Household Pulse Survey data decline in their utility in recovering from this national health event, the Census Bureau may conclude data collection activities prior to the clearance expiration date.

The Census Bureau proposes a data collection cycle that allows publication of results on a biweekly basis. As discussed above, the frequency and timeliness of the Household Pulse Survey is a key component of its ability to meet the needs of policymakers. The Census Bureau will review all existing and new items to ensure that the burden created by this frequency of collection is justified by the value of producing biweekly estimates.

7. Explain any special circumstance s that would cause an information collection to be conducted in a manner:

requiring respondents to report information to the agency more often than quarterly;

requiring respondents to pre pare a written response to a collection of information in fewer than 30 days after receipt of it;

requiring respondents to submit more than an original and two copies of any document;

requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax re cords for more than three years;

in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impede s sharing of data with other agencies for compatible confidential use; or

requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Collection of these data is conducted in a manner consistent with the guidelines in 5 CFR 1320.5. We note two special circumstances related to this collection, specifically:

Due to the design of the Household Pulse Survey and its purpose in providing data on a near-time basis to inform on response and recovery efforts associated with the pandemic, survey respondents are asked to complete the survey within a period of 13 days from their receipt of communication from the Census Bureau requesting their participation. After 13 days, the data collected in that period is processed and released within two weeks. A new sample of households is released every two weeks.

The Census Bureau randomly selects households in numbers sufficient to produce and disseminate statistics at a state level. Generally speaking, the sample is selected in a manner such that no household would be selected to participate in the Household Pulse Survey more than once; however, it is possible that this may occur in states with very small populations in order to continue producing data for those states. In those limited cases, it is possible that a given household may be asked to respond to the survey more than once in a calendar quarter.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instruction and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

The Census Bureau published Federal Register Notices informing the public of the Household Pulse Survey on May 19, 2020 (85 FR 29922-29923) and June 3, 2020 (85 FR 34178-34179). A 30-day notice referencing this Phase 3.1 Revision ICR was published on February 1, 2021 (86 FR 7692-7693) to the Federal Register for publication concurrent to this request. In response to the Notices, the Census Bureau received 30 comments from organizations and private citizens. The comments are available in Attachment F, and summarized as follows:

Of the 30 comments, 29 comments offered positive feedback conveying the value of the Household Pulse Survey in terms of its timeliness and the breadth of data made available; one comment offered negative feedback, indicating that the government and its data cannot be trusted.
Twenty-six comments explicitly requested that the Household Pulse Survey be continued; one commenter believed it should not be continued.
Thirteen comments indicated a desire to include additional content on the questionnaire focused on childcare; one comment indicated a similar desire for content relating to other dependent care demands (e.g., older parents, family member with disabilities)
Twelve comments indicated a desire for the survey to collect age ranges for children under 18.
Three comments indicated an interest in more information on the impacts the pandemic has had on children.
One comment indicated a desire for additional questions on educational reopenings.
One comment indicated a desire for the survey to collect information on household relationships.
One comment recommended improvements to the health insurance questions currently on the survey.
One comment recommended content on work conditions and employees’ sense of feeling safe and protected at the workplace relative to availability of PPE, social distancing and other practices designed to slow contagion.
One comment expressed interest in the survey including questions on households’ access and use of P-EBT benefits.
One comment expressed concerns that the survey’s online data collection mode could present a participation barrier for respondents, particularly those in the Latino community, given the “digital divide” in the U.S., and encouraged the Census Bureau to consider additional modes of collection.

One commenter requested additional data tables that crosstab gender and race, gender and households with and without children, and other gender-based data points.
One commenter requested more guidance on how the use the data and its limitations through the posting of additional documentation.

The Census Bureau appreciates the feedback received and has taken these important comments and recommendations under advisement, particularly the preponderance of requests for questions relating to childcare. Should additional collection cycles within Phase 3 be considered, we will evaluate the content and propose deletions, additions and revisions to the questionnaire in light of evolving data needs expressed in these comments and from other agencies and stakeholders. It is the goal of the Census Bureau and its Federal agency partners contributing to this effort that the survey continue to meet as broad a range of data needs as possible while managing household burden.

With regard to consult with outside agencies, the content and design of the Household Pulse Survey was developed initially to serve the needs of five agencies and the Census Bureau, as well as to serve as a data resource for the public benefit. Representatives of these agencies have been involved in the development of the content of the survey and in the dissemination of findings. Since its inception, interest in the survey has only grown, with additional agencies requesting content to support their data needs in supporting pandemic response. The following list contains analysts, researchers, economists, and organizational leaders who have collaborated with the Census Bureau and contributed content to the Household Pulse Survey:

Centers for Disease Control & Prevention, including the National Center for Health Statistics

Brian Moyer

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File Title	SUPPORTING STATEMENT
Author	Kenneth Smith
File Modified	0000-00-00
File Created	2021-03-26