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Formative Research and Tool Development

SSA

OMB: 0920-0840

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DASH DEMO: LGBTQ Inclusivity Toolkit Evaluation

Submitted under GenIC OMB No. 0920-0840

Expires 07/31/2024

Supporting Statement Part A

June 9, 2022

Contact Information:

Program Official/Project Officer

Name: Leigh Szucs

Title: Health Scientist

Organization: CDC Division of Adolescent and School Health

Address: 1600 Clifton Rd NE MS Us8-1. Atlanta, GA 30329

Phone Number: 404-718-6875

Email: [email protected]

Table of Contents

Section

A. Justification

Circumstances Making the Collection of Information Necessary
Purpose and Use of the Information Collection
Use of Improved Information Technology and Burden Reduction
Efforts to Identify Duplication and Use of Similar Information
Impact on Small Businesses or Other Small Entities
Consequences of Collecting the Information Less Frequently
Special Circumstances Relating to the Guidelines of 5 CFR 1320.5
Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency
Explanation of Any Payment or Gift to Respondents
Protection of the Privacy and Confidentiality of Information Provided by Respondents
Institutional Review Board (IRB) and Justification for Sensitive Questions
Estimates of Annualized Burden Hours and Costs
Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers
Annualized Cost to the Federal Government
Explanation for Program Changes or Adjustments
Plans for Tabulation and Publication and Project Time Schedule
Reason(s) Display of OMB Expiration Date is Inappropriate
Exceptions to Certification for Paperwork Reduction Act Submissions

B. Collection of Information Employing Statistical Methods

1. Respondent Universe and Sampling Methods

2. Procedures for the Collection of Information

3. Methods to Maximize Response Rates and Deal with Nonresponse

4. Tests of Procedures or Methods to be Undertaken

5. Individuals Consulted on Statistical Aspects and Individuals Collecting and/or Analyzing Data

Attachments

Att 1_LGBTQ Inclusivity Toolkit School and District Staff Climate Interview Guide

Att 2_LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey

Att 3_LGBTQ Inclusivity Toolkit Monthly Report Form

Att 4_LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide

Att 5_Authorization Legislation

Att 6_ Federal Register Notice, 60-day

Att 7_IRB Approval

Att 8_Privacy Impact Assessment

Att 9_Consent-School Staff Survey

Att 10_Consent-District Staff Climate Interview

Att 11_Consent-School Staff Climate Interview

Att 12_ Consent_Post-Pilot Feedback Interview

Att 13_Respondent Universe

Goal of the Study: The overall aim of the “DASH DEMO: LGBTQ Inclusivity Toolkit Evaluation”

Intended use of resulting data: Through the LGBTQ Inclusivity Toolkit Evaluation Study, CDC/DASH will gain valuable insight into the utility of a newly-designed and piloted toolkit in secondary school settings. LGBTQ Inclusivity Toolkit Evaluation Pilot Study will be implemented during the 2022-2023 academic year in three local education agencies (i.e., school districts) in the United States. Ultimately, findings from this study will provide evidence needed for strengthening existing materials to better facilitate the uptake of strategies to create safe and supportive environments for students with LGBTQ identities.

Methods to be used to collect data: The mixed-method evaluation design allows for measurement of district and school staff outcomes before the toolkit is implemented (pre/baseline), collection of information about toolkit implementation, measurement of outcomes following the 2022-2023 academic year (post), and collection of feedback about the toolkit post-implementation. Information will be gathered in this study using both quantitative and qualitative data collection methods.

The subpopulation to be studied: The LGBTQ Inclusivity Toolkit is a newly-developed resource that will be used by district and school-level staff (adults).

How data will be analyzed: Quantitative data from staff surveys (pre/post) using a web-based SurveyMonkey, will be analyzed using descriptive statistics, repeated measures t-tests, and chi-square tests and regression analysis to assess changes in school staff’s perceptions and experiences related to school climate and LGBTQ inclusivity. Qualitative data from the district and staff climate interviews, post-pilot feedback staff interviews, and toolkit monthly report will use thematic content analysis to identify emergent patterns related to school climate and inclusivity, and toolkit implementation, usability, and feasibility.

Section A: Justification for Information Collection

A. 1 Circumstances Making the Collection of Information Necessary

This information collection is being conducted using the currently approved generic information collection, NCHHSTP Generic Clearance Formative Research and Tool Development package (OMB # 0920-0840, expiration 7/31/2024). The overall aim of the “DASH DEMO: LGBTQ Inclusivity Toolkit Evaluation” formative research study is to understand the extent to which a lesbian, gay, bisexual, transgender, queer/questioning (LGBTQ) inclusivity toolkit designed for district and school-level staff supports the adoption and implementation of strategies to create safe and supportive school environments for students with LGBTQ identities in high school (grades 9-12). The study will also explore usability, feasibility, and acceptability information provided by district and school-level staff using the draft LGBTQ inclusivity toolkit to help inform revisions following the pilot study.

Through the LGBTQ Inclusivity Toolkit Demonstration Study, CDC/DASH will gain valuable insight into the utility of a newly-designed and piloted toolkit in secondary school settings. Ultimately, findings from this study will provide evidence needed for strengthening existing materials to better facilitate the uptake of strategies to create safe and supportive environments for students with LGBTQ identities.

This pilot study will begin in spring 2022 and continue through the 2022-23 academic year. ICF will coordinate the evaluation in collaboration with Charlotte-Mecklenburg Schools (NC), Boone County School District (KY), and Richardson Independent School District (ISD) (TX). ICF will provide a draft of the LGBTQ Inclusivity Toolkit to each school district following Phase 1 of the study (see additional details below). Charlotte-Mecklenburg Schools and Boone County School District will each select two high schools: one intervention school where the district will work with school administrators to select activities (e.g., staff professional development) and pilot the toolkit during the 2022-2023 academic year, and one control school that will only participate in evaluation data collections. Richardson ISD will select one high school to pilot the toolkit implementation.

The mixed-method evaluation design allows for measurement of district and school staff outcomes before the toolkit is implemented (pre/baseline), collection of information about toolkit implementation, measurement of outcomes following the 2022-2023 academic year (post), and collection of feedback about the toolkit post-implementation. Further, this study will assess both process and outcome measures. The evaluation will take place in the following phases:

Phase 1- Spring/Summer 2022- All Districts- Outcome Evaluation - Pre-Pilot LGBTQ Inclusivity Toolkit School and District Staff Climate Interviews (Attachment 1) with district and school staff at the intervention high school in each district to gather qualitative data about the district/school climate before using the toolkit.
Phase 2- Fall 2022- - Charlotte-Mecklenburg Schools and Boone County School District - Outcome Evaluation - Quantitative LGBTQ Inclusivity Toolkit Pre-Post Staff Survey (Attachment 2) to assess school staff perceptions and experiences of the school climate. The school staff survey (15-minutes) will be administered via an email invitation linking directly to the electronic survey for staff at intervention and control schools. School staff identifying information will be collected only for recruitment purposes.
Phase 3- Fall 2022-Spring 2023- All Districts- Process Evaluation - The point-of-contact in each district will complete the LGBTQ Inclusivity Toolkit Monthly Report Form (Attachment 3) to track toolkit activities and strategy implementation.
Phase 4- Spring 2023- Charlotte-Mecklenburg Schools and Boone County School District- Outcome Evaluation - Repeat LGBTQ Inclusivity Toolkit Pre-Post Staff Survey (Attachment 2) at intervention and control schools (repeat of Phase 2).
Phase 5- Spring 2023- All Districts- Outcome Evaluation - Post-Pilot LGBTQ Inclusivity Toolkit School and District Staff Climate Interviews (Attachment 1) at intervention schools (repeat of Phase 1).
Phase 6- Spring/Summer 2023- All Districts- Process Evaluation - LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interviews (Attachment 4) with district and school staff from intervention high schools who participated in the pilot to gather qualitative data about the utility of the toolkit and offered suggestions for improvement.

The results from this demonstration project will provide insight into the following:

the ways in which the LGBTQ inclusivity toolkit can better support districts/high schools in identifying areas for improvement in current LGBTQ inclusivity efforts,
the extent to which the toolkit helps districts/high schools identify and implement new or strengthen existing strategies,
the degree to which districts/high schools can diffuse policies/practices from the district to school-level implementation,
the ways in which using toolkit strategies changes awareness of and support for LGBTQ inclusivity and school climate across the district and high schools, and
the extent to which the toolkit provides guidance on incorporating LGBTQ inclusivity strategies in district and school-level diversity, equity, and inclusion (DEI) efforts.

Background

The Division of Adolescent and School Health (DASH) resides within the National Center for HIV, Viral Hepatitis, sexually transmitted disease (STD), and tuberculous (TB) Prevention (NCHHSTP) at the Centers for Disease Control and Prevention (CDC). The fundamental goal of DASH is to improve the health and well-being of our nation’s youth by working with education and health agencies, and other organizations to promote environments where youth can gain essential health knowledge and skills, establish healthy behaviors for a lifetime, connect to health services, and avoid becoming pregnant or infected with HIV or STDs.

NCHHSTP, which includes DASH, conducts formative research for developing and or testing new tools and methodologies or to build upon existing tools and methodologies that respond to the changing epidemiology of NCHHSTP’s five areas of responsibility and four groups of diseases (HIV, STD, TB, and viral hepatitis) that cause 80% of the disease morbidity in the United States.

DASH is a unique source of support for HIV, STD, and pregnancy prevention efforts in the nation’s schools. DASH works to protect youth by:

Collecting data that drive action.
Translating science into innovative programs and tools that work to protect youth.
Supporting a network of leaders in primary prevention by funding education agencies that reach nearly 2 million students.

DASH is committed to preventing HIV, STDs, and pregnancy among all youth. Taking a school-based health promotion and disease prevention approach, the Division works to prepare healthy youth for a successful future. The DASH NOFO PS18-1807 funds: (1) local education agencies (LEAs), (i.e., school districts), and (2) lead agencies of consortia (LEA or regional training education center). LEA is a commonly used synonym for a school district, or an entity which operates local public primary and secondary schools in the United States. These agencies are funded to build the capacity of districts and schools to effectively contribute to the reduction of HIV infection, other STDs, and related risk behaviors among adolescents, as well as the reduction of disparities in HIV infection and other STDs experienced among specific adolescent sub-populations. NOFO PS18-1807 builds upon and expands work previously accomplished through NOFO PS13-1308 (Promoting Adolescent Health Through School-Based HIV/STD Prevention and School-Based Surveillance).

In 2019, 38% of high school students in the United States (U.S.) had ever had sexual intercourse and 27% were currently sexually active. Among currently sexually active students, 46% did not use a condom, and 12% did not use any method to prevent pregnancy the last time they had sexual intercourse. ¹ In 2019, young people aged 13-24 accounted for an estimated 21% of all new HIV diagnoses in the United States. Half of the nearly 20 million new STDs reported each year were among young people aged 15-24.^1,
2 Today, two in five sexually active teen girls have had an STD that can cause infertility and even death.² Also, though rates of HIV are very low among adolescents, males make up more than 80 percent of HIV diagnoses among 13- to 19-year-olds.³

Research has shown that youth who identify as LGBTQ are more likely to experience negative attitudes and violent behaviors, including bullying, harassment, and physical assault, while at schools as compared to their heterosexual and cisgender peers.⁴ GLSEN’s 2019 National School Climate Survey found that most students identifying as LGBTQ (86%) experienced some form of harassment or assault based on personal characteristics, including sexual orientation, gender expression, and gender identity.⁵ According to the 2015 national Youth Risk Behavior Survey (YRBS), youth who identified as LGB were 140% more likely to not go to school at least one day during the 30 days prior because of prior safety concerns compared to heterosexual students.⁶

Youth who experienced higher levels of victimization based on their sexual orientation and gender expression were more likely to have lower GPAs, were nearly twice as likely to not plan to pursue post-secondary education and were nearly twice as likely to have been disciplined at school.⁵ Adverse childhood experiences, like youth violence, are associated with negative health and well-being outcomes, including impaired decision making, learning challenges, decreased connection to peers and adults, and trouble coping with stress.⁷ In 2019, the YRBS reported that nearly one-third (23.4%) of students identifying as LGB reported attempting suicide in the past year, compared to 6% of heterosexual youth.⁴

Establishing healthy behaviors during childhood and adolescence is easier and more effective than trying to change unhealthy behaviors during adulthood. In the U.S., schools have direct contact with more than 50 million students for at least 6 hours a day during 13 key years of their social, physical, and intellectual development.⁸ Schools can influence students’ risk for HIV infection and other STDs through parental engagement, sexual health education, connection to physical and mental health services, and connecting youth to each other and important adults.

CDC/DASH funded a five-year cooperative agreement, PS18-1807 Promoting Adolescent Health through School-based HIV Prevention, that funds LEAs and nongovernmental organizations (NGOs) to support efforts to implement school-based programs and practices designed to reduce HIV infection and other STDs among adolescents. Currently, 28 funded recipients, (25 LEAs, and 3 consortia) receive CDC funding to deliver high-quality, school-based HIV, STD, and pregnancy prevention programs with additional state and local agencies participating in school-based surveillance. Collectively, these LEAs reach 2 million of the 26 million middle and high school students in the U.S. through systems-level strategies that address (1) sexual health education, (2) access to sexual health services, and (3) safe and supportive environments. Preliminary data suggest that such strategies can influence key health risk behaviors and experiences among young people.⁸

PS18-1807 supports implementation of these activities at multiple levels of the education system to achieve health goals. School districts generally determine local health education curricula, policies, and services. In this program, the school districts and consortia provide training, resources, and technical assistance to schools to implement school-based strategies through district-level actions and decisions. They provide a range of highly-trained experts for professional development and technical assistance to advance HIV/STD prevention work. This funding facilitates a multi-component, multi-level effort to support youth reaching adulthood in the healthiest way possible.

CDC/DASH is working with ICF, an evaluation contractor, to provide support for a set of demonstration projects. The focus of this demonstration project is on LGBTQ inclusivity. This is a multi-year project which involves developing a toolkit designed for district and school-level staff to support the adoption and implementation of strategies to create safe and supportive environments for students with LGBTQ identities in high school (grades 9-12). The project will gather evidence needed for creating and strengthening materials to support uptake of school-based strategies to create safe and supportive environments for students with LGBTQ identities.

Data collection for this project is authorized under 42 U.S.C. 241, Chapter 6a - Public Health Service; Subchapter II - General Powers and Duties of the Public Health Service Part A - Research and Investigations Generally (Attachment 5).

Personal identifiable information (PII) for this study, including names and business email addresses will be kept in a separate location and accessible only to the ICF study team. This information will be destroyed when data collection is complete at the end of the 2022-2023 academic year. The information collected for this project will be maintained or stored locally under strict access controls limited to the local project leader/manager or their designate without PII. Under no circumstances will an individual be identified using a combination of variables such as gender, race, birth date, and/or other descriptors.

A.2 Purpose and Use of Information Collection

This information collection supports formative research for the development and improvement of tools and resources to improve LGBTQ inclusivity in schools and school districts. The purpose of this formative research pilot study is to field test an LGBTQ inclusivity toolkit and measurement instruments to determine usability, appropriateness, and effects on district and school-level implementation of inclusivity strategies. This study will allow ICF to determine necessary changes to the LGBTQ inclusivity toolkit to increase its utility, inform changes to the data collection process to increase data quality and efficiency, and reduce burden. This pilot study will begin in spring 2022 and continue through the 2022-2023 academic year. ICF will coordinate the mixed-methods evaluation in collaboration with Charlotte-Mecklenburg Schools, Boone County School District, and Richardson ISD. Each district will receive the toolkit in summer 2022 and participate in action planning, implementation, and data collection activities. The LGBTQ inclusivity toolkit is designed for district and school-level staff only and will not be used by students at any point during the pilot study.

Charlotte-Mecklenburg Schools and Boone County School District will each participate in the full outcome evaluation and Richardson ISD will participate in a process evaluation. Charlotte-Mecklenburg Schools and Boone County School District will each select two high schools: one intervention school where the district will work with school administrators to select activities (e.g., staff professional development) and pilot the toolkit during the 2022-2023 academic year, and one control school that will only participate in evaluation data collections. Staff at intervention high schools will complete the following information collections: 1) pre-post qualitative school climate interviews with district/school staff (2) pre-post quantitative surveys with school staff, 3) monthly progress reports on toolkit implementation by district staff, and 4) post-pilot feedback interviews with district or school staff. Staff at the control high schools will only complete (1) pre-post quantitative surveys with school staff.

Richardson ISD will participate in a process evaluation, selecting only one high school to pilot toolkit implementation. The selected high school will complete the following collections of information: 1) pre-post qualitative climate interviews with district or school staff, 2) monthly progress reports on toolkit implementation, and 3) post-pilot feedback interviews with district or school staff. Overall, the timeline for collection of information allows for baseline measurement of outcomes prior to toolkit implementation, collection of information about how the toolkit is used, follow-up outcome measurement, and collection of feedback about the toolkit post-implementation.

No sensitive information is being collected. PII (name and email) is only being collected for study communication (e.g., recruitment) with district and school staff for qualitative interview participation and incentives. This information will be kept separate from all written/electronic survey data, interview audio-recordings, notes and transcripts, and final report documentation. No PII will be displayed on or collected with electronic surveys and ICF will not share respondent information with CDC/DASH.

The school staff survey will be conducted via SurveyMonkey, an online survey platform that does not collect or include any identifying information. School staff may consent to participate and gain access to the web-based survey or decline participation; no PII will be collected.

Without this data collection, CDC/DASH would be unable to assess the following:

the ways in which the LGBTQ inclusivity toolkit can better support districts/high schools in identifying areas for improvement in current LGBTQ inclusivity efforts.
the extent to which the toolkit helps districts/high schools identify and implement new or strengthen existing strategies.
the degree to which districts/high schools can diffuse policies/practices from the district to school-level implementation.
the ways in which using toolkit strategies change awareness of and support for LGBTQ inclusivity and school climate across the district and high schools.
the extent to which the toolkit provides guidance on incorporating LGBTQ inclusivity strategies in district and school-level DEI efforts.

A.3 Use of Improved Information Technology and Burden Reduction

The LGBTQ Inclusivity Toolkit Pre-Post Staff Survey (Attachment 2) will be web-based. This approach ensures data quality and decreases participant burden with built-in skip logic is and designed to collect the minimum information necessary for meeting project objectives. In addition, the web-based administration allows staff respondents to easily access the data collection instrument at a time and location that is most convenient for them.

A. 4 Efforts to Identify Duplication and Use of Similar Information

The LGBTQ Inclusivity Toolkit is a newly-developed resource for district and school staff. It is designed to support the adoption and implementation of strategies to create safe and supportive school environments for students with LGBTQ identities in high school (grades 9-12). There is no existing information on this toolkit or any data collection activities related to its assessment. For this reason, the study team developed the LGBTQ Inclusivity Toolkit data collection tools. The newly-developed qualitative interview guides, quantitative survey, and monthly report form will allow the study team to collect relevant information. No existing information sources can provide relevant and needed data.

A. 5 Impact on Small Businesses or Other Small Entities

No small businesses or other small entities will be involved in or affected by this data collection.

A. 6 Consequences of Collecting the Information Less Frequently

This study will take place throughout the 2022-2023 academic year in Charlotte-Mecklenburg Schools, Boone County School District, and Richardson ISD. There are no legal obstacles to reducing the burden. Collecting the data less frequently would mean not collecting the data at all, and there could be negative consequences. The findings from this study will provide evidence needed for strengthening existing materials to better facilitate the uptake of strategies to create safe and supportive environments for students with LGBTQ identities.

A. 7 Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

This request fully complies with the regulation 5 CFR 1320.5.

A.8 Comments in Response to the Federal Register Notice and Efforts to Consult Outside Agencies

A. The Federal Register Notice was published for the generic umbrella collection on Friday, February 21, 2021, Vol. 86, No. 28, pp. 9346. No public comments were received. (Attachment 6).

B. CDC contractors in collaboration with CDC/DASH subject matter experts provided extensive input into the clarity of the instructions, content of the survey questions, and the respondent universe. A list of subject matter experts consulted is provided below. There were no major problems that arose during the consultation, and all issues raised were resolved.

A.9 Explanation of Any Payment or Gift to Respondents

All staff who volunteer to participate in the LGBTQ Inclusivity Toolkit Demonstration Study will have the opportunity to receive a token of appreciation. Studies suggest that tokens of appreciation can significantly increase response rates^9,
10and can improve the validity and reliability of the data, which is of utmost importance in this evaluation. The use of gifts can help minimize bias resulting from variations in interest in the topic by motivating potential study participants to commit the time necessary for their participation. Further, the gift helps emphasize that the assessment is important, which in turn, will make potential participants more inclined to make time to participate.¹¹

Based on this research, to encourage and improve response rates, tokens of appreciation will be provided to thank staff for their participation in the form of a $25 gift card for the following interviews: LGBTQ Inclusivity Toolkit School and District Staff Climate Interview (Attachment 1); and the LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview (Attachment 4). Staff members who complete the fall LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey (Attachment 2) will be entered into a drawing to win a $50 gift certificate. Similarly, staff who complete the spring LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey (Attachment 2) will be entered into another drawing to win a $50 gift certificate. Each district (Charlotte-Mecklenburg Schools and Boone County School District) will have their own separate drawings for gift certificates for the fall and spring administrations of the LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey (Attachment 2).

ICF expects the value of the gifts for staff to be sufficient to improve participation rates. In consultation with Charlotte-Mecklenburg Schools, Boone County School District, and Richardson ISD staff, ICF believes the tokens of appreciation are appropriate. Further, the IRB-approved study protocol includes a token of appreciation for staff (Attachment 7).

A10. Protection of the Privacy and Confidentiality of Information Provided by Respondents

The CDC NCHHSTP Privacy and Confidentiality Review Officer assessed this package for applicability of 5 U.S.C. § 552a and determined that the Privacy Act does not apply to the information collection. No individually identifiable information will be collected, and no sensitive information is being collected. CDC will not receive any PII. Staff names and emails are publicly available on school district websites. CDC staff reviewed this information collection request and determined that the Privacy Act does not apply (Attachment 8).

Quantitative and qualitative data and all identifying information about study participants will be handled in ways that prevent unauthorized access at any point during the study. No PII will be collected from the staff survey, so it will be completely anonymous. Information will be kept in separate password-protected files from the quantitative survey data and not provided to CDC/DASH. No PII will be recorded or stored as part of the survey or database. Once data collection is complete, it will be converted to SPSS file format and stored on a secure network location with respondent ID only.

Electronic data collection and data management systems used for these activities will comply with the current encryption security standards. Our information security process is based on the approach prescribed by the Federal Information Security Management Act of 2002 (FISMA, 44 U.S.C. § 3541 et seq.) as implemented by the Office of Management and Budget (OMB) in Circular A-130 and other policy documents. Electronic data are maintained in our Tier IV data center or in our high-security onsite systems and are set up using a “least privilege” protocol that permits users the least amount of access required to perform their duties.

Consent

Charlotte-Mecklenburg Schools and Boone County School District staff will be invited to participate in the LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey (Attachment 2) from the internal contact email list. This survey will be administered electronically through SurveyMonkey. All school staff from one intervention and one control high school at each district will receive an invitation email inviting them to take the survey. The survey link will lead them to the first page of the survey which includes the Consent Staff Survey (Attachment 9). Staff will have the opportunity to give their consent for participation in the survey both times the survey is administered (fall 2022, spring 2023). ICF will not see any names or email addresses of those who are invited to participate. ICF will not have access to any PII (name and email addresses). Staff may choose to opt out of the survey at any time.

In all three school districts, the study team will coordinate with study participants to schedule the District Staff Climate Interview, the School Staff Climate Interview, and the Post-Pilot Feedback Interview. At the time of the interview, the interviewee will be given either the District Staff Climate Interview Consent, the School Staff Climate Interview Consent, or the Post-Pilot Feedback Interview Consent to complete (Attachments 10, 11, 12, respectively). If the interviewee consents, then the interview will be conducted in-person or virtually (e.g., Microsoft Teams, Zoom).

A.11. Institutional Review Board (IRB) and Justification for Sensitive Questions

IRB Approval

The proposed web-based data collection and qualitative interviews were reviewed and approved on 11/23/2021 by the existing contractor’s IRB (Attachment 7). This project is approved until November 22, 2023.

Sensitive Questions

The LGBTQ Inclusivity Toolkit is designed to support school districts in developing programs that promote inclusion of students who identify as LGBTQ. To this end, study instruments may include items perceived as sensitive by study participants. Participants may skip any questions or stop participation in data collection activities at any time without penalty. Responses will only be reported in aggregate. All participant information associated with the study will be collected and stored in a password-protected electronic file on a secure network accessible only by the study team.

A.12. Estimates of Annualized Burden Hours and Costs

The annualized response burden is estimated at 275 hours. Exhibit A.12.A provides details about how this estimate was calculated. Timing was estimated during the instrument development process to support the overall burden per respondent.

Exhibit A.12.A Annualized Burden Hours

Type of Respondent	Form Name	Number of Respondents	Number of Responses per Respondent	Average Hours Per Response	Maximum Response Burden (Hours)
School Staff	LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey (Worksheet 2_Pre-Post School Staff Survey)	400	2	15/60	200
School Staff	LGBTQ Inclusivity Toolkit School Staff Climate Interview Guide (pre-toolkit; Worksheet 4_Toolkit School Staff Climate Interview Guide)	12	1	60/60	12
School Staff	LGBTQ Inclusivity Toolkit School Staff Climate Interview Guide (post-toolkit; Worksheet 4_Toolkit School Staff Climate Interview Guide)	12	1	60/60	12
District Staff	LGBTQ Inclusivity Toolkit District Staff Climate Interview Guide (pre-toolkit; Worksheet 6_District Staff Climate Interview Guide)	9	1	60/60	9
District Staff	LGBTQ Inclusivity Toolkit District Staff Climate Interview Guide (post-toolkit; Worksheet 6_District Staff Climate Interview Guide)	9	1	60/60	9
District Staff	LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide (Worksheet 8_LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide)	9	1	60/60	9
School Staff	LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide (Worksheet 8_LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide)	6	1	60/60	6
District Staff	LGBTQ Inclusivity Toolkit Monthly Report Form (Worksheet 9_Monthly Report Form)	3	12	30/60	18
Total					275

A.12.B Estimated Annualized Costs

Participants in the LGBTQ Inclusivity Toolkit Demonstration Study include school and district staff. The preschool, elementary, middle, secondary, and special education teachers labor category for district/school staff is the labor category that most closely matched the professional sample. The annualized cost to the respondents shown in Table A.12.B is based on this information.

The United States Department of Labor, Bureau of Labor Statistics Occupational Employment Statistics (https://www.bls.gov/oes/current/naics4_611100.htm) was used to estimate the hourly wage rate for district and school staff for this request. The median hourly wage for this category, $23.74 per hour, was used to estimate the hourly wage for school and district staff. The United States Department of Labor, Bureau of Labor Statistics Occupational Employment Statistics. Thus, the total anticipated annual cost to respondents for the collection of information is $8,223.95.

Exhibit A.12.B. Annualized Cost to Respondents

Activity	Total Burden Hours	Hourly Wage Rate	Total Respondent Cost
Consent-School Staff Survey	66.67	$23.74	$1,582.67
LGBTQ Inclusivity Toolkit Pre-Post School Staff Survey	200	$23.74	$4,748.00
Consent-School Staff Climate Interview (pre-toolkit)	1	$23.74	$23.74
LGBTQ Inclusivity Toolkit School Staff Climate Interview Guide (pre-toolkit)	12	$23.74	$284.88
Consent-School Staff Climate Interview (post-toolkit)	1	$23.74	$23.74
LGBTQ Inclusivity Toolkit School Staff Climate Interview Guide (post-toolkit)	12	$23.74	$284.88
Consent-District Staff Climate Interview (pre-toolkit)	.75	$23.74	$17.81
LGBTQ Inclusivity Toolkit District Staff Climate Interview Guide (pre-toolkit)	9	$23.74	$213.66
Consent-District Staff Climate Interview (post-toolkit)	.75	$23.74	$17.81
LGBTQ Inclusivity Toolkit District Staff Climate Interview Guide (post-toolkit)	9	$23.74	$213.66
Consent-LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview	1.25	$23.74	$29.68
LGBTQ Inclusivity Toolkit Post-Pilot Feedback Interview Guide	15	$23.74	$356.10
LGBTQ Inclusivity Toolkit Monthly Report Form	18	$23.74	$427.32
Total	346.42		$8,223.95

A.13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

CDC does not anticipate providing start-up or other related costs to private entities.

A.14. Annualized Costs to the Government

The total annualized cost to the government, including direct costs to the federal government and contractor expenses is $107,728.51. Cost will be incurred by the government in personnel time for overseeing the project. CDC time and effort for general project oversight of the contractor for project design, data collection, analysis, and dissemination are estimated at 5% for a GS-14 (step 7) level Atlanta-based CDC employee and 5% for a GS-13 (step 4) level Atlanta-based CDC employee for one year of the project. The grade and step levels were determined based on the staff currently proposed to work on the project. The average annual cost to the federal government for oversight is $12,293 (Table A.14.A).

The contractor’s costs are based on estimates provided by the contractor who helped plan the data collection activities. With the expected period of performance, the annual cost to the federal government from the contractor and other expenses is estimated to be approximately $95,493.51. This is the cost estimate based on the incurred and projected labor required to design, program, collect, clean, analyze, and report findings of the contractor at approximately 20% of the estimated contract value for the LGBTQ Inclusivity Toolkit Demonstration Study in option year one (approximately $86,653.51).

Exhibit A.14.A

Expense Type	Expense Explanation	Annual Costs (dollars)
Direct Costs to the Federal Government
CDC oversight of the project	1 CDC Senior Health Scientist at 5% (GS-14)	$6,815
CDC oversight of contractor and project	1 CDC Health Scientist at 5% (GS-13)	$5,478
Subtotal, Direct Costs		$12,293
Assistance with data collection, processing, and preliminary analysis	Labor and other direct costs for supporting data collection, processing, and analysis	$95,435.51
Total Cost to The Government		$107,728.51

A.15. Explanation for Program Changes or Adjustments

This is a new information collection.

A.16. Plans for Tabulation and Publication and Project Time Schedule

Data collection will take place over the 2022-2023 academic year. It is critical for this data collection to begin no later than April 2022 to engage district and school staff to participate in the LGBTQ Inclusivity Toolkit Demonstration Study over the 2022-2023 academic year. As such, ICF is requesting to receive OMB approval for this information collection by the end of July 2022. Preliminary data analysis, summaries, and reports (unpublished) will begin two weeks after the completion of the pre-LGBTQ Inclusivity Toolkit staff survey. ICF will conduct data analysis, final report documentation, and subsequent revisions to study instruments between September 2023 and September 2024. ICF will produce a summary of key findings to be shared with DASH.

Figure A.16: Project Time Schedule

Activity	Time Schedule
Design information collection instruments	Complete
Develop data collection protocol and analysis plan	Complete
Receive ICF IRB approval	Complete
Prepare OMB package	In Progress
Receive OMB approval	In Progress
Recruit school districts for participation in the LGBTQ Inclusivity Toolkit Demonstration Project	Complete
Data Collection	14 months following OMB approval
Data Analysis	30 months following OMB approval

A.17. Reason(s) Display of OMB Expiration Date is Inappropriate

The display of the OMB expiration date is not inappropriate. The web-based quantitative surveys will display the expiration date for OMB approval of the information collection. We are not requesting an exemption.

A.18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification.

Individuals consulted on statistical aspects and study design:

Christine Walrath, PhD

Senior Vice President, Chief Science Officer, ICF, 2635 Century Parkway NE, Suite 1000, Atlanta, GA 30345

File Type	application/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title	Supporting Statement for Request for Clearance:
Author	Karen Whitaker
File Modified	0000-00-00
File Created	2023-08-28