Supporting Statement A BPHC History Project Oct 19

Health Resources and Services Administration

SUPPORTING STATEMENT

Bureau of Primary Health Care – Program Management Resource Compendium - NEW

A. Justification

1. Circumstances of Information Collection

The Health Resources and Services Administration’s (HRSA) Bureau of Primary Health Care (BPHC) has engaged federal contractors to conduct an historical analysis of BPHC, its predecessor organizations, and the federal government’s role in managing the Health Center Program. Dating from the founding of the initial community health centers in the mid-1960s up to the present time, the analysis will consider the evolution and critical milestones of BPHC and the Health Center Program based on documentary research and interviews with individuals with historical knowledge of the Health Center Program and the health center movement.

Interviews are expected with current and former HRSA employees, as well as representatives of the National Association of Community Health Centers, other national organizations, state and regional Primary Care Associations, and HRSA-funded health centers. A list of possible interviewees has been compiled with input by current and former BPHC leadership and staff.

A maximum of 50 interviews is expected, 25 of them being non-federal respondents.

2. Purpose and Use of the Information

The results of the historical analysis will be presented in communication products for an internal audience, as well as products for an external audience. These may include published materials such as pamphlets or books, a website containing a detailed timeline of the program, and other online publications. The goals of the project are to increase awareness of the Health Center Program and its management by the federal government, both within the government and among the general public, as well as to inform BPHC’s future development by analyzing and drawing lessons from the government’s past administration of the Health Center Program.

The information gathered through interviews will be combined with information drawn from documentary research to inform the historical analysis. If information is not gathered from key former employees and representatives of external organizations, the historical analysis will be incomplete and will not provide a comprehensive picture of BPHC’s history and the history of the Health Center Program.

3. Use of Improved Information Technology

Interview subjects will be contacted electronically and asked to submit a brief initial screening survey, confirming their contact information and the details of their involvement with BPHC and the Health Center Program. Subjects will then be invited to choose an interview time via an online appointment scheduling application. Interviews will be conducted virtually by a trained moderator and note taker, using a structured in-depth interview guide.

4. Efforts to Avoid Duplication

The BPHC Program Management Resource Compendium represents the first comprehensive effort undertaken by HRSA to conduct a complete historical analysis of the federal government’s role in managing the Health Center Program, including interviews with key former employees and representatives of external organizations. The ideas, recollections, and perspectives of these individuals are not currently available to HRSA in any other form.

5. Involvement of Small Entities

A few individuals representing organizations such as the National Association of Community Health Centers, other national organizations, state and regional Primary Care Associations, and individual HRSA-funded health centers are intended to be included.

Each interview is expected to last approximately one hour. It is also anticipated that interviewees may spend up to 15 minutes preparing for their interviews, for example by reviewing historical files, as well as responding to the brief initial screening survey and scheduling the interview.

Interviewees will be able to select a time that is convenient via an online appointment scheduling application. Interviews are expected to occur over a period of approximately three months.

6. Consequences if Information Collected Less Frequently

A single interview is expected to occur with each subject. This is not expected to be a recurring request for information. Interviewees may be requested to answer minimal follow-up or clarifying questions.

7. Consistency with the Guidelines in 5 CFR 1320.5(d)(2)

These surveys will be implemented in a manner fully consistent with 5 CFR 1320.5(d)(2).

8. Consultation outside the Agency

The 60 day notice required in 5 CFR 1320.8(d) was published in the Federal Register, 86 Fed. Reg. 30962 (June 10, 2021). No public comments were received.

9. Remuneration of Respondents

Interview subjects will not be remunerated.

10. Assurance of Confidentiality

Interview subjects will be asked to sign a consent form indicating whether they give permission to be quoted directly, to be quoted using an alias, or do not give permission to be quoted within communication materials produced at the conclusion of the project.

11. Questions of a Sensitive Nature

No questions of a sensitive nature will be asked, and no personally identifying information will be collected from interview subjects beyond name, job title(s), and contact information.

12. Estimates of Annualized Hour Burden

Respondents: A maximum of 50 interviews is expected. Interviews are expected with current HRSA employees, as well as former HRSA employees, and also representatives of the National Association of Community Health Centers, other national organizations, state and regional Primary Care Associations, and HRSA-funded health centers.

Annual burden estimates:

Type of Collection	Number of Respondents	Responses per Respondent	Total Responses	Hours per Respondent	Total Burden Hours	Wage Rate	Total Hour Cost
Historical interview	25	1	25	1.25	31.25	$68.18	$2,130.63
Total	25		25		31.25		$2,130.63

For the purpose of this calculation, it has been estimated that 25 interviews will take place with current federal employees, while 25 will take place with non-federal employees.

Each respondent will participate in an interview lasting approximately one hour. In addition, it is anticipated that interviewees may spend up to 15 minutes preparing for their interviews, for example by reviewing historical files, as well as responding to the brief initial screening survey and scheduling the interview.

The majority of non-federal interviewees are currently employed in leadership roles at public or private organizations in the health care field, are working in the educational field, or are retired. To arrive at a very approximate estimated wage rate for all respondents, hourly wages were averaged for Chief Executives ($95.12), General and Operations Managers ($60.45), Medical and Health Services Managers ($57.12), and Health Specialties Teachers, Postsecondary (c. $60.04), yielding an average wage rate for survey respondents of $68.18.

Planned frequency of information collection:

A single interview is expected to occur with each subject. This is not expected to be a recurring request for information. Interviewees may be requested to answer minimal follow-up or clarifying questions.

13. Estimates of Annualized Cost Burden to Respondents

Additional costs are not anticipated for respondents, beyond the hour burden discussed above.

14. Estimates of Annualized Cost to the Government

The portion of the contract price dedicated to interview activities amounts to $103,365. This includes time dedicated to conducting and transcribing the interviews, as well as time devoted to preparing documents related to this information collection request clearance package. The annualized cost (for the three-year contract) is thus $34,455 per year.

While a small number of federal staff are involved in managing the contract and overseeing the project, they will not be directly involved in the interview process and thus will devote minimal time to this aspect of the project.

15. Change in Burden

Not applicable.

16. Plans for Analysis and Timetable of Key Activities

The contract consists of a base year, initiated in March 2021, and two option years. Preliminary requirements gathering, document collection, analysis, and planning have occurred during 2021. Interviews are expected to take place between December 2021 and February 2022. Continued analysis of documents and interview transcripts is expected to take place between March 2022 and March 2023, along with planning and initial development of communication products. Final development and production of these products is expected prior to contract completion in March 2024.

17. Exemption for Display of Expiration Date

No exemption is being requested. The expiration date will be displayed.

18. Certifications

This information collection activity will comply with the requirements in 5 CFR 1320.9.

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