NonSub Change Memo - Updates October 2021

To: Jordan Cohen

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: Caryn Blitz

Office of Planning, Research, and Evaluation (OPRE)

Administration for Children and Families (ACF)

Date: October 12, 2021

Subject: NonSubstantive Change Request – Personal Responsibility Education Program (PREP) – Performance Measures and Adulthood Preparation Subjects (PMAPS) (OMB #0970-0497)

This memo requests approval of nonsubstantive changes to the approved information collection, Personal Responsibility Education Program (PREP) – Performance Measures and Adulthood Preparation Subjects (PMAPS) (OMB #0970-0497).

Background

The approved PREP PMAPS information collection includes (1) grantee-, provider-, and program-level measures of PREP program structure and delivery, and (2) measures grantees collect through participant entry and exit surveys. OMB originally approved the information collection in April 2017 and approved a request for a data collection extension in June 2020. Since the extension request, OMB approved nonsubstantive changes to Instruments #3 and Instrument #4 to add, and then revise, a set of measures to capture changes in PREP programming resulting from the COVID-19 pandemic. The approved data collection instruments include the following:

Instrument #1: Participant entry survey

Instrument #2: Participant exit survey

Instrument #3: Performance reporting system data form – grantees

Instrument #4: Performance reporting system data form – subrecipients

The Family and Youth Services Bureau (FYSB) embarked on revising the performance measures collected through the PREP participant entry (Instrument #1) and exit surveys (Instrument #2) to (1) ensure that all items directly align with legislation, (2) reduce the number of items that some grantees might consider sensitive, (3) reduce burden, and (4) improve clarity. This review and the resulting updates were completed because some questions added by the last administration either did not reflect the program legislation and/or were not helpful to inform program improvement.

In addition, we are proposing to reduce the number of pandemic-related measures in Instruments #3 and #4. The effects of the pandemic on PREP programs have diminished as schools reopened and other pandemic restrictions lessened. As a result, many of the pandemic-related measures are less relevant, so we propose reducing them to only a few measures on the pandemic’s lingering effects. Streamlining this set of measures will also reduce burden of the data collection.

An additional factor motivating the revisions to all instruments is that the timing for implementation of the revised performance measures coincides with new cohorts of FY2022 PREP grantees whose awards begin in October 2021. The proposed changes to the data collection materials are detailed below.

Overview of Requested Changes

ACF is requesting approval for the following revisions to the data collection:

1. Add one additional version of the Entry and Exit Surveys (Instruments #1 and #2). Currently, there are three versions. The additional version is for middle school youth in PREIS/TPREP programs. Similar to currently approved versions 1b and 2b, the additional versions (1c and 2c) include a limited number of questions at Entry and Exit to decrease burden due to grantees’ participation in evaluation studies, which often include extensive surveys. These changes result in the following versions of the entry and exit surveys:

   • Instrument 1: Entry survey for high school and older youth (existing version)

   • Instrument 1a: Entry survey for middle school youth (existing version)

   • Instrument 1b: Entry survey for high school and older youth in PREIS/TPREP programs (existing version)

   • Instrument 1c: Entry survey for middle school youth in PREIS/TPREP programs (new version)

   • Instrument 2: Exit survey for high school and older youth (existing version)

   • Instrument 2a: Exit survey for middle school youth (existing version)

   • Instrument 2b: Exit survey for high school and older youth in PREIS/TPREP programs (existing version)

   • Instrument 2c: Exit survey for middle school youth in PREIS/TPREP programs (new version)

2. Revisions to questions in Instruments #1 and #2:¹

• Added an “Other (specify)” response category to question on race.

• Simplified wording of response categories in question on residence.

• Removed question on success sequencing.

• Reduced the number of sub-questions in several items on behaviors (at entry) and perceived program effects (at exit) related to adulthood preparation, as well as items on perceived program effects.

• Streamlined wording in questions on relationships and dating

• Removed exit survey questions on bullying in the program

• Modified the question stem for several questions on perceived program effects to include the qualifier “even if your program didn’t cover this topic, would you say…”

• For PREIS/Tribal versions, added items from other OMB-approved versions of Instrument #2 on program experiences and perceived program effects on sexual behaviors.

3. Revisions to Instruments #3 and #4:

• Revised Instrument 3 to align with proposed changes to Instruments 1 and 2.

• Removed 13 COVID-related measures around staffing vacancies and whether programming was offered virtually.

• Revised Instrument #4 to reflect items removed from Instrument #3

These changes are not expected to greatly impact the data and usability of the data already collected. For the most part, items have been deleted. The minor edits to wording and response categories will still allow us to compare to previous data (which only affects State PREP grantees). Finally, the new cohorts of PREP grantees will collect data for the first time.

The proposed changes to the instruments will reduce the burden hours for respondents. In addition, we have revised the burden table in Supporting Statement A to reflect minor changes in the numbers of PREP grantees (from 92 to 101) and subrecipients (from 391 to 400) and the expected corresponding changes to the number of PREP participants. We have also updated the burden table to reflect the latest wage rates based on the National Occupational Employment and Wage Estimates from the Bureau of Labor Statistics from May 2020. The combination of these changes decreases the expected annual burden by 813 hours. We have updated the burden table in Supporting Statement A to reflect these changes.

Time Sensitivities

ACF requests approval by mid October 2021 so that grantees can obtain any necessary school district or IRB approvals of the revised measures before beginning to use the revised surveys in January 2022.

1 Changes are proposed for all versions of Instruments #1 and #2 that contain the question.

3