Supporting Statement A - Strengthening the Implementation of Responsible Fatherhood Programs (SIRF)

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Formative Data Collections for ACF Program Support

Supporting Statement A - Strengthening the Implementation of Responsible Fatherhood Programs (SIRF)

OMB: 0970-0531

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Alternative Supporting Statement for Information Collections Designed for

Research, Public Health Surveillance, and Program Evaluation Purposes



Strengthening the Implementation of Responsible Fatherhood Programs (SIRF)



Formative Data Collections for Program Support


0970 - 0531





Supporting Statement

Part A

April 2021


Submitted By:

Office of Planning, Research, and Evaluation

Administration for Children and Families

U.S. Department of Health and Human Services


4th Floor, Mary E. Switzer Building

330 C Street, SW

Washington, D.C. 20201


Project Officers:


Katie Pahigiannis

Kriti Jain







Part A




Executive Summary


  • Type of Request: This Information Collection Request is for a generic information collection under the umbrella generic, Formative Data Collections for Program Support (0970-0531).


  • Description of Request: The Administration for Children and Families (ACF) at the U.S. Department of Health and Human Services (HHS) seeks approval to obtain information about program processes and outcomes during the course of rapid cycle evaluation activities and assistance to support development, implementation, refinement, and testing and of solutions to address recruitment, retention, and/or engagement challenges for the Strengthening the Implementation of Responsible Fatherhood Programs (SIRF) federally led evaluation. The current request builds on two previous information collections under the Formative Data Collections for Research and Evaluation (0970 – 0356), which collected information on common implementation challenges faced by fatherhood programs and how promising solutions to those challenges could be tested using rapid cycle methods in program settings. Information collected through this current request will support rapid cycle evaluations of interventions that will be implemented with ten fatherhood programs. The information learned from conducting these activities will allow the team to understand how the interventions are implemented during the rapid cycles.


We do not intend for this information to be used as the principal basis for public policy decisions.



  • Time Sensitivity: The awards of ACF’s new Responsible Fatherhood grant cohort were made in late September 2020. The rapid learning cycles are scheduled to begin in April, 2021, to coincide when the grantees start providing and collecting data on program services. The rapid cycle work will take approximately one year to complete and is meant to inform possible future impact evaluation studies with this grantee cohort, whose grants end in September, 2025.


A1. Necessity for Collection

Capacity- and evidence- building efforts have produced a growing body of evidence on the effectiveness of federally funded Responsible Fatherhood programs. However, these activities have repeatedly shown that Responsible Fatherhood and similar programs face challenges recruiting fathers, enrolling them in services, and keeping them actively engaged in services, which in turn make obtaining rigorous evidence on program effectiveness more difficult. To address these challenges, the overall Strengthening the Implementation of Responsible Fatherhood Programs (SIRF) project will use an iterative learning method (that is, rapid cycle evaluation) to test promising practices to address critical implementation challenges in Responsible Fatherhood programs. To do so, researchers have identified common implementation challenges and potential solutions and have identified Responsible Fatherhood programs to undertake iterative learning activities. The next steps for this project include working with sites on iterative learning activities to help strengthen implementation and build their capacity for summative evaluation.


This information request, described in more detail below, is necessary to understand how each intervention is implemented in the ten participating programs and to determine fidelity to the interventions being tested. This project will also analyze available performance data that will be collected by federal Responsible Fatherhood grantees through the Information, Family Outcomes, Reporting, and Management (nFORM) system, which is a requirement for federal grantees. The nFORM data collection is described in a separate information collection request (ICR title: Healthy Marriage and Responsible Fatherhood Performance Measures and Additional Data Collection1). Thus, using nFORM data for the SIRF study presents no additional burden for these sites that are federal grantees. However, one participating site is not a federal Responsible Fatherhood grantee, so this information collection request includes burden for a subset of the nFORM data collection instruments for that one site.


There are no legal or administrative requirements that necessitate this collection. ACF is undertaking the collection at the discretion of the agency.



A2. Purpose

Purpose and Use

This proposed information collection meets the following goals of ACF’s generic clearance for formative data collections for program support (0970-0531) to obtain information about program and grantee processes and to inform activities such as:

  • Delivery of targeted assistance and workflows related to program implementation or the development or refinement of program and grantee processes, and the development and refinement of recordkeeping and communication systems.

  • Planning for provision of programmatic or evaluation-related training or technical assistance (T/TA).

  • Use of rapid-cycle testing activities to strengthen programs in preparation for summative evaluation.



This information collection request will enable the project to collect information that will help determine how the SIRF interventions are being implemented within the rapid cycle or iterative learning environment. (See Appendix A for more information about the interventions being considered.) It will allow the SIRF study team to assess how well the interventions were implemented and whether there were any implementation problems. This will also inform the SIRF study team’s technical assistance to the SIRF programs to strengthen their interventions. This information will be critical in helping the SIRF study team decide how to iterate and what to test in the subsequent round of rapid cycle testing. It will also be critical in helping the SIRF study team understand the results of the tests – specifically helping the SIRF study team better understand the intervention that produced the results. This information collection request also includes the collection of baseline characteristics, enrollment, and participation data, as well as details about program operations through nFORM from a fatherhood program that is not a Responsible Fatherhood grantee. This will allow the project to learn and share lessons about a broader set of fatherhood programs.


The results from SIRF are intended to inform future large-scale impact evaluations of programs by providing insights about ways to improve recruitment, enrollment, and retention.


The information collected is meant to contribute to the body of knowledge on ACF programs. It is not intended to be used as the principal basis for a decision by a federal decision-maker and is not expected to meet the threshold of influential or highly influential scientific information.


Research Questions or Tests

Study activities outlined in this ICR seek to answer the following research questions from ten sites through written documentation, semi-structured discussions with staff and fathers, program observations, and data entry into the nFORM performance measures data collection system (for one site):

  1. What did it take for programs to implement the interventions within iterative learning (rapid) cycles? 

  2. Was the intervention being implemented well? What is the program doing to improve implementation of the intervention or its outcomes?

  3. What was the context within which the intervention was implemented, and how did it influence the fidelity or quality of implementation?

  4. What did staff think about the interventions tested? What did fathers think about the interventions tested? 

  5. What effect did the tested intervention have on program enrollment, participation, and retention?


Study Design

To answer the research questions, the study will use multiple data collection methods. The eight main components of data collection are outlined in Table 1, below.


  • Learning Cycle Managers at each site, who are the primary liaisons with the SIRF study team and coordinators of learning cycle implementation, will be asked to conduct observations of the iterative learning intervention (Instrument #1) when appropriate; not all interventions will be appropriate for observation. The purpose of observations is to assess staff fidelity to the interventions that are the subject of the SIRF study. The frequency of observation will depend on the intervention but will occur at least once per learning cycle. Observation findings will be shared with the SIRF study team and may also be used by the Learning Cycle Manager to frame professional development conversations with the staff person being observed.

  • Learning Cycle Managers and select line staff at each site will be asked to submit electronic written documentation reflecting on how the intervention went in the learning cycle (Instrument #2). This represents the beginning of the reflection process for the program in anticipation of making decisions with the SIRF study team about how to adjust the intervention approach for the next learning cycle. The written documentation will be submitted directly to the SIRF study team using Qualtrics.

  • Fathers will also be asked to reflect on their participation in the fatherhood program; their experiences will also inform the programs’ reflection process (Instrument #3). The frequency of soliciting fathers’ feedback will depend on the SIRF intervention being tested and the length of services for each cohort at each program site. Responses will also be collected using Qualtrics.

  • Toward the end of the SIRF study period the SIRF study team will ask to hold semi-structured discussions with program front line staff and managers at each program to gain additional insight into how each intervention was implemented, the context within which it was implemented, experience with the learning cycles and decision-making processes, and lessons from the experience (Instrument #4). These discussions will last approximately one hour each; they may be held in-person or remotely and may be individually or in small groups.

Toward the end of the SIRF study period the SIRF study team will ask to hold semi-structured discussions with fathers at each program to gain insight into the father’s experience in the program and to better understand how the iterative learning interventions influenced their participation in the program (Instrument #5). These conversations will last approximately one hour each; they may be held in-person or remotely and may be in small groups or individually.

  • Finally, we will ask one non-grantee site to collect data on applicant characteristics (Instrument #6), service delivery (Instrument #7), and program operations (Instrument #8) in the nFORM performance measures data collection system. This ICR includes burden to cover the site’s use of nFORM. The instruments associated with this burden (the Applicant Characteristics Survey, data entry fields to collect program information on enrollment, participation, and retention, and Program Operations Survey) are included in the Healthy Marriage and Responsible Fatherhood Performance Measures and Additional Data Collection OMB ICR package (ICR Ref #202102-0970-014).



Table 1. Description of Data Collection Activities and Instruments

Data Collection Activity

Instrument(s)

Respondent, Content, Purpose of Collection

Mode and Duration

Observation of Iterative Learning Intervention Activities

Instrument #1: SIRF Observation

Respondents: Learning Cycle Manager and line staff


Content: Observations will document information about the setting, methods used by the staff member, curriculum and key topics addressed, class/session structure, quality of delivery, participant engagement, strengths, and areas of improvement for staff member being observed.


Purpose: To develop a detailed snapshot of how the interventions are delivered and to assess staff fidelity to interventions that are the subject of SIRF study.

Mode: Learning Cycle manager to complete observation once a week for each staff person involved in the coaching cluster; each line staff across all sites will complete a self-reflection once a week (written observation)


Duration: 1 hour maximum (Learning Cycle Manager); 30 minutes (line staff self-reflection)


Frequency: Once a week

Written Documentation

Instrument #2: SIRF End of Learning Cycle Site Reflections for Staff

Respondents: Learning Cycle Manager and selection of line staff


Content: Topics include:

1) Assessment of implementation during the cycle

2) How challenges were addressed

3) How participants responded to the strategy tested


Purpose: Begin program’s reflection of learning cycle implementation

Mode: Electronic form using Qualtrics


Duration: 15 minutes each per respondent


Frequency: once during each learning cycle throughout the study period

Written Documentation

Instrument #3: SIRF Reflections from Fathers

Respondents: Fathers in each learning cycle


Content: Topics include:

1) Challenges to participating

2) Program’s support of goals

3) How program could better support goals


Purpose: contributes to the program’s reflection of learning cycle implementation

Mode: Electronic form using Qualtrics


Duration: 15 minutes each per respondent


Frequency: depends on SIRF intervention and length of each cohort: Minimum once per father per learning cycle, and maximum two times per father per learning cycle, throughout the study period.

Semi-structured Discussions with Program Staff

Instrument #4: SIRF Staff Semi-Structured Discussion Topics

Respondents: Program Staff (up to 6 program staff per program)


Content: Topics include:

organization and program context, changes made to accommodate SIRF, experience with learning cycles and changes over time, and key lessons or takeaways from the SIRF experience.


Purpose: Learn about the context in which the intervention was implemented, the intervention approach, successes, and challenges of implementing intervention approach, participant response, and opportunity for improvement.

Mode: In-person, Phone or video Call


Duration: 1 Hour


Frequency: once during the study period

Semi-structured Discussions with Fathers

Instrument #5: SIRF Father Semi-Structured Discussion Topics

Respondents: Fathers enrolled in the program (up to 10 fathers per program)


Content: Topics include:

how fathers learned about the program, the enrollment processes, challenges to enroll and how program helped fathers to overcome them, participation in services, challenges to participating, how the program helped fathers to attend.


Purpose: To solicit father input about the interventions being implemented in each site and to learn how programs support fathers to achieve their outcomes.

Mode: In-person, Phone or video Call


Duration: 1 Hour


Frequency: once during the study period

nFORM Burden for non-Grantee - Applicants

Instrument #6: Non-Grantee Use of nFORM’s Applicant Characteristics Survey

Respondents: Program Applicants


Content: Program applicants will be asked information about their demographics, financial well-being, family status, and health and wellbeing. These data will be provided to the SIRF team via de-identified data exports.


Purpose: This data collection would allow SIRF to include a non-grantee in the study, facilitating the team’s collection of baseline information on sample members.

Mode: audio computer-assisted self-interview software (ACASI)


Duration: 15 minutes


Frequency: once during the study period


nFORM Burden for non-Grantee - Staff

Instrument #7: Non-Grantee Use of nFORM – Staff Data Entry

Respondents: Program Staff


Content: Program staff will enter information into nFORM needed to enroll applicants (such as contact information) and information to track their engagement and participation in program services. These data will be provided to the SIRF team via de-identified data exports.


Purpose: This data collection would allow SIRF to include a non-grantee in the study, facilitating the team’s collection of program information on enrollment, participation, and retention – the same information that would be available for grantees in the SIRF study.

Mode: data entry into performance measures data collection system


Duration: 6 minutes per intake process; 2 minutes per service delivery entry


Frequency: Staff will enter information into the nFORM system upon enrollment and on a regular basis to track fathers through their program.

nFORM Burden for non-Grantee – Staff

Instrument #8: Non-Grantee Use of nFORM’s Program Operations Survey

Respondents: Site Administrator


Content: Program staff document strategies used to market and recruit fathers into programs; practices to support and monitor quality; staff qualifications and characteristics; implementation challenges.


Purpose: This data collection would facilitate SIRF’s collection of consistent information about program operations across all sites in the study, including the non-grantee.

Mode: data entry into performance measures data collection system


Duration: 19.2 minutes per response


Frequency: Quarterly


Other Data Sources and Uses of Information

The SIRF study team will use information from nFORM, (as noted above, the nFORM instruments are currently seeking clearance under another ICR) the management information system used by all federally funded Responsible Fatherhood programs, supported by an ACF contract. Deidentified data from nFORM will be used to inform the study team about current program service utilization patterns. Nine of the ten SIRF sites will be Responsible Fatherhood grantees who will be required to use nFORM; using nFORM presents no additional burden for these sites. We are including burden in this request to cover collection of data of applicant characteristics, service delivery, and program operations for a non-grantee.


Additional documentation used for this study may include OFA Responsible Fatherhood grantee applications, existing program-specific documents provided by the study sites, or information from program provider websites. These documents will supplement the information we gather from the data sources described in this request.



A3. Use of Information Technology to Reduce Burden

This study will use information technology, when possible, to minimize respondent burden and to collect data efficiently. For example, a simple electronic form will collect reflection responses from program staff and fathers at each site once per learning cycle. To the extent possible, discussions with program staff and fathers will be done via telephone or video conference calling to reduce burden on the respondents.



A4. Use of Existing Data: Efforts to reduce duplication, minimize burden, and increase utility and government efficiency

This project is relying almost exclusively on existing data to measure outcomes, which in turn will minimize burden to programs. Specifically, outcomes – such as measures of initial engagement in and retention over time in fatherhood services – will be pulled from the nFORM system (which is already in use by nine of the 10 SIRF sites, as noted above). The SIRF team will ask the one non-grantee to enter only minimal information into nFORM to minimize any possible duplicate data entry with the provider’s primary management information system.


In this information collection request, the SIRF study team is seeking approval from OMB to collect data specifically to understand how SIRF interventions are implemented and to determine whether the SIRF interventions are being implemented as intended. When possible, the study team will seek to embed questions from instruments #1, #2, or #3 into a program providers’ existing continuous quality improvement (CQI) or local evaluation efforts to avoid duplicating established feedback loops.


We will avoid undue burden by only speaking to those program staff with experiences with the learning cycle intervention that can inform our understanding of implementation. Further, each discussion will be tailored to each respondent considering information we have already gathered from other discussions or other data sources. A limited number of fathers will be engaged in discussions and the questions asked of them will also be informed by other information the SIRF study team already has.



A5. Impact on Small Businesses

Some of the ten (10) sites that will be part of SIRF are small community-based organizations. To minimize the burden of the study on program staff, SIRF will provide resources for each site to hire a Learning Cycle Manager. This staff person will be the SIRF team’s main contact at the site and will support study functions including data collection efforts such as this one. Furthermore, burden will be minimized for respondents by restricting the length of each discussion and by conducting discussions at times convenient to the respondents. Discussions may also take place over telephone or video conferencing rather than in-person, which is an additional burden relief.



A6. Consequences of Less Frequent Collection

The SIRF study team aims to collect information only as frequently as needed to achieve the aims of the study. The SIRF study team is minimizing the request of information for programs in each cycle and is only planning to conduct semi-structured discussions one time with each site during the study period. Eliminating any of the proposed data collection items would compromise our ability to address key research questions.



A7. Now subsumed under 2(b) above and 10 (below)



A8. Consultation

Federal Register Notice and Comments

In accordance with the Paperwork Reduction Act of 1995 (Pub. L. 104-13) and Office of Management and Budget (OMB) regulations at 5 CFR Part 1320 (60 FR 44978, August 29, 1995), ACF published two notices in the Federal Register announcing the agency’s intention to request an OMB review of this information collection request. The first notice was published on October 13, 2020, Volume 85, Number 198, page 64480, and provided a sixty-day period for public comment. The second notice published on December 28, 2020, Volume 85, Number 248, page 84343, and provided a thirty-day period for public comment. ACF did not receive any substantive comments.


Consultation with Experts Outside of the Study

A panel of experts in the fatherhood field (including both practitioners and researchers) provided guidance to the study team and ACF during the earlier phase of the project. The purpose of engaging subject matter experts was to supplement the knowledge of the project team as it developed a list of priorities for implementation challenges to address and promising approaches to address them, as well as methodological issues related to the study design.


The team had Cynthia Osborne (Associate Dean for Academic Strategies; Director, Center of Health and Social Policy; Director, Child and Family Research Partnership; Director, Prenatal-to-Three Policy Impact Center, University of Texas, Austin) and David Pate (Chair and Associate Professor, School of Social Work, University of Wisconsin) review the instruments included in this data collection request.



A9. Tokens of Appreciation

Small tokens of appreciation – by way of $20 gift cards – will be offered to fathers participating in a 60-minute semi-structured focus group or interview. Focus group and interview data are not intended to be representative in a statistical sense, in that they will not be used to make statements about the prevalence of experiences in responsible fatherhood programs. However, it is important to secure participants with a range of background characteristics to capture a variety of possible experiences in responsible fatherhood programs. Without offsetting the direct costs incurred by respondents for attending the focus groups, such as arranging child care or transportation, the research team increases the risk that only individuals able to overcome financial and time barriers to attend will participate in the study. Participants will receive a $20 gift card to account for incidental expenses such as transportation and/or child care that may otherwise prevent their participation. We believe $20 is a reasonable amount for the time and cost associated with participation in this data collection activity, but is not so high as to appear coercive for potential participants.


A10. Privacy: Procedures to protect privacy of information, while maximizing data sharing

Personally Identifiable Information

The only personally identifiable information collected will be through audio recordings of interviews. It will be limited to the interviewee’s voice and first name; the only reason for collecting first name is to better engage fathers in dialogue throughout the interview. Data collected from the nFORM management information system that Responsible Fatherhood grantees are required to use will not include any personally identifiable information. Information will not be maintained in a paper or electronic system from which data are actually or directly retrieved by an individuals’ personal identifier.


Assurances of Privacy

Information collected will be kept private to the extent permitted by law. Respondents will be informed of all planned uses of data, that their participation is voluntary, and that their information will be kept private to the extent permitted by law. As specified in the contract, the Contractor will comply with all Federal and Departmental regulations for private information.


Data Security and Monitoring

As specified in the contract, the Contractor shall protect respondent privacy to the extent permitted by law and will comply with all Federal and Departmental regulations for private information. The Contractor, MDRC is committed to maintaining the security of sensitive data. MDRC adheres to FedRAMP and FISMA standards (per NIST SP 800-53 revision 4) regarding the collection, transfer, storage, access, monitoring, and sharing of data. MDRC acquired FedRAMP moderate accreditation and received a FedRAMP moderate Authority to Operate (ATO) in summer 2020. MDRC conducts regular audits and reviews of the software, hardware, vendors, network configuration, and data stored on its network. MDRC systems primarily operate on the cloud and control implementation follows the guidance prescribed by FedRAMP for Software-as-a-Service (SaaS) Cloud Service Providers (CSPs).


MDRC’s security procedures include the following:

  1. Access to information on a need-to-know basis, supported by multi-factor authentication factors.

  2. End-to-end encryption, in-transit and at-rest, using TLS 1.2+ and AES256 via FIPS 140-2 modules for systems integrity, systems and communications protection, and media protection.

  3. Continuous monitoring of application and transport-level traffic for inbound and outbound flows

These are supplemented by 1) employee nondisclosure agreements and annual data security training, 2) IT support teams well-versed in cyber security, and 3) policies for responding to data security incidents.


A11. Sensitive Information 2

There are no sensitive questions in this data collection.


A12. Burden

Explanation of Burden Estimates

The estimated annual burden for this information collection request is 3,232 hours. This effort includes observations or self-reflections of the SIRF intervention, semi-structured discussions with staff and fathers, written reflections (web-based) from staff and fathers. Burden is also included for the one non-federally funded program’s use of nFORM to collect baseline characteristics, enrollment, and participation data, and program operations information. Each source of burden is detailed below in Table 2.


Estimated Annualized Cost to Respondents


This information collection request will include two types of respondents: program staff and fathers. The hourly wage rate for each type of respondent was calculated using the following criteria:3

  • Program Staff: According to the Bureau of Labor Statistics’ Current Population Survey 2020, the median weekly earnings for full-time employees age 25 and over with a bachelor’s degree is $1355. We assume a full-time work week for program staff is 40 hours per week. Therefore, the estimated hourly wage is $33.88.4

  • Fathers: The average hourly wage of program applicants is based on the federal minimum wage ($7.25).


Table 2. Total Burden Under this Information Request


Instrument

Respondent

No. of Respondents (total over request period)

No. of Responses per Respondent (total over request period)

Avg. Burden per Response (in hours)

Annual/ Total Burden (in hours)

Average Hourly Wage Rate

Total Annual Respondent Cost


Instrument #1: SIRF Observation

Learning Cycle Manager and Program Staff

69

55

.6

2,277

$33.88

$77,144.76


Instrument #2: SIRF End of Learning Cycle Site Reflections

Program Staff

60

4

0.25

60

$33.88

$2,032.80

Instrument #3: SIRF Reflections

Fathers

774

2

0.25

387

$7.25

$2,805.75


Instrument #4: SIRF Staff Semi-Structured Discussion Topics

Program Staff

60

1

1

60

$33.88


$2,032.80


Instrument #5: SIRF Program Participant Semi-Structured Discussion Topics

Fathers

100

1

1

100

$7.25

$725.00


Instrument #6: Non-Grantee Use of nFORM’s Applicant Characteristics Survey

Fathers

400

1

0.25

100

$7.25

$725.00


Instrument #7: Non-Grantee Use of nFORM – Staff Data Entry

Program Staff

3

1,334

0.04

160

$33.88

$5,420.80


Instrument #8: Non-Grantee Use of nFORM’s Program Operations Survey

Program staff

10

4

.32

13

$33.88

$440.44


Total


1,476


3.71

3,157

$191.15

$91,327.35



A13. Costs

There are no additional costs to respondents.


A14. Estimated Annualized Costs to the Federal Government


Cost Category

Estimated Costs

Instrument Development and OMB Clearance

$37,356.00

Field Work

$ 629,918.49

Publications/Dissemination

$0

Total costs

$667,274.49



A15. Reasons for changes in burden

This is for an individual information collection under the umbrella formative generic clearance for program support (0970-0531).



A16. Timeline

Information collection activities will begin in April 2021 (pending OMB approval) and continue until September 30, 2022.



A17. Exceptions

No exceptions are necessary for this information collection.

Attachments

Instrument #1 SIRF Observation

Instrument #2 SIRF End of Learning Cycle Reflections for Staff

Instrument #3 SIRF Reflections from Fathers

Instrument #4 SIRF Staff Semi-Structured Discussion Topics

Instrument #5 SIRF Father Semi-Structured Discussion Topics

Instrument #6 Non-Grantee Use of nFORM’s Applicant Characteristics Survey

Instrument #7 Non-Grantee Use of nFORM – Staff Data Entry

Instrument #8 Non-Grantee Use of nFORM’s Program Operations Survey

Appendix A_About SIRF Interventions and Sites

Appendix B_Information for staff to tell fathers about opportunities to provide input

Appendix C_Postcard for fathers about opportunity to provide input

Appendix D_Outreach to program staff to schedule semi-structured interview time

Appendix E_Outreach to fathers to schedule semi-structured interview time

Appendix F_Meeting topics for program staff

Appendix G_ SIRF Project Description (has already been approved as part of package #2)

1 ICR Ref #202102-0970-014

2 Examples of sensitive topics include (but not limited to): social security number; sex behavior and attitudes; illegal, anti-social, self-incriminating and demeaning behavior; critical appraisals of other individuals with whom respondents have close relationships, for example, family, pupil-teacher, employee-supervisor; mental and psychological problems potentially embarrassing to respondents; religion and indicators of religion; community activities which indicate political affiliation and attitudes; legally recognized privileged and analogous relationships, such as those of lawyers, physicians and ministers; records describing how an individual exercises rights guaranteed by the First Amendment; receipt of economic assistance from the government (for example, unemployment or WIC or SNAP); immigration/citizenship status.

3 The sources of hourly wage rate data for program staff for this package are different from what is used in other recent OMB packages, such as the new nFORM package and STREAMS. For example, the new nFORM package uses the Bureau of Labor Statistics’ May 2019 National Occupational Employment and Wage Estimates for Social and Community Service Managers to estimate program staff wages.

4 U.S. Department of Labor, Bureau of Labor Statistics. (2020). News Release: Usual Weekly Earning of Wage and Salary Workers Third Quarter 2020. Retrieved from https://www.bls.gov/news.release/wkyeng.htm.

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