OMB NSOAAP Memo TOC 2022 ER Module

DEPARTMENT OF HEALTH & HUMAN SERVICES

Administration for Community Living
Washington, D.C. 20201

To:

Julie Wise, OIRA
Desk Officer for ACL

Through:

Tomakie Washington
ACL PRA Portfolio Manager

From:

Vicki Gottlich, Esq.
Director, Center for Policy and Evaluation

Re:

Non-Substantive Modifications to the Information Collection Tools for the National
Survey of Older Americans Act Participants (NSOAAP) OMB 0985-0023

Date:

28 April 2022

Vicki Gottlich
-S

Digitally signed by Vicki
Gottlich -S
Date: 2022.04.28 16:42:50
-04'00'

In summary, ACL has submitted a 30-Day FRN for the addition of a rotating module on Emergency
Preparedness to be added to the 16th NSOAAP. The purposes of this memo are to alert OMB to a)
changes to the information collection instruments that include the integration of the questions on
malnutrition and food insecurity in response to the Terms of Clearance listed in the 5/25/21 NOA and
b) emergency preparedness module non-substantive changes to the information collection
instruments (OMB Control Number: 0985-0023).
On May 25, 2021, OPE received Paperwork Reduction Act approval for an extension of the approved
information collection “National Survey of Older Americans Act Participants” which included a
rotating module on COVID-19 (OMB Control Number: 0985-0023). The Terms of Clearance state:
Approval is granted for the 15th National Survey. In future updates to the collection, we look forward
to seeing survey improvement specifically in the areas of malnutrition and gender identity. We
understand that survey redesign scheduled to take place for the 2023 NSOAAP may include
malnutrition updates, while testing of gender identity questions may begin as early as 2022.
On March 31, 2022, ACL published a 30-day FRN (Vol. 87, No. 62) for a rotating module on
Emergency Preparedness. ACL remains compliant with the remainder of the Terms of Clearance.
Currently ACL leadership is in discussion on best measures to adhere to the remainder of the TOCs
regarding testing of gender identity questions. ACL intends to update this and any information
collections containing gender identity classification/standards based on leaderships determined
approach; the anticipated timeframe for this determination is pending (see below).
Anticipated Timelines Related to the Terms of Clearance
Table 1 outlines ACL’s timing and actions related to the Terms of Clearance for the NSOAAP.
Table 1
PRA
Package
Currently
Approved
Information
Collection
Instrument to

Action

Date

ACL submitted PRA package for extension of an approved
information collection instrument, addition of rotating module,
and non-substantive modifications to the collection instrument.
The 60-day FRN included the Emergency Preparedness
Rotating Module. Due to the ongoing COVID-19 pandemic,

4/6/21

be collected
2021-2023

Next 3-year
Information
Collection
Instrument to
be collected
2024-2026

ACL decided to supplant the Emergency Preparedness
Rotating Module with a Rotating Module on COVID-19. The
30-day FRN included the COVID-19 Rotating Module.
OMB approved with change (OMB Control Number: 09850023, expires 5/31/2024)
ACL collected information with collection instrument and
COVID-19 Rotating Module.
ACL published a 30-day FRN for Rotating Module on
Emergency Preparedness and non-substantive modifications to
the collection instrument.
Anticipated OMB approval of Rotating Module on Emergency
Preparedness and non-substantive modifications to the
collection instrument
ACL collects information with collection instrument and
Emergency Preparedness Rotating Module
ACL submits PRA package for 30-day FRN for new Rotating
Module TBD and non-substantive modifications to the
collection instrument.
Anticipated OMB approval of new Rotating Module TBD and
non-substantive modifications to the collection instrument
ACL collects information with collection instrument and new
Rotating Module TBD.
ACL submits PRA package for next 3-year clearance package
with new Rotating Module TBD.
Anticipated OMB approval of next 3-year clearance package
ACL collects information with collection instrument and new
Rotating Module TBD

5/25/21
Summer 2021
3/31/22

Anticipated
5/20/22
Summer 2022
Anticipated
12/1/22
Anticipated
3/1/23
Summer 2023
Anticipated
4/1/23
Anticipated
1/1/24
Summer 2024

Rotating Module
The first rotating module on ‘The Effect of COVID-19 on Access to and Use of Older Americans Act
Programs and Services’ was added to the 2021 NSOAAP. This module supplanted the module on
‘Emergency Preparedness’ that was included in the 60-day FRN due to the health crisis older adults
were experiencing as a result of COVID-19. The Emergency Preparedness module is now included
as part of the 2022 collection instrument. Per correspondence with OMB dated January 14, 2020,
below is ACL’s justification for why Emergency Preparedness is of particular interest to ACL as well
as how it was identified as a priority for inclusion in the NSOAAP.
Older adults often have unique needs during an emergency or crisis. For example, they may have
mobility challenges and/or chronic health conditions, or they may not have any family or friends
nearby to support them. Support services that an older adult relies on to live at home, such as help
from family caregivers, in-home health care, and home delivered meals, may be unavailable due to
an emergency disaster. These conditions increase a person’s vulnerability and may lead to nursing
home care that may have been otherwise avoidable. In addition, older adults may be hearing or vision
impaired or have a cognitive impairment such as dementia, which may make it difficult to access and
respond to emergency directions. The purpose of adding questions on emergency preparedness to the
NSOAAP is to measure the extent to which older adults have received training on, and are prepared
for, an emergency event.

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Summary of Malnutrition and Food Insecurity TOC Changes

As part of the 2021 PRA package review process, ACL received public comments from researchers
and advocacy organizations about the ability of the survey to accurately measure food insecurity and
malnutrition for OAA clients. The nature and number of these comments resulted in OMB stating in
its Notice of Action (NOA) dated 5/25/2021 that they “look forward to seeing survey improvements
specifically in the areas of malnutrition...” ACL convened a NSOAAP Nutrition Technical Expert
Panel (TEP) during the winter of 2021-2022 to advise and reach consensus on recommendations to
ACL for survey questions related to malnutrition and food insecurity for future NSOAAPs.
Based on recommendations from the Nutrition TEP, three questions on food insecurity were added to
the information collection to complete the six item USDA food insecurity measure. In addition, the
existing malnutrition question was expanded and revised to become the Malnutrition Screening Tool
(MST). Two additional questions on malnutrition were added to better understand the risk of
malnutrition. (See Table 2)
Table 2
ORIGINAL QUESTION

REVISED QUESTION

Malnutrition
The question below was revised to become the
Malnutrition Screening Tool (MST) which is a
standardized item set recommended by the
Nutrition TEP.
In the past 12 months, have you lost or gained
weight without trying to lose or gain weight?
Would you say…
Yes, I gained 10 pounds or more,
Yes, I gained less than 10 pounds,
No, I stayed the same,
Yes, I lost 10 pounds or more
Yes, I lost less than 10 pounds?
YES, BUT I TRIED TO LOSE OR GAIN WEIGHT

Have you recently lost weight without
trying?
These three questions comprise the
If yes, how much weight have you lost? (2Malnutrition Screening Tool (MST)
13 lb, 14-23 lb, 24-33 lb, 34 lb or more,
Unsure)
Have you been eating poorly because of a
decreased appetite?
Have you recently gained weight without
These two questions were added to better
trying?
understand risk of malnutrition.
How much weight have you gained? Enter
number said ____ pounds
Food Insecurity
Three additional questions were added to the
In the last 12 months, did you ever eat less
three existing food insecurity questions (listed than you felt you should because there
below) to complete the USDA 6-item food
wasn't enough money for food?

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insecurity measure which was recommended
by the Nutrition TEP.

In the last 12 months, were you ever hungry
but didn't eat because there wasn't enough
money for food?

The food that we have just didn’t last and we
didn’t have money to get more. Was that often,
sometimes, or never true for your household in
the last 12 months?
We couldn't afford to eat balanced meals. Was
that often, sometimes, or never true for your
household in the last 12 months?

How often did this happen? Was it almost
every month, some months but not every
month, or in only 1 or 2 months?

In the last 12 months, since last (name of
current month), did you ever cut the size of your
meals or skip meals because there wasn't
enough money for food?

Summary of Non-Substantive Changes
Changes to the Collection Instruments

Table 3 includes the non-substantive modifications that were made to the information collection
instruments – column 1 is the original presentation and column 2 is the modified.
Table 3
ORIGINAL QUESTION
In the last year, have you found financial help
for the care recipient including helping
him/her apply for Medicaid?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending for
vacations or travel?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut down on your own spending for
groceries?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending on health
care or dental care?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending for basic
home maintenance?

REVISED QUESTION
In the last year, have you needed assistance
with applying or accessing other
programs or services for the care
recipient or yourself?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending for
vacations or travel, entertainment, going
out, or other leisure activities?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut down on your own spending for
groceries or meals?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending on health
care, dental care, or prescription medicine?
As a result of caregiving-related changes in
your employment or expenses, have you had
to cut back on your own spending for
household expenses and maintenance?

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Table 3
ORIGINAL QUESTION

Do you have any recommendations to improve
the caregiver support service? If yes, what
recommendations do you have for improving
service?

In the last year, have you paid for care
recipient's medications or medical care?
In the last year, have you paid for care
recipient's insurance premiums or
copayments?
In the last year, have you paid for care
recipient's mobility devices, such as walkers,
canes, or wheelchairs?
In the last year, have you paid for features that
have made the care recipient's home safer?
In the last year, have you paid for any other
assistive devices that make it easier or safer
for the care recipient to do activities or do
them on his/her own?
Do you live with your children?
The food that I bought just didn’t last, and I
didn’t have money to get more. Was that often,
sometimes, or never true for you in the last 12
months?
I couldn’t afford to eat balanced meals. Was
that often, sometimes, or never true for you in
the last 12 months?

In the past 12 months, have you been to see a
doctor? Do not include going to the hospital
emergency department.

REVISED QUESTION
What main recommendations do you have
for improving caregiver support services
you have received? What is the main area
that needs improving: 1) Information
about Available Services, 2) Assistance
Gaining Access to Services, 3) Caregiver
Education/Training, Individual
Counseling, and Support Groups, 4)
Respite Care, 5) other Supplemental
services, and 6) OTHER (something else).
In the last year, have you used your own
money to pay for care recipient's
medications or medical care?
In the last year, have you used your own
money to pay for care recipient's insurance
premiums or copayments?
In the last year, have you used your own
money to pay for care recipient's mobility
devices, such as walkers, canes, or
wheelchairs?
In the last year, have you used your own
money to pay for features that have made
the care recipient's home safer?
In the last year, have you used your own
money to pay for any other assistive devices
that make it easier or safer for the care
recipient to do activities or do them on
his/her own?
Do you live at the home of one of your
children? Do one or more of your children
live with you?
The food that we have just didn’t last and we
didn’t have money to get more. Was that
often, sometimes, or never true for your
household in the last 12 months?
We couldn't afford to eat balanced meals.
Was that often, sometimes, or never true for
your household in the last 12 months?
In the past 12 months, have you been to see a
doctor or gone to an urgent care center?
Do not include going to the hospital
emergency department.
In the past 12 months, have you ever
missed or delayed routine doctor visits
because of your caregiving situation?

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Table 3
ORIGINAL QUESTION
{Have you/Has the care recipient? received flu
shots, pneumonia shots, or other
immunizations other than those from his/her
own doctor?
In the past year {have you/has NAME OF
PARTICIPANT} {has CARE RECIPIENT}
received meals from the meals program?
In the past year, {have you/has the care
recipient} received chore services?

REVISED QUESTION
{Have you/Has the care recipient? received
flu shots, pneumonia shots, COVID
vaccination, or other immunizations?
In the past year {have you/has NAME OF
PARTICIPANT} {has CARE RECIPIENT}
received meals or other food from the meals
program?
In the past year, {have you/has the care
recipient} received heavy chore services,
such as washing windows, yardwork, or
shoveling snow?

Cc: Amanda Cash, Director Office of Performance and Evaluation

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