HS2EHS Supporting Statement A_June

Alternative Supporting Statement for Information Collections Designed for

Research, Public Health Surveillance, and Program Evaluation Purposes

Study on the Conversion of Enrollment Slots from Head Start to Early Head Start (HS2EHS Study)

OMB Information Collection Request

0970 – New Collection

Supporting Statement

Part A

June 2022

Submitted By:

Office of Planning, Research, and Evaluation

Administration for Children and Families

U.S. Department of Health and Human Services

4^th Floor, Mary E. Switzer Building

330 C Street, SW

Washington, D.C. 20201

Project Officer:

Jenessa Malin

Part A

Executive Summary

• Type of Request: This Information Collection Request is for a new information collection. We are requesting 1 year of approval.

• Description of Request:

This is a primary data collection request to examine, using a qualitative multi-case study, how and why Head Start grant recipients convert enrollment slots from Head Start to Early Head Start, how grant recipients plan and implement Early Head Start services, and the facilitators and barriers to the implementation of high-quality Early Head Start services following conversion. The study will include up to six cases, each focusing on a specific grant recipient. This study aims to present an internally valid description of the conversion process for up to six purposively selected grant recipients, not to promote statistical generalization to different grant recipients or service populations.

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

A1. Necessity for Collection

Converting enrollment slots from Head Start to Early Head Start (i.e., shifting funding from services for Head Start preschool-age children to Early Head Start services for pregnant women, infants, and toddlers) necessitates strategic planning and the careful development and implementation of new processes to ensure high quality service delivery tailored to the unique needs of pregnant women, infants, and toddlers and delivered in accordance with the Head Start Program Performance Standards¹. Little is known about why grant recipients convert enrollment slots, what the conversion process entails, and what barriers and facilitators exist for grant recipients to effectively and efficiently convert enrollment slots. This proposed study will provide much needed information to the Office of Head Start, ACF-funded training and technical assistance (T/TA) providers, and Head Start grant recipients about the conversion process as well as about facilitators and barriers to successfully convert enrollment slots and to provide high-quality Early Head Start services to infants, toddlers, and pregnant women.

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

The purpose of this information collection is to conduct qualitative research (a multi-case study) with up to six grant recipients to address key gaps in the existing knowledge base about the conversion of enrollment slots from Head Start to Early Head Start. Specifically, this study will collect information about (a) how and why each grant recipient converted enrollment slots from Head Start to Early Head Start; (b) planning for and implementation of high-quality Early Head Start services following conversion; and (c) barriers and facilitators to the provision of high-quality Early Head Start services that meet community needs. We will also collect information about the state and local early care and education (ECE) context and community need for Early Head Start services.

Findings from this study are intended to identify promising practices and lessons learned in the conversion of enrollment slots from Head Start to Early Head Start. This information can help both those who work with grant recipients during the conversion process and grant recipients themselves, who are ultimately responsible for implementing conversions and delivering high quality Early Head Start services following conversion. Notably, results are intended to support ACF in its efforts to improve the quality of care for infants and toddlers in Early Head Start settings. Findings will be shared in public-facing products such as a reports, briefs, and presentations that are targeted to federal staff, Head Start grant recipients, ACF-funded Training and Technical Assistance providers, and researchers.

We will purposively select grant recipients that vary on key elements of implementation. More details about the purposive selection criteria are available in Section B2 of Part B under Respondent Recruitment and Site Selection.

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

Table 1. Research Questions

Phase of Conversion	Research Questions
Motivation	What motivates grant recipients to prepare for and convert slots?
Application	What facilitates a successful conversion application?
Preparation	How do grant recipients plan for Early Head Start (EHS) service implementation?
Post Conversion Implementation	To what extent are grant recipients successful at implementing high-quality EHS services following conversion?

Research sub-questions are included in Appendix A.

Study Design

Data collection will consist of gathering qualitative data from up to six purposively selected grant recipients (i.e., cases). We will select grant recipients that had a conversion application approved between 12 -18 months prior to the beginning of data collection. We anticipate collecting data in the fall and winter of 2022, pending OMB approval.

During data collection, we will conduct qualitative, semi-structured interviews with up to 100 people across up to six grant recipients who were involved with implementing the conversion. Additional information about the participants that we will interview is available in Section B2 of Part B under Target Population. We will purposively select respondents to ensure they bring the range of perspectives needed to fully address the study’s research questions. We will also gather documents relevant to the conversion process, including grant recipients’ application materials from the Head Start Enterprise System (HSES).

To identify grant recipients for participation in this data collection, we will start by compiling information from HSES to develop a list of grant recipients that meet all initial eligibility criteria. We will also request nominations of grant recipients with promising approaches to conversion from federal staff via email. Using this information, we will purposively select up to six grant recipients, as well as identify three backup grant recipients.

More information about how we will identify potential grant recipients, narrow the pool of grant recipients to up to six, and make final grant recipient selections is available in Section B2 of Part B, under Respondent Recruitment and Site Selection.

We will have a purposive sample and qualitative approaches to collecting data, as these methods provide the flexibility needed to fully capture grant recipients’ diverse experiences with conversion. The study’s key potential limitation is that our cases might not ultimately reflect the full range of experiences converting enrollment slots and, thus, might not entirely address the information needs of the range of ACF and other study stakeholders. This limitation will be acknowledged when sharing findings from the study. More details about the rationale of our study design are available in Section B1 of Part B under Appropriateness of Study.

Table 2. Data Collection Activities

Data Collection Activity	Instruments	Respondent, Content, Purpose of Collection	Mode and Duration
Preparatory Data Collection	Preparatory Interview with Head Start Directors and Coordinator (Instrument 1)	Respondents: Head Start Director, Coordinator Content: confirm conversion history to determine eligibility for potential grant recipients Purpose: inform selection of the final set of grant recipients	Mode: Virtual (i.e., phone, video) Duration: 60 minutes
Preparatory Data Collection	Preparatory Email Request (Instrument 2)	Respondents: Head Start Director Content: potential grant recipients- and respondents Purpose: inform selection of the final set of grant recipients and identify respondents within those grant recipients	Mode: Email Duration: 30 minutes
Data Collection	Full Interview for Head Start Staff and T/TA Staff Protocol (Instrument 3)	Respondents: Administrative staff (this may include the director, finance director, HR director, policy council representative, community partnership coordinator; facilities manager); Practitioner staff (this may include the education director, Eligibility, Recruitment, Selection, Enrollment, and Attendance director, teachers, family service manager, disability service coordinator); T/TA Staff (this may include national T/TA, regional T/TA network, local grant recipient T/TA) Content: motivation for conversion, involvement in the conversion process, preparation and implementation of EHS services (each respondent will receive a subset of the questions OR select modules relevant to their role) Purpose: understand the process of conversion (beginning to end) from the Head Start perspective	Mode: Virtual (i.e., phone, video) Duration: 90 minutes
Data Collection	Full Interview for Non-Head Start Staff Protocol (Instrument 4)	Respondents: state or local ECE leaders and/or community partners Content: supply of ECE, systems coordination and challenges Purpose: understand the greater community context re: the supply of ECE and the successes and challenges of ECE system coordination	Mode: Virtual (i.e., phone, video) Duration: 90 minutes

Other Data Sources and Uses of Information

We will select potential grant recipients using information contained in HSES, an online data platform that houses grant recipient information and application materials.

A3. Use of Information Technology to Reduce Burden

The data collection plan is designed to efficiently obtain information and minimize respondent burden. When feasible, we will gather information from existing data sources like HSES.

We will email respondents to ask them to provide electronic copies of relevant documents to us by email. None of the documents will include personally identifiable information (PII) or other sensitive information. If respondents have any concerns, however, we will suggest they send documents using an encrypted email, or we can provide a secure File Transfer Protocol site.

We will interview people virtually. After we obtain permission from each participant, we will record all interviews to ensure that we capture information accurately at one time point.

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

Our examination of work in this area has not identified other current or planned efforts to examine how and why Head Start grant recipients convert enrollment slots from Head Start to Early Head Start and the facilitators and barriers to the implementation of high-quality Early Head Start services following conversion.

None of the data collection instruments ask for information that can be obtained from alternative data sources (including administrative data). We will use publicly available information and information available in the Program Information Report (PIR) and HSES as much as possible to identify and select potential grant recipients and respondents and complement the information collected. The design of the data collection instruments ensures minimal duplication of data collected across instruments and does so only in cases for which we require the perspective of more than one type of respondent to answer specific research questions.

A5. Impact on Small Businesses

Some of the non-Head Start respondents may be part of small organizations, including community-based organizations and other nonprofits. We will schedule all interviews at times that are convenient for the respondents selected to be interviewed.

A6. Consequences of Less Frequent Collection

This is a one-time data collection.

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 a notice in the Federal Register announcing the agency’s intention to request an OMB review of this information collection activity. This notice was published on April 4, 2022 (87 FR 19519) and provided a sixty-day period for public comment. No comments were received during the notice and comment period.

Consultation with Experts Outside of the Study

We consulted with experts to complement the knowledge and experience of the research team (Table 3). Consultants included those with expertise in Head Start and Early Head Start policies and grant recipient implementation. Consultants provided input on the study’s research questions, types of respondents that would be of value to the study, and the approach to data collection. Throughout the study, we will continue to work with expert consultants.

Table 3. Expert Advisors

Name	Affiliation
Tamara Halle	Child Trends
Cynthia Osborne	Vanderbilt University
Diane Horm	University of Oklahoma at Tulsa
Tom Rendon	Independent Head Start consultant
Stephanie Curenton-Jolly	Boston University
Brenda Jones-Harden	University of Maryland, Baltimore
Dawn Dow	Urban Institute Equity Scholar

A9. Tokens of Appreciation

There are no tokens of appreciation proposed for respondents in this data collection. We propose to offer honoraria, as described in Section A13.

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

Personally Identifiable Information

We will be collecting individual contact information to schedule interviews and send honoraria to program directors to receive on behalf of their programs, coordinators and policy council members (see A13 for more on Honoria). 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

We will inform all respondents of all planned uses of data and that their participation is voluntary. We will also inform respondents that in future reports it may be possible to infer their identity given their positions and the fact that the grant recipients, while not named in our reports, briefs, or other publications, may be identified by an astute reader due to the small sample size. Information about respondents will be kept private (they and their agency or organization will not be acknowledged by name in future reports), and we will tell respondents that their information will be kept private to the extent permitted by law. Interviews for all respondents will be recorded with the permission of the respondents, and no one besides the research team and a transcriptionist will listen to the recording. If respondents want to say anything that they prefer not to be recorded, they can ask the interviewer to pause the recording. Recordings and interview notes will be destroyed after the study. 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 has developed a Data Safety and Monitoring Plan that assesses all protections of respondents’ PII. The Contractor shall ensure that all of its employees, subcontractors, and employees of each subcontractor, who perform work under this subcontract, are trained on data privacy issues and comply with the above requirements. 

As specified in the evaluator’s contract, the Contractor shall use Federal Information Processing Standard compliant encryption (Security Requirements for Cryptographic Module, as amended) to protect all instances of sensitive information during storage and transmission. The Contractor shall securely generate and manage encryption keys to prevent unauthorized decryption of information, in accordance with the Federal Processing Standard.  The Contractor shall: ensure that this standard is incorporated into the Contractor’s property management/control system; establish a procedure to account for all laptop computers, desktop computers, and other mobile devices and portable media that store or process sensitive information. Any data stored electronically will be secured in accordance with the most current National Institute of Standards and Technology requirements and other applicable Federal and Departmental regulations. In addition, the Contractor must submit a plan for minimizing, to the extent possible, the inclusion of sensitive information on paper records and for the protection of any paper records, field notes, or other documents that contain sensitive or PII that ensures secure storage and limits on access.  

A11. Sensitive Information ²

No sensitive information will be requested.

A12. Burden

Explanation of Burden Estimates

Table 4 provides an estimate of time burden for the data collections, broken down by instrument and respondent. Respondents will include up to 9 Head Start Program Directors who will respond to a subset of items in Instrument 1 and respond to Instrument 2; up to 9 Coordinators who will be asked to engage in logistical activities, as described in Appendix E, to coordinate the data collection in collaboration with the research team and also respond to a subset set of items in Instrument 1; up to 30 Head Start Administrative Staff, 22 Head Start Practitioner Staff, and 6 T/TA Staff who will each respond to a subset of items in Instrument 3; and up to 6 leaders in the ECE field and 6 community partners who will each respond to a subset set of items in Instrument 4. More details about how the research team will identify the appropriate subset of items within each instrument for each respondent is available in Section B4 of Part B under Quality and Consistency in Data Collection Activities.

We expect the total annual burden to be 164 hours.

Explanation of Cost Estimates

The research team based average hourly wage estimates for deriving total annual costs on data from the Bureau of Labor Statistics, Occupational Employment Statistics (2021). For each instrument included in Table 4, we calculated the total annual cost by multiplying the annual burden hours by the average hourly wage.

The mean hourly wage of $25.87 for education administrators of preschool and child care centers or programs (occupational code 11-9031) is used for Head Start grant directors, coordinators, and administrative staff of Head Start grant recipients. The mean hourly wage for childcare workers (occupational code 39-9011) of $13.31 is used for Head Start practitioner staff. The mean hourly wage of $55.41 for General and Operations Managers (occupational code 11-1021) is used as a proxy for local ECE leaders. The mean hourly wage of $61.92 for training and development managers (occupational code 11-3131) is used as a proxy for T/TA staff. The mean hourly wage of $24.28 for community and social service specialists (occupational code 21-1099) is used as a proxy for community partners.

Tables from which these wages were drawn are available at the following links:

• Program director/child care administrators: https://www.bls.gov/oes/current/oes119031.htm

• Childcare workers (Head Start practitioners): https://www.bls.gov/oes/current/oes399011.htm

• ECE leaders: https://www.bls.gov/oes/current/oes111021.htm

• T/TA staff: https://www.bls.gov/oes/current/oes113131.htm

• Community Partners: https://www.bls.gov/oes/current/oes211099.htm

Table 4. Estimated Annualized Cost to Respondents

Instrument	No. of Respondents (total over request period)	No. of Responses per Respondent (total over request period)	Avg. Burden per Response (in hours)	Total Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
Coordination Activities (Appendix E)	6	1	3	18	$25.87	$465.66
Preparatory Interview with Head Start Directors and Coordinators (Instrument 1) Directors/ Coordinator	18	1	1	18	$25.87	$465.66
Preparatory Email Request (Instrument 2) Directors	9	1	.5	5	$25.87	$129.35
Full Interview for Head Start Staff and T/TA Staff Protocol (Instrument 3) HS Admin Staff	30	1	1.5	45	$25.87	$1,164.15
Full Interview for Head Start Staff and T/TA Staff Protocol (Instrument 3) HS Practitioner Staff	28	1	1.5	42	$13.31	$559.02
Full Interview for Head Start Staff and T/TA Staff Protocol (Instrument 3) T/TA Staff	12	1	1.5	18	$61.92	$1114.56
Full Interview for Non-Head Start Staff Protocol (Instrument 4) ECE leaders	6	1	1.5	9	$55.41	$498.69
Full Interview for Non-Head Start Staff Protocol (Instrument 4) Community partners	6	1	1.5	9	$24.28	$218.52
Total				164		$4,615.61

A13. Costs

We will offer each of the six grant recipient programs a $300 honorarium to acknowledge their contribution to a timely and complete data collection and to acknowledge their participation in activities that are not requirements of, or supported by, their Head Start grant.

A14. Estimated Annualized Costs to the Federal Government

Table 5. Estimated Cost

Cost Category	Estimated Costs
Field Work	$173,963.40
Analysis	$93,672.60
Publications/Dissemination	$110,001
Total costs over the request period	$377,637

A15. Reasons for changes in burden

This is a new information collection request.

A16. Timeline

Table 6. Estimated Timeline

Activity	Timing
Recruitment
Case selection (including system-level screening)	To begin immediately after OMB’s approval and extend for 2 months
Data collection
Case study interviews	To begin 2 months after OMB’s approval and extend for 5 months
Grant recipient-level screening and interviews	To begin 3 months after OMB’s approval and extend for 6 months
Analysis
Case study analysis	To begin 8 months after OMB’s approval and extend for 3 months
Reporting
Site Specific Memoranda	To begin 4 months after OMB’s approval and extend for 7 months
Multi-case Study Report	To begin 8 months after OMB’s approval and extend for 4 months

A17. Exceptions

No exceptions are necessary for this information collection.

Attachments

Instruments:

Instrument 1: Preparatory Interview with Head Start Directors and Coordinators

Instrument 2: Preparatory Email Request

Instrument 3: Full Interview for Head Start Staff and T/TA Staff Protocol

Instrument 4: Full Interview for Non-Head Start Staff Protocol

Appendices:

Appendix A. Study Research Questions

Appendix B. Recruitment Letter for Head Start Directors (Research Team will send)

Appendix C. Responses to FAQs

Appendix D. Eligibility and Logistics Email to Head Start Directors

Appendix E. Recruitment Letter for Coordinator

References:

Bureau of Labor Statistics, U.S. Department of Labor. “Occupational Employment Statistics.” [www.bls.gov/oes/]. May 2021.

1 OMB #0970-0148

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, e.g., 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 (e.g., unemployment or WIC or SNAP); immigration/citizenship status.

12