Final - Part A_Family Options

Family Options 12-Year Study: Survey Data Collection – Phase II

Part A Supporting Statement for Paperwork Reduction Act

(OMB control number 2528-0259)

Background

The U.S. Department of Housing and Urban Development (HUD) has invested considerable resources into strategies to address family homelessness. Senate Report 109-109 for the FY2006 Transportation, Treasury, Judiciary, HUD, and Related Agencies Appropriations bill directed the Department to focus its energies on families who experience homelessness and to “undertake research to ascertain the impact of various service and housing interventions in ending homelessness for families.” In 2008, HUD launched the Family Options Study, a multi-site experiment designed to test the impacts of different housing and service interventions on families who experience homelessness, in five key domains: housing stability, family preservation, adult well-being, child well-being, and self-sufficiency. The study, conducted by Abt Associates and its partner Vanderbilt University, compared the effect of three active interventions—long-term housing subsidy, community-based rapid re-housing, and project-based transitional housing—to one another and to the usual care available in the study communities.

From September 2010 through January 2012, 2,282 families (with 5,397 children) across 12 communities enrolled in the Family Options Study after spending at least 7 days in emergency shelter. At the time of enrollment families provided their consent to participate in the study and completed a baseline survey (OMB #2528-0259, Expiration Date: 05/31/2013). The study randomized these 2,282 families to one of four interventions distinguished by the type and duration of housing assistance and supportive services. The research team tracked the families for over three years and administered two follow-up surveys to families during that time period under the same OMB control number; a 20-month followup survey (OMB #2528-0259, Expiration Date: 3/31/2015) and a 37-month followup survey (OMB #2528-0259, Expiration Date: 3/31/2017).

Both the design and the scale of the study provided a strong basis for conclusions about the relative impacts of the interventions over time. The outcomes measured the 20- and 37 months after enrollment yielded powerful evidence of the positive impact of providing a long-term rent subsidy to a family experiencing homelessness. It is possible, though, that some effects of the various interventions might change over time or take longer to emerge, particularly for child well-being. In 2017, approximately three years after the 37-month data collection had been completed, HUD conducted participant tracking to re-establish contact with the study sample, update the contact information for all participants, collect additional information on key outcomes of interest, and, ultimately, assess the feasibility of future research efforts (OMB #2528-0259, Expiration Date: 8/31/2020). The success of that tracking effort has motivated HUD to pursue a new wave of primary data collection with the study families.

The Information Collection Request (ICR) for the 12-year data collection for the Family Options Study is being submitted to OMB in two phases. The first ICR, approved in April 2022 (OMB #2528-0259, Expiration Date: 4/30/2025) included the instruments associated with the first phase of data collection—the Tracking and Reengagement Data Collection phase. In this second phase, HUD is seeking approval from OMB for the 12-Year Survey Administration phase, which includes three 12-year survey instruments (adult head of household; child; and adult child); outreach materials to study families, and the informed consent materials to be administered to the study families. Exhibit A-1 depicts the sequencing of the planned data collection for the Family Option Study 12-Year Followup.

Exhibit A-1. Sequencing of Data Collection for the Family Options Study 12-Year Followup

The survey and data collection will ensure meaningful language access for persons with Limited English Proficiency (LEP) so they can fully participate. The surveys will also be translated into Spanish to ensure Spanish-speaking respondents can participate. In addition, as part of the survey and data collection efforts, reasonable accommodations will be made, whenever necessary, for persons with disabilities and researchers will ensure there is effective communication for persons with disabilities as required under Section 504 of the Rehabilitation Act of 1973.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

HUD plans to conduct 12-year data collection with the families who enrolled in the Family Options Study between 2010 and 2012. Through this effort, we will locate the original sample, administer informed consent, and then administer a survey with the adult head of household.¹ We will also survey a sample of minor children (ages 10 – 17) residing with the adult head of household, and attempt to survey a sample of adult children (ages 18 - 30). This sample of adult children is a new sample and is comprised of young adults who were the minor children of study families during the enrollment period and early years of the Family Options Study over a decade ago. The adult Head of Household data collection instrument and the child data collection instrument to be administered during the 12-Year Study largely mirror the surveys that were previously administered to the adults and children enrolled in the Family Options Study with some minor updates (see materials associated with OMB#2528-0259, Expiration Date: 3/31/2017). The sample of adult children, however, is a new collection that was not previously conducted.

This Information Collection Request includes all materials for the 12-Year Survey Administration phase and is the second and final request to be submitted to OMB related to this long-term data collection effort for the Family Options Study.

The survey data collection in this request has three components:

• Adult Head of Household Survey and Supporting Materials

The 12-Year data collection will begin with outreach to the 2,241 study families. Outreach materials will include an advance letter (Adult Head of Household Advance Letter included as Appendix A), an outreach e-mail (Adult Head of Household Outreach E-mail included as Appendix B), and an outreach flyer (Adult Head of Household Outreach Flyer included as Appendix C). After notifying study participants about the new data collection, the study team will contact the adult heads of household and renew their consent to participate in the study (Consent to Participate- Adult Respondent included as Appendix D) in this new data collection effort.

The interviewer will then administer the Adult Head of Household Survey (included Appendix E). In most cases the research team will conduct the interviews by telephone. However, if the research team is unable to complete the interview by phone, the survey may be conducted in-person. See Exhibit A-2 for the topics to be covered in the Adult Head of Household survey.

Exhibit A-2. Adult Head of Household Survey Topics

Housing Stability and History

• Current housing stability

• Experiences of homelessness in the past 6 months, three years, and five-year periods

• Experience with eviction in past five years

• Housing experiences during the COVID-19 pandemic

Family Composition and Preservation

• Information about all family members living with the adult head of household

• Child separations or foster care placements since the beginning of study period

Housing Quality and Affordability

• Housing crowding

• Housing quality

• Number of places stayed

• Current rent burden and utility costs

Employment, Self-Sufficiency, and Economic Hardship

• Current employment and earnings

• Benefit receipt

• Education and training since study enrollment

• Food security

Adult Well-Being

• Current physical and mental health

• Substance use

• Experiences of intimate partner violence

Parent on Child Information

• Younger children

• Enrollment in school, number of schools attended

• Absences

• Physical health

• Police involvement

• Daily activities

• Older children

• Educational attainment

• Family composition and parenthood

• Employment

• Experiences of homelessness and housing instability

COVID-19 Experiences

• Household member mortality from COVID-19

• Employment disruptions from COVID-19

• Education disruptions from COVID-19

• Economic impacts of COVID-19 on household

Contact Information

• Email for adult respondent

• Contact information for two close contacts

• Contact information for adult children

• Child Survey (ages 10-17) and Supporting Materials

After administering the adult head of household survey, the interviewer will ask the parent for permission to administer the child survey to up to three focal children ages 10-17² that currently reside in the home (Parent Permission Form is included as Appendix F). Some households will have no children ages 10-17 and other will have between 1 and 3 children. Altogether, the sample for the minor child survey is 2,220. Prior to administering the child survey, the interviewer will review the Child Assent Form with the child (included as Appendix G). The interviewer will then administer the Child Survey (included as Appendix H). See Exhibit A-3 for a list of the topics to be included in the Child Survey.

Exhibit A-3. Child Survey Topics

Pro-social Behavior

• Strengths and Difficulties Questionnaire with items on internalizing and externalizing problems and pro-social behavior

Life Events

• Key life events that may apply to the child’s family, including their parents and siblings

Youth Risky Behaviors

• Smoking cigarettes, e-cigarettes, and using other tobacco products ever or in the last 30 days

• Consuming alcoholic beverages ever, in the last 30 days, and before work or school

• Using marijuana ever, in the last 30 days, or before work or school

• Using other drugs ever or in the past 30 days

School Grades/Attendance/Problems/Efforts

• Absences from school

• School satisfaction

• Completing homework

• Being suspended or expelled from school

Parental Monitoring and Involvement

• Level of parental engagement in the child’s daily life and activities

• Parent’s knowledge of child’s activities during non-school hours

Social Support and Community Engagement

• Goals for after high school

• Presence of adult support in child’s life

• Participation in school-based and community-based activities

• Current satisfaction with life outlook

• Adult Child Survey (ages 18-30) and Supporting Materials

As part of the Phase 1 Tracking and Reengagement Data Collection approved in April 2022 (OMB #2528-0259, Expiration Date: 4/30/2025), interviewers will ask the adult head of household for contact information for up to three of their children who are now ages 18-30 and were with the family at study enrollment. Using this contact information, interviewers will conduct an enrollment call with each adult child (Adult Child Enrollment Call Script included as Appendix I). During this enrollment call, the interviewer will explain the research study, obtain their consent to participate in the study (Consent to Participate- Adult Child included as Appendix J), request their Social Security number, and collect the consent to release their information to HUD at the conclusion of the study (Adult Child Information Release Form included as Appendix K).

Exhibit A-4. Adult Child Survey Topics

Housing

• Housing stability and

• Experiences of homelessness on their own without their parents

Educational attainment

• High school graduation or GED,

• Post-secondary education;

• Degree and training programs; and

• Anticipated future educational attainment

Employment

• Any employment disruptions due to the COVID-19 pandemic

Food security

Psychological distress

Substance use

Domestic violence

Arrests

Family formation

• Parenting and its timing

Access to health care

• Insurance

The study team will then email the adult child a link to the web-based survey (Adult Child E-mail Invitation text included as Appendix L; Adult Child Survey instrument included as Appendix M). Exhibit A-4 presents the topic covered by the Adult Child Survey.

HUD contracted with Abt Associates in September 2021 to conduct the Family Options 12-Year Study. A copy of the relevant section of law authorizing the Department to undertake “such programs of research, studies, testing, and demonstration relating to the mission and programs of the Department” (12 USC 1701z-1 et seq.) is included as Appendix N.

2. Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

The experimental design of the Family Options Study provided a strong basis for conclusions about the relative impacts of the interventions on housing stability and many other aspects of family well-being at both 20 and 37 months after enrollment. To summarize, the 20- and 37-month analyses found that:

• The offer of a long-term rent subsidy led to substantial reductions in homelessness and residential instability relative to usual care. Families who were offered vouchers were less than half as likely to report being homeless or doubled up in the previous six months at the 37-month follow-up survey, and less than a quarter as likely to stay in an emergency shelter in the last year. They stayed in fewer different places.

• The offer of a long-term rent subsidy had radiating and largely positive impacts in each of the other domains relative to usual care.

• Parents offered long-term rent subsidies reported less psychological distress, alcohol and substance abuse, and domestic violence. That is, problems that can sometimes lead to homelessness were reduced when families had access to stable affordable housing.

• Children in families offered vouchers were less likely than those in families offered usual care to be separated from parents or to be in foster care at 20 months, although these effects were no longer detected at 37 months. In addition, at this later time, parents who had been in shelter together were more likely to be separated. Because of the high rate of intimate partner violence family heads had experienced, and the correlation between intimate partner violence and separations, the subsidies may have enabled some respondents to escape violent relationships.

• Children in families offered vouchers had fewer school moves, better attendance (at 20 months) and fewer behavior problem as reported by parents (at 37 months) than children in families offered usual care. In analyses conducted after Gubits et al., 2016, 3- to 4-year-old children and 13 to17 year-old children in families who received vouchers were more likely to be in a higher functioning group across all outcome domains than children in usual care. Results here were mediated by improvements in housing stability and housing quality, reductions in family stress, and strengthened family routines (Brown, 2021).

The Family Options Study continues to provide an unparalleled research platform for studying sheltered family homelessness. The 12-year study will measure the long-term outcomes of access to a long-term housing subsidy such as a Housing Choice Voucher for families who have experienced homelessness. Those outcomes include returns to homelessness, other aspects of family well-being, and the life trajectories of children who have aged into adulthood during the 12 years since they experienced an episode of sheltered homelessness with their parents.

Specifically, this round of data collection will examine the following topics:

• The long-term outcomes for a family after a stay in shelter in the absence of priority access to a long-term rent subsidy.

• The long-term impacts of priority access to a long-term rent subsidy on returns to homelessness and other forms of housing instability; life trajectories of children as they age into adolescence and young adulthood; and other aspects of family well-being including family preservation, self-sufficiency, and adult well-being.

• Whether the patterns of homelessness and housing stability were affected by the COVID-19 pandemic and whether access to a long-term rent subsidy have an impact on pandemic-related outcomes and families’ ability to weather the pandemic.

The research team previously conducted adult and child data collection at enrollment, and again approximately 20 months and 37 months after the date of study enrollment. The research team also conducted short tracking surveys 6, 12, and 27 months after enrollment. An additional round of adult data collection occurred 78 months after enrollment. This new round of data collection will start by conducting the Adult Head of Household Survey, then proceed with the administration of the Child Survey and web-based Adult Child Survey. The objective for all data collection activities is to understand the experiences of families 12 years after they enrolled in the study and received priority access to one of four housing and service interventions (long-term rent subsidy, community-based rapid re-housing, project-based transitional housing, or usual care).

The primary beneficiary of the survey efforts will be HUD. HUD will use the information from the 12-year study to understand the longer-term impacts of receiving a long-term rent subsidy. Other federal and non-federal researchers working with the Family Options Study data will also benefit, as the additional data collected under the long-term data collection effort will be appended to the existing Family Options Study dataset currently stored at the U.S. Census Bureau³.

HUD, policy makers at all levels of government, and local homeless service providers have benefitted greatly from the data collected for this study under earlier data collection efforts included under OMB Approval Number 2528-0259. The study data collected to date were used in the following reports, all of which can be found on the study webpage located at https://www.huduser.gov/portal/family_options_study.html:

• Interim Report published in March 2012 (Daniel Gubits et al., Interim Report, Family Options Study (Washington, DC: U.S. Department of Housing and Urban Development, March 2013);

• The Family Options Study: Short-Term Impacts of Housing and Services Interventions for Homeless Families (Gubits et al., 2015), presents findings from the 20-month impact analysis;

• The Family Options Study: Three-Year Impacts of Housing and Services Interventions for Homeless Families (Gubits et al., 2016) presents findings from the 37-month impact analysis;

• Family Options Study: Long-Term Tracking Project (McInnis et al., 2020), presents the results of a 6-month effort to assess the quality of the study sample contact information and limited descriptive data on the sample;

• A series of research briefs on special topics sponsored by the U.S. Department of Health and Human Services;

• A public use dataset (available on www.huduser.gov) and a restricted access dataset (available through the U.S. Census Bureau); and

• A series of academic papers published in peer-reviewed journals.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Improved information technology will be used in support of this information collection in the following ways:

• to maintain all demonstration data in a single location; and

• to facilitate the collection of survey data in standardized and accurate ways that also accommodates the confidential collection and storage of sensitive data.

The Family Options 12-Year Study will continue to generate a substantial amount of data on both adults and selected focal children, as well as new information on adult children. For adults, the 12-year data collection includes an interview with the head of household about their own experiences and about their minor children ages 10-17 (up to three focal children). The adult interview also asks about the transition to adulthood for up to three of their now adult children ages 18-30. For focal children (up to three per enrolled family ages 10-17 and up to three per family ages 18-30), the 12- year data collection includes a survey for focal children ages 10-17, an enrollment call and web-based survey for adult children ages 18-30. All survey data from study participants will be entered into a master evaluation database, which contains data previously collected from enrolled families at study enrollment, random assignment records, tracking interviews, and the 18 and 37-month follow-up surveys. This master evaluation database also contains historical contact information for all study participants as well as administrative data from HUD.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The Family Options Study is the largest experimental study of interventions serving families who experienced homelessness that has been conducted to date. The study sample provides a unique opportunity to examine the effects of the interventions and to explore family dynamics and well-being over time. By the time the long-term data collection begins (anticipated in October 2022), approximately 4.5 to 5 years will have passed since the last contact with study participants.

Information about the study participants’ current contact information is not available through any other source, though the research team will seek to reduce the burden on respondents by also reviewing HUD data systems to gather location information for any study families that are currently receiving HUD housing assistance. The research team will also consult other proprietary databases that may provide contact information for the study sample.

The research team will avoid duplication by using a centrally maintained database to electronically store the contact information for the sample. This database will link all data collected in the follow-up survey to information collected from study participants previously on the baseline and tracking surveys, as well as with any administrative data collected for study participants. This reduces the need to ask about personal characteristics and background factors on the 12-year survey that have already been collected for the family. In addition, information collected during the prior rounds of data collection has been stored in the study database and will be referenced during the 12-year interview. In this way, the 12-year survey will involve verification and correction of previously provided information on family composition and contact information rather than collecting each item anew.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I) describe any methods used to minimize burden.

Respondents for this data collection include families who voluntarily enrolled in the study, not business entities. There is no expected burden on small businesses.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Previous analyses of data collected from the Family Option Study provided important information about the relative impacts of four interventions, community-based rapid rehousing, project-based transitional housing, a long-term rent subsidy, and emergency shelter on housing stability and many other aspects of family well-being at both 20 and 37 months after enrollment. It examined outcomes in five domains: (1) housing stability; (2) family preservation; (3) adult well-being; (4) child well-being; and (5) self-sufficiency. The striking impacts of priority access to a long-term rent subsidy in reducing homelessness support the view that for most families, homelessness is a problem of housing affordability that can be remedied with long-term rent subsidies. The study also provides important evidence about the shorter-term experiences of families who did not receive a special offer after a stay in shelter.

The 12-Year survey offers a unique opportunity to understand if the striking reductions in homelessness and positive effects on other aspects of adult and child well-being found during earlier analyses continue over a longer period. Also, this data collection can help discover whether new outcomes emerge at this later point in time. Failure to complete the 12-year data collection with the adult heads of household and their children will deny HUD a crucial opportunity to study the outcomes of young adults who experienced homelessness with their families as a child and whether experiencing homelessness in childhood leads to homelessness as an adult.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

The proposed data collection activities are consistent with the guidelines set forth in 5 CFR 1320 (Controlling Paperwork Burdens on the Public). There are no special circumstances that require deviation from these guidelines. The following below is “Not Applicable” to this collection:

• requiring respondents to report information to the agency more than quarterly – “Not Applicable;”

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it – “Not Applicable;”

• requiring respondents to submit more than an original and two copies of any document – “Not Applicable;”

• requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years – “Not Applicable;”

• in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study – “Not Applicable;”

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB – “Not Applicable;”

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use – “Not Applicable;” or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law – “Not Applicable.”

7. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

• Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.

• Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8 (Paperwork Reduction Act of 1995), HUD published a 60-Day Notice of Proposed Information Collection in the Federal Register on April 26, 2022 (Docket No. FR-7060-N-03, pages 24572 - 24573). The notice provided a 60-day period for public comments, and comments are due June 27, 2022. (See Appendix O for a copy of the 60-Day Notice of Proposed Information Collection.)

The Family Options Study research design was developed and is being implemented with the assistance of Abt Associates Inc., the prime contractor. Several subcontractors and consultants have collaborated with the Abt team to develop the study design, including Dr. Marybeth Shinn of Vanderbilt University. Key members of the Abt team for the 12-year followup study are:

• Ms. Michelle Wood and Dr. Daniel Gubits (Co-Principal Investigators)

• Ms. Lauren Dunton (Project Director)

• Dr. Scott Brown (Director of Analysis)

• Dr. Jill Khadduri and Dr. Laura Peck (Co-Project Quality Advisors)

• Ms. Debi McInnis and Ms. Brenda Rodriguez (Directors of Survey Data Collection)

• Mr. Doug Walton and Dr. Samuel Dastrup (Administrative Data Task Leads)

• Mr. Tom McCall (Data Files Task Lead)

HUD has collaborated on the design of the evaluation with the research team throughout all phases of the study to date. The purpose of such consultation is to ensure the technical soundness and usefulness of the data collection instruments in carrying out the aims of the evaluation.

The period of data collection for the adult head of household survey, the child survey, and the adult child web-based survey is fifteen months.

1. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

Incentive payments have been a powerful tool for maintaining low attrition rates in longitudinal studies, and in the Family Options Study in particular. By the time that the survey effort begins (anticipated October 2022) it will have been approximately 4.5 to 5 years since the participants were last surveyed by the research team. Given the substantial time that has elapsed and the burden of continued participation in the study, we propose offering incentives to participating households to help minimize non-response bias and to offset the costs of participation. Given the importance of obtaining a high response rate for all three surveys, we are proposing the following incentive structure for the survey effort:

• Adult head of households will receive a $50 incentive payment for completing the Adult Head of Household Survey;

• Children ages 10-17 will receive a $25 incentive payment for completing the Child Survey (ages 10-17);

• Adult children (18-30) will receive $15 for completing the enrollment call and $25 after completing the web-based survey.

Over the past decade, the use of incentive payments for the Family Options Study helped to ensure a high response rate to the prior data collection efforts to facilitate unbiased impact estimates to analyze the effects of the interventions studied.

Three factors helped to determine the incentive amounts for each round of data collection:

1. Respondent burden, both at the time of the interview and over the life of the study;

2. Costs associated with participating in the interview at that time; and

3. Other studies of comparable populations and burden.

The Family Options Study panel is small (2,241 families) and avoiding attrition is essential to the success of the study. Achieving a high response rate during the 12-year study data collection is critical, therefore we believe it is crucial to take every possible step to minimize panel attrition. Ensuring minimal attrition is the core justification for an incentive system for the survey activities. The challenges associated with maintaining the study are further complicated by the housing instability likely in this study population.

Our experience with this study population shows that the sample does respond positively to incentive payments. Previous research has shown that sample members with certain socio-economic characteristics are significantly more likely to become survey respondents when incentive payments are offered. Sample members with low incomes and/or low educational attainment have proven responsive to incentives. These characteristics are expected to be heavily represented in this study panel (Duffer et al. 1994); Educational Testing Service (1991).

Based on our prior experience with this study sample, the previously approved incentive structures and the additional considerations and prior research experience cited here, we believe that that the use of incentives will improve substantially the probability of participant re-engagement. We chose to keep the incentive structure the same as the 37-month follow-up survey for the adult head of household and the child survey respondents. Since this is a new data collection effort for the adult child sample, we seek approval to offer them incentives for completing both the enrollment call and the web-based survey. For the enrollment call, we propose the same $15 incentive provided to adult heads of household for completing tracking calls. We propose a $25 incentive for completing the web survey, comparable to child survey respondents.

9. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.

HUD entered a contract with an independent research team, Abt Associates to conduct this research effort. HUD and Abt Associates will make every effort to maintain the privacy of respondents, to the extent permitted by law. The information requested under this collection is protected and held confidential in accordance with 5 U.S.C. § 552a (Privacy Act of 1974).

A Privacy Impact Assessment completed for the Family Options Study data files is on file with HUD, and a System of Records Notice (SORN) was published in the Federal Register in October 2010 (FR-5386-N-10), and subsequently amended at the time of the 37-month data collection and published in the Federal Register in February 2014 (FR-5763-N-02). A revised SORN in support of the 12-year data collection is currently under review by OMB.

All research staff working on the project have been trained to protect private information and the study has a Data Security Plan governing the storage and use of the data collected through the study. Individuals will not be cited as sources of information in prepared reports. All respondents included in the study will be informed that their participation in the data collection is voluntary and the information they provide will be used for statistical purposes only.

9. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The Adult Head of Household Survey includes questions about the adult’s history of homelessness, household income and other financial circumstances. The survey also includes questions about the adult’s physical and emotional health and experiences with domestic violence and substance use. These items are necessary to evaluate the impacts of the housing and services interventions being tested. It also asks the adult questions about their child(ren)’s health, educational attainment, and behavior—items that can be considered sensitive. As with all information collected on the interviews, responses will be kept confidential and will be used only for the purposes of evaluating the housing and services interventions tested in the evaluation. To encourage candid responses, respondents will be reminded during the interviews that their responses will be kept confidential. Respondents will also be reminded that they can refuse to answer any question. The contractor has not experienced any difficulty administering these questions under the 20-, 37-, and 78-month follow-up data collections. The interviewers have not reported any negative feedback from respondents regarding these questions. Study participants will be reminded that they can choose not to answer any questions or stop the interview at any time.

The Child Survey (ages 10-17) asks questions about the child’s experiences with family separation or loss, substance use, and negative school experiences, which all can be considered sensitive. The survey includes prompts throughout to remind the child respondent that they are

not required and can stop the interview at any time if they feel upset. The contract has not experienced any difficulty administering similar questions under the 20- and 37-month surveys.

The Adult Child Survey (ages 18-30) includes questions about the young adult’s experiences with homelessness, domestic violence, substance use, psychological distress, and arrests and incarceration. The survey will be administered online and will allow the respondent to skip questions they do not want to answer. Before each of these sensitive items, the survey will include a reminder that they can choose not to answer and a reassurance that their responses will be kept confidential and will not have any effect on services they receive now or in the future.

The study is also seeking a Certificate of Confidentiality from the National Institute of Child Health and Development to provide further protection of the data.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices;

• if this request covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I; and

• provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

The survey period is anticipated to last roughly fifteen months. The survey data collection includes the administration of the adult head of household survey, the child survey, and the web-based survey of adult children. The target respondent group for the Adult Head of Household Survey for this information collection are the 2,241 families that comprise the sample for the Family Options Study, therefore, this information collection will affect 2,241 individuals—one individual representing each family.⁴

The Adult Head of Household outreach materials, including the advance letter, the outreach e-mail, and the outreach flyer, are expected to take roughly 3 minutes each to review (0.05 hours). Completion the Adult Head of Household Survey is expected to take on average one hour, with the consent form taking an additional 10 minutes or 0.1 hours per respondent.

For the child survey, the process will begin with the administration of the Adult Head of Household Parent Permission, which is estimated to take ten minutes, or 0.17 hours. Following completion of the Parent Permission form, the Child Assent Form will be administered, taking roughly ten minutes or 0.17 hours on average to complete. Finally, the Child Survey will be administered, taking 30 minutes on average to complete.

Engagement with the adult child sample will take roughly 30 minutes—10 minutes for the enrollment call, 10 minutes for the informed consent, and 10 minutes to explain and complete the information release form. We expect the email invitation for the web-based Adult Child Survey will take approximately 3 minutes to review and the survey itself will take 15 minutes to complete per respondent on average. Estimates are based on prior experience administering very similar versions of these forms. The Adult Head of Household Survey, the Child Survey, and the Adult Child Survey, will be completed a single time by each eligible respondent (see Exhibit A-5).

The estimated total annual burden of this information collection is 6,309.6 hours. The estimated total annual cost for this information collection is $48,945.33 The estimated total annual cost is calculated by multiplying the total number of respondent hours for adults (4,822.2) by $10.15. The amount of $10.15 was calculated using the minimum hourly wage ($7.25) plus an assumed 40 percent for fringe benefits (see Exhibit A-1). Annualized cost estimates were not calculated for the child sample. The child sample eligible to participate in the 12-year study will be under the age of 18. Most, if not all, will be enrolled in school and working part-time at the most. Thus, we did not calculate an hourly wage for the child sample.

Exhibit A-5: Estimated Hour and Cost Burden of Information Collection

Annualized Burden Table
Information Collection	Number of Respondents	Frequency of Response	Responses Per Annum	Burden Hour Per Response	Annual Burden Hours	Hourly Cost Per Response	Cost
Adult Head of Household Survey and Supporting Materials
Adult Head of Household Advance Letter (Appendix A)	2,241	1	2,241	.05	112.05	$10.15	$1,137.31
Adult Head of Household Outreach E-mail (Appendix B)	2,241	1	2,241	.05	112.05	$10.15	$1,137.31
Adult Head of Household Outreach Flyer (Appendix C)	2,241	1	2,241	.05	112.05	$10.15	$1,137.31
Consent to Participate- Adult Respondent (Appendix D)	2,241	1	2,241	.17	380.97	$10.15	$3,866.85
Adult Head of Household Survey (Appendix E)	2,241	1	2,241	1	2,241	$10.15	$22,746.15
TOTAL					2,958.12		30,024.92
Child (10-17) Survey and Supporting Materials
Parent Permission Form (Appendix F)	2,241	1	2,241	.17	380.97	$10.15	$3,866.85
Child Assent Form (Appendix G)	2,220	1	2,220	.17	377.40	NA	-
Child Survey (Appendix H)	2,220	1	2,220	.5	1,110.00	NA	-
TOTAL					1,868.37		$3,866.85
Adult Child (18-30) Survey and Supporting Materials
Adult Child Enrollment Call (Appendix I)	1,831	1	1,831	.17	311.27	$10.15	$3,159.39
Consent to Participate- Adult Child (Appendix J)	1,831	1	1,831	.17	311.27	$10.15	$3,159.39
Adult Child Information Release Form (Appendix K)	1,831	1	1,831	.17	311.27	$10.15	$3,159.39
Adult Child E-mail Invitation (Appendix L)	1,831	1	1,831	.05	91.55	$10.15	$929.23
Adult Child Survey (Appendix M)	1,831	1	1,831	.25	457.75	$10.15	$4,646.16
TOTAL					1,483.11		$15,053.57
Final Total					6,309.60		$48,945.33

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in Items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s) and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities;

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10) utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

This data collection effort involves no recordkeeping or reporting costs for respondents other than the time burden to complete the consent and surveys as described in item 12 above. There is no known cost burden to the respondents.

13. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

The survey data collection effort will be carried out under a HUD Contract with Abt Associates. HUD estimates the total cost to the Federal government of the data collection effort to be approximately $3,601,794 (see Exhibit A-6). This total cost can be broken down into two components: 1) professional labor, to carry out the survey data collection effort ($3,408,851) and 2) incentive fees associated with each of the three surveys ($192,943).

The professional labor includes the labor hours required to implement three surveys, including the administration of informed consent to all study participants: 1) the Adult Head of Household Survey; and 2) the Child Survey and 3) the Adult Child Enrollment Call and Web Survey. The labor hours also include time to process the responses to these three survey efforts. This includes the cost related to salaries of Abt employees, hours for subcontracted interviewers, and operational expenses such as developing the web-based data collection system, translation costs, and mailing and shipping costs.

The total incentive fees anticipated to be paid are based on the expected response rate and the incentive to be offered for each outreach effort.

Exhibit A-6: Estimated Annual Cost to the Federal Government

Activity	Estimated Cost to Federal Government	Total Labor Hours for Information Collection
Professional Labor	$3,408,851	14,714
Incentive Fees	$192,943	N/A
Total	$3,601,794	14,714 hours

15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the OMB Form 83-I.

This submission to OMB is a revision of a currently approved collection. The current collection, approved in April 2022 (OMB #2528-0259, Expiration Date: 4/30/2025) included the instruments associated with the first phase of data collection—the Tracking and Reengagement Data Collection phase. In this second phase, HUD is seeking approval from OMB for the 12-Year Survey Administration phase, which includes three 12-year survey instruments (adult head of household; child; and adult child); outreach materials to study families, and the informed consent materials to be administered to the study families.

16. For collection of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The information collected under this ICR will result in a publicly available published report on the 12-year study findings.

The proposed timeline for the survey effort is as follows:

• Begin Adult Head of Household Survey (November 2022)

• Begin Child Survey and Adult Child Survey (December 2022)

• Conclude Adult Head of Household Survey (October 2023)

• Conclude Child Survey and Adult Child Survey (January 2024)

If the timeline for the 12-year study adheres to the schedule above, a final report would be expected in Winter 2025.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

All data collection instruments will prominently display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in item 19.

This submission describing data collection requests no exceptions to the Certificate for Paperwork Reduction Act (5 CFR 1320.9).

References

Duffer, Allen P. et al., Effects of Incentive Payments on Response Rates and Field Costs in a Pretest of a National CAPI Survey, (Research Triangle Institute, May 1994).

Gubits, Daniel et al., Interim Report, Family Options Study, Washington, DC: U.S. Department of Housing and Urban Development, March 2013. http://www.huduser.org/portal/publications/homeless/hud_503_FOS_interim_report.html

Gubits, Daniel, Marybeth Shinn, Stephen Bell, Michelle Wood, Samuel Dastrup, Claudia D. Solari, Scott R. Brown, Steven Brown, Lauren Dunton, Winston Lin, Debi McInnis, Jason Rodriguez, Galen Savidge, and Brooke E. Spellman. 2015. Family Options Study: Short-Term Impacts of Housing and Services Interventions for Homeless Families. Washington, DC: Government Printing Office U.S. Department of Housing and Urban Development.

Gubits, Daniel, Marybeth Shinn, Michelle Wood, Stephen Bell, Samuel Dastrup, Claudia D. Solari, Scott R. Brown, Debi McInnis, Tom McCall, and Utsav Kattel. 2016. Family Options Study: Three-Year Impacts of Housing and Services Interventions for Homeless Families. Washington, DC: Government Printing Office U.S. Department of Housing and Urban Development.

McInnis, Debi, Daniel Gubits, Brenda Rodriguez, Scott Brown, and Michelle Wood. 2020. Family Options Study: Long-Term Tracking Project. Washington, DC: Government Printing Office U.S. Department of Housing and Urban Development. Washington, DC: Government Printing Office U.S. Department of Housing and Urban Development.

National Adult Literacy Survey Addendum to Clearance Package, Volume II: Analyses of the NALS Field Test (Educational Testing Service, September 1991), pp. 2-3.

1 While the initial study sample included 2,282 families, in previous data collection the study team has confirmed that in 41 families the head of household is deceased. Thus, the sample for the 12-year study is 2,241 families.

2 The mode of data collection for the child survey will most often mimic the mode of the adult survey since the parent must give their permission for the child to participate. In rare instances, interviewers may need to schedule separate appointments. Those appointments may be by phone or in-person.

3https://www.census.gov/about/adrm/linkage/projects/HUDmtofos.html#:~:text=The%20Family%20Options%20Study%20(FOS,or%20less%20from%20different%20interventions.

4 Note the sample size for the Information Release Form is 1,272, not 2,241. The sample size is smaller because we only need to collect the information release from those who did not provide it one of the prior interviews.

Part A: Justification ▌pg. 15