OMB Memo

Cognitive Testing of Supplemental Nutrition Assistance Program Client Integrity Messaging, Submitted Under Generic Clearance for Questionnaire Pretesting

Request: The Census Bureau plans to conduct additional research under the generic clearance for questionnaire pretesting research. We plan to conduct up to 30 cognitive interviews to test Client Integrity messages for the Supplemental Nutrition Assistance Program (SNAP). The purpose of this study is to evaluate Client Integrity messages from a selection of states. Client Integrity messages communicate SNAP program rules that SNAP recipients need to follow. We plan to evaluate the messages with regard to whether they are clear and easy to understand in order to improve Client Integrity message guidance provided to states by the Food and Nutrition Service (FNS), which administers SNAP.

Purpose: Client Integrity refers to FNS’ efforts to ensure SNAP program integrity by preventing and correcting the misuse of program funds. One aspect of this effort involves program participant education with the goal of ensuring that SNAP participants understand program rules and are empowered to report suspected violations. Client Integrity education covers four categories:

• Electronic Benefits Transfer card management

• Eligible and ineligible purchases

• Benefits trafficking

• Fraud reporting

FNS provides Client Integrity information and guidance to state agencies that administer SNAP, and the latter decide how to present the information to program participants. FNS’ motivation for this research is to evaluate the Client Integrity messages currently used by a selection of states and identify a set of best practices as well as less effective communication strategies that should be avoided. Our goal is to test whether current messaging is clear and easy to understand, and to provide recommendations for correcting any issues we might find. The findings from this study will be used to improve FNS’ guidance to state SNAP programs for communicating Client Integrity information. This study will be carried out under contract by RTI International, a private research organization, under the direction of the Center for Behavioral Science Methods (CBSM).

The current request is for approval to conduct up to 30 cognitive interviews in three states/districts (10 interviews each in Alabama, Pennsylvania, and the District of Columbia). We will ask for approval to conduct 20 additional interviews in two additional states in a separate request, for a total of 50 interviews.

Interviews in each state/district will test messaging that is in use in that state/district. Because SNAP is a federal program but is administered at the state/district level, this research is designed as a set of case studies. Each case study will evaluate the messaging for a particular state/district to determine whether the messages are clear and easy to understand, and also provide general lessons applicable to all states.

Population of Interest: Current or past recipients of food assistance, and individuals who would likely qualify for food assistance if they applied.

Timeline: Between February 2023 and June 2023, staff from RTI will conduct cognitive interviews with up to 30 participants.

Language: Interviews will be conducted in English.

Sample: We will focus on recruiting participants who have participated in SNAP or are eligible to receive SNAP benefits. We will also sample for diversity based on age and level of education.

Recruitment: Participants will be recruited with the help of local government assistance offices and charitable food assistance organizations in the three sites. CBSM will provide the organizations in the three sites with flyers and advertisements that can be sent electronically to recipient listservs, posted on local websites, or physically posted in public areas of service offices. These materials will include a toll-free number that potential participants can use to complete a screening interview, and a URL for an online screening questionnaire (See Attachment 4: Recruitment materials). Research team members will then contact eligible participants to schedule them for an interview if they qualify (See Attachment 10: Screening Questions). Participants will receive a $50 incentive for in-person participation and $40 for remote interviews.¹

Locations of interviews: The first round of interviews will be conducted in three areas:

• Opelika, Alabama

• Scranton, Pennsylvania

• District of Columbia

We chose the three sites because of the density and diversity of SNAP recipients in these areas. Interviews will be conducted in locations convenient to participants such as local government assistance offices, public libraries, community centers, and RTI office space.

Protocol: The protocol is designed to test Client Integrity messaging presented in a variety of text-based formats including applications, letters, attachments, pamphlets, and web and social media content. The documents all include descriptions of one or more of the four areas of Client Integrity education. The test materials were provided by the SNAP program representatives in each state/district. The materials we plan to test are included as attachments and are listed in Table 1 below. Attachments 7, 8, and 9 are zip files, each of which contains the testing material files from Pennsylvania, Alabama, and the District of Columbia, respectively. The individual testing material files are listed in Table 1 according to their corresponding exhibit numbers as used in the protocols.

Participants will be trained to think aloud and to give their immediate reactions to what they are reading. Researchers will remind participants to think aloud as they are reading the materials and ask scripted and spontaneous probes designed to gauge comprehension and interpretation of the materials being tested (see Attachments 1, 2 and 3: Interview Protocols). As needed throughout the interview period, CBSM and RTI staff will update the interview protocol to address feedback from participants.

Table 1. Attachments
Attachment Number	Title/Description of Contents
Attachment 1.	Pennsylvania Cognitive Interview Protocol
Attachment 2.	Alabama Cognitive Interview Protocol
Attachment 3.	Washington, DC Cognitive interview Protocol
Attachment 4.	Recruitment materials
Attachment 5.	Incentive voucher
Attachment 6.	Consent form
Attachment 7.	Pennsylvania SNAP Testing Materials Exhibit 1. Informational Flyer Exhibit 2. EBT Brochure Exhibit 3. Social Media Posting on Scams Exhibit 4. SNAP FAQ Exhibit 5. SNAP Application Exhibit 6. Excessive Card Letter Exhibit 7. Fraud FAQs
Attachment 8.	Alabama SNAP Testing Materials Exhibit 1. SNAP Integrity Flyer Exhibit 2. SNAP Application
Attachment 9.	Washington, DC SNAP Testing Materials Exhibit 1. Protecting Benefits Guide Exhibit 2. SNAP Approval Notice Exhibit 3. Out of State Travel Flyer Exhibit 4. DC SNAP Website Exhibit 5. SNAP Integrated Application Exhibit 6. Multiple Card Replacement Letter
Attachment 10.	Screening questions

Informed Consent: We will inform participants that their participation is voluntary and that the information they provide is confidential and will be accessed only by employees involved in the research project. The consent form will also indicate that the respondent agrees that the interview can be audio-taped to facilitate analysis of the results. Participants who do not consent to be audio-taped will still be allowed to participate. A copy of the consent form is attached (see Attachment 6: Consent Form).

Incentive: Participants will receive $50 for their participation in this research to offset costs such as travel and parking.

Length of Interview: We estimate that each of the 30 in-person cognitive interviews will take approximately 60 minutes. This results in a burden of 30 hours.

The pre-approved generic screening questionnaire will take approximately ten minutes per person, and the additional screening questions specific to this research will take two minutes per person (see Attachment 10). We estimate that we will screen up to three people for each successful recruit for each of the 30 interviews. Therefore, we estimate a total of 90 people screened for a total of about 3 hours (90 people at 2 minutes each).

The total estimated participant burden for this request is 60 hours.

Category	Number of participants	Participation Time	Burden
Screening	90	2 minutes	3 hours
Cognitive Interviews	30	60 minutes	30 hours
Totals			33 hours

The contact person for questions regarding this request is listed below:

Alfred “Dave” Tuttle

Center for Behavioral Science Methods

U.S. Census Bureau

Washington, D.C. 20233

(301) 763-7809

[email protected]

1 We do not currently plan on remote interviews but if conditions change, we will consider remote interviewing.

3