SSA - Program Support GenIC: ACF Privacy and Confidentiality Toolkit Case Studies

Alternative Supporting Statement for Information Collections Designed for

Research, Public Health Surveillance, and Program Evaluation Purposes

ACF Privacy and Confidentiality Toolkit Case Studies

Formative Data Collections for ACF Program Support

0970 – 0531

Supporting Statement

Part A

December 2021

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 Officers:

Brett Brown

Aaron Goldstein

Executive Summary

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

• Description of Request: The U.S. Department of Health and Human Services’ Administration for Children and Families Office of Planning, Research, and Evaluation contracted with Westat, Inc. (Westat) to develop case studies on human service organizations that developed responsible data sharing initiatives with the goal of encouraging other organizations to develop their own initiatives. Westat may ask a small number of organizations to complete a short questionnaire about their initiative to help determine if they are the best candidate for a case study. Once an organization is selected, Westat will interview key individuals connected to the initiative. Since each organization has a different structure, uses different technology, must abide by different state laws, and faces different external influences, the case studies will not include specific guidance that is generalizable to, or otherwise represents, all other organizations.

A1. Necessity for Collection

The U.S. Department of Health and Human Services’ Administration for Children and Families (ACF) Office of Planning, Research, and Evaluation (OPRE) seeks approval to collect information needed to develop case studies that will describe human service organization’s experiences with developing responsible data sharing initiatives.

This proposed information collection meets the goals of ACF’s generic clearance for formative data collections for program support (0970-0531) as it is intended to collect information that will (a) obtain information about program and grantee processes and needs and (b) inform activities, such as the delivery of targeted assistance related to program implementation and the development and refinement of program and grantee processes.

ACF has contracted with Westat, Inc. (Westat) to develop these case studies and collect the necessary information.

Background

OPRE has found that data sharing initiatives can significantly improve the quality of child welfare services and research. At the same time, OPRE has found that individuals who work within organizations that promote the well-being of children and families often oppose data sharing initiatives because of real and perceived challenges (e.g., legal, structural, technical, cultural). For example, we found that these individuals often do not understand:

• The many ways to mitigate many privacy and confidentiality risks; and

• If and how laws governing privacy and confidentiality apply to various activities.

We believe a series of case studies that show how organizations have developed a data sharing initiative that improved the quality of child welfare services and/or research while meeting the relevant privacy and confidentiality challenges could inspire and provide relevant and helpful information to other organizations to develop their own initiatives. The proposed interviews will provide nuanced information that will be helpful to other organizations as they develop or evolve data sharing initiatives.

Legal or Administrative Requirements that Necessitate the Collection

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

A2. Purpose

Purpose and Use

The purpose of the proposed case studies is to inspire and provide relevant and helpful information to organizations that promote the well-being of children and families to develop their own data sharing initiatives. ACF will benefit by learning how to better assist organizations who want to develop these data sharing initiatives. The information will contribute to ACF’s internal planning of future support efforts such as training and technical assistance for funding recipients.

Per the terms of the umbrella generic (0970-0531), findings based on GenICs may be shared with audiences such as federal leadership and staff, grantees, local implementing agencies, and/or T/TA providers, for example through technical assistance materials and other documents.¹ Consistent with these terms, ACF plans to make available on the OPRE website a report from each case study site for use as a T/TA resource. The target audience isACF grantees, primarily state and local human services agencies, that operate programs similar to those described in each case study. We fully recognize that each stakeholder has a different structure, uses different technology, must abide by different state laws, and faces different external influences. For these reasons, the case studies are intended as examples and will clearly indicate that the information may not be generalizable to other organizations. These limitations will be discussed in the report’s disclaimer and throughout the report itself.

Each case study report will be written for individuals who work within similar organizations and will illustrate:

• How responsibly sharing data with other organizations can enhance service delivery and research efforts,

• The processes that can help assure data sharing goals are successful, and

• Some of the important privacy and confidentiality items to consider when developing an initiative.

The goal is for each publication to have a similar look and feel. Each will include an overview, a standardized outline to the degree it is relevant (Attachment 2 - Draft Case Study Outline), and various resources and tools connected to the case study report (e.g., data sharing agreements). Going back to the above comment about each case studies being unique, and how no one case study could be generalized to another site, this uniformity is wanted because organizations considering their own data sharing effort should read several case studies and consider whether any of the themes and ideas in one or more of them could apply to their organization. Likewise, ACF staff should read several case studies to better understand how to provide assistance to a broad range of organizations that need or want to share data.

Guiding Questions

The guiding questions for this work include the following:

1. What are some of the key privacy and confidentiality requirements that govern the sharing of data to improve the quality of child welfare services and research?

2. How do organizations navigate the legal, structural, technical, and cultural challenges that often arise when trying to share data that could improve the quality of child welfare services and research?

Study Design

Each case study will focus on an organization working to share data across one or more programs which are funded and/or regulated by ACF. Most organizations will be state or local departments of human services Respondents will primarily be staff of these departments.

For each case study, Westat will begin by determining if an organization wants to participate, if their data sharing initiative is relevant to other organizations, if the initiative is different from other case studies such that the additional information will be helpful, and if their story is likely to inspire others. Westat plans to identify the organizations by reviewing publicly available information and soliciting suggestions from a small panel of experts. Westat may also send promising organizations a questionnaire about their data sharing initiative and interest in becoming a case study (Instrument 1 - Questionnaire to help select organizations).

Once an organization is selected, Westat will contact the organization’s leadership to confirm interest. If interested, Westat will try to gather and review any harder-to-find or longer public documents about the organization. Westat will also ask to interview individuals who understand different aspects of the data sharing initiative. The semi-structured interviews are necessary because much of the information needed to develop a case study is not publicly available.

Westat drafted a set of questions to help guide each semi-structured interview (Instrument 2 - Semi-Structured Interviews). The specific questions asked during each semi-structured interview will depend on (a) what Westat already learned about that organization from publicly available information, (b) the interviewee’s role within the organization and (c) the interviewee’s response to prior questions asked during that interview. Westat will give each interviewee the option to respond verbally and/or send documents.

Most data sharing initiatives involve multiple organizations. In those cases, Westat may ask for public documents about, and interview individuals connected to, one or more of the other organizations. Similar to interviewing individuals within the primary organization, Westat will select the most applicable interview instrument, then ask the questions in that instrument which best match the role of the interviewee.

Once Westat completes the data collection for a case study (i.e., interviews available individuals and reviews the necessary documents), they will compile their notes into a case study report that will be published on ACF’s website (as described under purpose and use, above).

Data Collection Activity	Instruments	Respondent, Content, Purpose of Collection	Mode and Duration
Questionnaire to help select organizations for a case study	Instrument 1 - Questionnaire to help select organizations	Respondents: Staff working for organizations participating in the data sharing initiative. Content: Key high-level aspects of the data sharing initiative Purpose: To determine whether a particular organization wants to participate in a case study and has a story that is likely to inspire other organizations.	Mode: Email or Phone Duration: 30 minutes
Semi-structured interviews to help gather information needed for a case study	Instrument 2 - Semi-Structured Interviews	Respondents: Staff working for organizations participating in the data sharing initiative. Content: Their knowledge and perspectives on the data sharing initiative Purpose: To learn how the data sharing initiative evolved, currently functions, and may be enhanced in the future.	Mode: Virtual or in-person; subject to the interviewee’s preferences. Interviewees can respond to each question orally and/or with documents. Duration: 90 minutes

Other Data Sources and Uses of Information

Where possible, Westat will look for publicly available documents about the organizations.

A3. Use of Information Technology to Reduce Burden

Individuals asked to complete a questionnaire will have the option to either (a) complete it electronically and email it back to Westat or (b) have Westat ask the questions over the phone and respond over the phone. If Westat has any follow-up clarifying questions they will cover those via email or phone. Westat will offer these methods because they are generally the most convenient and the information is not sensitive enough to warrant another method.

Individuals asked to participate in a semi-structured interview will have the option to participate in-person, via a web conference, or via telephone because those are generally the most convenient forums for interviewees. They will also have the option to e-mail documents to Westat if that is more efficient than orally responding to a question.

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

Westat will seek out publicly available source material about each organization and their data sharing initiative and will only request information needed for a case study that cannot be found publicly. Organizations that promote the well-being of children and families often publicize a privacy statement that summarizes their current privacy and confidentiality practices. However, they generally do not publicize the level of detail that each case study report intends to include. They also generally do not publicize how a data sharing initiative evolved, such as the history, the underlying concerns that shaped the end results, the parties that participated in the decisions, and why certain plans were cancelled.

A5. Impact on Small Businesses

No small businesses will be involved with this information collection.

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 two notices in the Federal Register announcing the agency’s intention to request an OMB review of the overarching generic clearance for formative information collection. This first notice was published on October 13, 2020, Volume 85, Number 198, page 64480, and provided a sixty-day period for public comment. The second notice published on December 28, 2020, Volume 85, Number 248, page 84343, and provided a thirty-day period for public comment. ACF did not receive any substantive comments.

Consultation with Experts Outside of the Study

The only experts involved in this study are the Westat staff and a small panel of experts. Both the Westat staff and the panel of external experts have experience developing questionnaires, interviewing experts, child welfare services and research, data sharing initiatives, and/or the laws that govern the sharing of data which could improve the quality of child welfare services and research. Experts will assist with identifying organizations that could make a good case study. A few experts will also be asked to review each case study and to provide feedback on potential improvements (e.g., if additional information could be beneficial, if anything was confusing).

A9. Tokens of Appreciation

No tokens of appreciation will be provided to participants or their organization.

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

Personally Identifiable Information

• The only elements of personally identifiable information (PII) that will be collected during this project are the name and business contact information of the organizations’ leaders and potential interviewees. This information will be used by Westat to do the following: Confirm organization leader interest in the case study, interview them, and confirm that the case study report accurately reflects their organization.

• Schedule interviews and follow-up if needed.

This 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

Anyone that Westat asks to participate in this project will be informed that:

• A request for an interview or documents is voluntary;

• The information may be used to produce a case study report that will be published on ACF’s website;

• The case study report will identify the organization;

• Any quotes in the case study report will not be attributed to a particular individual; and

• They can contact one of the ACF project leads if they have any questions about this project.

Westat will also confirm, before beginning an interview, that participants are comfortable if their name and title, or office and title, are included in the public report.

Westat’s contract states that they will comply with all ACF regulations regarding PII.

All Westat projects undergo an IRB review per company policy. The Westat team submitted an application for this project and the IRB responded that this activity is exempt.

Data Security and Monitoring

All PII will be stored on, and protected by, the Westat corporate network. It is a typical example of an enterprise information system in that it includes physical infrastructure, network hardware, firewalls, servers, workstations, and other assets. Logical controls help prevent co-mingling of information between systems, while logical and physical controls help with overall security. A robust Continuous Monitoring and Risk Mitigation program helps ensure the system is updated and that the level of security matches the type of work and sensitivity of the data being handled.

Westat closely monitors network access, while automated tools regularly review the system logs to identify suspicious behavior. Westat will notify the ACF COR within an hour of an incident and the response procedures will follow Westat’s incident response process.

All individuals with access to system components or data are authorized for such access. The project director or system manager will remove an individual’s access to project data when the project is transferred or terminated or when the individual no longer need access because they have left the project, they no longer need access to the data to complete their work, or similar. All individuals also took Westat’s security awareness training when hired.

A11. Sensitive Information ²

No sensitive information will be collected during the course of this project.

A12. Burden

Explanation of Burden Estimates

This collection request is for 3 years. During that time, we estimate that Westat will:

• Complete three case studies per year (9 case studies in total).

• Send a questionnaire to the top three candidates for each case study (27 questionnaires in total).

• Interview an average of eight individuals per case study (72 in total).

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)	Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost*
Instrument 1 - Questionnaire to help select orgs	27	1	.5	13.5	5	$47.54	$427.86
Instrument 2 - Semi-Structured Interviews	72	1	1.5	108	36	$47.85	$3,445.20
Total					41		$3,873.06

*Total costs include fringe benefits and overhead.

Estimated Annualized Cost to Respondents

The cost to recipients was calculated using the Bureau of Labor Statistics Occupational Outlook Handbook’s information as of October 21, 2021 (https://www.bls.gov/ooh) and job codes came from the May 2020 Occupation Profiles (https://www.bls.gov/oes/current/oes_stru.htm).

We are assuming that the questionnaires (30 minutes) will be completed by an individual with the following job category and rate:

BLS Job Title	Hourly Rate
Administrative Services And Facilities Managers (11-3010)	$47.54
Average	$47.54

We are assuming that the semi-structured interviews (90 minutes) will be completed by eight individuals who all fit one of the following job categories and rates. We are counting each role once because we (a) assume at least one interviewee in each case study will match each role and (b) are not sure which role will best describe the remaining interviewees.

BLS Job Title	Hourly Rate
Social And Community Service Managers (11-9151)	$33.46
Computer And Information Systems Managers (11-3021)	$72.67
Administrative Services And Facilities Managers (11-3010)	$47.54
Lawyers (23-1011)	$61.03
Database Administrators And Architects (15-1245)	$47.53
Social Workers (21-1020)	$24.88
Average	$47.85

When determining the Total Annual Respondent Cost, we doubled everyone’s hourly rate to account for fringe benefits and overhead.

A13. Costs

There are no additional costs to respondents.

A14. Estimated Annualized Costs to the Federal Government

Cost Category	Estimated Costs
Field Work	$90,672
Publications/Dissemination	$431,010
Total costs over the request period	$521,682
Annual costs	$173,894

A15. Reasons for changes in burden

This is for an individual information collection under the umbrella generic, Formative Data Collections for ACF Program Support (0970 – 0531).

A16. Timeline

Westat plans to complete three case studies every 12 months, beginning September 2021 and ending August 2025. This request covers activities over the next three years. An extension request will be submitted to continue data collection through August 2025.

A17. Exceptions

No exceptions are necessary for this information collection.

Attachments

Instrument 1 - Questionnaire to help select organizations

Instrument 2 - Semi-Structured Interviews

Attachment 1 - Example Letter of Engagement

Attachment 2 - Draft Case Study Outline

1 Language from the Generic IC: The following are some examples of ways in which we may share information resulting from these data collections: technical assistance plans, presentations, infographics, project specific reports, or other documents relevant to stakeholders such as federal leadership and staff, grantees, local implementing agencies, and/or T/TA providers. In sharing findings, we will describe the study methods and limitations with regard to generalizability and as a basis for policy. Any planned uses, including for publication or sharing of information from this IC will be described and submitted for approval in each individual GenIC.

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.

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