Supporting Statement A

Alternative Supporting Statement for Information Collections Designed for

Research, Public Health Surveillance, and Program Evaluation Purposes

Culture of Continuous Learning Project: Landscape Survey

Formative Data Collections for ACF Research

0970 – 0356

Supporting Statement

Part A

April 2023

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:

Nina Philipsen

Part A

Executive Summary

• Type of Request: This Information Collection Request is for a generic information collection under the umbrella generic, Formative Data Collections for ACF Research (0970-0356).

• Description of Request: This request is for a study to conduct surveys of early care and education administrators, directors, and managers to assess the current landscape of quality improvement (QI) delivery systems in states, territories, and Head Start regions. The surveys are part of the Culture of Continuous Learning Project (CCL) which aims to investigate the feasibility of implementing a continuous quality improvement method, called the Breakthrough Series Collaborative, in early care and education programs and systems to support the use and sustainability of evidence-based practices. The proposed information collection has one primary purpose: to gather information about early care and education professionals’ experience with their state, territory, or regional QI delivery systems. The information gathered will inform the development of future CCL research activities. We do not intend for this information to be used as the principal basis for public policy decisions.

A1. Necessity for Collection

States, territories, and Head Start agencies have developed large-scale professional development (PD) and quality improvement (QI) delivery systems that supply training and technical assistance (T/TA) to the early care and education (ECE) field. Recipients of Head Start grants and Child Care and Development Fund (CCDF) funds must plan and report on the use of Head Start and CCDF funds for training and QI purposes. Despite the scale of this QI delivery infrastructure, very little is known about the prevalence of specific attributes of these QI delivery systems and the variation in QI delivery systems among states, territories, and Head Start regions.

Because of the wide variation among states, territories, and Head Start regions, the study’s research goals can only be met by gathering information from as many states, territories, and Head Start regions as possible, ideally all of them. Building on secondary data collection and analysis, the proposed study will use surveys to gather specific information from ECE administrators, managers, and directors regarding the T/TA offered to ECE professionals through QI delivery systems to help improve a child’s learning and development.¹ The findings from this study will directly inform the Culture of Continuous Learning Project (CCL) case studies, which will be submitted to OMB as a full information collection request, and support future research designs related to QI.

There are no legal or administrative requirements that necessitate this collection. The Administration for Children and Families (ACF) is undertaking the collection at the discretion of the agency. ACF has contracted with Child Trends to carry out this study.

A2. Purpose

Purpose and Use

This primary data collection is intended for research purposes and is part of the Office of Planning, Research, and Evaluation (OPRE)-funded CCL Project. The findings from this study will directly inform the development of future CCL research activities in two ways:

1. The data collected will help contextualize the findings from the CCL case studies that will begin after OMB approval² by elucidating the current landscape of QI delivery systems in the states, territories, and Head Start regions in which the CCL case studies will be located; and

2. The entire study, including this data collection, will inform the development of study design options for future evaluations of the Breakthrough Series Collaborative (BSC).

As federal and state governments make large investments in QI delivery systems, we believe this landscape survey study will also contribute to the field’s understanding of the variation in infrastructure and QI offerings among states, territories, and Head Start regions. While we do not intend for this information to be used as the principal basis for a decision by federal decision-makers, we anticipate that federal and state policymakers could use the findings from this information collection and the CCL study overall to help inform their own decisions about QI delivery systems.

This proposed information collection meets the following goals of ACF’s generic clearance for formative data collections for research and evaluation (0970-0356):

• inform the development of ACF research

• maintain a research agenda that is rigorous and relevant

• ensure that research products are as current as possible.

The information collected is meant to contribute to the body of knowledge on ACF programs and 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. Findings will be shared with ACF through an internal report, as well as in public materials to help contextualize the findings from the CCL case studies, and to inform future research designs.

Guiding Questions

This data collection is designed to answer the following guiding questions:

1. What is the QI delivery infrastructure in the state, territory or Head Start region supporting early care and education programs or professionals? To what extent do components of the QI infrastructure vary within and across states, territories, and Head Start regions?

2. In what ways do states, territories, or Head Start regions include individual training, individual coaching, organizational coaching, or collective organizational training in their QI systems serving Head Start programs and CCDF-funded child care programs?

3. How has COVID-19 affected the implementation of QI opportunities (e.g., mode of delivery, availability of trainings or coaches, requirement waivers, increased collaboration)?

4. To what extent and how is the implementation of the Pyramid Model³ supported in states, territories, and Head Start regions?

Table 1 provides a crosswalk between the study instruments, guiding questions, and study objectives. Table 2 describes each of the instruments in more detail.

Table 1. Guiding questions, objectives, and study instruments

Guiding questions	Child Care Development Fund (CCDF) Admin Survey	Child Care Resource & Referral (CCR&R) or QI Delivery Contractor Survey	Head Start Collaboration Office (HSCO) Director Survey	Head Start Education Manager Survey	Head Start Regional Program Manager or Head Start Regional ECE Specialist Survey	Pyramid Model State Lead Survey	Quality Rating and Improvement System (QRIS) Admin or Professional Development (PD) Director Survey
1. What is the QI delivery infrastructure in the state, territory or Head Start region supporting ECE programs or professionals? To what extent do components of the QI infrastructure vary within and across states, territories, and Head Start regions?	X	X	X	X	X	X	X
2. In what ways do states, territories, or Head Start regions include individual training, individual coaching, organizational coaching, or collective organizational training in their QI systems serving Head Start programs and CCDF-funded child care programs?	X	X	X	X	X		X
3. How has COVID-19 affected the implementation of QI opportunities (e.g., mode of delivery, availability of trainings or coaches, requirement waivers, increased collaboration)?	X	X	X	X	X	X	X
4. To what extent and how is the implementation of the Pyramid Model supported in states, territories, and Head Start regions?	X		X		X	X
Study objectives
1. Contextualize the CCL case studies by examining the current landscape of QI delivery systems in the states, territories, and Head Start regions the CCL case studies will be located	X	X	X	X	X	X	X
2. Inform study design options for future evaluations of the BSC	X	X	X	X	X	X	X

Study Design

To answer the guiding questions, the research team will build off secondary data collection and analysis (see Table 3 for details) to conduct one-time, web-based surveys of ECE administrators, Pyramid Model leads, and local Head Start education managers in states, territories, and Head Start regions about their QI delivery infrastructure, coaching and training opportunities at the individual and organizational level, the effect of COVID-19 on the provision of QI opportunities, and the extent to which the Pyramid Model is implemented in the state/territory/region. This data collection will also ask about perceptions of collaboration and integration of these QI delivery systems with states, territories, and among Head Start regions.

Data collected from this study will provide important context for the CCL case studies. For example, findings from this study will allow us to describe how the states in which the CCL case studies are located compare to other states in terms of QI infrastructure, thereby enabling us to make more informed recommendations for integration of a BSC into existing QI systems. Survey methodology is an efficient and reliable form of data collection from individuals to characterize aspects of their experiences. This sample is not intended to be nationally representative, and our interpretation of the data will limit generalizability.

Table 2. Summary of proposed data collection activity

Instruments	Respondent, Content, Purpose of Collection	Mode and Duration
Instrument 1: CCDF Administrator Survey	Respondents: CCDF administrators from each state and territory Content: Questions about aspects of administrators’ QI policies, infrastructure, training, and the way their QI opportunities are implemented Purpose: Gather information from CCDF administrators about their state or territory QI delivery infrastructure, how they include training and coaching opportunities in their QI system, how COVID-19 has affected implementation of QI opportunities, and the extent to which the Pyramid Model is implemented in their state or territory	Mode: Web-based Duration: 20 minutes
Instrument 2: CCR&R or QI Delivery Contractor Survey	Respondents: CCR&R or QI delivery contractor from each state and territory Content: Questions about aspects of contractors’ QI policies, infrastructure, training, and the way their QI opportunities are implemented Purpose: Gather information from CCR&R or QI delivery contractors about their state or territory QI delivery infrastructure, how they include training and coaching opportunities in their QI system, and how COVID-19 has affected implementation of QI opportunities	Mode: Web-based Duration: 20 minutes
Instrument 3: Head Start Collaboration Office (HSCO) Director Survey	Respondents: Head Start Collaboration Office director from each state and DC  Content: Questions about aspects of directors’ QI policies, infrastructure, training, and the way their QI opportunities are implemented Purpose: Gather information from Head Start Collaboration Office directors about their state QI delivery infrastructure, how they include training and coaching opportunities in their QI system, how COVID-19 has affected implementation of QI opportunities, and the extent to which the Pyramid Model is implemented in their state	Mode: Web-based Duration: 20 minutes
Instrument 4: Head Start Education Manager Survey	Respondents: Head Start education manager from each region Content: Questions about aspects of Head Start education managers’ experiences with QI opportunities and support Purpose: Gather information from Head Start education managers about their region’s QI delivery infrastructure, how they include training and coaching opportunities in their QI system, and how COVID-19 has affected implementation of QI opportunities	Mode: Web-based Duration: 20 minutes
Instrument 5: Head Start Regional Program Manager or Head Start Regional ECE Specialist Survey	Respondents: Head Start regional manager or Head Start regional ECE specialist from each region Content: Questions about aspects of managers’ QI policies, infrastructure, training, and the way their QI opportunities are implemented Purpose: Gather information from Head Start regional managers or Head Start regional ECE specialists about their region’s QI delivery infrastructure, how they include training and coaching opportunities in their QI system, how COVID-19 has affected implementation of QI opportunities, and the extent to which the Pyramid Model is implemented in their region	Mode: Web-based Duration: 20 minutes
Instrument 6: Pyramid Model State Lead Survey	Respondents: Pyramid Model state lead from each state Content: Questions about aspects of Pyramid Model state leads’ policies, infrastructure, training, and the way their implementation supports are offered Purpose: Gather information from state Pyramid Model leads about their state QI delivery infrastructure, how COVID-19 has affected implementation of QI opportunities, and the extent to which the Pyramid Model is implemented in their state	Mode: Web-based Duration: 20 minutes
Instrument 7: QRIS Administrator or PD Director Survey	Respondents: QRIS administrator or PD director from each state Content: Questions about aspects of QI administrators’ policies, infrastructure, training, and the way their implementation supports are offered Purpose: Gather information from QRIS administrators or PD directors about their state QI delivery infrastructure, how they include training and coaching opportunities in their QI system, and how COVID-19 has affected implementation of QI opportunities	Mode: Web-based Duration: 20 minutes

Other Data Sources and Uses of Information

Secondary data analysis including web searches and document reviews will be used to research existing QI delivery systems in each state, territory, and Head Start region prior to the administration of surveys. For this analysis, we are using publicly available information that has already been synthesized as to not duplicate any other data sources. The proposed data sources and how they will be used for this study are illustrated in Table 3.

Information from this data collection will inform the case study that is part of OPRE’s larger CCL project (as noted previously).

Table 3. Proposed secondary data analysis sources and use

Proposed data source	Data description	Most recent year available to include in scan	States/Regions included	Key variables/fields
CCDF State Plans	All CCDF lead agencies are required to submit a plan for use of their CCDF funds, including the use of funds for professional development and quality improvement activities	FFY 2022-2024	All CCDF state and territory recipients	Section 6 describes the ways that lead agencies are offering, coordinating, and providing incentives for professional development (PD) Section 7 describes the activities that lead agencies offer for quality improvement, and what financial incentives and other supports they offer to ECE providers for participating in these activities
CCDF Quality Progress Reports	All CCDF lead agencies are required to submit an annual report on their quality goals, spending, activities, participation, etc., based on their stated goals from the most recent CCDF plan. This is a record of the previous years' activities and spending on the 10 approved QI activities	FFY 2022	All CCDF state and territory recipients	Section 1 describes the number of providers across provider types. It also lists the lead agencies’ goals for QI Section 2 includes information about use of workforce registries, PD supports to providers, and PD participation
Quality Compendium	QRIS administrators are asked to complete an extensive profile of their QRIS, including program participation, indicators of quality, technical assistance, financial incentives, observation and assessment, etc. These data are self-reported and only some items verified for accuracy	2021	50 states and DC	Includes types of TA and QI activities available by program type, participation rates in TA and QI activities, duration of TA, number of TA and QI providers in the state, eligibility requirements for TA or QI supports, and types of data included in QI data system
Head Start Program Information Report (PIR)	Grantees report on aspects of Head Start implementation (i.e., number of children and families served, staff qualifications) and performance indicators. These data are reported annually. The PIR report database allows users to aggregate any of the data fields at the national-, Head Start Region-, state-, grantee-, or program-level. Most data are available in raw counts as well as percentages or proportions	FFY 2021	All Head Start, Early Head Start, and AIAN Head Start grantees	Includes staff counts, performance indicators about staff qualifications, staff race/ethnicity and languages spoken Also includes relevant Pyramid Model implementation fields, and counts of available coaches, and teachers receiving intensive coaching
Education Commission on the States Annual Early Childhood Governance Report	This report lists the location of the lead agency for a variety of early childhood programs (e.g., CCDF, HSCO, Part C) in the 50 states and DC	2020	50 states and DC	Indicates the lead agency for CCDF, HSCO, and other early childhood programs
Pyramid Model Consortium Website	The Pyramid Model Consortium lists all current partner and affiliate states that access Pyramid Model resources	2020	50 states, DC, and territories	Lists states and affiliates, as well as participation in training modules from states not officially affiliated with the consortium
Pyramid Model report “Statewide Implementation in Early Care and Education programs”	This report compares the various ways that states and territories support the implementation of the Pyramid Model. The appendix table in the report provides a state-by-state (and territory) overview of the state of implementation and what types of Pyramid Model activities the state or territory accesses (e.g., professional development only, statewide leadership team, coaching and training cadre). The report also provides contact information for each state and territory coordinating organization	2021	50 states, DC, and territories	Lists states, description of activities, state of implementation, funding sources, state-level coordinating organization contact information

A3. Use of Information Technology to Reduce Burden

Surveys will be administered online through REDCap, the study team’s secure online data collection platform. Links to the survey will be distributed electronically. Conducting surveys online will allow respondents to complete the survey on their own time and take pauses as needed, thereby minimizing respondent burden.

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

The proposed study does not duplicate any other work being done by ACF and does not duplicate any other data sources. A secondary data analysis scan is being conducted prior to survey administration to reduce burden and ensure participants are not asked information that is publicly available; see section A2 for more information.

A5. Impact on Small Businesses

Many ECE center and family child care (FCC) directors included in this study will be small businesses. We will minimize the burden to respondents by limiting the survey length and providing the survey in a web-based format that respondents can complete at their convenience.

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 (PRA) 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 November 3, 2020, Volume 85, Number 213, page 69627, and provided a sixty-day period for public comment. The second notice published on January 11, 2021, Volume 86, Number 6, page 1978, and provided a thirty-day period for public comment. ACF did not receive any substantive comments.

Consultation with Experts Outside of the Study

To prepare for and inform the development of the study plan and instruments, the research team consulted with one Pyramid Model National Consortium leader and four Office of Head Start (OHS) staff (Table 4). The input from these experts helped the CCL study team identify sources of secondary data, as well as barriers to collecting information from ECE administrators, managers, and directors in states, territories, and Head Start regions. Specifically, discussions with OHS staff informed the language and framing of the survey questions. Additionally, our conversations with experts helped the CCL team determine whether the survey questions are in the realm of respondents’ purview, such that we can reasonably expect respondents will know how to answer each question. Fewer than 10 experts were engaged in this consultation, therefore this activity is not subject to PRA.

Table 4. CCL Project expert consultants

	Name and Affiliation	Expertise
	Methodological and Content Experts
1.	Anna Wimmer, Quality Assurance Coordinator for the Pyramid Model Consortium	Pyramid Model; has worked with EC caregivers to provide evidenced-based strategies that promote social and emotional development and reduce challenging behaviors; has also provided a variety of trainings to state teams, early childhood programs, and professionals in the implementation of the Pyramid Model
	Head Start Experts
2.	Kiersten Beigel, Training and Technical Assistance Data Lead and Parent and Family and Community Engagement Lead, OHS	Head Start T/TA; Socio-emotional learning (SEL)
3.	Karen Haying, Senior Program Analyst and liaison to Head Start Collaboration Office Directors, OHS	Head Start T/TA; State coordination between Head Start and other ECE systems
4.	Sharon Yandian, Director of Comprehensive Services and TTA, OHS	Head Start T/TA implementation and administrative data

A9. Tokens of Appreciation

Head Start Education Managers and state/territory CCR&R or QI delivery agency/contractor representatives will provide valuable information about their understanding of the QI landscape in their state, territory, or region—information that it vital to capturing the full landscape of QI delivery systems. The CCL team is concerned that an inadequate response rate from these participants would degrade the overall study and prevent it from meeting study objectives. Unlike other respondents, completing the survey in this study is above and beyond the typical job responsibilities of a Head Start Education Manager or CCR&R or QI delivery agency/contractor representative. To increase engagement with data collection efforts for these participants and collect data that are as representative as possible, the CCL team will provide a $20 token of appreciation to Head Start Education Managers and state/territory CCR&R or QI delivery agency/contractor representatives who complete the one-time, 20-minute survey.

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

Personally Identifiable Information

In most states, territories, and Head Start regions, the research team will gather ECE professionals’ names and contact information (work telephone numbers and work email addresses) from publicly available sources, when available, for the purposes of recruitment and follow-up to maximize survey response rates. Email addresses will be initially associated with survey responses to track who has completed the surveys and, thus, who needs a follow-up reminder. For Head Start education managers, their contact information may not be systematically available online in public directories. We will request names and contact information (work telephone numbers and work email addresses) from the Office of Head Start for a random sample of Head Start grantees within each state. All data will be completely de-identified once data collection is complete.

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

Information collected will be kept private to the extent permitted by law. Respondents will be informed of all planned uses of data, that their participation is voluntary, and that their information will be kept private to the extent permitted by law. As specified in the contract, the Contractor will comply with all Federal and Departmental regulations for private information. The research team obtained an Institutional Review Board (IRB) letter of exemption for all aspects of this study.

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 Security Plan that assesses all protections of respondents’ Personally Identifiable Information (PII). As is described in the Data Security Plan, during data collection all PII and data will be stored in REDCap, our secure online data collection and management platform, hosted on a FISMA-compliant Microsoft Azure Server. For analysis of the open-ended questions, data will be read into Dedoose, a FedRAMP and NIST 800-53 compliant data analysis package. We will ensure that all employees, subcontractors (at all tiers), and employees of each subcontractor who have access to these data are trained on data privacy issues and comply with the above requirements. At the completion of data collection and analysis, data will be stored on Child Trends’ secure drive to which only authorized users have access. The secure drive utilizes Windows Active Directory security groups for access control and utilizes Encrypting File System (EFS) on demand.

A11. Sensitive Information ⁴

We will ask respondents to provide their gender, race, and ethnicity in the survey instruments. While not necessarily considered sensitive information by all respondents, some respondents may find these questions sensitive in nature. Like all other questions, these demographic questions are voluntary, and will only be reported in aggregate. The purpose of asking these demographic questions is to understand the representation of these social identities in the administrators in QI delivery systems in ECE.

A12. Burden

Explanation of Burden Estimates

To estimate the burden for the surveys, the project team piloted each survey with fewer than ten individuals. Each survey will take no more than 20 minutes to complete. Table 5 summarizes our burden estimates for the proposed instruments. See Supporting Statement Section B2 for more information on participant sampling methods.

Estimated Annualized Cost to Respondents

The estimated annualized cost for respondents is shown in Table 5. The source for the mean hourly wage information for each respondent type is based on information from the Bureau of Labor Statistics, Occupational Employment and Wages, May 2021.

• For Pyramid Model leads, Head Start Regional Program managers, Head Start Collaboration Office managers, CCDF and QRIS administrators, and CCR&R and QI delivery contractors, the mean hourly wage of $40.80 was used, based on the wage for state government, excluding schools and hospitals, “Education and Childcare Administrators, Preschool and Daycare: Child Day Care Services” (https://www.bls.gov/oes/current/oes119031.htm).

• For Head Start education managers, the mean hourly wage of $25.87 was used, based on the wage for “Education and Childcare Administrators, Preschool and Daycare: Child Day Care Services” (https://www.bls.gov/oes/current/oes119031.htm).

 

Table 5. Annual burden and cost estimates

Instrument	No. of Respondents (total over request period)	No. of Responses per Respondent (total over request period)	Avg. Burden per Response (in hours)	Total/Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
CCDF Administrator Survey	56	1	0.33	19	$40.80	$775.20
CCR&R or QI Delivery Contractor Survey	56	1	0.33	19	$40.80	$775.20
Head Start Collaboration Office Director Survey	54	1	0.33	18	$40.80	$734.40
Head Start Education Manager Survey	280	1	0.33	92	$25.87	$2,380.04
Head Start Regional Program Manager or Head Start Regional ECE Specialist Survey	12	1	0.33	4	$40.80	$163.20
Pyramid Model State Lead Survey	32	1	0.33	11	$40.80	$448.80
QRIS Administrator or PD Director Survey	56	1	0.33	19	$40.80	$775.20
Total/Annual Burden and Costs:				182		$6,052.04

A13. Costs

There are no additional costs to respondents.

A14. Estimated Annualized Costs to the Federal Government

The total cost to the Federal government for the data collection activities under this current request will be $258,660.61.

Cost Category	Estimated Costs
Data Collection	$125,000
Analysis	$75,000
Reporting	$58,660.61
Total/Annual costs over the request period	$258,660.61

A15. Reasons for changes in burden

This is for an individual information collection under the umbrella formative generic clearance for ACF research (0970-0356).

A16. Timeline

Activity	Anticipated Duration after OMB approval
Begin recruitment	Within 1 month
Data collection	Months 1 through 3 (3-month window)
Data analysis	Months 4 through 5 (2-month window)
Draft report	Months 6 through 7 (2-month window)
Final report	Month 8

A17. Exceptions

No exceptions are necessary for this information collection.

Attachments

Instrument 1: CCDF Administrator Survey

Instrument 2: CCR&R or QI Delivery Contractor Survey

Instrument 3: Head Start Collaboration Office Director Survey

Instrument 4: Head Start Education Manager Survey

Instrument 5: Head Start Regional Program Manager or Head Start Regional ECE Specialist Survey

Instrument 6: Pyramid Model State Lead Survey

Instrument 7: QRIS Administrator or PD Director Survey

Appendix A: Recruitment materials/outreach

Appendix B: Recruitment materials/outreach for Head Start Education Managers and CCR&R Representatives

1 Throughout this Supporting Statement, “QI delivery systems” is used to refer to the activities of the system (provision of professional development, financial supports such as grants and loans, quality rating systems, and data capacity building) and system infrastructure components (the agencies and organizations that carry out QI, financing, procedures, and policies).

2 The referenced CCL case studies will be submitted to OMB as a full ICR in the near future. The 30-day public comment period for that request began on December 16, 2022 (ICR Reference No: 202212-0970-007).

3 The Pyramid Model is a framework for how to support children’s social emotional development in early childhood classrooms and a focus of the larger CCL project. Many states have adopted the use of Pyramid Model as their primary social emotional development strategy. For these states, there is a “state lead” who is typically a state agency staff member in either a human service, education, or health agency.

4 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.

4