OMB Change Justification Memo 0584-0680 - 6.28.23_Clean _OMB - FNS_Clean

Food and

Nutrition
Service

1320

Braddock

Place

Alexandria,

VA

22314

T O: Laurel Havas

OMB Desk Officer

Office of Information and Regulatory Affairs

Office of Management and Budget (OMB)

THROUGH: Ruth Brown

Department Clearance Officer

United States Department of Agriculture

Office of Chief Information Office (OCIO)

Jamia Franklin

Information Collection Clearance Officer

OPS/Planning and Regulatory Affairs Office

Food and Nutrition Service (FNS)

FROM: Anna Vaudin

SNAP Evaluation Branch

OPS/SNAP Research and Analysis Division

Food and Nutrition Service (FNS)

DATE: June 15, 2023

SUBJECT: Justification for changes to text messages sent in Minnesota Hennepin intervention for OMB Control No: 0584-0680 “Rapid Cycle Evaluation of Operational Improvements in Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T) Programs”.

The Food and Nutrition Service (FNS) is requesting a non-substantive change to the study of Rapid Cycle Evaluation of Operational Improvements in Supplemental Nutrition Assistance Program (SNAP) Employment & Training (E&T) Programs, approved under OMB Control No. 0584-0680; expiration date of March 31, 2026. FNS made non-substantive edits to the text messages that will be sent to participants at the Massachusetts, Minnesota-Hennepin, Minnesota-Rural, Rhode Island, and Colorado study sites. Some of these changes are due to policy changes that require states to enforce time limits on how long able-bodied adults without dependents (ABAWDs) can receive SNAP while remaining unemployed. Each site is navigating this change a bit differently, and changes in messaging relevant to the new policy are described below.

Only one of the changes resulted in a change to the study design (Minnesota-Hennepin site, described below and in the attachments). None of the revisions ask respondents to submit any new or additional documentation to FNS. The estimated time for reading and taking action in response to the text messages is not impacted by these changes. There will be no changes to the burden table.

Please see the following information for a detailed explanation regarding the requested changes for each site. The changes to the text messages are shown in the attachments.

Colorado:

The time limit waiver for ABAWDs is also ending in Colorado. Due to this policy change, the Colorado site will be sending different messages to ABAWDs and non-ABAWD work registrants. The non-ABAWD messages are the same as those approved in the original OMB package, and the messages for ABAWDs have been updated to acknowledge the time limit.

There are two types of text messages being tested in this site (mere exposure and endowment), and both will now have an ABAWD version and a non-ABAWD version. These are shown below and in the attached Appendix B2.

Message 1: Mere Exposure

Old Message (still being used, non-ABAWDs only):

“Hi [NAME]! I’m [NAME] with [COUNTY NAME] County’s Employment First Program. I’m here to help you enroll in Employment First, a program supported through your SNAP benefits that can help you find a job or enroll in training to help you get the job you want. We can support a flexible schedule that works best for you. You can also get help with the costs of transportation, work or training supplies, and rent as you participate in the program. Lots of people like you have enrolled in our services and received well-paying jobs. We are holding a spot for you!

Reply YES to receive a call to learn more and enroll today or STOP to stop receiving messages”

New Message (ABAWDs only):

“Hi [NAME]! I’m [NAME] with [COUNTY NAME] County’s Employment First Program. There are rules about SNAP benefits that [will come into effect soon/are in effect] that may require you to have a job or enroll in training to keep getting your SNAP benefits. Luckily our program offers free help to find a job or get training for a job so you can follow these rules and keep your SNAP benefits.

We understand that you might need a flexible schedule that works for you, and we can support that. We can also help you with the costs of transportation, work or training supplies, and rent while you’re in the program. Lots of people like you have enrolled in our services and found well-paying jobs. We are holding a spot for you!
Reply YES to receive a call to learn more and enroll today or STOP to stop receiving messages”

Message 2: Endowment

Old Message (still being used, non-ABAWDs only):

“[NAME], you are entitled to free services supported by your SNAP benefits to help you find a job or enroll in training to help you get the job you want. We can help with the costs of transportation, rent, and other work or training supplies, and support a flexible schedule that works best for you. Your spot in Employment First is waiting for you!

Reply YES to receive a call to learn more and enroll today!”

New Message (ABAWDs only):

“[NAME], you may be close to losing your SNAP benefits because of changes to the current work rules. I can help you keep your benefits by enrolling you in free services to help you find a job or enroll in training to help you get the job you want. We can help with the costs of transportation, rent, and other work or training supplies, and support a flexible schedule that works best for you. Your spot in Employment First is waiting for you!

Reply YES to receive a call to learn more and enroll today!”

Message 3: Loss Aversion Old Message (still being used, non-ABAWDs only):

“[NAME], don't miss your chance to get free services to help you find a job, enroll in training, and help with the costs of transportation, rent, and other work and training supplies offered through your SNAP benefits! By signing up for food benefits, you have already started on the path to finding a long-term career. Take advantage of these free services on a flexible schedule that works for you!

Reply YES to receive a call to learn more and enroll today or STOP to stop receiving messages”

New Message (ABAWDs only):

“[NAME], don't miss your chance to get free services that will help you keep your SNAP benefits. You are entitled to a spot in Employment First to help you find a job, enroll in training, and help with the costs of transportation, rent, and other work and training supplies! By signing up for SNAP, you have already started on the path to finding a long-term career. Take advantage of these free services on a flexible schedule that works for you!
Reply YES to receive a call to learn more and enroll today or STOP to stop receiving messages”

Text in the emails is also changing for ABAWDs vs non-ABAWDs. The following describes the text that is changing. The text context of the images that will comprise the emails is included in the attachments in Appendix B2. There are different images by county because the E&T

Old Email Text: “Your spot is waiting! Achieve your career goals with career coaching and support with transportation and work items. Interested? Click here to receive a call from us to learn more. Or call XXX-XXX-XXXX to enroll. Visit bitly.url to learn more.”

New Email Text:

For non-ABAWDs: “Your spot is waiting! Find and keep a well-paying job with career coaching & support with transportation and work items. Interested? Reply YES to this email to receive a call from us to learn more and get started.”

For ABAWDs: “Your spot is waiting! WE can help you meet your work requirements to keep your SNAP benefits. Find and keep a well-paying job with career goaching & support with transportation and work items. Interested? Reply YES to this email to receive a call from us to learn more and get started.”

*Note, there are different emails for different locations because the E&T program has different names in these different locations.

The text on the postcard is also changing for ABAWDs.

Old Postcard Text (remains the same for non-ABAWDs): “Achieve your career goals with career coaching & support with transportation and work items.”

New Postcard Text (ABAWDs only): “We can help you meet your work requirements to keep your SNAP benefits. Find and keep a well-paying job with career coaching & support with transportation and work items.:

Massachusetts:

The approved text message content has not changed, however the study team at the Massachusetts Department of Transitional Assistance reviewed the languages spoken by the population they serve and decided it was important to have the texts translated into Haitan Creole, Chinese, Portuguese, Spanish, and Vietnamese. These translated messages are shown below, as well as in the attachments in Appendix B2.

Text message #1 in English:

“Hi [NAME], since you signed up for food benefits, you have access to free help with employment and training! Text YES to receive information about how to enroll. Your spot is waiting for you!”

Haitian Creole: Alo [NAME], paske ou te enskri pou avantaj manje, ou gen aksè ak èd gratis pou travay ak fòmasyon! Voye Tèks WI pou w resevwa enfòmasyon sou fason pou w enskri. Plas ou la ap tann ou!

Chinese: [NAME]，您好！您已经注册了食品补助金，现在可以免费获得就业和培训帮助！发送短信“YES”，获得有关如何报名的信息。欢迎报名！ 

Portuguese: Oi [NOME], desde que você se inscreveu nos benefícios de alimentação, você tem acesso a ajuda gratuita com emprego e treinamento! Responda SIM para receber informações sobre como se inscrever. Sua vaga está aguardando você! 

Spanish: Hola [NAME], como se inscribió para recibir beneficios alimentarios, ¡tiene acceso a ayuda gratuita para empleo y formación! Envíe SÍ por mensaje de texto para recibir información sobre cómo inscribirse. ¡Hay un lugar esperando por usted! 

Vietnamese: Xin chào [NAME], vì bạn đã đăng ký nhận phúc lợi thực phẩm, bạn có quyền truy cập để nhận trợ giúp việc làm và đào tạo miễn phí! Soạn tin nhắn CÓ để nhận thông tin về cách đăng ký tham gia. Chỗ của bạn đang chờ bạn! 

Text message #2 in English:

Public Burden Statement

This information is being collected to assist the Food and Nutrition Service in evaluating operational improvements in Supplemental Nutrition Assistance Program (SNAP) Employment and Training (E&T) programs that aim to improve delivery of services and program outcomes. This is a voluntary collection and FNS will use the information to assess the effectiveness of changes made to the SNAP E&T program. This collection does request any personally identifiable information under the Privacy Act of 1974. According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0584-[xxxx]. The time required to complete this information collection is estimated to average 1 minute (0.0167 hours) per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to: U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, 1320 Braddock Place, 5th Floor, Alexandria, VA 22306 ATTN: PRA (0584-xxxx). Do not return the completed form to this address.

“Hi [NAME]. Did you know you are eligible to enroll in free employment and training services to help you advance your career as part of your food benefits? It’s true! Respond YES to learn more.”

Haitian Creole: Alo [NAME]. Èske w te konnen ou kalifye pou w enskri nan sèvis travay ak fòmasyon gratis pou ede w avanse nan karyè w kòm yon pati nan avantaj manje ou yo? Se verite! Reponn WI pou aprann plis.

Chinese: [NAME]，您好。您知道吗？作为食品补助金的一项福利，我们可免费为您提供就业和培训服务，助您取得更好的职业发展。这是真的！回复“YES”即可了解详情。   

Portuguese: Oi [NOME]. Você sabia que você está apto(a) à se inscrever nos serviços gratuitos de emprego e treinamento para ajudá-lo(a) a progredir em sua carreira como parte dos seus benefícios alimentares? É verdade! Responda SIM para saber mais.   

Spanish: Hola [NAME]. ¿Sabía que como parte de sus beneficios alimentarios es elegible para inscribirse gratuitamente en los servicios de empleo y formación que le ayudarán a progresar profesionalmente? ¡Es así! Responda SÍ para obtener más información.   

Vietnamese: Xin chào [NAME]. Bạn có biết bạn đủ điều kiện đăng ký tham gia các dịch vụ việc làm và đào tạo miễn phí nhằm giúp bạn thăng tiến trong nghề nghiệp như một phần của phúc lợi thực phẩm? Đó là sự thật! Phản hồi CÓ để tìm hiểu thêm.   

Minnesota-Rural:

The Minnesota IRB requested that the first text message sent to the participants states that it is from the Department of Human Services, and includes a statement that tells recipients how to opt out of receiving messages. There are no other changes. The changes are shown below, and in the attached Appendix B2.

Original message: Hi [NAME], because you're on SNAP, [PROVIDER] can help you reach your employment and training goals. Call XXX-XXX-XXXX today to learn about SNAP E&T.

New Message: This is the Department of Human Services. Hi [NAME], because you're on SNAP, [PROVIDER] can help you reach your employment and training goals. Call XXX-XXX-XXXX today to learn about SNAP E&T. If you do not want to receive messages, please reply with STOP.

Minnesota-Hennepin:

Due to the COVID-19 public health emergency ending, the time limit waiver that would allow ABAWDs to receive SNAP benefits even if they are not employed is expiring. The State government will be sending text messages to affected ABAWDs to let them know their benefits could expire if they don’t obtain employment. Since ABAWDs who are not yet enrolled in SNAP E&T are the target audience of this intervention, the intervention text messages need to be adjusted to be relevant within the context of the policy change and the text messages from the state.

There are two versions of each: one that is a single text that does not mention the participant by name (“Group 1”), and one that will arrive as two sequential texts (one immediately following the other), which will mention the participant by name (“Group 2”). Due to character limits, the participant’s name would not fit into a single text, hence the inclusion of the 2-text version. The intervention will test the effect of receiving messages from Group 1, the effect of receiving messages from Group 2, and the effect of receiving no messages (control group).

This updated design is described further in the attached Appendix B1. The revised text messages are shown below, and also in the attached Appendix B2.

Original Messages:

Text message 1: Mere exposure

Hi [NAME]. I’m [NAME] with SNAP E&T at Hennepin County. I’m here to help you enroll in employment and training as part of your food benefits. Call XXX-XXX-XXXX to learn more.

Text message 2: Endowed progress

Hi [NAME]. Since you’re already getting food benefits, you’re on your way to getting job training! Call the SNAP E&T team today at XXX-XXX-XXXX. Your spot is waiting for you!

Text message 3: Loss aversion

Hi [NAME]. I saw that you are about to lose your food benefits. I can help you keep them by enrolling you in an employment and training program. Call the SNAP E&T team today at 999-999-9999.

Revised Messages:

Text message 1: Mere exposure	HENN-Hi I’m Colleen with SNAP E&T. For help finding a job or getting training call XXX-XXX-XXXX	#1:HENN-Hi NAME. I’m Colleen with SNAP E&T #2: HENN-I can help you find a job or get training. Call XXX-XXX-XXXX to learn about this exciting program!
Text message 2: Loss aversion and endowed progress effect	HENN- SNAP work rules are in effect soon but we provide help finding a job or training! Call XXX-XXX-XXXX now	#1: HENN-Hi NAME. SNAP work rules come back into effect soon, but getting SNAP qualifies you for free job search or training help #2: HENN-Call us at XXX-XXX-XXXX. Your spot with us is waiting!
Text message 3: Loss aversion	HENN-You may soon lose SNAP. Enroll in our job program to keep your benefits. Call XXX-XXX-XXXX	#1-HENN-Hi NAME. You may be close to losing your SNAP #2: HENN-I can help you keep your benefits by finding a job or getting training. Call XXX-XXX-XXXX today

Rhode Island:

The time limit waiver for ABAWDs is also ending in Rhode Island, and so the Rhode Island intervention will only target non-ABAWD work registrants. The OMB originally approved 2 messages for each person: ABAWDs were to receive an endowment and then loss aversion message and non-ABAWD work registrants were to receive two endowment messages. The ABAWD pathway is not longer possible, but the non-ABAWD work registrants (and ABAWDs that are exempt from the work requirement) are still receiving two endowment messages as before. The total number of participants remains the same.

Original Messages:

ABAWDs and Work Registrants Text/Email: Endowment

Hi [NAME]! It’s [NAME], from Rhode Island DHS. Did you know that as part of your SNAP benefits you are eligible for free education and training and/or job search support? If you participate, you may be able to get help paying for things like transportation, childcare, or other items. Reply Y and we will call you to get started. [or “Visit [web address] to learn more about these exciting opportunities.”] Reply STOP to stop receiving messages about employment and training.

Work Registrants Text/Email: Endowment

Hi [NAME]! It’s [NAME], from Rhode Island DHS. Just a reminder that as part of your SNAP benefits you are eligible for free training. You could be eligible for all kinds of training, including for a job as a [nursing assistant, truck driver, or machinist.] Reply Y and we will call you to help you get started on a new career today. [or “Visit [web address] to learn more about training opportunities.”] Reply STOP to stop receiving messages about employment and training.

ABAWDs Text/Email: Loss aversion

Hi [NAME]! It’s [NAME], from Rhode Island DHS. Did you know your ABAWD grace period is running out? Don’t worry, I can help! I can enroll you in an employment and training program, so you meet your work requirements and keep your SNAP benefits. The program offers free services to help you find a job or start education/training. We also have supports you need for your employment journey! Reply Y today and we will call you to share more information! [or Visit [web address] to get started.] Reply STOP to stop receiving messages about employment and training

New Messages:

Message #1 (Endowment Effect) for Work registrants and exempt ABAWDs

Hi [NAME]! This is the SNAP Employment &Training program at RI DHS. Did you know that as part of your SNAP benefits you are eligible for free education and training and/or job search support? Once you’re enrolled in the program and participating, you may be able to get help paying for things like transportation, childcare, or other items. Reply Y and we will call you to get started. [or Visit https://risnapet.org/snap-participants/ to learn more about these exciting opportunities.] Reply STOP to stop receiving messages about employment and training.

Message #2 (Endowment Effect) for Work registrants and exempt ABAWDs

Hi [NAME]! This is the SNAP Employment &Training program at RI DHS. Just a reminder that as part of your SNAP benefits you are eligible for free training. You could be eligible for all kinds of training, including for a job as a nursing assistant, truck driver, or machinist. Reply Y and we will call you to help you get started on a new career today. [or Visit https://risnapet.org/snap-participants/ to learn more about training opportunities.] Reply STOP to stop receiving messages about employment and training.

If you have any questions regarding this request, please contact Jamia Franklin, FNS Information Collection Clearance Officer for the Food and Nutrition Service, Planning & Regulatory Affairs Office at (703) 305-2403.

Attachments:

• Appendix B1. Summary of Intervention Designs

  • Shows updated intervention design for Minnesota-Hennepin Site. Clean and Tracked Changes versions included.

• Appendix B2. Intervention Outreach Materials

  • Show edits to messages for Massachusetts, Minnesota-Henepin, Minnesota-Rural, Rhode Island, and Colorado. Clean and Tracked Changes versions included.

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