COSS Memo to OMB

U.S. Department of Justice

Office of Justice Programs

Bureau of Justice Statistics

Washington, D.C. 20531

MEMORANDUM TO: Robert Sivinski

Office of Statistical Policy and Planning

Office of Management and Budget

THROUGH: Kevin M. Scott

Acting Director

Bureau of Justice Statistics

Shelley S. Hyland

Senior Statistical Advisor

Bureau of Justice Statistics

Kristin Tennyson

Deputy Director

Bureau of Justice Statistics

Richard Kluckow

Chief, Prisons Corrections Statistics Unit

Bureau of Justice Statistics

FROM: Tracy L. Snell

Statistician, Prisons Corrections Statistics Unit

Bureau of Justice Statistics

SUBJECT: BJS request to conduct interviews with data administrators and/or human resources staff to assess the feasibility of developing a complete and accurate data collection on stressors and potential correlates of suicide among correctional officers working in federal, state, local, and private correctional facilities under the OMB generic clearance agreement (OMB Control # 1121-0339)

DATE: May 30, 2024

Introduction

The Bureau of Justice Statistics (BJS) is requesting clearance under the OMB generic clearance agreement (OMB Control # 1121-0339) to conduct a feasibility study for the Correctional Officer Stressors and Suicide (COSS). The results of this study will be used to develop recommendations for how BJS can obtain complete and accurate data on stressors and correlates of suicide for correctional officers (COs) working in federal, state, local, and privately-operated correctional facilities. The goal of the feasibility study is to identify if correctional facilities can provide information relevant to CO stress and suicide, understand challenges in collecting such data, and develop an appropriate research design to minimize such challenges if BJS determined that it is feasible to pursue a national survey collection.

BJS’s data collection agent for this project, Abt Global (Abt), will conduct the COSS feasibility study on behalf of BJS starting in Summer 2024 through approximately September 2024. BJS will work together with Abt to recruit and conduct interviews with up to 40 respondents from state departments of correction (DOC), the Federal Bureau of Prisons (BOP), local jail jurisdictions, and large private corporations that operate contract correctional facilities. Respondents will be asked to participate in telephone or virtual interviews to learn if they can answer survey questions about administrative data related to CO stress and suicide and the challenges of summarizing data from their systems to BJS. The feasibility study will examine how correctional agencies manage and track information potentially related to correctional officer stress and suicide, what data are available from these systems, and the presence of technical and confidentiality issues that may affect their ability to provide data to BJS. The total burden is estimated at 95 minutes per respondent, including 15 minutes for scheduling each interview, 60 minutes for conducting the interview, and 15 minutes for data quality follow-up for about ⅓ of respondents. BJS will use the findings from the COSS feasibility study to develop a draft survey instrument, which will be tested in a subsequent round of cognitive testing.

Justification

This feasibility study is being conducted in response to the Joint Explanatory Statement accompanying the Consolidated Appropriations Act of 2021 (Public Law 116-260), which directed the Office of Justice Programs (OJP) to collect data on law enforcement suicide. Given the comprehensive definition of law enforcement as specified in the Law Enforcement Suicide Data Collection Act (LESDCA; Title 34, United States Code, Section (§) 50701), which includes correctional officers, BJS seeks to specifically examine the stressors and correlates associated with suicide for correctional officers in this study.

BJS has collected information pertaining to correctional staff characteristics in the Census of State and Federal Adult Correctional Facilities (CCF – OMB Control # 1121-0147) and the Census of Jails (COJ – OMB Control # 1121-0100). These data collections have not included data on workplace stressors and correctional officer suicide. In order to address this request, BJS will conduct a study to determine the feasibility of conducting a national establishment survey on correctional officer stressors and suicide in federal, state, local, and private facilities.

Feasibility Study Design and Procedure

The purpose of the proposed feasibility study is to determine if operators of correctional facilities can provide data for a national establishment survey on indicators of CO stress and correlates of suicide. To that end, the study will allow BJS to assess the availability of data and identify potential obstacles to providing these data to BJS (e.g., legal, technological, resource, and confidentiality issues).

Sample Design

The goal is to conduct interviews with a total of 40 correctional agencies, including state DOCs, BOP, private correctional operators, and jail jurisdictions of varying sizes (e.g., average daily inmate population of 1-49 inmates, 50-249, 250-999, and 1000+) and geographic diversity (state and region). For purposes of learning about the availability of data, BJS intends to select a convenience sample of participants from the 50 state DOCs, the BOP, the 2,850 locally operated jail jurisdictions,¹ and approximately nine private companies operating correctional facilities for state DOCs.² For state correctional authorities, BOP, and jail jurisdictions and private companies that operate multiple facilities under contract with state DOCs, a single interview will account for multiple facilities, but for the purposes of this collection are considered one interview. BJS will conduct recruitment with 80 potential respondents to meet the goal of completing of 40 interviews. We expect the final sample to include approximately 24 DOCs, the BOP, 13 local jail jurisdictions, and 2 private correctional operators. Table 1 summarizes the universe of facility operators and the expected number of participants.

Table 1: Universe of adult correctional facilities, by operator
Facility operator	Number of operators in census collections	Number of expected interviews
State departments of corrections	50	24
Federal Bureau of Prisons	1	1
Local jails	2,850	13
Private/contract correctional companies	9	2
Total	2,910	40

Data Collection Schedule

In Spring 2024, BJS and Abt will work on selecting the sample of respondents while OMB reviews this request. Upon receiving OMB approval, outreach to respondents will begin. First, an invitation letter will be sent via email to administrators at selected state DOCs, BOP, and jail jurisdictions operating multiple facilities (Attachment A) and private companies operating multiple prisons under contract to house persons for state (e.g., CoreCivic, GeoGroup, Management & Training Corporation) (Attachment B). Agency heads will be asked to participate in the study and to identify a respondent who can provide information about their prisons and staff. A BJS study invitation letter will be sent directly to locally operated jail jurisdictions operating a single jail facility (Attachment C) requesting participation in the study. After the invitation letter is sent, Abt and/or BJS may follow up by email or phone as needed to encourage participation in the study. Once a POC or representative is identified, an email (Attachment D) will be sent acknowledging their agency’s agreement to participate and to schedule an interview time. The email will also include attached biographies of the Abt interviewers (Attachment E); the biographies demonstrate the team’s experience in conducting similar research. An FAQ sheet (Attachment F) will be sent with the letters and will provide further information about topic areas on the questionnaire that will be asked during the interview, how the information provided will be used by BJS, and the confidentiality and security provisions that govern information collected by BJS.

Abt will work with participants through July 2024 to schedule the interviews and conduct semi-structured interviews (either by phone or video) with up to 40 respondents. Senior Abt staff will follow a semi-structured interview guide (Attachment G) when conducting the interviews, which include informed consent. The introduction script read to respondents at the beginning of the interview will provide information about the purpose of the COSS, the voluntary nature of the study, and how the respondent was selected. It will announce the estimated length of the interview in advance, allowing the participant an opportunity to decline if the burden would be unacceptable. Abt staff will seek consent for recording of the call and an analyst at Abt will take notes during the call. The interview protocol will focus on asking respondents about:

1. Staffing levels and work schedules for COs.

2. Salary and time off for COs

3. Education and training for COs

4. CO stressors and indicators of stress

5. Services and programs available to COs

6. Characteristics of COs and facilities

During the project performance period, Abt will provide ongoing progress reports to BJS that include updates on the number of scheduled interviews, number of completed interviews, common themes from interviews, systems/facilities that need to be prompted by BJS, as well as any challenges and mitigation strategies. Abt will deliver to BJS the data tabulations, a description of the data (including the data availability, data quality, and coverage for each system or facility type), and a final report. The final report will include the methodology, the findings from an environmental scan conducted prior to conducting interviews, as well as recommendations for next steps, including possible strategies for implementing data collection to additional facilities that could provide national estimates. A draft report will be submitted to BJS by August 30, 2024. After BJS review, the final report will be submitted to BJS by September 30, 2024. The project schedule is summarized in Table 2.

Table 2. Schedule for Feasibility Study on Correctional Officer Stressors and Suicide
March - April 2024	Compile sample while awaiting OMB review
May 2024	Upon OMB approval, begin outreach to jails and prisons
May 2024 - July 2024	Conduct interviews; transcribe responses; code key themes by group; write draft report
August 2024	Submit draft deliverables to BJS for review
September 2024	Submit final deliverables

Burden Hours

The total burden is estimated at up to 95 minutes per interview. BJS will conduct recruitment with 80 potential respondents with a goal of scheduling 40 interviews. The estimated burden of initial recruitment is 5 minutes. The total burden for the 40 respondents who do not participate is 5 minutes. For the 40 respondents who agree to participate, the burden will be about 15 minutes for scheduling each interview, about 60 minutes to complete the interview, and for one-third of respondents 15 minutes for follow-up. The total burden per jurisdiction that participates in the interview and requires follow-up is estimated at 1 hour and 35 minutes. The total burden for all respondents is 60 hours. Estimated burden hours are summarized in Table 3.

Table 3. Summary of Burden Hours and Cost for Feasibility Study on Correctional Officer Stressors and Suicide
Type of Contact	Category of Respondent	Number of Respondents	Participation Time	Total Hours
Initial contact to determine appropriate POC	State, federal, and local governments; Private correctional companies	80	5 minutes	7 hours
Scheduling with POC	State, federal, and local governments; Private correctional companies	40	15 minutes	10 hours
Interview	State, federal, and local governments; Private correctional companies	40	60 minutes	40 hours
Follow-up *	State and local governments; Private correctional companies	13	15 minutes	3 hours
Total		80		60 hours

*Based on recent feasibility studies Abt has conducted for BJS, Abt estimated that one-third of respondents from the initial interview required follow-up to answer outstanding questions. The 15-minute burden estimate includes the time needed for respondents to track down the outstanding requests, and communicate back to Abt.

Cost to the Federal Government

The estimated cost to the Federal government is $55,000 for the Abt portion of the work and an estimated $3,000 for 40 hours of the GS-13 project manager’s work for a total of $58,000.

Data confidentiality and security

BJS is authorized to conduct this data collection under 34 U.S.C. § 10132. The interview will collect identifying information including the name of the respondent, address, email, and telephone number. All information related to the interviews, including the recordings of interviews, will be stored on a secure drive at Abt with access restricted to only staff members who are directly involved in data collection and reporting. To protect the identities of the respondents, no identifying information will be kept in the final data file. In addition, the recorded conversations of the interviews will be erased upon completion of the report summarizing the findings of the feasibility study. We estimate this to be one month after the interviews have been completed. Once the summary report is completed, all copies of the interview data will be destroyed. All project staff are required to sign a pledge of confidentiality and privacy certificate which confirms the maintaining of data and following the procedures outlined above. Furthermore, all interviews will be conducted by project staff at Abt, who must complete official security training.

As outlined in the BJS Data Protection Guidelines, BJS maintains a robust IT security program in compliance with the DOJ Cybersecurity Program and the DOJ IT Security Rules of Behavior (ROB) for General Users to facilitate the privacy, security, confidentiality, integrity, and availability of BJS computer systems, networks, and data in accordance with applicable federal and Department policies, procedures, and guidelines. Abt complies to all BJS data protection guidelines and maintains data securely in compliance with 28 CFR §22.23(b)(5) and the project’s data security plan. The data security plan addresses staff control and access to data, privacy and confidentiality protections, secure storage of paper and electronic data, secure transfer of data, data destruction, and required staff training on data security and confidentiality.

Protection of Human Subjects

Abt’s Institutional Review Board (IRB), which has Federal-wide assurance, reviewed the project per 28 CFR 46 and determined that all aspects of the project do not meet the definition of human subjects research (Attachment H).

Contact Information

Questions regarding any aspect of this project can be directed to:

Tracy L. Snell

Statistician

Bureau of Justice Statistics

U.S. Department of Justice

810 7th Street NW

Washington, DC 20531

Office Phone: 202-598-1660

E-Mail: [email protected]

Attachments

Attachment A. Invitation to DOC/BOP/Multiple-jail jurisdiction Head

Attachment B. Invitation to Private Correctional Company Representative

Attachment C. Invitation to Single-Facility Jail Jurisdictions

Attachment D. E-mail to Designated Point of Contact

Attachment E. Biographies of Abt Interviewers

Attachment F. Frequently Asked Questions

Attachment G. Interview Guide

Attachment H. Institutional Review Board Determination

1Census of Jails, 2005-2019 – Statistical Tables (NCJ-255406), BJS, October 2021.

2Census of State and Federal Adult Correctional Facilities, 2019 – Statistical Tables (NCJ-301366), BJS, November 2021.

Page 7 of 7