OMB Change Justification Memo_0584-0682_April 2024

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TO:		Laurel Havas
OMB Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget (OMB)

THROUGH: 	Rachelle Ragland-Greene
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:	Michael Burke
SNAP Evaluation Branch
OPS/SNAP Research and Analysis Division
Food and Nutrition Service (FNS)

DATE:		April 9, 2024

SUBJECT:	Justification for changes to study materials for OMB Control No: 0584-0682 “Understanding the Relationship Between Poverty, Well-Being, and Food Security”.


The Food and Nutrition Service (FNS) is requesting a non-substantive change to the Understanding the Relationship Between Poverty, Well-Being, and Food Security study, approved under OMB Control No. 0584-0682; expiration date of April 30, 2026. FNS made non-substantive edits to the survey questionnaire (Appendix S1) that will be administered to respondents living at sampled addresses. Small changes were also made to SSA, SSB, and Appendix U. Incentive Experiments to remove a previously proposed notification experiment and revise sampling procedures.

The following is a summary of the changes made:

    • Final Selected Counties (SSA, SSB, and Survey)
        ◦ At the time of initial OMB submission, the six counties had not yet been recruited. We have updated the text to indicate that the final recruited counties include: Dougherty County, GA; Estill County, KY; Bolivar County, MS; Ouachita Parish, LA; Dona Ana County, NM; and Dallas County, AL.
    • Incentive Experiment (SSA and Appendix U)
        ◦ The initial submission included an experiment with different presentations of the $5 pre-paid incentive in the advance letter mailing. The experiment, which has not yet been fielded, proposed to provide the prepay incentive in three different ways: (1) prepaid cash visible with the $5 dollar value showing, (2) prepaid cash visible without the dollar value showing, and (3) prepaid cash not visible through the window. In the time since the OMB package was written and approved, the literature has more definitively shown that visible pre-pay incentives are more effective in soliciting survey response compared to not showing the incentive.1,2,3 We do not feel that this experiment would add value to the literature at this point and that it is clear that we will achieve a higher response rate if the $5 prepay value is displayed through the envelope window. More specifically, a 2023 study by Bilgen et al.1 tested showing the tender amount of the dollar bill compared to simply showing an image of the cash, and found that showing the cash amount was more likely to improve recruitment rates. This is essentially the experiment we were going to conduct. As such, we have revised the study protocols to display the pre-pay incentive for all respondents and have removed mention of this experiment from SSA and Appendix U: Incentive Experiments. 
    • Sampling procedures (SSB)
        ◦ We adjusted the sampling approach slightly to facilitate the identification of areas within each county with a higher probability of SNAP eligible non-participants while ensuring the sample is representative of the county as a whole. Our revised approach starts by pulling the full set of addresses in the county. We will then match the State administrative data to the list of all addresses in the county. We will use the density of SNAP participants by census block to identify areas more likely to contain SNAP-eligible non-participants. This is an improvement from our previous approach, which used ACS data to identify blocks more likely to contain eligible non-participants. The ACS data contains estimates based on limited data as opposed to the State administrative data which contains all current SNAP participants.
    • Survey. We made some small revisions, dropped several questions and added some others. The questions that were dropped offset the burden of added questions, so burden estimates remain unchanged. 
        ◦ Updated fills and transition text. We made small updates to the programmatic fills throughout the instrument to 1) account for our final set of selected counties, or 2) facilitate respondent understanding and readability. 
        ◦ Survey Screening Section [S]. This section will allow the study team to screen respondents out of the second and third sample releases if necessary (screening process described in SSB). Because three of the selected counties (Estill County, KY; Dallas County, AL; Dougherty County, GA) use different income thresholds based on household disability status, we have added two questions to collect this information. We use disability status to inform the income thresholds presented to the respondent in these counties at question S3. 
        ◦ Dropped questions: We removed three questions in section RFE (RFE6a, RFE6d, and RFE6f) to reduce respondent burden. Questions RC9a, RC9d, and RC10, which collected information about race and ethnicity, were combined into one question to align with the OMB revised race/ethnicity standards.4 
        ◦ Added questions: We added the following questions to the survey to collect important study data, or to facilitate logical skips that will reduce survey burden for some respondents:
            ▪ RC18 – RC19: These questions were added to collect additional information from respondents who are not currently working. They will only be asked if the respondent reports not working last week. 
            ▪ FS2: This question, that asks about household food security, was added to facilitate screening some households out of the food security module (FS4 – FS21). If responses to FS2 and FS3 indicate a high degree of food security, and respondents are at or above 185% FPL, they will now skip out of the food security module (FS4 – FS21). This mirrors the approach taken by the Current Population Survey (CPS).
            ▪ FS22 and FS23: These questions were added to collect information about perceptions of social unacceptability as it relates to food security.
            ▪ FAP5b: This question collects the amount of SNAP benefits last received, if the respondent reports receiving SNAP benefits.


The following is a detailed description of the changes made to the survey instrument (Appendix S1):

Table 1. Survey Instrument Updates
Question
Update
Details/Rationale
Overall updates
County fills
Revised to include the final set of selected counties
    • Removed Cocke County, Maverick County, and Pitt County and added in Ouachita Parish, Dona Ana County, and Dallas County
TANF fills
Revised for final counties and readability
      
SNAP fills
Revised for final counties and readability
      
Income thresholds
Revised using 2024 thresholds
    • Updated household income thresholds based on the HHS Poverty Guidelines for 2024
Introduction Section [I]
Section I
Revised “your household” with the sampled address
    • Revised for respondent clarity
Screener Section [S]
S2a and S2b
Added questions to determine if anyone in the household has a disability, to facilitate the screen out process
    • We added questions to collect household disability status in States where that impacts income thresholds for SNAP eligibility (Kentucky, Alabama, and Georgia)
S3
Revised response options
    • Updated the question to have two response options, not three.
    • Updated the thresholds that fill (see programmer box S3 thresholds) to account for different SNAP eligibility criteria by state
Respondent and Household Characteristics [RC and HHC]
RC5 & HHC5
Revised question to ask a yes/no question about whether they were born in the US, rather than asking where they were born (with US and Outside the US as response options)
    • Edited to reduce respondent burden and to more directly get at the question we care about
RC9a, RC9d, RC10
HHC9a*, HHC9b*, HHC10*
Collapsed race/ethnicity questions into one item, per revised OMB guidance5
    • Revised to align with updated guidelines 
RC18 – RC19
Added questions
    • Added questions to collect information from people who say they are not working
HHC2
Revised question wording
    • Revised the phrasing of the question collecting gender to be consistent with earlier questions
Income [IN]
IN0
Revised intro language to notify respondents that we will ask about several income categories. Removed language about income being reported at the person-level.  
    • Revised to provide clearer guidance to respondents
IN1a
Added line to let respondents know not to include income from self-owned businesses or farms.
    • Revised to provide clearer guidance to respondents
IN4a, IN4c, IN5a
Revised “Social Security” to “Social Security retirement benefits”
    • Revised to provide clearer guidance to respondents
IN9c
Final thresholds entered instead of placeholder fills
    • Categories finalized upon review of 2024 data
Food Security [FS]
FS0
Section transition sentence added
    • Revised to provide clearer guidance to respondents
FS2
Added to facilitate screening people out of the food security section if they meet certain thresholds (indicate food secure status at FS2 and FS3 and are at or above 185% FPL), following the CPS model.
    • Reduce respondent burden
FS4-6
FS14-FS16
Revised skip logic to skip households out if they indicate high food security at FS2, FS3 and are above 185% FPL.
    • Reduce respondent burden
FS16, FS18
Changed question wording from “couldn’t afford more/enough food” to “wasn’t enough money for food”
    • Revised to align with 2023 CPS FSS recommendations6
FS18 – FS20
Questions reordered to match CPS FSS
    • Align with CPS FSS module
FS22 & FS23
Added questions to measure perceptions of social unacceptability as it relates to food security.
    • Data item needed for analysis. 
Throughout FS
Small Spanish translation updates to facilitate understanding
    • Revised to provide clearer guidance to respondents
Perception of local retail food environment and local food assistance [RFE & FAP]
RFE1
Added a lookup table to allow respondents to search for local stores instead of choosing from a list of only 10 stores.
    • Reduce respondent burden
RFE6a, RFE6d, RFE6f
Removed questions
    • Reduce respondent burden
FAP5b
Added question to collect amount of SNAP benefits for participants receiving SNAP
    • Data item needed for analysis
FAP8, FAP10
Minor wording changes to facilitate understanding
    • Revised to provide clearer guidance to respondents



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:
    • SSA_Persistent Poverty 
    • SSB_Persistent Poverty
    • S1. Household Survey (English-Spanish)
    • U. Incentives Experiments