Non Substantive Change Memo 1.7.25

5600 Fishers Lane

Rockville, MD 20857

DATE: January 6, 2025

TO: Dan Cline, OMB Desk Officer

FROM: Joella Roland, HRSA Information Collection Clearance Officer

______________________________________________________________________________

Request: The Health Resources and Services Administration (HRSA) Maternal and Child Health Bureau requests approval for changes to the Alliance for Innovation on Maternal Health (AIM) Biannual Reporting Survey (OMB 0906-0091 expiration date 05/31/2027).

Purpose: The purpose of this request is to make changes to the survey instrument to clarify the descriptive and guidance language and add questions to gather clearer information and reduce the follow-up with respondents.

Collection of this information will provide more accurate data reporting on key measures, allowing HRSA to better track and report on participation in AIM, gain a better understanding of the entities involved in implementing the program, and plan technical assistance. The changes will provide clearer guidance to the respondents on how to answer questions in the survey and will fill in gaps in information that previously required follow-up with participants to understand responses.

This memo explains the changes and supporting rationale.

Changes: Table A includes the instrument that is changing, the variable number being altered or added, a description of the change, and the rationale for the change. The survey instrument with changes tracked is attached, as well as a clean version of the survey showing all proposed changes accepted, for reference. The overall scope of change to the screening and main survey instrument is minimal, representing primarily an update of existing content. Three new questions or sub-questions have been added to fill in gaps in information that previously required back and forth with the respondents after they submitted their responses. HRSA and the AIM Technical Assistance Center analyzed the results of the previous survey to identify where the survey questions could be clarified and improved to reduce inconsistencies in the information collected and reduce the amount of follow-up required to gather missing details and verify responses.

Nothing is changing about the survey administration and no sampling protocol is used.

Time Sensitivity: The data collection changes must be completed in a timely manner to ensure that the survey data collection schedule will not experience significant delay. Approval of these changes is needed by January 22, 2025 to implement the changes in the data collection instrument and to prepare for the timely collection of data critical to the HRSA program.

Burden: These changes included herein do not substantially change the estimated reporting burden for AIM state and jurisdiction teams. Although several items were added, they do not require respondents to collect additional data and the additions are expected to decrease the amount of time required for follow-up with respondents to clarify and validate responses. Making these changes will allow HRSA to have more accurate data available sooner for reporting, planning and providing technical assistance, and providing oversight and guidance to award recipients.

PROPOSED CLARIFICATIONS AND NON-SUBSTANTIVE CHANGES:

Table A

Instrument	Variable	Change implemented	Rationale
AIM Biannual Reporting Survey	T1 (Instructions)	Added text saying “Please refer to your [PREVIOUS SEASON YEAR] AIM Biannual Reporting Survey responses in Dropbox to support your completion of this survey.”	Several of the questions in the survey ask respondents about changes that have occurred since the previous survey. The new language in the instructions was added to remind respondents where they can find the information they previously submitted.
AIM Biannual Reporting Survey	Q4	Definition of birthing facilities added to question text.	This is a key question that relates to multiple other responses. The definition of birthing facilities was added to the question language to make it easy for respondents to understand what the term means without having to scroll to other parts of the survey.
AIM Biannual Reporting Survey	Q4c	Sub-question added “Are any of these facilities Indian Health Service or Tribal facilities? (Yes/No)”	This question was added to cover a missing piece of information. The respondents define and collect data on birthing facilities in different ways. The previous question did not capture whether IHS and Tribal facilities were included in the data, which has implications for how HRSA and the TA provider conduct outreach and technical assistance. Adding this question will allow HRSA to understand whether IHS and Tribal facilities have chosen to engage through the state and jurisdiction team and, if not, engage through IHS and Tribal organizations.
AIM Biannual Reporting Survey	Q7	New question: “Since [DATE OF PRIOR BIANNUAL SURVEY], what changes have occurred in the birthing facilities (hospitals with labor and delivery units and freestanding birth centers) in your state or jurisdiction. Refer to your state or jurisdiction responses to the [DATE OF PRIOR BIANNUAL SURVEY] in the Dropbox link shared with you by the AIM TA Center. Select all that apply or “No changes.”	Previously the survey asked about reasons for decreases in facility numbers, but not reasons for overall changes in facility numbers. As a result, it was often not clear why and how birthing facility numbers changed in a state over time, requiring additional follow-up with respondents to clarify their survey responses. This question is included so respondents can report all reasons for changes in numbers of birthing facilities as part of their survey response and reduce the amount of follow-up required.
AIM Biannual Reporting Survey	Q8	Question guidance revised.	The definition of participation was updated to be consistent with recent descriptions and guidance provided by the program and provide clearer guidance in the survey.
AIM Biannual Reporting Survey	Q9	Question guidance revised.	The definition of participation was updated to be consistent with recent descriptions and guidance provided by the program and provide clearer guidance in the survey.
AIM Biannual Reporting Survey	Q9	Sub-questions added: “Q9a How many of these facilities are hospitals? _________ Q9b How many of these facilities are freestanding birth centers (i.e. not a labor and delivery unit within a hospital)? _______ “ Q9c Are any of these facilities Indian Health Service (IHS) or Tribal facilities? (Yes/No)	This question was added to be consistent with other parts of the survey and reduce the follow-up required with respondents and the time burden on them. Previously it was not clear how much new participation was among hospitals and birth centers, requiring additional follow-up with respondents to clarify their survey responses. This question is included so respondents can report the relevant information as part of their survey response. Hospitals and birth centers have different capacities and services available and often require different levels and types of technical assistance and information resources. The information will be used for planning technical assistance geared towards the types of facilities participating and allow for more accurate reporting on the types of facilities participating in AIM. Adding the question on IHS and Tribal facilities will allow HRSA to understand whether IHS and tribal facilities are choosing to participate in AIM through the state and jurisdiction team and where to engage more with IHS and Tribal organizations.
AIM Biannual Reporting Survey	Q10	Question language revised.	The revised language makes it clear that this question refers to closures of birth centers as well as labor and delivery units in hospitals and makes the terminology consistent with other parts of the survey.
AIM Biannual Reporting Survey	Q11	Question language revised.	The revised language makes it clear that this question refers to closures of birth centers as well as labor and delivery units in hospitals and makes the terminology consistent with other parts of the survey.
AIM Biannual Reporting Survey	Q12	Definition of term (birthing facilities) added to question text.	The definition of birthing facilities was added to the question so that respondents can see it when they are answering it without having to scroll to other parts of the survey.

Attachments:

1. MCHB-AIM Biannual Survey-0906-009-Dec 2024_ Tracked Changes (All changes and additions are tracked in the attached document)

2. MCHB-AIM Biannual Survey-0906-009-Dec 2024_Clean (All proposed changes and additions accepted)