November 28, 2017
Office of the Secretary
Department of Health and Human Services
200 Independence Avenue S.W.
Washington DC, 20201
RE: Information Collection Request Title: Prevention Communications Formative Research-Revision-OMB No. 0990-0281-60D
Dear Ms. Funn,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Office of Disease Prevention and Health Promotion (ODPHP) regarding the proposed prevention communication formative research. Representing over 100,000 registered dietitian nutritionists (RDNs)1, nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of nutrition and dietetics professionals in the United States and is committed to improving the nation’s health through food and nutrition across the lifecycle.
The Academy supports ODPHP's work to develop and disseminate health information to the public. The Academy has worked closely with ODPHP through partnerships with the Diabetes Advocacy Alliance on Healthy People 2020, and also supporting dissemination of the Dietary Guidelines for Americans. We look forward to continuing to work with ODPHP on the creation and dissemination of Healthy People 2030 and the Dietary Guidelines for Americans 2020, including the B-24 guidelines.
The Academy offers the following specific comments on ODPHP's proposed communication research to improve the dissemination of health information to the public.
i. The necessity and utility of the proposed information collection for the proper performance of the agency's functions
The Academy believes that the proposed information collection is very important to the work of ODPHP. Formative and usability research on various education pieces created and distributed by ODPHP is important to assure nutrition education messages are clear, concise, meaningful to the population and easily accessible. The broad variety of proposed collection methods seems appropriate, and we recommend that ODPHP include evaluation methods completed by both consumers and health professionals to further enrich the data collection.
The Academy recommends that ODPHP collaborate across federal agencies when developing communication and education materials for the public. The proposal does not include information on any interagency initiatives, such as partnering with the Centers for Disease Control and Prevention or the Center for Nutrition Policy and Promotion, which do education for the public and have materials that require evaluation. A collaborative approach could help reduce replication of efforts and increase the utility of the data collection.
The Academy also recommends that ODPHP utilize the Academy's Evidence Analysis Library (EAL)2 to identify existing research and any gaps in nutrition research. The EAL contains research on various nutrition and health projects through systematic reviews that look at the effectiveness of interventions on specific disease states. The Academy would be pleased to partner with ODPHP to reduce duplication of data collection efforts.
ii. The accuracy of the estimated burden
When reviewing the estimated burden in the proposed information collection, the Academy seeks clarification of the estimated burden for both the participant and the research team. For the participant, the Academy recommends that the burden include travel time to focus groups, time for child care, and other related time constraints. For the researchers, the Academy recommends including time for preparation and analysis both prior to and following the data collection. Additionally, focus groups may run longer or shorter than the proposed time, and often it is best to overestimate in these calculations in order to leave time for continuing meaningful interviews to capture rich data.
iii. Ways to enhance the quality, utility and clarity of the information to be collected
The Academy recommends more of a focus on diversity and reducing health inequities in the interview questionnaires. We were concerned by the lack of prioritization for populations with limited English proficiency, disabilities and variety of race and ethnic groups. It is important that the data collection account for specific populations, which are more heavily burdened by health inequities. Identifying appropriate ways to target communications based on diverse factors while working to overcome health inequities should be critical to this process.
It would also be helpful to describe the specific target population, as the current "consumers or health professionals" is a vague description. For example, ODPHP should identify specific populations that are the target of a communication initiative, based on factors such as specific geographic locations, age groups, genders, disease states or languages spoken.
When collecting information from a diverse group of participants, the following should be considered:
- Interviewers that are fluent in multiple languages;
- Cultural competency of data collectors;
- Identifying, recruiting and training lay health advisors;
- Providing options for child care, reimbursement for child care, or holding open focus groups that allow parents with infants to participate;
- Providing travel vouchers;
- Involving community schools, places of worship, public libraries, health centers and public transportation hubs in recruitment efforts;
- Providing an inviting and accessible space for focus groups or interviews; and
- Offering a choice of days and times for participants to sign up for an interview or focus group.
iv. The use of automated collection techniques or other forms of information technology to minimize the information collection burden
The Academy recommends that ODPHP consider the feasibility and utility of web or phone based apps and/or text messages for gathering data.
The Academy appreciates the opportunity to comment on the Office of Disease Prevention and Health Promotion's proposed Prevention Communication Formative Research and looks forward to working with ODPHP as communication and education efforts are further refined throughout the process. Please contact either Jeanne Blankenship at 312-899-1730 or by email at firstname.lastname@example.org or Stefanie Winston Rinehart at 202-775-8277, ext. 6006, or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Vice President, Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Stefanie Winston Rinehart, JD, MPH
Director, HHS Legislation and Policy
Academy of Nutrition and Dietetics
1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2 Academy of Nutrition and Dietetics Evidence Analysis Library. Accessed November 27, 2017.