Submission of Proposed Information Collection to OMB

Federal RegisterAug 9, 1995

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SUMMARY: The proposed information collection requirement described

below has been submitted to the Office of Management and Budget (OMB)

for review, as required by the Paperwork Reduction Act. The Department

is soliciting public comments on the subject proposal.

DATES: Comments due date: August 23, 1995.

ADDRESSES: Interested persons are invited to submit comments regarding

this proposal. Comments must be received within 14 days from the date

of this notice. Comments should refer to the proposal by name and

should be sent to: Joseph F. Lackey, Jr., OMB Desk Officer, Office of

Management and Budget, New Executive Office Building, Washington, DC

20503.

FOR FURTHER INFORMATION CONTACT:

Kay F. Weaver, Reports Management Officer, Department of Housing and

Urban Development, 451 7th Street SW., Washington, DC 20410, telephone

no. (202) 708-0050. This is not a toll free number.

SUPPLEMENTARY INFORMATION: This notice informs the public that the

Department of Housing and Urban Development has submitted to OMB for

processing an information collection package related to the National

Survey of Homeless Assistance Providers and Clients (hereinafter

``survey''). HUD is requesting a review of this information collection

on or before September 8, 1995.

The survey will provide estimates of the number and characteristics

of service providers and an assessment of the types of programs and

services available to people who are homeless. It will also provide

detailed characteristics of persons using services. Under the auspices

of the Interagency Council on the Homeless, the survey is being co-

sponsored by 11 Federal agencies:

Department of Housing and Urban Development

Department of Health and Human Services

Department of Veterans Affairs

Department of Agriculture

Department of Commerce

Department of Education

Department of Energy

Department of Labor

Department of Transportation

Social Security Administration

Federal Emergency Management Agency

The survey includes two phases: the collection of information on

service providers and the collection of information on service users

(clients). In Phase 1, the Census Bureau will:

(1) Select a sample of geographic areas;

(2) Development a comprehensive list of service providers in the

survey sample areas;

(3) Collect basic information from all service providers within the

sample areas on programs offered, via a computer-assisted telephone

interview; and

(4) Select a subsample of providers and collect detailed

information on programs and services by mail, with telephone follow-up.

Phase 1 of the national survey is planned to be conducted starting

in October 1995 and conclude by January 1996.

In phase 2, the Census Bureau will:

(1) Select a sample of service users (clients) within the sample

areas:

(2) Select a sample of providers in designated programs; and

(3) Select clients and conduct personal visit interviews at

selected service provider facilities.

This request is for clearance to conduct Phase 1 of the survey. A

second package will be submitted to OMB later for Phase 2.

This request is for the following questionnaires:

NSHAPC-100A Service Provider Core Data.

NSHAPC-100B Emergency Shelter Programs; 100C Transitional

Housing Programs; 100D Voucher Programs; and 100E Permanent Housing for

the Homeless Programs. Note: Each of these surveys is identical except

for its title and modest wording differences under the Voucher

instrument.

NSHAPC-100F Alcohol/Drug Programs; 100G Mental Health Care

Programs; 100H Physical Health Care Programs; 100I Drop-In Center

Programs; 100J HIV/AIDS Programs; and 100L Other Programs. Note: Each

of these surveys is a shortened version of the Emergency Shelter

Program survey and each is identical to the other.

NSHAPC-100K Outreach Program.

NSHAPC-100M List of Providers Offering Homeless Programs.

A pre-test of the survey was conducted in April 1995 in three

areas: Atlanta, GA; Pittsburgh, PA (including Allegheny, Fayette,

Washington, and Westmoreland Counties); and the Armstrong County

Community Action Agency Catchment area (a rural Community Action Agency

service area outside Pittsburgh). The survey instruments have been

revised to reflect the experience gained in the pre-test. The Census

Bureau sought and obtained substantial expert input over a two-year

period to develop the survey instruments.

The Department has submitted the proposal for the collection of

information, as described below to OMB for review, as required by the

Paperwork Reduction Act (44 U.S.C. Chapter 35):

(1) The title of the information collection proposal;

(2) The office of the agency to collect the information;

(3) The description of the need for the information and its

proposed use;

(4) The agency form number, if applicable;

(5) What members of the public will be affected by the proposal;

(6) How frequently information submission will be required;

(7) An estimate of the total number of hours needed to prepare the

infromation submission including numbers of respondents, frequency of

response, and hours of response;

(8) Whether the proposal is new or an extension, reinstatement, or

revision of an information collection requirement; and

(9) The names and telephone numbers of an agency official familiar

with the proposal and of the OMB Desk Officer for the Department.

Authority: Section 3507 of the Paperwork Reduction Act, 44

U.S.C. 3507; Section 7(d) of the Department of Housing and Urban

Development Act, 42 U.S.C. 3535(d).

Dated: July 27, 1995.

Michael A. Stegman,

Assistant Secretary, Office of Policy Development and Research.

Notice of Submission of Proposed Information Collection to OMB

Proposal: National Survey of Homeless Assistance Providers and

Clients (NSHAPC).

Office: Policy Development and Research.

Description of the Need for the Information and its Proposed Use:

This national survey would provide up-to-date information about the

providers of homeless assistance and the characteristics of homeless

persons who use services. The survey will be conducted in 76 areas

including metropolitan and nonmetropolitan settings. The data will:

[[Page 40641]]

(1) be compared with the findings of a 1987 Urban Institute survey

of homeless characteristics to understand reported changes in the

nature of homelessness, especially those related to families with

children;

(2) provide a basis for assessing local efforts to construct

``continuums of care'' for homeless people;

(3) be used to develop measures to assess the impact and

performance of current homeless programs;

(4) will assist local governments and nonprofit organizations in

designing more effective local programs; and

(5) provide a baseline for examining the effects on the homeless

population of proposed changes to the McKinney homeless assistance

programs, and America's ``safety net'' programs for the poor (e.g.,

Section 8, AFDC, JTPA, and Medicaid programs).

Form Number: None.

Respondents: Homeless service providers and homeless persons.

Frequency of Submission: One-time.

Reporting Burden: See attachment.

Total Estimated Burden Hours: Phase 1, Provider Surveys 17,500.

Status: New Survey.

Contact: James E. Hoben, HUD, (202) 708-0574 X132, George A.

Ferguson, HUD, (202) 708-1480, Joseph F. Lackey, Jr., OMB, (202) 395-

7316.

Date: July 27, 1995.

Supporting Statement

A. Justification

1. Necessity of Information Collection

The National Survey of Homeless Assistance Providers and Clients

(NSHAPC) includes two phases: the collection of information on service

providers (providers) and the collection of information on service

users (clients).

Phase 1: In Phase 1, the Census Bureau will:

(1) Select a sample of geographic areas

(2) Develop a comprehensive list of service providers in the survey

sample areas.

(3) Collect basic information from all service providers within the

sample areas on programs offered, via a computer-assisted telephone

interview.

(4) Select a subsample of providers and collect detailed

information on programs and services by mail, with telephone follow-up.

Note: Steps 1 and 2 must be completed if Phase 2 is conducted.

Phase 2: In Phase 2, the Census Bureau will:

(1) Select a sample of service users (clients) within the sample

areas in two other stages.

(2) Select a sample of providers in designated programs.

(3) Select clients and conduct personal visit interviews at

selected service provider facilities.

This request is for clearance to conduct Phase 1 of the survey. A

second OMB package will be submitted later for Phase 2. This request is

for the following questionnaires listed by title and code number.

Data to be collected from all providers:

NSHAPC--100A, Service Provider Core Data Questionnaire.

Data to be collected from major shelter providers: (Note: Each of

these instruments is essentially identical, except for the title.

Therefore, review of one satisfies review of the others.)

NSHAPC-100B, Emergency Shelter Programs.

NSHAPC-100C, Transitional Housing Programs.

NSHAPC-100D, Voucher Programs.

NSHAPC-100E, Permanent Housing for the Homeless Programs.

Data to be collected from special service providers: (Note: Each of

these instruments is essentially identical, except for the title.

Therefore, review of one satisfies review of the others.)

NSHAPC-100F, Alcohol/Drug Programs.

NSHAPC-100G, Mental Health Care Programs.

NSHAPC-100H, Physical Health Care Programs.

NSHAPC-100I, Drop-In Center Programs.

NSHAPC-100J, HIV/AIDS Programs.

NSHAPC-100L, Other Programs.

Data to be collected from homeless outreach programs:

NSHAPC-100K, Outreach Programs.

Instrument for updating list of providers in a geographic area:

NSHAPC-100M, List of Providers Offering Homeless Programs.

The national survey will provide estimates of the number and

characteristics of service providers, and an assessment of the types of

programs and services available to people who are homeless. The survey

will also provide (in Phase 2) detailed characteristics of persons

using services.

The national survey is being sponsored by the following Federal

agencies:

Department of Housing and Urban Development (HUD).

Department of Health and Human Services (HHS).

Department of Veterans Affairs (VA).

Department of Agriculture (USDA).

Department of Commerce (DOC).

Department of Education (ED).

Department of Energy (DOE).

Department of Labor (DOL).

Department of Transportation (DOT).

Social Security Administration (SSA).

Federal Emergency Management Agency (FEMA).

Data will be collected under HUD's data collection authority.

As part of the 1990 Census, the Census Bureau enumerated persons

residing in homeless shelters and pre-identified street locations.

However, this operation was not designed to provide the full range of

information needed for guiding policy decisions related to

homelessness. With this understanding, in September of 1993, the Bureau

of the Census convened a conference of researchers, representatives of

public interest groups, and government representatives to discuss ways

of improving data collection on the homeless population. The consensus

among this group was that the decennial census is not the appropriate

vehicle for gathering information on the homeless population. They

suggested that a new national survey using updated methodologies to

obtain an accurate and useful picture of those homeless people who use

services in the United States is needed.

2. Needs and Uses

The information the new survey would provide is critical for

developing the kinds of effective public policy responses needed to

break the cycle of homelessness, both through targeted programs and the

leveraging of mainstream resources. This survey would provide up-to-

date information about the characteristics of today's providers of

homeless services and the homeless population who use services. The

last comparable national study was in 1987 when the Urban Institute

completed a survey of homeless persons. Also, included in the NSHAPC

would be the first national examination of the characteristics of

homelessness in rural America, fulfilling a Congressional mandate for a

report on this subject.

The national NSHAPC survey would:

1. Provide information on the types of programs and services

available to homeless persons, including population groups primarily

served (e.g., veterans, people with mental illness); days of operation,

occupancy levels, and sources of funding.

2. Provide national information on the types of services available

to homeless persons in both urban and rural communities.

3. Provide information not addressed by the last national study in

1987 such

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as: What are the triggering events that precipitate homelessness? Where

were homeless people living before they became homeless? How prevalent

is AIDS among homeless persons? What impact does rural homelessness

have on urban homelessness? What differences are there among homeless

persons found in cities, suburbs, and rural areas?

4. Tell us what characteristics of the homeless population have

changed since the 1987 study.

5. Collect additional information related to drug use, mental

illness, AIDS, tuberculosis, and previous episodes of homelessness.

6. Include smaller cities, nonmetropolitan and rural areas in order

to more accurately and fully reflect homelessness in the United States.

The survey would interview a sufficient number of people using services

in 76 geographic areas to ensure reliability of the national estimates.

Of these 76 geographic areas, 28 would be large metropolitan areas, 24

would be medium and small metropolitan areas, and 24 would be

nonmetropolitan areas (small cities and rural areas).

Discussion of Phase 1 Activities

Phase 1 will be on-going from October 1, 1995 through January 1996.

Three steps occur in Phase 1.

Step 1: Completing the CATI Interview

1. Beginning on October 1, 1995, Census Bureau staff will use a

computer-assisted telephone interview (CATI) to contact all service

providers in the 76 sample communities. Service providers interviewed

would include those with programs specifically targeted to the homeless

(e.g., homeless shelters, soup kitchens, homeless outreach programs) as

well as other community service providers with programs for which

homeless individuals are eligible. The purpose of the survey of service

providers would be to assess the types of programs and services

available to homeless persons in these metropolitan, suburban, and

rural areas. All service providers in the areas will be asked about the

types of programs offered and basic information about each program

offered, such as source of funding, days of operation, and population

group primarily served (e.g., veterans, people with mental illness).

Prior to the CATI calls, an advance letter, NSHAPC L(1)l, will be

mailed to each provider.

Providers will be asked via the CATI the questions contained in the

NSHAPC Form 100A, Service Provider Core Data Questionnaire. The

following information about the service provider and programs offered

at that address will be collected:

Name.

Contact for the facility.

Address.

Telephone number.

Type of facility.

Programs provided.

The following information will be collected for each program

offered:

Average number of adults and children participating in

programs on a daily basis, and percent homeless.

Average number of adults and children the facility serves

on a daily basis.

Familial status of persons the facility serves on a daily

basis.

Public or private affiliation.

Source of funding.

If the program is targeted to a specific subpopulation

group.

Number of facilities under contract to, or accepting

vouchers.

Expected days of operation for each program in February,

1996.

Contact person for each program.

Step 2: Reviewing the List of Service Providers

Once the CATI interview is completed, service providers will be

mailed a comprehensive list of service providers in the sample areas.

Service providers asked to review the list for completeness and

accuracy, will be asked to correct any incorrect entries, and to

identify service providers that are omitted from the list. The updated

lists are to be mailed back to the Census Bureau. After receipt of the

reviewed list, Census Bureau personnel will remove duplicate entries

from the list and prepare a master list of service providers for a

geographic area. New service providers added to the list will then be

contacted and Census Bureau staff will administer the CATI interview.

The Census Bureau plans to generate listings of service providers

for each of the sample areas in the survey and mail, NSHAPC Form 100-M,

List of Providers Offering Homeless Programs and the NSHAPC-L(2) letter

to all service providers shown on the comprehensive list and all

knowledgeable local persons. The knowledgeable local persons and

service providers will be asked to review the listing of all service

providers in their area for completeness, and to add any missed service

providers to the list. Note: A sample of providers will be asked to

provide additional information about the services they offer. This is

discussed below under Phase 1, Step 3.

The Census Bureau is obtaining copies of national files of service

providers from national organizations, Federal agencies, and from

Community Action Program (CAP) coordinators. The Census Bureau has

obtained a copy of lists of service providers from the following

Federal agencies: FEMA, Health and Human Services, Veterans Affairs,

and Labor, and it will obtain lists from Housing and Urban Development.

National organizations, such as the National Coalition for the

Homeless, National Alliance to End Homelessness, National Law Center on

Homelessness and Poverty, National Network of Runaway and Youth

Services, Catholic Charities, Better Homes Foundation, and Volunteers

of America, Inc., have provided lists to the Census Bureau. The Census

Bureau plans to unduplicate and merge these files into one

comprehensive listing of service providers. This comprehensive list

will be used as the initial sampling frame for identifying and

interviewing service providers in the sample areas.

The local update may also provide the Census Bureau with additional

names of service providers and local persons or organizations

knowledgeable about homeless services. (Federal, State, and Local

Agencies may not have the name of a service provider if the provider

does not receive any federal, state, or local funding.)

Census Bureau personnel also will contact the state homeless

coordinator designated in accordance with the McKinney Homeless

Assistance Act. The Census Bureau will tell them about the survey,

indicate which counties in their state are included in the survey, and

provide them with a list of service providers in each of the sample

areas. The state coordinators will be asked to review the list of

service providers and note any additions or changes.

Note: Census Bureau personnel have already completed some

initial contacts with Federal and state government offices,

agencies, organizations, and knowledgeable local persons to begin

compiling a national list of service providers.

Shelters for abused women and runaway youths will not be on the

listings to be reviewed by service providers but are included in the

sampling frame. This is to preserve the confidential locations of

shelters for abused women and runaway youth.

The Census Bureau will use the master list of service providers

as the frame to select the sample of service providers who will

receive the detailed program questionnaires and to select the sample

of provider facilities where client interviewing will be conducted.

Step 3: Completing the Detailed Information on Programs and Services

Once the CATI interviews are completed, a subsample of service

providers will be asked to provide more detailed information about the

specific

[[Page 40643]]

programs and services offered at their facility. Separate

questionnaires for each program (e.g., NSHAPC Forms 100B to 100L) have

been developed. Program managers will be asked to complete a

questionnaire by mail for each program they administer. For each

program offered, program managers will receive a copy of the

appropriate program questionnaire and the NSHAPC L(3) L-letter. Census

Bureau staff will follow up by telephone all nonresponding providers.

Discussion of Phase 2 Activities

The second phase of the survey consists of interviewing a sample of

persons using services at homeless shelters, soup kitchens, and other

service locations where homeless people are found. Interviews will take

place continuously over a four-week period in order to obtain a

representative sample. In addition to providing data on characteristics

of the portion of the homeless population who use services, this phase

of the survey would identify homeless subgroups and help determine

their use of various types of assistance programs. It would also

collect limited comparative data on housed persons with very low

incomes who also rely on soup kitchens and other emergency assistance.

The survey will estimate characteristics at the national level

only. The sample size is not large enough to produce estimates of

client characteristics at the regional or local levels.

In 1987, the Urban Institute completed a survey of homeless

persons. Data from the 1987 Urban Institute study represent the only

national level data specific to homeless persons. Since the 1987 study,

no significant national studies have been conducted to provide national

information about the characteristics of homeless persons using

services for homeless people.

NSHAPC data will be used to plan future programs and services

funded via the McKinney Homeless Assistance Act and other programs to

prevent homelessness as well as ameliorate it. Understanding the causes

of homelessness can help guide the development of preventive

strategies. Data from the NSHAPC will be used by the participating

agencies to prepare reports in accordance with the requirements of the

McKinney Homeless Assistance Act and other homeless assistance

programs.

The following programs will benefit from the data collected in the

NSHAPC.

Emergency/Temporary Shelter Assistance

Emergency Food and Shelter Program (FEMA)--Assistance directed toward

temporary shelter

Emergency Shelter Grants Program (HUD)

Shelter for the Homeless [Department of Defense (DOD)]

Homeless Support Initiatives--Surplus Blankets (DOD)

Food and Nutrition Assistance

Commodities for Soup Kitchens (USDA)

Emergency Food and Shelter Program--Food Assistance (FEMA)

Commissary/Food Bank Initiatives (DOD) and (Department of

Transportation (DOT)]

Federal Grain Inspection Service--Donation of Surplus Samples (USDA)

General Health Assistance

Health Care for the Homeless Grant Program (HHS)

General Health Assistance

Health Care for the Homeless Grant Program (HHS)

Domiciliary Care for Homeless Veterans Program (VA)

Assistance to Homeless Persons with Disabilities

Shelter Plus Care Program (HUD)

Supportive Housing Program (HUD)

Projects for Assistance in Transition from Homelessness (PATH) (HHS)

Access to Community Care and Effective Services and Supports (ACCESS)

(HHS)

Community Support Program--homeless-specific portion (HHS)

National Institutes of Health (NIH) Research on Homelessness (HHS)

Homeless Chronically Mentally Ill Veterans Program (VA)

Safe Havens (HUD)

National Institute on Alcohol Abuse and Alcoholism (NIAAA) Research

Demonstration on Homelessness (HHS)

Drug Abuse Prevention for Runaway & Homeless Youth (HHS)

Education, Training, and Employment Assistance

Education for Homeless Children & Youth State Grants Prog. (ED)

Examplory Projects Program--Homeless Children (ED)

Adult Education for the Homeless (ED)

Job Training for the Homeless Demonstration Program (DOL)

Homeless Veterans Reintegration Project (DOL)

Housing Assistance

Supportive Housing Program (HUD)

Section 8 Assistance for SROs (HUD)

Single Family Property Disposition Initiative (HUD)

Transitional Housing Demonstration Program (HHS)

Transitional Living Program for Homeless Youth (HHS)

Farmer's Home Administration (FMHA) Homes for the Homeless (USDA)

Shelter for Homeless Vets--Acquired Property Sales (VA)

Base Closure Properties (DOD, HUD)

Homeless Prevention

Emergency Food and Shelter Program (FEMA)--Prevention Assistance

Emergency Community Services Homeless Grant Program (HHS)

Emergency Shelter Grants program (HUD)

General/Misc. Aid to Homeless Providers

Emergency Community Services Homeless Grant Program (HHS)

Excess & Surplus Federal Real Property (GSA)/(HUD)/(HHS)

Runaway and Homeless Youth Program (HHS)

Programs for Homeless Children/Youth/Families

Family Support Centers (HHS)

Transitional Housing Demonstration Program (HHS)

Supportive Housing Program (HUD)

Education for Homeless Children & Youth State Grants Program (ED)

Exemplary Projects Program--Homeless Children (ED)

Runaway and Homeless Youth Program (HHS)

Transitional Living Program for Homeless Youth (HHS)

Drug Abuse Prevention for Runaway & Homeless Youth (HHS)

Programs for Homeless Veterans

Domiciliary Care for Homeless Veterans Program (VA)

Homeless Chronically Mentally Ill Veterans program (VA)

Shelter for Homeless Vets--Acquired Property Sales (VA)

Homeless Veterans Reintegration Project (DOL)

Information collected in Phase 1 will be used to: (1) develop a

comprehensive listing of service providers nationwide and to develop a

national profile of the types of programs offered to homeless people;

(2) to select a sample of providers that will be asked more detailed

information about services offered; and (3) to select the sample

providers where client interviewing will be conducted.

3. Efforts to Minimize Burden

Not applicable. Respondents are individuals at provider facilities

who

[[Page 40644]]

cannot respond with computer tapes or disks. We are also minimizing the

burden of the FEMA Local Board Contact Persons, government contacts,

service providers and knowledgeable local persons by giving them the

combined listing of service providers to review as opposed to asking

them to list all service providers in their area.

4. Efforts to Identify Duplication, and Use of Available Information

HUD consulted with other government agencies and outside experts

and determined that the proposed national NSHAPC will be the only

current, national data source with detailed information on the types

and availability of programs and services offered and on the

characteristics of literally homeless persons who use services. The

most recent national data is the 1987 Urban Institute Study.

In March 1987, the Urban Institute conducted a survey of homeless

persons who used services in cities of 100,000 or more. The NSHAPC is

intended to parallel and extend the methodology used by the Urban

Institute in the 1987 survey to capture a higher proportion of the

literally homeless population who use services.

a. The NSHAPC will include additional geographical coverage. Cities

with populations of 100,000 or less and areas outside of cities will be

included in the survey sample. (The 1987 Urban Institute survey only

included cities with populations over 100,000.)

b. The NSHAPC will include additional topic coverage. The client

questionnaire covers more topics and in greater depth than was covered

in the 1987 Urban Institute Survey. There are also some questions

similar to those in the 1987 survey so that a comparison may be made

between the results of the two surveys. (The 1987 Urban Institute

survey only asked about drug treatment. The NSHAPC asks about drug

treatment, as well as, types and frequencies of drugs used, and

information about mental health.--

c. The interview period for client interviews for the national

survey will be one month. The interview period for the Urban

Institute's 1987 survey was one week.

While the results from the Urban Institute's 1987 survey provide

characteristics of homeless persons who used services, it does not

include the NSHAPC's additional emphasis on geographical and topic

coverage as described in A.4. The 1987 study did not provide any

information on the types of programs and services offered. The Urban

Institute survey is also almost 10 years old. More recent information

is needed. Thus, there is no similar information available that could

be used or modified for use for the purposes described.

5. Minimizing Burden on Small Businesses

The Census Bureau plans on using the combined files from Federal

agencies and national organizations and advocacy groups to generate

listings of service providers for each sample area in the survey and

mail the listings to all service providers contacted by telephone and

all knowledgeable local persons. The knowledgeable local persons and

service providers will be asked to review the listing for completeness

of all service providers in their area and to add any missed service

providers to the list. The state homeless coordinator will only be

asked to review the listing of service providers (Form NSHAPC 100M).

The Census Bureau believes the file will provide an initial

comprehensive listing of service providers currently offering services

to the homeless, thus reducing the burden of the service providers,

government contacts, and knowledgeable local persons. No small

businesses will be contacted.

6. Consequences of Less Frequent Collection

Not applicable. This is a one-time survey. Phase 1 will be

conducted from October 2, 1995 to January 15, 1996, and Phase 2 from

January 21 to March 30, 1996.

7. Consistency with 5 CFR 1320.6

The Census Bureau will collect these data in a manner consistent

with the guidelines in 5 CFR 1320.6.

8. Consultations Outside the Agency

Consultations have been made with the following people:

Dr. Martha Burt, The Urban Institute, 2100 M Street, NW., Washington,

DC 20037, Tel: (202) 857-8551

Ms. Lorraine Reilly (formerly of) The Urban Institute, 2100 M Street,

NW., Washington, DC 20037, Tel: (202) 857-8551

Dr. Michael Dennis, Research Triangle Institute, Center for Social

Research and Policy Analysis, P.O. Box 12194, Research Triangle Park,

NC 27709-2194, Tel: (919) 541-6429

Dr. Greg Owen, Wilder Foundation, Wilder Research Center, 1295 Bandana

Blvd., North--Suite 210, St. Paul, MN 55108-5197, Tel: (612) 647-4612

Ms. Joanne Wiggins, U.S. Dept. of Education, 600 Independence Avenue,

SW--Room 4143, Washington, DC 20202, Tel: (202) 401-1958

Mr. Tom Fagan, U.S. Dept. of Education, 400 Maryland Avenue, SW--Room

2043, Washington, DC 20202, Tel: (202) 401-0039

Mr. John Pentecost, USDA-FmHA, Room 5345-South, MFHD-PD, Washington, DC

20250, Tel: (202) 720-8983

Mr. Tom Sanders, USDA-FmHA, Room 5343-South, MFHD-PD, Washington, DC

20250, Tel: (202) 720-1626

Ms. Amy Donoghue, USDA-FmHA-PAS, 3101 Park Center Drive--Room 1130,

Alexandria, VA 22302, Tel: (703) 305-2920

Ms. Jean Whaley, Dept. of Housing and Urban Development, 451 Seventh

Street, SW--Room 7267, Washington, DC 20410, Tel: (202) 708-1234

Ms. Jane Karadbil, Dept. of Housing and Urban Development, 451 Seventh

Street, SW--Room 8112, Washington, DC 20410, Tel: (202) 708-1537

Mr. Lafayette Grisby (formerly of) Dept. of Labor, Room N-5637, 200

Constitution Avenue, NW., Washington, DC 20210, Tel: (202) 535-0677

Mr. John Heinberg, Dept. of Labor, Room N-5637, 200 Constitution

Avenue, NW., Washington, DC 20210 Tel: (202) 535-0682

Mr. David Lah, Dept. of Labor, Room N-5637, 200 Constitution Avenue,

NW., Washington, DC 20210, Tel: (202) 535-0682

Mr. Pete Dougherty, Homeless Programs Specialist, Dept. of Veterans

Affairs, 801 Vermont Avenue, NW., Washington, DC 20420, Tel: (202) 273-

5716

Mr. Eric Lindblom (IIIC) (formerly of) Office of Mental Health, Dept.

of Veterans Affairs, 801 Vermont Avenue, NW., Washington, DC 20420,

Tel: (202) 535-7311

Dr. Robert Rosenheck, MD, VA Medical Center, NEPEC-182, 950 Campbell

Avenue, West Haven, CT 06516, Tel: (203) 937-3850

Ms. Cynthia Taeuber, Office of the Deputy Director, Bureau of the

Census, Washington, DC 20233, Tel: (301) 457-4358

Ms. Annetta Clark, Special Places/Group Quarters Team, Office of the

Assistant Division Chief, Population Division, Bureau of the Census

Washington, DC 20233, Tel: (301) 457-2378

Ms. Denise Smith, Special places/Group Quarters Team, Office of the

Assistant Division Chief, Population Division, Bureau of the Census,

Washington, DC 20233, Tel: (301) 457-2378

Dr. Charles H. Alexander, Demographic Statistical Methods Division,

Bureau

[[Page 40645]]

of the Census, Washington, DC 20233, Tel: (301) 457-4290

Mr. David Hubble, Victimization and Expenditure Branch, Demographic

Statistical Methods Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-4239

Ms. Marjorie Dauphin, Victimization and Expenditure Branch, Demographic

Statistical Methods Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-4190

Ms. Miriam Rosenthal (formerly of) Victimization and Expenditure

Branch, Demographic Statistical Methods Division, Bureau of the Census,

Washington, DC 20233, Tel: (301) 457-4270

Mr. David Hornick, Victimization and Expenditure Branch, Demographic

Statistical Methods Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-4190

Mr. John Bushery, Quality Assurance and Evaluation Branch, Demographic

Statistical Methods Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-1915

Ms. Andrea Meier, Quality Assurance and Evaluation Branch, Demographic

Statistical Methods Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-1983

Mr. Michael McMahon, Field Division, Bureau of the Census, Washington,

DC 20233, Tel: (301) 457-4901

Mr. Chester Bowie, Demographic Surveys Division, Bureau of the Census,

Washington, DC 20233, Tel: (301) 457-3773

Mr. Steven Tourkin, Methods, Procedures and Quality Control Branch,

Demographic Surveys Division, Bureau of the Census, Washington, DC

20233, Tel: (301) 457-3791

Ms. Jacquie Lawing, Deputy Assistance Secretary for Economic

Development, Department of Housing and Urban Development, 451 Seventh

Street, SW, Suite 7204, Washington, DC 20410, Tel: (202) 708-0270

Mr. Mark Johnston, Senior Advisor on Homelessness, Department of

Housing and Urban Development, 451 Seventh Street, SW, Suite 7274,

Washington, DC 20410, Tel: (202) 708-5528

Mr. Mike Roanhouse, Office of Special Needs Assistance, Department of

Housing and Urban Development, 451 Seventh Street, SW, Room 7258,

Washington, DC 20410, Tel: (202) 708-1234

Mr. James Hoben, Office of Policy Development and Research, Department

of Housing and Urban Development, 451 Seventh Street, SW, Washington,

DC 20410, Tel: (202) 708-0574

Mr. Keith Lively, Acting Deputy Assistance Secretary for Program

Systems, Department of Health and Human Services, 200 Independence

Avenue, SW, Room 447D, Washington, DC 20201, Tel: (202) 690-8774

Mr. Gerald Britten (formerly of) Deputy Assistant Secretary for Program

Systems, Department of Health and Human Services, 200 Independence

Avenue, SW, Room 447D, Washington, DC 20201, Tel: (202) 690-8774

Ms. Mary Ellen O'Connell, Office of the Assistant Secretary for

Planning and Evaluation, 200 Independence Avenue, SW, Room 447D,

Washington, DC 20201, Tel: (202) 260-0391

Mr. Fred Osher (formerly of) Office of Programs for the Homeless

Mentally Ill, National Institute of Mental Health, Dept. of Health and

Human Services, Parklawn Bldg., Room 3C06, 5600 Fishers Lane,

Rockville, MD 20857, Tel: (301) 443-3706

Mr. Walter Leginski, Homeless Programs Branch, Center for Mental Health

Services, Parklawn Building, room 11c-05, Rockville, MD 20857

Dr. Robert Huebner, Ph.D., Health Services Research Branch, National

Institute of Alcohol Abuse and Alcoholism, Dept. of Health and Human

Services, Willow Building, Suite 505, 600 Executive Boulevard,

Rockville, MD 20892-7003, Tel: (301) 443-0786

Mr. Steve Bartolomei-Hill, Human Service Policy, Office of the

Assistant Secretary for Planning and Evaluation, Dept. of Health and

Human Services, Hubert H. Humphrey Bldg., Room 410E, 200 Independence

Avenue, SW, Washington, DC 20201, Tel: (202) 690-7148

Ms. Rhoda Davis, Office of Supplemental Security Income, Dept. of

Health and Human Services, Altmeyer Building, 6401 Security Blvd.

Baltimore, MD 21235, Tel: (410) 965-6210

Ms. Terry Lewis, Administration on Children, Youth, and Families,

Administration for Children and Families, Dept. of Health and Human

Services, Mary E. Switzer Bldg., Room 2426, 330 C Street, SW,

Washington, DC 20201, Tel: (202) 205-8051

Dr. Joan Turek Brezina, Ph.D., Program Systems, Office of the Assistant

Secretary for Planning and Evaluation, Dept. of Health and Human

Services, Hubert H. Humphrey Bldg., Room 444F, 200 Independence Avenue,

SW., Washington, DC 20201, Tel: (202) 690-6141

Mr. Mike Jewell (formerly of) Office of the Assistant Secretary for

Planning and Evaluation, Dept. of Health and Human Services, Hubert H.

Humphrey Bldg--Room 447D, 200 Independence Avenue, SW, Washington, DC

20201, Tel: (202) 690-7316

Ms. Peg Washnitzer, Office of Community Services, Administration for

Children and Families, Dept. of Health and Human Services, Aerospace

Bldg., 7th Floor, 370 L'Enfant Promenade, SW, Washington, DC 20447,

Tel: (202) 401-2333

Mr. Richard Chambers, Division of Intergovernmental Affairs, Health

Care Financing Administration, Dept. of Health and Human Services,

Hubert H. Humphrey Bldg., Room 410B, 200 Independence Avenue, SW,

Washington, DC 20201, Tel: (202) 690-6257

Ms. Joan Holloway, Health Resources and Services Administration, Public

Health Services, Dept. of Health and Human Services, Parklawn Bldg.,

Room 9-12, 5600 Fishers Lane, Rockville, MD 20857, Tel: (301) 443-8134

Ms. Marsha A. Martin (formerly of) Executive Director, Interagency

Council on the Homeless, 457 Seventh Street, NW, Washington, DC, Tel:

(202) 708-1480

Mr. George Ferguson, Interagency Council on the Homeless, 457 Seventh

Street, NW, Washington, DC, Tel: (202) 708-1480

Ms. Della Hughes, National Network of Runaway and Youth Services, 1319

F Street, N.W., Suite 401, Washington, D.C. 20004, Tel: (202) 783-7949

Ms. Vera Johnson, SASHA Bruce Center Runaway Shelter, 1022 Maryland

Avenue, N.E., Washington, D.C. 20002, Tel: (202) 675-9340

As a result of these consultations, all issues were resolved.

9. Assurance of Confidentiality

The provisions of the Privacy Act of 1974 (5 USC 552a) assure the

confidentiality of the data from this survey.

During Phase 1 of the national survey, service providers contacted

by telephone will receive an advance letter explaining the survey and

the confidentiality of their responses and the voluntary nature of the

NSHAPC along with other information required by the Privacy Act of 1974

at the time of initial contact. Service providers will also receive

NSHAPC L(3)--letter with

[[Page 40646]]

the NSHAPC Form N List of Providers, and with the detailed program

questionnaires, NSHAPC Forms 100B to 100L, (Attachments B to L,

respectively) explaining the survey and the confidentiality of their

responses. As can be seen on the NSHAPC questionnaire cover sheets

(Attachments B through M respectively), a statement of confidentiality

assurance is printed at the top of the form. Careful procedures are

followed by the Bureau of the Census to assure privacy during the

interview, and to protect the confidentiality of materials generated

during the course of the interview. Every Bureau of the Census employee

takes an oath and is subject to a jail sentence and a fine for

improperly disclosing any information that would identify an individual

or household. All field representatives are trained to interview

respondents in private. All questionnaires associated with the national

survey will be kept under secured conditions by the Bureau of the

Census.

10. Justification for Sensitive Questions

The NSHAPC-100A to NSHAPC-100M questionnaires do not include any

questions of a sensitive nature.

11. Cost

The total estimated cost for Phase 1 of the national survey is

$1,950,000. Cost for Phase 1, Steps 1 and 2 is $1,500,000. Cost to

collect detailed program and service level data (Step 3) is $450,000.

We compiled this estimate using individual estimates developed within

each Census Bureau division involved in this survey. Estimates are

based on the size of the sample and the length of the questionnaires.

Administrative overheads, design, printing, and mailing costs are

included.

The total estimated cost for Phase 2 is $2,200,000.

The only cost to the service providers and the service users

(clients) is the time it takes to complete the questionnaire.

12. Estimate of Respondent Burden

The projected number of government contacts, service providers and

clients to be contacted and the estimated burden for the survey are

indicated below:

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We estimate the average time to complete the NSHAPC-100A, Service

Provider Core Data Questionnaire (refer to Attachment A) to be 15

minutes; the review of the combined list of service providers to be 15

minutes, and the detailed program level questionnaire (refer to

Attachments B to L) to be 30 minutes. These estimates are based on in-

house testing of the questionnaires by the Census Bureau. We estimate

the information burden for these forms to be 20,350 hours. This

includes:

6,250 hours for the CATI interview.

6,250 hours for review of the combined list of service

providers.

5,000 hours for the detailed program level questionnaire.

2,850 hours for the Client Questionnaire.

13. Reason for Change in Burden

Not Applicable. This is a new survey. There are, therefore, 0 hours

in the current OMB inventory.

14. Project Schedule

Beginning in October 1, 1995, the Census Bureau plans on

telephoning all service providers within sample areas to collect basic

information about programs offered. After the phone calls are

completed, the Census Bureau will mail the listings of service

providers by sample area and the NSHAPC--L(2)L letter to providers

contacted by telephone. A subsample of providers will also be asked to

provide more detailed information about the services they offer. After

conducting the CATI interviews, the Census Bureau will mail the

appropriate questionnaires, NSHAPC Form 100B to 100L, to the providers

in sample.

Census Bureau personnel also will contact individuals from federal

and state governments, agencies, organizations and knowledgeable local

persons and ask them to review the lists of service providers. The

Census Bureau will conduct these operations during October 1995 to

January 1996.

B. Collection of Information Employing Statistical Methods

1. Universe and Respondent Selection

The Census Bureau will conduct the national survey in 76 primary

sampling areas. The Census Bureau will interview all service providers

in the sample areas to collect basic information about the programs

offered. This is a total of 25,000 interviews. The Census Bureau will

select a subsample of providers within those areas and conduct detailed

mail interviews for the programs and services offered by the provider.

This is a total of a 5,000 providers.

Phase 1 of the survey will provide information on the types of

programs and services available to homeless people. Phase 2 of the

survey will provide detailed characteristics about homeless service

users (clients), including the literally homeless. Most research to

date has been conducted in urban and suburban areas. For such areas,

there is a growing consensus among researchers that a service-based

survey design with sampling over time (vs. one-time sampling) will give

a good representation of the homeless population. For nonmetropolitan

areas, the consensus is that an expansion of the types of service

providers is needed to cover the homeless adequately. The Department of

Agriculture requested an increase in the number of sample areas and the

Census Bureau identified ways to design the survey to produce

reasonably precise estimates of rural homelessness. However, it should

be noted that the procedures for measuring rural homelessness will be

less sophisticated than our procedures in urban areas. There is much to

learn about rural areas and the NSHAPC is an excellent opportunity to

collect information about rural homelessness. In the nonmetroplitan

areas the sampling frame is the set of Community Assistance Program

(CAP) ``Catchment Areas'', wherever they exist. CAP catchment areas are

counties or local areas grouped together to receive funding and provide

services to the needy and are served by a CAP agency. Our preliminary

research indicates that CAP agencies are a good source for lists of

services in the nonmetropolitan areas they cover. In a few

nonmetropolitan areas where CAPs do not exist, the sampling frame is

the set of counties or groups of counties.

2. Procedures for Collecting Information

Sampled Service Providers

The Census Bureau will conduct the survey in 76 sample areas; this

is the first stage of sampling. Within each sample area, a

comprehensive list of service providers will be developed. All

providers will furnish basic, core information on programs offered.

Phase 1, also includes a second stage of sampling where a subset of

service providers will be selected within each sample area to be asked

more detailed information about their programs and services.

Sample of Clients (Service Users)

In Phase 2, a sample of clients will be selected for interviewing.

This is a three-stage sample, where the first-stage sample corresponds

to the same 76 geographic areas discussed above for the provider-

interview sample. In the second stage, a sample of providers will be

selected in each sample area but only in designated programs. In the

third stage, a sample of the clients at each of the sample provider

facilities will be selected.

Estimation

In Phase 1, the estimates needed are proportions of providers

falling in different categories.

The estimates needed for Phase 2 consist of proportions of clients

falling in different categories. The base for these proportions can be

derived in two ways:

a. Weighted estimates of the average number of persons using

services on any given day in February;

b. Weighted estimates of the total number of persons using services

at any time during February.

Other estimates can be derived from these. For example, the weights

applied to obtain estimates (a) or (b) could be used for estimates only

of those service-using persons who are homeless according to different

definitions of homelessness. For the national survey, it is likely that

a range of estimates will be provided, corresponding to different

assumptions about coverage and multiplicity biases.

The weights for (a) will be standard survey weights based on the

selection probability, with adjustments for nonresponse. There will be

a ``multiplicity'' adjustment to reduce the relative weight of people

who have more than one change of selection because they use more than

one type of program, for example, both shelters and soup kitchens, as

determined from the questionnaire.

For (b) three estimation methods are under consideration. One

purpose of the pretest was to get information to evaluate these

methods.

METHOD 1: The weight will be proportional to the number of

consecutive days prior to the interview (up to 28 days) that the person

did not use a shelter (for the shelter sample) or soup kitchen (for the

soup kitchen sample), and likewise for other types of programs. For

example, a person who says this is their first night in any shelter in

the last 28 days will be given a weight 28 times the typical weight of

a person who was in a shelter the night before. (Intuitively, the

method assumes that for every person we find who is just entering

homelessness, there are 27 others whom we miss because we did not

happen to interview them on their first day.) There is a precise

mathematical justification for the

[[Page 40649]]

method as given an unbiased estimate of the total number of service

users during 28-day periods centered around February, making some

assumptions that overall patterns of service use are fairly constant

throughout the month.

This is intended to be our primary method. The potential drawback

of this method would be if the pretest finds too many people who are

just starting to use services after a long absence, resulting in too

many large weights. Limited research from 1990 census evaluation

projects suggests that this should not be a problem. However, if this

turns out to be a problem we would either use the Method 2 or use

Method 1 with a 7-day ``window'' instead of a 28-day ``window''.

METHOD 2: The weight will be inversely proportional to the number

of days in the last week the client used a shelter (for the shelter

sample) or soup kitchen (for the soup kitchen sample), and likewise for

other types of programs. This is the procedure used in the 1987 Urban

Institute study. We will ask this question for comparability with that

survey. This approach has two disadvantages. First, even if the

questions are answered accurately, the method has a mathematical bias

unless each person has the same pattern of service use each week.

Second, it is not reasonable to ask a person for his/her average

shelter use for an entire month, so the method cannot give direct

estimates for the total number using services during a period longer

than a week.

METHOD 3: Capture-recapture. We are not using capture-recapture

estimation. It would require selecting the sample independently each

day, so that there would be a chance that a person or small shelter

might come into sample numerous times.

The Urban Institute and the Census Bureau developed the survey

design. As part of Joint Statistical Agreements between the Urban

Institute and the Census Bureau, the following operational papers and

references were developed. Each are available from the Census Bureau on

request.

Joint Statistical Agreement 91-30

--Developing a Provider List--November 27, 1991

--Methodological Issues and Options--November 27, 1991

--Options for Evaluating Coverage in Urban Areas--December 10, 1991

--Ranking of Data Items by Federal Agencies--December 10, 1991

Joint Statistical Agreement 92-01

--Draft Questionnaire and Agency Data Needs--March 26, 1992

--Developing Provider Lists for a National Homeless Survey--March 26,

1992

--Proposed Methodology for a National Homeless Survey--March 26, 1992

--Questions for Unduplicating and for Estimating a Month-Long Point

Prevalence and Annual Prevalence--March 26, 1992

--Developing Estimates of the Number of Service Providers in Different

Strata--April 10, 1992

--Options for Evaluating Survey Coverage in Urban Areas, and

Preliminary

--Information on Rural Areas--April 10, 1992

Joint Statistical Agreement 92-04

--Mechanics of List Development and Additional Field and Survey

Procedures--August 14, 1992

--Estimates of Service Providers and Users in Non-MSA Areas, and

Options for

--Evaluating Survey Coverage in These Areas--August 4, 1992

List of References

3. Methods to Maximize Response

a. Survey Frame for Client Interviews

New research indicates the greatest improvement in coverage of the

homeless population is through sampling this population over time,

(e.g., soup kitchens and shelters) and outreach programs during a four-

week period. The NSHAPC survey design uses a service-based methodology.

A ``service user'' is anyone who uses generic services or shelters,

soup kitchens, or other services for the homeless. The survey frame

will include shelters, soup kitchens, outreach programs, and possibly

other programs. A ``non-service user'' is anyone who does not use any

of these services.

According to the 1987 Urban Institute study, the shelter frame

covers homeless people who use shelters, which may be 35 to 40 percent

of the homeless on any given night, and about 50 percent over the

course of a week. If conducted on a one-night basis, the shelters'

sampling frame taken by itself will miss many homeless who use shelters

infrequently, homeless service users who do not use shelters but do use

soup kitchens and other services, and homeless people who do not use

any services. If data collection involves repeated samples from the

same shelters over the course of a week or a month, a considerably

higher proportion of the homeless (perhaps as high as 70 percent) is

likely to be captured through a methodology based on shelters.

The soup kitchen sampling frame, taken by itself over the course of

a week, will capture a proportion of very poor people residing in

conventional dwellings who may turn out to be at imminent risk of

hopelessness. According to the 1987 Urban Institute study, 43 percent

of soup kitchen users are not literally homeless. When shelter and soup

kitchen frames are combined during the course of a week, the shelter

and soup kitchen frames will probably cover about 70 percent of the

literally homeless and a small but unknown proportion of the service-

using at-risk population. When data collection covers a month (as

planned for the national survey), the coverage will be even greater--

perhaps as high as 85-90 percent of the literally homeless.

In many cities, the array of services for the homeless include one

or more outreach programs. These programs may be operated by a shelter,

soup kitchen, drop-in center, health care center, neighborhood center,

or other service facility. Their target population is homeless people

who do not routinely use shelters or soup kitchens. The outreach

programs typically distribute food, and sometimes blankets or warm

clothing. Outreach teams typically follow a route that covers the known

locations frequented by homeless street people, or where homeless

street people assemble at the time they know the ``food wagon'' will

come by. Including outreach programs in a design as a sampling frame

allows one to maintain the control and efficiency associated with

sampling service programs and their users, while still reaching the

``reachable'' proportion of the street homeless population. Outreach

programs are probably the best single source of information about the

hidden street population and the most cost effective opportunity to

make contact with the street population. Additional enumeration of

street locations and encampments yields little overall coverage

improvement when shelters, soup kitchens, and outreach programs are

interviewed over time.

The NSHAPC is designed to cover as much of the literally homeless

population as possible and still meet the cost considerations of the

sponsors. From previous research, it appears that up to 90 percent

coverage of the literally homeless population is achievable with the

shelter/soup kitchen/outreach programs methodology conducted during a

winter month. This service-based methodology will be considerably

cheaper and easier than implementing a street enumeration to attempt to

get the last 10 percent. In addition, even if the resources were

committed to achieve

[[Page 40650]]

full coverage, there is not guarantee we would get the last 10 percent.

b. Incentives to Participate in the Survey

The letters and information on the survey have been written to

explain the benefits of the survey so that respondents will be

encouraged to participate in the survey. Also, the Census Bureau has

designed the survey questionnaires to minimize respondents' time and

efforts. We think this effort will encourage providers to participate

in the survey.

4. Contacts for Statistical Aspects and Data Collection

The following individuals are being consulted on statistical

aspects of the survey design:

Dr. Martha Burt, The Urban Institute, 2100 M Street, NW, Washington, DC

20037, Tel: (202) 857-8551

Dr. Michael Dennis, Research Triangle Institute, Center for Social

Research and Policy Analysis, PO Box 12194, Research Triangle Park, NC

27709-2194, Tel: (919) 541-6429

Dr. Charles H. Alexander, Demographic Statistical Methods Division,

Bureau of the Census, Washington, DC 20233, (301) 457-4290

The Census Bureau will collect the data for this survey. Mr. Steven

Tourkin is responsible for the collection of all data and is the Census

Bureau contact person for the survey.

Mr. Steven C. Tourkin, Demographic Surveys Division, Bureau of the

Census, Washington, DC 20233, (301) 457-3791

List of Attachments

Attachment A NASHAPC-100A, Service provider Core Data Questionnaire

Attachment B NASHAPC-100B, Emergency Shelter Program Questionnaire

Attachment C NASHAPC-100C, Transitional Housing Program Questionnaire

Attachment D NASHAPC-100D, Voucher Program Questionnaire

Attachment E NASHAPC-100E, Permanent Housing for the Homeless Program

Questionnaire

Attachment F NASHAPC-100F, Alcohol/Drug Program Questionnaire

Attachment G NASHAPC-100G, Mental health Care Program Questionnaire

Attachment H NASHAPC-100H, Physical Health Care Program Questionnaire

Attachment I NASHAPC-100I, Drop-in Center Program Questionnaire

Attachment J NASHAPC-100J, HIV/AIDS Program Questionnaire

Attachment K NASHAPC-100K, Outreach Program Questionnaire

Attachment L NASHAPC-100L, `Other' Program Questionnaire

Attachment M NASHAPC-100M, Provider Update Form Questionnaire

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[FR Doc. 95-19597 Filed 8-8-95; 8:45 am]

BILLING CODE 4210-01-C

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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