November 5, 2021

Ms. Maria G. Button
Director, Executive Secretariat
Health Resources and Services Administration (HRSA)
5600 Fishers Lane Room 14N136B
Rockville, MD 20857

Submitted Electronically: paperwork@hrsa.gov 

RE: Information Collection Request Title: DoNation General Workplace Campaign Scorecard, 0906–XXXX—New Document Number: 2021 – 19313 

Dear Ms. Button:

Thank you for the opportunity to provide input to the Health Resources and Services Administration (HRSA)’s Information Collection Request (ICR) entitled “DoNation Workplace Campaign Scorecard for Organ Donation”.

AOPO is the national representative of 48 federally designated, non-profit Organ Procurement Organizations (OPOs) in the United States, who together serve millions of Americans. AOPO is dedicated to providing education, information sharing, research, and technical assistance, and collaboration with OPOs, other stakeholders, and federal agencies to continue this nation’s world-leading transplant rates while consistently improving towards the singular goal of saving as many lives as possible. Hence, the goal of the HRSA workplace campaign — to enlist the help of America’s workplaces to increase the number of registered organ, eye and tissue donors by hosting awareness, education, outreach, and donor registration events in their companies, workplaces, and communities — is a commitment AOPO shares. We enthusiastically encourage HRSA to continue this campaign to ensure maximum participation in organ and tissue donation through every means possible.

Specifically, HRSA has requested comment on 4 issues: (1) the necessity and utility of the proposed information collection for the proper performance of the agency’s functions; (2) the accuracy of the estimated burden; (3) ways to enhance the quality, utility and clarity of the information collected; and (4) the use of automated collection techniques or other forms of information technology to minimize the information burden. AOPO has addressed each of these issues below:

1. Necessity and utility of the proposed information collection for the proper performance of the agency’s function

As noted in the ICR, there is a substantial imbalance between the number of people whose life depends on an organ transplant and the annual number of organ transplants. In response to this need, HRSA conducts public outreach initiatives to encourage Americans to enroll in their state registry as future organ, eye and tissue donors.

AOPO agrees that the HRSA scorecard campaign can motivate businesses to join this life-saving campaign, as well as facilitate participation by providing materials and guidance towards that end. Points awarded for each activity and recognition of milestone achievements can stimulate competition, encourage greater participation among work colleagues, and ultimately save and heal more lives. The score card better enables HRSA to measure and evaluate the campaign’s process and outcomes by providing consistent data among participants. This data can help HRSA evaluate the overall success of the campaign and help make data-based decisions for improvement in subsequent campaigns.

2. Accuracy of the estimated burden

HRSA estimates the individual response time for participation to be about 15 minutes per respondent, with approximately 150 respondents, or 37.5 hours per organization would be expended by persons to generate, maintain, retain, disclose, or provide the information requested.

AOPO agrees that the total time per participant would be approximately 15 minutes, however, many businesses will not have 150 respondents simply due to the size of the company. In addition, the ICF, indicates that the time estimate also includes the time needed to acquire, install, and utilize technology and systems for the purposes of collecting, validating and verifying information, process and maintain information and to train personnel. AOPO believes these functions can require more time than indicated and suggests HRSA separately designate additional time per workplace for administrative set-up and launch of the campaign.

3. Ways to enhance the quality, utility and clarity of the information collected

AOPO believes the HRSA DoNation scorecard, which identifies certain activities that participants can implement and assign points to each activity, is a straightforward approach.

In addition, HRSA has indicated that participants that earn a certain number of points annually will be recognized by HHS/HRSA and other national organizations that support the campaign’s mission. While this approach seems logical, AOPO believes that all businesses that participate in the campaign should be recognized based on the percentage of participation or percentage of designations to the overall workforce. Regardless of the number of points earned, we don’t want to discourage small businesses with fewer employees from participating in this important life-saving campaign. However, perhaps those businesses that exceed certain thresholds can receive additional recognition.

4. Use of automated collection techniques or other forms of information technology to minimize the information burden

AOPO strongly supports HRSA’s intention to create an electronic version of a user-friendly scorecard to collect information from workplaces. A digital template that is easily accessible to employees of workplaces participating in the campaign would likely increase participation, capture participation rates, and reduce the time burden for collection for business and the review of data by HRSA. AOPO suggests HRSA work with Donate Life America to partner in potential ways to use existing methodologies to track the success of the campaign and the needed donor designation information.

As the nation’s leading voice for OPOs, AOPO represents the thousands of dedicated OPO professionals working together with donor families, hospitals, and transplant programs, to ensure every donation opportunity results in a life saved.

We appreciate this opportunity to provide feedback and welcome future opportunities to collaborate with HRSA and other stakeholders toward our shared goal of improving the health of those in need of life-saving transplants. If you have any questions about the content of this letter, please contact Mark Cribben, Director of Government Affairs, at mcribben@aopo.org.

Thank you,

Jan Finn
President, AOPO