FABP.Focus Groups.Supporting Statement A

Supporting Statement A
U.S. Election Assistance Commission
Study of the Feasibility and Advisability of Establishing a Program of Free Return or
Reduced Postage for Absentee Ballots
Focus Groups
A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
Section 246 of the Help America Vote Act (HAVA) of 2002 (42 U.S.C. 15301) mandates that
the U.S. Election Assistance Commission (EAC), in consultation with the United States Postal
Service, to conduct a study on the feasibility and advisability of establishing a program under
which the U.S. Postal Service shall waive or otherwise reduce the amount of postage applicable
with respect to absentee ballots returned by voters in general elections for Federal office. This
study does not address the cost to the U.S. Postal Service for free postage for sending absentee
ballots but may consider costs to election officials that are related to implementing such a
program including the costs of sending absentee ballots to voters. It also does not include
consideration of the 39 USC 3406 provisions for the mailing of balloting materials for military
and overseas absentee voters. As part of the study the Commission is directed to conduct a
survey of potential beneficiaries, including the elderly and disabled, and to take into account the
results of this survey in determining the feasibility and advisability of establishing such a
program. HAVA §246(b)(1) requires the Commission to submit to Congress a report on the
study conducted under HAVA §246(a)(1) together with recommendations for such legislative
actions as the Commission determines appropriate. In addition, the report is required to contain
an estimate of the costs of establishing the program described in HAVA §246(a)(1), an analysis
of the feasibility of implementing such program with respect to the absentee ballots to be
submitted in the general election for Federal office held in 2004, and recommendations on ways
the program would target elderly individuals and individuals with disabilities and methods for
increasing the number of such individuals who vote in elections for Federal office.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
HAVA §246 mandates the EAC conduct a one-time information collection regarding the
feasibility and advisability of establishing a program under which the U.S. Postal Service shall
waive or otherwise reduce the amount of postage applicable with respect to absentee ballots
returned by voters in general elections for Federal office. HAVA §246(b)(1) requires the
Commission to submit to Congress a report on the study conducted under HAVA §246(a)(1)
together with recommendations for such legislative actions as the Commission determines
appropriate. In addition, the report is required to contain an estimate of the costs of establishing
the program described in HAVA §246(a)(1), an analysis of the feasibility of implementing such

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program with respect to the absentee ballots to be submitted in the general election for Federal
office held in 2004, and recommendations on ways the program would target elderly individuals
and individuals with disabilities and methods for increasing the number of such individuals who
vote in elections for Federal office.
The information for this collection will be collected through a one-time public opinion survey of
1,200 randomly selected U.S. citizens throughout the fifty U.S. States and through nine focus
groups meetings designed to explore, in-depth, issues concerning the potential beneficiaries of
this program. The beneficiaries include those who will be more likely to participate in federal
elections should this program be implemented, including the elderly, the disabled, and the
impoverished. This Information Collection Request (ICR) is only for the focus groups, the
national voter survey is being submitted as a separate ICR for review and clearance in
accordance with the Paperwork Reduction Act of 1995.
The focus groups to be carried under this proposed information collection will be divided as
follows: three (3) focus groups will be dedicated to issues confronting the elderly population;
three (3) focus groups will be dedicated to issues confronting the disabled population; and three
(3) focus groups will be dedicated to issues confronting the impoverished. Locations of the focus
groups have been determined through consultation with the U.S. Postal Service and the study
contractor, see Figure 1 below.
Figure 1
Urban
Rural
Suburban

Low-income
Washington, DC
Lenawee/Hillsdale
County Michigan
Memphis, Tennessee
Metro (Marshall
County, Mississippi)

Senior Citizens
Sacramento,
California
Lafayette County,
Mississippi
Colorado Springs,
Colorado

Individuals with Disabilities
Washington, DC
Central Valley, California
Detroit area Michigan

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
Not applicable to this collection.
4. Describe efforts to identify duplication.
This information collection is mandated by HAVA §246. Previous and contemporaneous public
opinion surveys on the subject matter have been reviewed to eliminate duplication.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This collection of information will seek out assistance from small entities that specialize in

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working with the elderly, impoverished, and disabled in securing participants for the focus
groups. The study contractor will also seek out assistance from small entities in meeting any
special needs of the possible participants. The assistance provided by these small organizations
will be on a voluntary basis and will have minimal economic impact.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
HAVA §246 mandates the EAC conduct this information collection. This is a one-time
information collection. HAVA §246(b)(1) requires the Commission to submit to Congress a
report on the study conducted under HAVA §246(a)(1) together with recommendations for such
legislative actions as the Commission determines appropriate. In addition, the report is required
to contain an estimate of the costs of establishing the program described in HAVA §246(a)(1), an
analysis of the feasibility of implementing such program with respect to the absentee ballots to
be submitted in the general election for Federal office held in 2004, and recommendations on
ways the program would target elderly individuals and individuals with disabilities and methods
for increasing the number of such individuals who vote in elections for Federal office. Failure to
conduct the collection of this information may result in the EAC being unable to meet its
statutory requirements under HAVA (42 U.S.C. 15301). This information collection was
required to be carried out no later than the date that was 1 year after the date of the enactment of
HAVA (2002); as such, it is not recommended that the collection or the report due to Congress
be delayed further.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Not applicable.

8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
The EAC published a notice in the Federal Register on November 14, 2006, at 71 FR 66321
soliciting comments for a period of sixty (60) days. A second notice was published on May 18,
2007, at 72 FR 28036 soliciting comments for a period of thirty (30) days.
Public Comment Summary:
1. This information collection request received a comment from the U.S. Postal Service citing a
concern over the potential establishment of a program of free return or reduced postage for
absentee ballots. The U.S. Postal Service indicated that it lacks appropriations to fund such a

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program, and the positive experience of Oregon and Washington, which rely almost exclusively
on a vote-by-mail system, suggests that increased voter participation is not correlated with free
or reduced postage for absentee ballots. In a separate communication, the U.S. Postal Service
provided suggestions to improve this information collection.
2. This information collection request received a comment from a member of the public
indicating that the study will fail to draw any valid conclusions due to such a small sample of
potential beneficiaries.
Actions Taken:
In response to these comments, the EAC and the study contractor decided to increase the number
of focus groups from three to nine. Each selected group (individuals with disabilities, Senior
Citizens and people with low-incomes) will have three dedicated focus groups. To ensure the
diversity of responses and participants, each selected group will have one focus group from an
urban, rural, and suburban location (Figure 1).
Figure 1.
Urban
Rural
Suburban

Low-income
Washington, DC
Lenawee/Hillsdale
County Michigan
Memphis, Tennessee
Metro (Marshall
County, Mississippi)

Senior Citizens
Sacramento,
California
Lafayette County,
Mississippi
Colorado Springs,
Colorado

Individuals with Disabilities
Washington, DC
Central Valley, California
Detroit area Michigan

Furthermore, in consideration of the concerns presented by the U.S. Postal Service and in
consultation with the EAC, the study contractor adjusted the focus group discussion guides to
address these issues.
The EAC and the study contractor have consulted extensively with the U.S. Postal Service in
preparing the information collection request. Wherever possible and in consultation with the
EAC, the study contractor adjusted the information collection to accommodate the comments
from the U.S. Postal Service. In addition, U.S. State and county election officials were consulted
extensively during the development of the focus group materials.

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
Respondents will be supplied a cash incentive at the rate of $25 per participant. Providing an
incentive for participation will help in the process of securing respondents for this study.

10.
Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.

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Prior to volunteering to participate, respondents will be assured that responses will not be
associated with a particular respondent.

11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
There are no questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.
The burden to each respondent is 1 hour 15 minutes. Each focus group will last no longer than 1
hour and 15 minutes. One-hundred and eight (108) respondents are required for this study. Total
annual burden is estimated at 135 hours.
Due to comments received from the U.S. Postal Service and U.S. state and county election
officials, the number of focus groups was increased from originally three (3) to nine (9). This has
increased the Total annual burden to 135 hours.
a. Number of respondents = 108
b. Number of responses per each respondent = 1
c. Total annual responses = 1
d. Hours per response = 1.25 hours
e. Total annual reporting burden = 135 hours (# of respondents x frequency of
response x hours of response)

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in #12
above).
We have identified no reporting and recordkeeping “non-hour cost” burdens associated with this
proposed collection of information.

14. Provide estimates of annualized cost to the Federal government.
The estimated cost to the Federal Government is $46,940.This estimate includes $27,984 for
personnel, $13,243 for travel expenses, $210 in office expenses, and $5,593 for the focus group
events.

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We estimate $27,984 for personnel to design the study, oversee its implementation,
oversee the focus groups, and draft a final report. The travel expenses for this project are
estimated at $13,243.
We estimate $210 for office expenses including telephone and printing costs.
We estimate $5,593 for the focus group events, including payment of $25 to each
participant.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14
of the OMB 83-I.
This is the first time this information collection has been performed by the Federal government.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
HAVA §246(b)(1) requires the Commission to submit to Congress a report on the study
conducted under HAVA §246(a)(1) together with recommendations for such legislative actions
as the Commission determines appropriate. In addition, the report is required to contain an
estimate of the costs of establishing the program described in HAVA §246(a)(1), an analysis of
the feasibility of implementing such program with respect to the absentee ballots to be submitted
in the general election for Federal office held in 2004, and recommendations on ways the
program would target elderly individuals and individuals with disabilities and methods for
increasing the number of such individuals who vote in elections for Federal office. The report
will also be made available to the public on the EAC website at www.eac.gov.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
Not applicable to this collection.

18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
To the extent that the topics apply to this collection of information, we are not making any
exceptions to the “Certification for Paperwork Reduction Act Submissions.”

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