Supporting Statement Part A

Supporting Statement to Accompany
OMB Clearance of Customer Satisfaction Surveys:
Phase Two 2009 HUD Partners Surveys

Part A: Justification

U.S. Department of Housing and Urban Development

February 2010

PART A:
JUSTIFICATION
A1

Circumstances that Make the Collection of Information Necessary

This information collection complements an information collection that was
approved by the Office of Management and Budget in September 2009 under OMB
Control Number 2535-0116, which expires on February 29, 2012. Both the earlier
(Phase One) and the present (Phase Two) information collection involve surveys of key
customers (program delivery partners) of the U.S. Department of Housing and Urban
Development (HUD) to determine whether the Agency is appropriately and adequately
serving their needs. They follow from HUD's commitment, as articulated in its Annual
Performance Plan, to measure its partners’ satisfaction with its performance, operations
and programs, as well as changes in satisfaction.1 The purpose of the surveys is to
facilitate the acquisition of information that will help the Department improve its
performance, not only in relation to its partners but, more importantly, its end customers.
The premise is that when those who deliver HUD’s programs receive quality service
from HUD, the individuals and households who benefit from HUD’s programs and
activities will, in turn, receive the best possible service.
The 2009 HUD Partner Surveys are being done in two phases. Phase One
(previously approved by OMB) involves the following partner groups: mayors, directors
of public housing agencies (PHAs), directors of local community development
departments, executives of National Association of Housing Partnerships (NHPN)affiliated nonprofit organizations, directors of fair housing agencies (FHAPs), and
directors of Fair Housing Initiative Program (FHIP) grantee organizations. Phase Two,
presented in this submission, involves: owners of multifamily housing properties assisted
under section 202/811; owners of HUD-insured, unsubsidized multifamily housing
properties; owners of HUD-assisted, subsidized multifamily housing properties; and
HUD/FHA-approved single family mortgage lenders.

1

HUD’s FY 2009 Annual Performance Plan (February 2008) states that HUD will survey its partners
approximately every three years to determine partner satisfaction with the Department and compare the
most recent findings with prior surveys to measure change over time. See http://www.hud.gov/offices/
cfo/reports/cforept.cfm. Under HUD’s strategic goal of embracing high standards of ethics, management,
and accountability, there is the strategic objective of improving the accountability, service delivery, and
customer service of HUD and its partners. To track its commitment to this goal and strategic objective, HUD
has established the following performance indicator: “HUD partners become more satisfied with the
Department’s performance, operations and programs” (p. 103).

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The 2009 HUD Partners Surveys (Phase One and Phase Two) are a follow-up to
information collections that were approved, and undertaken, in previous years—2000
and 2005. The 2000 surveys2 established baseline measures and the 2005 surveys3
provided an initial follow-up. A report on the baseline, 2000 survey, How’s HUD Doing:
Agency Performance as Judged by Its Partners, was published by HUD in 2001. A
report on the second, 2005 survey, Partner Satisfaction with HUD’s Performance: 2005
Survey Results and Trends Since 2001, was published by HUD in 2006.
Of the four partner groups to be surveyed in Phase Two of the 2009 HUD
Partners Surveys, the three multifamily owner groups were previously surveyed in 2000
and 2005 such that change in partner satisfaction over time can be assessed. The
fourth group, HUD/FHA single family mortgage lenders, is being surveyed for the first
time in 2009.
The information produced by this customer satisfaction survey will enable HUD to
better serve its program delivery partners by identifying aspects of HUD’s service that
need improvement. It will also enable HUD to determine whether its customer service,
and the satisfaction of its partners, has improved over the last four years—for those
groups surveyed in prior years. Finally, as a significant extension of the previous
Partners Surveys, the 2009 surveys will provide reports on customer service and
satisfaction at the field office level—where most agency contact with HUD partners takes
place on a day-to-day basis.
A2

How and By Whom the Data Will Be Used

This section discusses how and by whom the data will be used. It provides a
project overview, states the purpose of the data collection, indicates who will use the
information, and gives justification for the various items to be included in the survey.
A2.1

Project Overview

HUD administers an array of programs in the housing, public housing, fair
housing, and community and economic development areas. HUD's end customers
generally receive assistance, services, or benefits through intermediaries (i.e., program
delivery partners) such as public agencies that own and manage public housing, fair
housing agencies that provide educational and adjudication services, and state and local
government agencies and officials involved in community improvement. This data
collection consists of a survey by mail, with telephone follow-up, of a sample of four
distinct partner groups—consisting of approximately 33,500 partners.

2

OMB approval for the 2000 surveys expired on October 31, 2003.

3

OMB approval for those surveys ended on May 31, 2008.

3

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A2.2

Purpose of the Data Collection

The information produced by this customer satisfaction survey will measure
changes in partners’ opinions since 2005 when HUD last conducted a similar survey of
its partners. A report based on the information gathered in this study will satisfy HUD’s
FY 2008 Annual Performance Plan requirement and is intended to provide information
that supports better cooperation toward meeting objectives shared by HUD and its
partners.
A2.3

Who Will Use the Information

The customer satisfaction survey findings will be used by senior Department
management and program staff, including the Office of Field Policy and Management, to
assess and improve organizational performance. In particular, the survey results will
enable HUD to identify specific issues regarding HUD-customer relationships that
partners consider to be impediments to their efforts to implement HUD’s housing,
community development, and fair housing programs.
The information will also be made available in report form for dissemination to the
general public—including the participating partner groups and other stakeholders and
interested parties—to allow for public assessment of HUD’s performance vis-à-vis its
program delivery partners.
A2.4

Survey Instrument

The survey instrument, containing approximately 45 questions, is divided into two
clusters. The first cluster, approximately 35 questions, will be completed by, or
administered to, all respondents; the second cluster, containing approximately 15
questions, is specific to each partner type.
Cluster one: questions that apply to all partner groups. The first cluster of
questions deals with:
°
°
°
°
°
°
°
°
°

Satisfaction with HUD’s programs and the way HUD runs its programs
Opinions about the quality and timeliness of information received from HUD
Opinions about the quality and consistency of guidance received from HUD
Satisfaction with partners’ ability to reach staff at HUD when necessary
Opinions about responsiveness and competence of HUD staff
Satisfaction with training and technical assistance
Satisfaction with electronic communication
Satisfaction with Grants.gov (formerly eGrants)
Opinions about HUD’s management controls and monitoring systems

Collectively, these items cover key dimensions of HUD's relationships with its partners

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and will provide the Department with information on specific areas of performance.
Cluster two: questions specific to each partner group. Because each
partner group has a somewhat different type of relationship to and association with HUD,
the survey instrument includes questions specific to each group. Based on input from
HUD program offices and previous input from representatives of the organizations that
represent such groups, the following types of items are considered central to assessing
HUD's service to each group:
¾ Questions specifically for owners of multifamily properties: These
questions address respondents' satisfaction with HUD field office staff,
physical inspections by HUD’s Real Estate Assessment Center with respect
to physical inspections and electronic submission of financial information,
understanding the distinctions between dealing with HUD’s different offices,
hubs and centers, the consistency with which HUD provides interpretations of
its policies and regulations, HUD’s capacity to monitor and provide oversight,
and the clarity of HUD’s organizational structure.
¾ Questions specifically for HUD/FHA-approved single family mortgage
lenders. These questions address satisfaction with: FHA’s Neighborhood
Watch Early Warning System, which allows FHA-approved lenders to identify
and analyze the performance of loans they originate, underwrite, or service;
FHA Connection, which provides FHA-approved lenders and business
partners with direct, secure, online access to HUD computer systems; FHA’s
Quality Assurance Monitoring Reviews, which include on-site loan-level
examination of lender files as well as assessment of lenders’ compliance with
FHA loan origination and servicing requirements; and FHA’s Post
Endorsement Technical Reviews that are intended to provide useful feedback
to lenders regarding compliance with FHA requirements.
.
A3

Use of Improved Technologies

Under contract to the Urban Institute (Washington, DC), the surveys will be
administered by Silber & Associates, an independent survey research organization
(Clarksville, MD), which makes full use of the latest methodological and technical
developments in mail surveys and telephone interviewing, including proprietary software
to check the accuracy of mailing addresses. The surveys will be conducted by mail, with
telephone follow-up where appropriate or necessary.
A4

Efforts to Identify Duplication

Discussions with knowledgeable HUD officials and others outside the
Department indicate that there are no similar, independently conducted surveys of a

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broad range of HUD partner groups that assess HUD's current organizational
performance or changes in performance since the 2001 baseline survey and the 2005
follow-up survey.
A5

Involvement of Small Entities

Respondents to this survey will be officials of large and small for-profit
businesses and non-profit organizations that are involved with HUD multifamily and
single family housing programs. As such, they partner with HUD to provide services or
benefits to end customers. Since some respondents will be officials of small entities,
sampling only a portion of the universe of such entities and establishing the voluntary
nature of participation in this survey are all geared to minimize the burden, and
perceived burden, on such entities. Based on the experience with predecessor surveys
in 2001 and 2005, the majority of such entities, including small entities, are interested in
providing customer feedback to HUD; response rates have been high.
A6

Consequences of Less Frequent Data Collection

The data collection is designed as a follow-up to two previous surveys and is
needed to track changes in HUD partner satisfaction with Departmental performance.
Without the follow-up survey, HUD lacks an important scientific and systematic basis for
evaluating changes in partner/customer satisfaction over time.
A7

Special Circumstances

The proposed data collection activities are consistent with the guidelines set forth
in 5 CFR 1320.6 (Controlling Paperwork Burden on the Public--General Information
Collection Guidelines). There are no special circumstances that require deviation from
these guidelines.
A8

Consultations Outside the Agency

Prior to conducting the 2001 and 2005 HUD partner surveys, consultations were
held with representatives of organizations that represented most of the partner groups.
Their purpose was to seek ideas for questions that might be asked related to HUD’s
service to and relationships with these groups. The questionnaires that were developed
in 2001 and 2005 took into account suggestions and ideas offered as a result of these
outside consultations and are carried over to the 2009 survey.
Since establishing trends over time in HUD partners’ satisfaction with the
Department is an important objective of the 2009 HUD Partners Surveys, the
questionnaires designated for owners of multifamily properties, for the most part, contain
items previously included in the 2000 and 2005 HUD Partners Surveys. Those items,

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therefore, were previously pre-tested as part of the pre-survey consultation process, and
then administered. As a result, they do not require pre-testing again in 2009. However,
since the survey of FHA-approved single family mortgage lenders has not previously
been administered, pre-tests were conducted as part of the consultation process. This
involved asking fewer than nine randomly selected pre-test respondents to complete a
survey questionnaire and, then, participate in a telephone debriefing consultation to
determine if, in their judgment, the questions were relevant, appropriate, and
understandable, and if the survey format was user-friendly and efficient.
A9

Payments to Respondents.

Participants voluntarily agree to participate in this data collection and do not
receive any payment.
A10

Arrangements and Assurances Regarding Confidentiality

For this survey to produce valid results it is essential that respondents know the
information they provide about HUD’s customer service will not be associated with their
names, organizations, business, or communities—i.e., that their customer service
responses will be combined with all other customer service responses such that
identifying information will not be disclosed to HUD or anyone else, or cited or reported
in any way that could identify them. Therefore, procedures will be employed to ensure
that neither a dataset nor report resulting from the survey will identify respondents.
During the survey operations period, Silber & Associates will be able to associate
responses with respondents for quality control purposes, but such linkages will be
separated when they are no longer operationally necessary. Prior to that, strict
procedures will be in place to make certain such linkages are used only for survey
management. The dataset provided to HUD at the end of the study will not contain any
identifying information (such as name, organization, location, or address of respondents)
that could permit identification—directly or by deductive inference.
A11

Sensitive Questions

The questions being asked are not considered sensitive. Sensitive questions are
defined as those whose answers, if made public, could cause physical, mental,
emotional, economic, or other harm to an individual.
A12

Estimate of Annualized Burden Hours

Exhibit 1 summarizes the sampling frames, survey samples, and projected
number of respondents. The estimated response rates were derived from the results of
the 2005 customer satisfaction survey. Exhibit 2 shows the estimated burden per
respondent and for the project overall.

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Exhibit 1

Respondent Group
Section 202/811
Multifamily Ownership
Entities
HUD-Insured,
Unsubsidized
Multifamily Ownership
Entities
HUD-Assisted,
Subsidized
Multifamily Ownership
Entities
HUD/FHA Approved
Single Family
Mortgage Lenders
TOTAL

Projected
Number of
Completed
Surveys

Universe
Size

Sample
Size

Estimated
Response
Rate

6,926*

1,894

66%

1,250**

4,468*

2,118

59%

1,250**

12,500*

2,016

62%

1,250**

9,606

2,082

60%

1,250

33,500

10,004

62%

5,000

*Estimated based on HUD property-based dataset.

**Estimated based on response rates for the 2005 HUD Partners Surveys.
Exhibit 2

Projected Number
of Respondents
(Completed Surveys)
5,000

A13

Burden
Minutes Per
Respondent
16

Total Annual
Burden
(in Minutes)
80,000

Total Annual
Burden
(in Hours)
1,333

Estimated Recordkeeping and Reporting Cost Burden on Respondents

The cost burden to respondents (who are responding in their capacity as officials
of the organizations in which they are employed) is the time required to respond to
survey questions, which can be valued at the equivalent of the earnings of such persons
for that amount of time.
•

For the survey of owners of multifamily properties, respondents may range from
property managers to company executives. The Bureau of Labor Statistics’
(BLS) Occupational Outlook Handbook indicates that the 2006 median annual
earnings of property, real estate and community association managers was
$43,070, while that of company managers was $105,130. Assuming that one

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half of the respondents will be property managers and the remaining half
company mangers, the average earnings would amount to $74,100 (with
corresponding hourly earnings of $36.32), and the annualized “cost” burden on
all respondents is estimated to be $36,320; the equivalent “cost” per respondent
for completing the 16-minute survey is estimated to be $9.68.
•

A14

For the survey of FHA-approved single family mortgage lenders, respondents
may range from mid-level managers to financial managers. The Bureau of Labor
Statistics’ (BLS) Occupational Outlook Handbook indicates that the 2006 median
annual earnings of administrative services managers was $67,690 while that of
financial managers was $90,970. Assuming that one half of the respondents will
be administrative services managers and the remaining half financial managers,
the average earnings would amount to $79,330 (with corresponding hourly
earnings of $38.89), and the annualized “cost” burden on all respondents is
estimated to be $12,963 the equivalent “cost” per respondent for completing the
16-minute survey is estimated to be $10.37.
Estimated Cost to the Federal Government

The total contracted cost to the Federal Government for developing,
administering, and reporting on Phase Two of the 2009 HUD Partners Surveys is
$417,898.
A15

Reasons for Changes in Burden

This submission to OMB is a request for an extension to Phase Two of the 2009
HUD Partner Survey information collection activity, where Phase One was previously
approved by OMB.
A16

Tabulation Plans

Immediately following completion of data collection, the survey administrator,
Silber & Associates, will prepare a data set containing respondents' answers to each of
the questions and some additional demographic information (such as community size,
size of housing authority, etc.) that derive from the sampling lists. The Urban Institute,
under contract to HUD, in conjunction with its subcontractor, Silber & Associates, will
analyze the survey data. The Urban Institute will have primary responsibility for the
preparation of the research report, with Silber & Associates preparing histograms and
other visual displays for the report. A report and data set (minus any personal identifiers
or demographic information that could, through inference, connect responses to
respondents) will be delivered to HUD approximately four months after the data
collection ends.

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Although the four partner groups being surveyed are major HUD partners, they
do not cover all of the partner groups with which HUD associates. Moreover, their
relationship with the Department varies considerably with the programs and program
areas with which they are involved. It is not appropriate, therefore, to combine them into
a single "partners" group for analytic purposes. Accordingly, each partner group will be
analyzed separately, with comparisons made among the four as well as with the partner
groups surveyed during Phase One.
Analyses will be primarily descriptive in nature. Each partner group’s current
level of satisfaction with various aspects of its relationship with HUD will be presented for
2009 and compared with similar data from the 2005 partner surveys. This will permit
assessment of changes that have occurred. Appropriate tests of statistical significance
of differences will be used. In addition, results for each partner group will be cross
tabulated by such factors as frequency of partner contact with HUD, years of interaction
with HUD, entity size, and whether respondents perceive their relationships with HUD to
involve primarily regulation or a combination of regulation and support.
Reports will consist of the following:
•

A main report—comparing 10 partner groups—those covered by this
collection (Phase Two) and those covered by a previous collection (Phase
One)—on all of the question items for which comparison is possible. It will
contain an executive summary, an explanation of who HUD’s partners are
and the role they play, and why HUD is surveying such partners, and the
results of the surveys with verbal description, pictorial and numeric
presentation of results, and explanations where possible.

•

Individual partner group data binders—presenting survey responses for
the respective groups cross tabulated by such factors as size of organization/
agency, frequency of interaction with HUD, and years of experience with
HUD. Each will contain a description of the respective partner group and
survey highlights.

•

Individual field-unit data binders. Eighteen separate binders—one for
each multifamily hub—will be prepared for analyzing the responses of
multifamily owners; and four separate binders—one for each single family
homeownership center—will be prepared for analyzing the responses of
FHA-approved single family mortgage lenders. These will present survey
responses disaggregated to the appropriate field-unit level and compare them
to the national aggregation.4

4

Field unit data binders will not be prepared in cases where the number of respondents is fewer than 10; in
such cases, responses will be combined at the Regional Office level.

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A17

Expiration Date Display Exemption

Any reproduction of the data collection instrument will prominently display the
OMB approval number and expiration date.
A18

Exceptions to Certification

This submission, describing data collection, requests no exceptions to the
Certificate for Paperwork Reduction Act (5 CFR 1320.9).

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