Supporting Statement for Paperwork Reduction Act Submissions

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Access Points:  Supporting Statement for Paperwork Reduction Act Submissions


A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy
of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Background
The Workforce Investment Act of 1998 (WIA) requires recipients of grants to provide universal access to job search and labor market information.  In order to provide access in an efficient and non-duplicative manner, the Act establishes One-Stop Career Centers in local areas throughout the country.  While One-Stop Centers provide employment-related services to a large number and wide array of job seekers, some of the individuals on the margins of the labor market, such as high school dropouts, ex-offenders, and persons with low occupational skill levels in high-poverty neighborhoods, still have difficulty in accessing the One-Stop system.  To reach them and to provide them with employment services in a cost-effective manner, in 2002 the Department of Labor’s (DOL’s) former Center for Faith-Based and Community Initiatives (CFBCI) and the Employment and Training Administration (ETA) initiated a system of employment centers called Access Points.
Access Points are run by local Faith-Based and Community Organizations (FBCOs) as a volunteer effort, and they serve as satellites to One-Stop Career Centers.  They are located in areas that include a relatively large number of unemployed individuals with few of the resources needed to find stable employment.  Access Points provide job seekers from their neighborhoods with job-search information, some services, and referrals to One-Stops and other service providers.  Access Points participate in SHARE Networks – statewide computerized networks that provide employment-related information at the local level.  SHARE Networks include non-profit FBCOs, for-profit organizations, and government agencies that provide employment services and choose to participate in the network.  
In order to establish Access Points, training and technical assistance has been provided to SHARE Network Coordinators, who are usually staff members at One-Stops or the Workforce Investment Boards (WIBs) that oversee the local workforce development system.  The SHARE Network Coordinators, in turn, train local FBCO Points of Contact (POCs) in procedures for establishing Access Points.  The POCs mobilize the effort to start Access Points and usually continue to run them.  (In this document, the POCs are referred to as “Access Point POCs” because of their continuing role in operating the Access Points.)
The Department has used three principal methods of providing training to the SHARE Network Coordinators:
1) Direct, in-person training; 
2) Distance training by means of Webinars, an Access Point Tool Kit, and related materials; and
3) A combination of direct and distance training. 
Circumstances that Make the Data Collection Necessary
The Access Point initiative is relatively new but draws on the knowledge about customer service and outreach practices accumulated by the Department and its partners since the implementation of the Workforce Investment Act.  The first Access Point was established in 2005, and the process of starting new centers continues today.

 In order to make the program as effective and efficient as possible, the Department is conducting an independent evaluation of the Access Point initiative.  The evaluation focuses on processes and will be conducted by the Social Science Research Group (SSRG) under subcontract to Performance Excellence Partners, Inc.  The evaluation has three related purposes: 1) To learn how the Access Point initiative is being implemented in terms of training, support, and Access Point operations; 2) To determine whether it is expanding services to hard-to-serve job seekers; and 3) To discover Access Points are integrated into local workforce systems.  Collecting this information will enable the Department to identify shortcomings or gaps in the program, formulate steps to remedy those issues, and improve the program to further achieve the goal of universal access to employment and training services. The evaluation will assess the merits of three training and technical assistance delivery models. 
The Access Point program evaluation will be based on three surveys:
	1) A SHARE Network Coordinator Survey that assesses DOL training received and relations with Access Points;
	2) An Access Point POC Survey that provides data on the implementation and functioning of Access Points; and
	3) A One-Stop Director Survey that provides an external assessment of Access Points and their relation to the local workforce system
The following flow chart shows the steps in the AP training and implementation process, with the proposed surveys related to specific steps in the process (Exhibit 1).


2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. 

The proposed surveys are new data collections.

DOL and its contractor, SSRG, will analyze the data from the SHARE Network Coordinator Survey, the Access Point POC survey, and the One-Stop Director Survey for an evaluation report. The Department will use the report to assess the three training approaches, identify any shortcomings in the Access Point initiative, improve the program, and inform future decision-making.  

The SHARE Network Coordinator Survey will provide policy makers with information with which to assess the effectiveness of the three approaches to training and the steps taken by the coordinators to establish Access Points.  It will also provide information on relations between the coordinator and Access Points.  

The Access Point POC Survey will provide policy makers with information about the implementation and operations of Access Points, and the support from SHARE Network Coordinators.

Data from the Survey of One-Stop Directors will provide Department policy makers with data on the degree of integration of Access Points into the local workforce system and an overall assessment of the efficacy of the Access Point program in their service areas.  The Access Point POC Survey and the One-Stop Directors Survey will also provide data that will enable DOL policy makers to determine whether Access Points effectively support the WIA mandate that One-Stop Career Center Systems provide “universal access.”  

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

All data collection will be electronic.  

The Access Point POC Survey, SHARE Network Coordinator Survey, and One-Stop Director Survey will be electronic and interactive.  Emails to respondents will provide them with an internet link to the survey.  Respondents will complete and submit the survey on-line.  SSRG will use telephone and email prompts to convert non-response.  The survey data will automatically be entered into a database for later analysis. 

4. Describe efforts to identify duplication.  Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

Access Points are relatively new (started in 2005), and these surveys are the first effort to collect information on their use.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden. 

The respondents to the One-Stop Director Survey and the SHARE Network Coordinator Survey are staff at One-Stop Career Centers and/or Workforce Investment Boards.  Both surveys are one-time data collections, and both are brief – the One-Stop Director Survey takes only six minutes to complete and the Share Network Coordinator Survey takes 10 minutes, based on pretests with nine or fewer respondents per survey.  Access Points are small, volunteer non-profit entities.  The Access Point POC survey is a one-time data collection that takes an average 17 minutes to complete. 

Methods to minimize burden in all the surveys include making them electronic, limiting the number of questions, and avoiding questions that would require respondents themselves to collect data – from records or elsewhere – in order to answer the questions.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles
to reducing burden. 

Without the SHARE Network Coordinator Survey, Department program administrators will not know which of the three training approaches is most effective. 
 
More broadly, without the evaluation based on the SHARE Network Coordinator Survey, the Access Point POC Survey, and the One-Stop Director survey, program administrators in the Department will not have the information they need for a full assessment of the initiative, and policy makers will not have information with which to make decisions about whether Access Points can be incorporated into the nation’s employment and training system.    

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

* requiring respondents to report information to the agency more often than quarterly;

The SHARE Network Coordinator, Access Point POC, and One-Stop Director Surveys are one-time data collections.

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Not applicable.

* requiring respondents to submit more than an original and two copies of any document;

Not applicable.

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

Not applicable.

* in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

Not applicable.  

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB; 

Not applicable.

* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

Not applicable.  Data are not sensitive, and there will be no pledge of confidentiality.

* requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

Not applicable. 

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and
hour burden. Describe 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. Consultation with representatives of those from whom
information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
In accordance with the Paperwork Reduction Act of 1995, the public was given an opportunity to review and comment through a notice in the Federal Register (Vol. 74, No. 129, p 32648, July 8, 2009.)  No comments were received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

Not applicable.  There will be no payment or gift to respondents.

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

Not applicable.  There will be no pledge of confidentiality.

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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

Not applicable.  There are no questions of a sensitive nature. 

12. Provide estimates of the hour burden of the collection of information. The statement should:
* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden
hours for customary and usual business practices.

Estimates of time to complete the surveys are based on small-scale in-person pretesting with nine or fewer respondents from each of the three survey populations in the Newport News/Hampton, VA area in January 2009.  Exhibit 2 shows the estimated response burden and cost for each survey, based on the populations surveyed, the anticipated response rates, and the hours per survey estimated from the pretests.  







Exhibit 2.  Access Point Evaluation Respondents, Burden Hours, and Cost for Four Surveys








 
 
Response 
Total 
Hours per
Total
Pay
Total
Survey
Population
rates
respondents
response
hours
rate
Cost
SHARE Network Coordinators
230
75%
              173 
0.17
         29 
 $  20.00 
 $      587 
Access Point POCs
300
75%
              225 
0.28
         63 
 $  19.00 
 $  1,197 
One-Stop Center Directors
80
75%
        60          
0.1
 6 
 $  36.00 
  $      216 
Total
610

458

98

$  2,000
 
The SHARE Network Coordinator, Access Point POC, and One-Stop Director Surveys are one-time surveys that will be administered in 2009, for a total burden of 98 hours.  

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13. 13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

Estimates of cost burden are based on the pretests with nine or fewer respondents from each of the three survey populations in the Newport News/Hampton, VA area.
  
SHARE Network Coordinator Survey:  Pretesting suggests that the average pay of SHARE Network Coordinators is $20 per hour.  Multiplying this rate by slightly more than 29 hours (Exhibit 2) yields a total cost to respondents of $587.

Access Point POC Survey:  Pretesting suggests that the average pay of Access Point POCs who are compensated for their service is $19 per hour.  The respondents are estimated to spend 63 hours completing the survey (Exhibit 2), so the expected total cost is $1197.

One-Stop Center Director Survey: Consultation with One-Stop Center Directors suggests that average pay is approximately $36 per hour.  Exhibit 2 shows that the directors are expected to spend six hours altogether completing the survey.  Consequently, the expected total cost to respondents is $216.

For the three surveys, the total burden cost is $2,000.  

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

Not applicable.  Respondents do not need to develop, maintain, or refer to records in order to answer the questions in these surveys.  There is no cost to respondents other than that of the hour burdens.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The salaries of One-Stop Center Directors and SHARE Network Coordinators are funded by the U.S. Department of Labor.  The cost of their time in responding to the surveys totals $803.  The Social Science Research Group’s cost for conducting the evaluation is $64,778, as shown in Exhibit 3.

Exhibit 3.  Cost of Access Point Evaluation

 Cost Categories
Cost
Professional Labor Subotal
 $ 58,981.90 
Telephone Follow-up Subtotal
 $  4,237.62 
Data File Construction Subtotal
 $  1,338.19 
Other Costs Subtotal
$220.00
Total
 $ 64,777.71 

The total cost to the government will be $803 + $64,778 = $65,581.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. 

This is a new information collection; hence, the added burden.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Analysis Plan

The Access Point Evaluation will be a descriptive analysis based primarily on frequency distributions and textual responses to open-ended questions.  No complex analytical techniques will be used.  A few measures of central tendency – means and medians – will be used, together with two-way cross-tabulations.  The results of the analysis will be included in a process evaluation report delivered to the Department in electronic form.  The Department’s Employment and Training Administration will make the relevant findings available to the general public on its Website (www.doleta.gov) and Workforce3One (www.workforce3one.org).

  
Exhibit 4 shows the subject areas to be analyzed, together with the evaluation measures, data sources, question numbers, and analytic measures.  

Exhibit 4.  Analytic Design for Access Point Evaluation 
Subject Area
Evaluation Measures
Data Sources
Survey Questions
Analytic Results
1. Access Point Implementation
 
 
 
 
    Training  
 
 
 
 
        Stage 1  
Quality of DOL training of Network Coordinators
Network Coordinator Survey
Qs. 2-7
Frequencies, open-end
        Stage 1
Utility of three types of training
Network Coordinator Survey
Qs. 3-7
Crosstab Qs. 4-7 with Q. 3
        Stage 2  
Number of Access Points and personnel trained
Network Coordinator Survey
Qs. 15,16
Total
        Stage 2
Usefulness of two-stage training process
Network Coordinator Survey
Qs. 17, 18
Frequencies, open-end
        Stage 2
Quality of Network Coordinator training 
AP POC Survey
Q. 10
Frequencies, open-end
      Support
Network Coordinator support of Access Points
AP POC Survey
Q. 10
Frequencies, open-end

Network Coordinator support of Access Points
Network Coordinator Survey
Qs. 8-10, 16
Frequencies, open-end

Types of support provided to Access Points
AP POC Survey
Q. 11
Frequencies, open-end
     Operation
Operational issues and challenges
AP POC Survey
Q. 8
Frequencies, open-end

Goods and services available
AP POC Survey
Q. 6
Frequencies
2. Expanding Access
Number of Access Points
PEP
Record data
Totals by year and cumulative

Income of Access Point ZIP codes
U.S. Census
 Census ZIP data
Mean income of AP & comparison ZIP codes
 
Time Access Points open
AP POC Survey
Qs. 3,4
Frequencies

Number of computers available
AP POC Survey
Q. 5
Totals, averages

Outreach methods
AP POC Survey
Q. 7
Frequencies, open-end
 
Public relations for workforce system
One-Stop  Director Survey
Q. 6
Frequencies
 
Number of customers
AP POC Survey
Q. 22
Frequencies, averages
 
Increase in number of customers
One-Stop  Director Survey
Q. 1
Frequency 
 
Customer characteristics
AP POC Survey
Qs. 23,24
Frequencies
 
Increase in hard-to-serve customers
One-Stop  Director Survey
Qs. 2,3
Frequencies
3. Access Point/Workforce System Integration
Access Point Referrals to One-Stops
AP POC Survey
Q. 25
Frequency

Relations, Access Point and SHARE Coordinator
AP POC Survey
Q. 12
Frequency

Relations, Access Point and SHARE Coordinator
Network Coordinator Survey
Qs. 11, 16
Frequencies, open end
 
System integration
One-Stop  Director Survey
Qs. 4-6
Frequencies
 
Value of Access Points to workforce system
One-Stop  Director Survey
Q. 7
Open end

1. Access Point Implementation. The first subject area concerns the implementation of the Access Point initiative – is it being implemented as intended?  The subject is broken into three parts – training, support, and operation.  As explained earlier, the training occurs in two stages: First, DOL contractors train local SHARE Network Coordinators in how to set up and run Access Points; second, the coordinators train Access Point POCs.  The Share Network Coordinators Survey and the Access Point POC Survey ask their respondents a series of questions concerning the training they received and the quality of the training.  The primary analysis of these data will use frequency distributions – the percentages of Network Coordinators and of Access Point POCs who responded in one way or another.  In order to assess the relative perceived value of in-person training, distance training, and combined training, the responses of Network Coordinators to the training questions will be cross-tabulated with the method of training they report having received. 

The second part of implementation concerns the coordinator’s support of Access Points, once established.  To address this subject, the SHARE Network Coordinator Survey asks about the number of hours the coordinator and related staff spend supporting/training Access Point personnel.  (Ongoing training after the initial training is a form of support.) The Access Point POC survey also asks whether the Network Coordinator has provided a given type of support and if so, how helpful the support has been.  An “Other, please specify” response option is provided at the end.  In addition, the AP survey asks respondents to assess the quality of the support received.  The analysis will be based on frequency distributions – the percentage of respondents who say that a given type of support is or is not provided and the percentage of the positive responses selecting each indicator of helpfulness.  The open-ended responses will be classified and counted, and text examples will be presented.  

The third part of implementation concerns certain aspects of the operation of Access Points.  The information with which to address this subject will be collected in the Access Point POC survey.  The survey asks what kind of goods and services the Access Point provides; it also presents a list of issues and asks how much of a problem each one is.  Frequency distributions and open-ended responses will be used in this analysis.  Mean and median numbers of computers available in Access Points will be calculated.  

2. Expanding Access.  The second major subject area concerns the extension of job-search services beyond One-Stop centers.  One of the main purposes of the Access Point program is to extend the reach of the local workforce employment system to greater numbers of job seekers, especially hard-to-serve job seekers in poverty neighborhoods.  The first question in this area concerns the number of Access Points created over time.  Data with which to answer this question will come from the records of Performance Excellence Partners, Inc. which trains the Network Coordinators.  The number of Access Points created each year will be graphed, as will the cumulative number of Access Points over time.

The second area of investigation is the extent to which Access Points are located in hard-to-serve neighborhoods.  Information with which to answer this question will come from Census data on income in the ZIP codes of the Access Points.  These data will be entered into the analytic database for Access Points.  Mean and median incomes in these areas will be compared with the means and medians of surrounding areas.   

The third area of investigation concerns Access Point availability and outreach to job-seekers.  The Access Point Survey asks about the number of hours the Access Point is open and the number of computers available to job seekers.  It also asks about the outreach methods used to recruit job seekers to Access Points.  The One-Stop Director Survey asks a broader question about the public relations for the workforce system.  

The fourth area of investigation concerns the number and characteristics of the job seekers served by Access Points.  Access Point POCs will be asked to estimate how many first-time job seekers used the computers to search for jobs in the last 30 days and to describe certain characteristics of these job seekers.  One-Stop Center Directors will be asked to what extent Access Points have increased the number of job seekers served by their systems and the extent to which they have increased access for hard-to-serve job seekers.  Frequencies of the responses will be presented.

3. Access Point/Workforce System Integration.  Access Points are intended to be integrated into the workforce investment system in partnership with One-Stop Career Centers.  They are supposed to refer job seekers who could benefit from the services of One-Stops to those centers and to interact with the One-Stops in a variety of other ways.  The Access Point POC Survey asks respondents to provide the percentage of job seekers they have referred to One-Stops.  The SHARE Network Coordinator Survey asks about the coordinators’ relation with the Access Points in their areas and asks the respondents to comment on their relationships with Access Points.  Further, the One-Stop Director Survey asks questions concerning the degree of Access Point integration into the workforce system and an open-ended question concerning the value of Access Points to their systems.   Frequencies will be generated for the questions with pre-coded responses.  Textual material in the open-ended question will be classified and presented, and illustrative examples will be provided. 

The (future) schedule for the Access Point evaluation is as follows (Exhibit 5):













Exhibit 5. Schedule for Access Point Evaluation  


Tasks, Events
Dates
Federal Register public comment on surveys
July 8 – Sept 7, 2009
Revision after public comment
Sept 8 – Sept 17
OMB clearance 
Sept 28 – Nov 30
Collect data from records and enter in database
Sept 3 – Nov 30
First round electronic data collection for the SHARE Network Coordinator, Access Point POC, and One-Stop Director Surveys

Dec 1 – Dec 31
Email and telephone follow-up of non-response in SHARE Network Coordinator, Access Point POC, and One-Stop Director Surveys

Jan 1 –  Feb 1, 2010
Analyze survey and record data 
Feb 2 – April 2
Prepare first draft of evaluation report
April 3 – May 31
Prepare second draft of evaluation report
June 1 – June 15
Deliver final evaluation report
June 15 – June 31

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Not applicable.

18. Explain each exception to the certification statement identified in Item 19, Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

Not applicable. 

B. Collections of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked, "Yes," the following documentation should be included in the Supporting Statement to the extend that it applies to the methods proposed: 

Sampling will not be used.  The survey populations consist of 230 SHARE Network Coordinators, 300 Access Point POCs, and 80 One-Stop Directors.  Considering the largest of these numbers, a random 50 percent sample of Access Point POCs would yield 150 cases to survey.  A 75% response rate would reduce the number of cases for analysis to 113.  The 95% confidence interval around an estimate of 50 percent would be 7.3 percent (incorporating the finite population adjustment factor) , or from 42.7 percent to 57.3 percent, too large a range to be useful.  Surveying the whole population will result in no sampling error. 

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons)
in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the
collection had been conducted previously, include the actual response rate achieved during the last collection.

Exhibit 6 shows the universe for each survey in the evaluation.

Exhibit 6.  Universe for Access Point Evaluation Surveys
Survey
Survey Universe
Access Point POC Survey
300
SHARE Network Coordinator Survey
230
One-Stop Director Survey
80

The expected response rate is 75 percent.  There has been no previous collection of these data.

2. Describe the procedures for the collection of information including:

* Statistical methodology for stratification and sample selection,

Sampling will not be used.

* Estimation procedure,  

Estimation will be based on weighted estimates.  The base weights will all be 1, but these weights will be adjusted for unit nonresponse.   Factors used to determine the weighting classes to adjust the weights will be gender (inferred from name of record, so there may be some classification error), area income based on Census data and (multiple) ZIP codes, and state and/or region.  Item nonresponse will be treated as a separate response category.

* Degree of accuracy needed for the purpose described in the justification,

With no sampling error, a 75% response rate, and a weighting adjustment for unit non-response, the degree of accuracy will easily satisfy that needed for the stated purpose.

* Unusual problems requiring specialized sampling procedures, and

There are no unusual problems requiring specialized sampling procedures.

* Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

The data will be collected only once.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

The following elements in the data collection process are designed to maximize response.  

1. The questionnaires are short and straightforward; pretest respondents found them easy to respond to.

2.  Lists of respondents and contact information are accurate and up-to-date.

3. An email letter will be sent to each potential respondent from an appropriate Department of Labor administrator.  The letter will explain the need for the evaluation and the form of the survey and will encourage timely response.  

4. The Social Science Research Group will contact each respondent by email, introducing the survey and providing an internet link to the electronic survey.  Clicking on the link will bring the survey up on the respondent’s computer screen.  The respondent may complete the survey in one sitting, or more than one.  The data will automatically be entered in an electronic database.

5. Following the first month of electronic data collection, non-respondents will be contacted by telephone and asked if they wish to respond by completing the electronic form or to respond verbally over the phone.  Those who wish to respond verbally will be interviewed by phone, and their responses will be entered in the electronic database.  Those who wish to respond directly by answering the survey questions electronically will be given two weeks in which to do so.  Those who still do not respond will be contacted again by phone and asked to respond via telephone interview.  

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of test may be submitted for approval separately or in combination with the main collection of information.

Small-scale in-person pretesting with nine or fewer respondents from each of the three survey populations was conducted in the Newport News/Hampton, VA area in January 2009.  Respondents completed the online surveys, time to completion was noted, and respondents were debriefed item by item to assure that they understood the questions and anwered accordingly.  Respondents were asked to rephrase each question and explain why they answered as they did.  There were relatively few misunderstandings; in some cases, respondents suggested improvements in the language of items.  Changes in the questionnaires were made accordingly.  

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

Statistician
Dr. Michael P. Cohen	
Social Science Research Group			
(202) 232-4651 			

Data Collection and  Analysis
Dr. David Boesel
Social Science Research Group
200 Severn River Road
Severna Park, MD 21146
(410) 544-4054; [email protected]