-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Tuesday, April 03, 2007 10:53 AM
To: Axt, Kathy
Cc: Rudolph, Kim
Subject: OMB comments on FSA generic clearance master plan (1845-0045)

Attached please find OMB's comments on the subject collection.  Please respond no later than COB Wednesday, April 11th.  Thanks.

1. In the IC list, we cannot open the file entitled "Att_Appendix C - Approved Focus group.doc" (it appears to be corrupted). Can you reupload a new copy to ROCIS?  [Axt, Kathy] Another copy has been updated into ROCIS. 
2. In order to ensure that all relevant information is included in generic clearance requests, OMB has been working with agencies to develop a template for generic clearance requests.  This statement should be detailed so that all necessary information is included, and can be submitted in lieu of a full supporting statement or the outdated 83-C.  A full submission would, therefore, include the statement and the instrument, plus any other data required by ROCIS; we would like to move this FSA collection to this process.  I have attached a sample template document used by another agency.  Please review and let us know if all of the necessary data for FSA submissions would be captured by this template.  If you have suggested edits to the template, please submit back to us in tracked changes and we will review.  [McGinnis, Colleen] I have reviewed the suggested template.  Since our current format has the same information included, we have absolutely no problem transferring to this new template.   
3. Please identify the types of focus groups that FSA plans to conduct under this generic approval. [McGinnis, Colleen] Student groups, parent groups, and financial aid officers regarding changes to FAFSA; students, schools, financial partners regarding e-Government initiatives; schools and financial partners regarding any program changes due to the Reauthorization of the HEA. 
4. Please explain the policy rationale behind FSA's decision to submit more surveys and hold more focus groups in the next three years.  That is, what is driving the need to collect more customer data?  Will this inform a particular initiative at the Department? [McGinnis, Colleen]  The 1,500 hours is in anticipation of program changes due to reauthorization and/or other legislation (such as HERA). 
5. Please note the terms of clearance that OMB plans to issue for this collection and let us know if ED has questions about the generic clearance process.  This generic clearance for ED/ FSA customer satisfaction focus groups and surveys is approved under the following conditions:
   1) FSA shall use the generic clearance to collect customer satisfaction data (via surveys, focus groups or software usability testing sessions) where the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions.
   2) Focus groups should be of limited size and scope.
   3) For individual surveys or focus groups, FSA shall submit a generic clearance request in ROCIS along with an abbreviated supporting statement in the template agreed to by OMB and Education. This statement shall include all relevant information, including a statement of need, intended use of information, description of respondents, information collection procedures, expected response rate, justification for incentive, estimated burden.
   4) OMB will respond with clearance or questions within 10 working days.[McGinnis, Colleen] FSA has no problems with these terms of clearance that OMB plans to issue for this collection.