OMB Supporting Statement - Generic Focus Groups (7-30-10)

Focus Groups for Traffic and MotOR VEHICLE SAFETY Programs and Activities

SUPPORTING STATEMENT

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.

1. Circumstances Making the Collection Necessary

The National Highway Traffic Safety Administration (NHTSA) was authorized by the Highway Safety Act of 1966 to carry out a Congressional mandate to reduce the mounting number of deaths, injuries and economic losses resulting from motor vehicle crashes on our Nation’s highways. In support of this mission, NHTSA is requesting generic clearance to conduct information collections in the form of Focus Group Studies over the next three years. These studies are necessary to develop and refine NHTSA’s problem identification, messaging, resource development, and strategic approaches.

Focus groups are an important information gathering technique because they allow for more in-depth understanding of the driving public’s beliefs, attitudes, motivations, and self-reported behaviors than do other kinds of studies. Focus groups are essential to obtain drivers’ reactions to different technologies, public information materials, and countermeasure strategies. They are used to gather suggestions on how to design countermeasure strategies or highway safety programs. Focus group sessions are narrowly defined to provide direct and informal feedback on a specific topic. The information obtained from focus groups complement other research findings (e.g. crash data, citations and arrests) by providing a window into the thinking, motivations, and understanding of drivers and others about traffic safety and various potential countermeasures to enhance safety.

2. Statute authorizing the collection of information

The Highway Safety Act of 1966, Title 23 United States Code, Section 403 (a,b,c,d) and the National Traffic and Motor Vehicle Safety Act of 1966, Title 15 United States Code 1395, Section 106 (b), give the Secretary authorization to conduct research, testing, development, and training as authorized to be carried out by subsections of these titles. The Vehicle Safety Act was subsequently re-codified under Title 49 of the U.S. Code in Chapter 301, Motor Vehicle Safety. See Title 23 Section 403 and Title 49 Chapter 301 for further information.

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.

Focus Groups, used as a qualitative research tool, have five major purposes:

• Problem Identification - To better understand the beliefs, attitudes, motivations, and practices associated with traffic safety behavior, particularly among high-risk populations and subject matter experts.

• Strategic Messaging - To ensure that creative material designed to communicate information about a specific traffic safety issue is effective and appropriate for its target audience.

• Resource Development - To assess the needs of the driving public and highway safety professionals in order to develop and provide resources to address those needs.

• Strategic Approaches and Program Initiatives - To obtain reactions to strategic approaches and program initiatives.

• Technological Approaches - To examine the effectiveness, acceptability, and limitations of technological approaches to traffic safety and vehicle safety issues.

Focus Group moderators elicit participant discussion and infer the underlying views and assumptions of the group. Focus Groups are used for formative research purposes and provide data about public opinion and general reaction to new concepts, messages, or technologies. These data cannot be generalized to the population at large. In the past the agency has used focus groups to test and refine ideas and concepts, prior to the use of more quantitative research methods that can guide the development of programs, public messages, or technologies, but they do not contribute to the development of policies. Without the appropriate use of focus groups the agency could potentially waste time and resources pursuing ineffective approaches and programs.

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 information technology. Also describe any consideration of using information technology to reduce burden.

To facilitate analysis, focus group moderators sometimes record or videotape discussions to ensure that notes and summary reports accurately reflect participants’ comments, suggestions, and questions. If sessions are recorded, recordings are kept in a secured location and destroyed at the conclusion of the study.

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.

Each focus group study is formative and designed to address a narrowly defined need. Focus groups are only considered for use when no other source of relevant information is available. Therefore, to the best of our knowledge, the kind of information we are seeking is not available to the Federal government.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

There will be no impact on small business or other small entities. The collection of information involves selected individuals, not small businesses.

6. Describe the consequences to Federal Program or policy activities if the collection is not collected or collected less frequently.

Focus Group studies can be an invaluable part of the development process for highway safety countermeasures and initiatives. Without examining the attitudes, beliefs, and motivations of the driving public, NHTSA cannot adequately define its programs, messages, and materials to reduce traffic injuries and fatalities.

For example, NHTSA is assessing new vehicle technologies. After putting the technologies into vehicles, it is important to obtain feedback from vehicle users about the technology – how did it operate, how acceptable was it, what were the difficulties with the technology, and what is the likelihood that a driver would want this technology on their next vehicle? Such feedback is necessary to design technology and introduce technology in ways to maximize acceptance and minimize problems.

When developing communication messages, it is important to obtain drivers’ reactions to various concepts to determine which approaches are most likely to resonate with target groups of different demographics.

Without the information obtained from focus groups NHTSA may make assumptions about driver attitudes, knowledge, and understanding of proposed messages, labels, or countermeasures that are not accurate or useful.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines set forth in 5 CFR 1320.6.

No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5CFR 1320.6.

8. Provide a copy of the Federal Register document soliciting comments on the collection of information, a summary of all public comments responding to the notice, and a description of the agency’s actions in response to the comments. Describe efforts to consult with persons outside the agency to obtain their views.

1. Federal Register Notice

A Federal Register Notice (75 FR 8426) announcing NHTSA’s intention to collect information by means of focus groups was published on February 24, 2010, providing 60 days for public comment. As of April 26, 2010, no public comments were received.

A second Federal Register Notice (75 FR 25034) announcing that NHTSA intended to forward an Information Collection Request to OMB was published on May 6, 2010, providing 30 days for public comment directly to OMB.

2. Expert Consultation

NHTSA uses in-house experts (behavioral researchers, engineers, communications and marketing specialists) and experienced contractors to develop focus group plans and materials. In accordance with OMB guidelines, NHTSA will establish an independent review process to assure the development and implementation of high quality focus groups. When submitting an ICR for a Focus Group study, NHTSA will provide OMB with a copy of all related materials for review and inclusion in the public docket (see Appendix A for a sample screening questionnaire and moderator’s guide that was previously approved by OMB for use under ICR 2127-0664).

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

It is standard practice to reimburse focus group respondents for their time and out of pocket expenses. NHTSA will provide, on average, $75.00 payment as reimbursement for expenses and compensation for their time. Compensation will vary based on requirements of each study (e.g., duration, location). It is unrealistic to expect respondents to incur expenses (e.g. to travel to a focus group location, pay for parking, etc.) as a result of participation. In many locations, without some form of reimbursement and compensation it would be virtually impossible to recruit participants.

10. Describe any assurance of confidentiality provided to respondents.

Respondents will participate in person, and therefore no assurances of complete confidentiality can be issued. However, moderators conducting Focus Groups will explain to participants that qualitative results will not be associated with identifying information or with a particular participant. Moderators and contractors will follow procedures to prevent unauthorized access to respondent data and will not disclose to the public the identities or responses of individual participants.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.

NHTSA does not anticipate asking questions that are of a sensitive nature or discussing matters commonly considered private. NHTSA will provide the specific discussion topics and questions with each individual ICR submitted under this generic clearance and will, if necessary, provide additional justification for questions of a sensitive nature at that time.

12. Provide estimates of the hour burden of the collection of information on the respondents.

Each NHTSA office was asked for the number of studies that would involve focus groups and the number of the focus groups that they plan to conduct next year. The following burden estimates are based on NHTSA’s projected annual focus group usage.

Studies: NHTSA plans to conduct approximately 19 Focus Groups studies per year.

Focus Groups per Study: A Study will require approximately 6 to12 groups

(averaging 11 groups), depending on the requirement

Participants: Each focus group will involve an average of 9 participants. Therefore, the total number of participants is estimated to be 1,881.

Burden: Individuals will be recruited via advertisement, intercept, or randomly dialed telephone calls and screened based on the study criteria. The recruiting and screening process is estimated to take no more than 10 minutes per person. Selected individuals will participate in a single session which, on average, lasts 80 minutes. Thus, the total burden per participant is estimated to be 90 minutes (1.5 hours).

	ESTIMATED ANNUAL REPORTING BURDEN
Studies 19 x		Focus Groups	Participants per Group	Total Participants	Hours per Participant	Total Hours
		11 x	99	= 1,881	x 1.5	= 2,822

Therefore, the total annual estimated burden imposed by this collection of information is approximately 2,822 hours.

The maximum total input cost per year, calculated by multiplying the average hourly wage by the required participation time, is estimated as follows:

$15.57 per hour¹ x 2,822 interviewing hours = $ 43,939

13. Provide an estimate of the total annual cost to the respondents or record keepers resulting from the collection of information.

Respondents will have no additional burden beyond the hours shown in item A12. Respondents will not need capital equipment, ongoing recordkeeping operations, or services to complete the information collection.

A.14) Provide estimates of the annualized cost to the Federal Government.

The Agency incurs costs to set up the focus groups, including hiring the contractor (facilitator or moderator), renting meeting space, travel, subsistence, and participant compensation, all of which may vary by location. For these expenses, NHTSA estimates the costs to be approximately $11,000 per study, and $209,000 annually.

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

This is a new information collection adding 2882 burden hours to NHTSA's overall burden hour total.

A.16) For collection of information whose results will be published, outline plans for tabulation and publication.

There are no tabulated results for this information collection.

A.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.

NHTSA will display the expiration date for OMB approval on any collection materials (e.g., screening questionnaire, moderator guide).

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

No exceptions to the certification are made.

Appendix A: Sample Screening Questionnaire and Moderator Guide for Focus Group Study

1 From Bureau of Labor and Statistics’ median hourly wage (all occupations) in the May 2008 National Occupational Employment and Wage Estimates, Updated May 2009

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