Focus Groups
UNITED STATES DEPARTMENT OF AGRICULTURE
INDEPENDENT ASSESSMENT OF THE DELIVERY OF
TECHNICAL AND FINANCIAL ASSISTANCE
PART A
CONTRACT AG-3142-C-09-0030
OMB CONTROL NUMBER 0503-NEW
Customer Focus Groups; Community Based Organizations; and Approved Insurance Providers and Brokers/Agents
Table of Contents
Page
INTRODUCTION 1
JUSTIFICATION 2
A.1 Circumstances Making the Collection of Information Necessary 2
A.2 Purposes and Uses of the Collected Information 3
A.3 Use of Technology to Reduce Burden 6
A.4 Efforts to Identify Duplication 6
A.5 Methods to Minimize Burden on Small Entities 7
A.6 Consequences of Not Collecting Data 7
A.7 Special Circumstances 7
A.8 Federal Register Comments and Persons Consulted Outside the Agency 8
A.9 Decision to Provide Any Payments or Gifts to Respondents,
Other than Remuneration of Contractors or Grantees 9
A.10 Assurances of Confidentiality 9
A.11 Justification for Any Questions of a Sensitive Nature 10
A.12 Estimates of the Hour Burden 11
A.13 Estimate for the Total Annual Cost Burden to Respondents 14
A.14 Estimate of Annual Cost to the Federal Government 15
A.15 Reasons for any Program Changes or Adjustments 15
A.16 Plans for Tabulation and Publication of Results, Analytic Techniques,
and Time Schedule 15
A.17 Approval to Not Display the OMB Expiration Date 18
A.18 Explanation of Exceptions 18
List of Tables
Page
Table 1A Estimated Annual Reporting Burden for Focus Groups 13
Table 1B Estimated Annual Reporting Burden for CBO Interviews 13
Table 1C Estimated Annual Reporting Burden for AIP Interviews 13
Table 1D Estimated Annual Reporting Burden for Entire Information Collection 14
List of Exhibits
Exhibit A-1 Schedule for the Data Collection Component of the Study 17
Justification
INDEPENDENT ASSESSMENT OF THE DELIVERY OF TECHNICAL AND FINANCIAL ASSISTANCE
SUPPORTING STATEMENT for paperwork reduction act submission
INTRODUCTION
The United States Department of Agriculture (USDA) administers and manages commodities, credit, conservation, disaster, grant and loan programs, as authorized by Congress, through a network of State, county, local and area offices. At the local level, USDA delivers its programs and services through, among others, the Farm Service Agency (FSA), Natural Resources Conservation Service (NRCS), Rural Development (RD), and Risk Management Agency (RMA) throughout rural America. USDA has contracted with Jackson Lewis LLP (“Jackson Lewis” or “JL”) to conduct the independent external civil rights assessment that examines whether there is equitable delivery of technical and financial programs at the State and local level by the four agencies listed above (the “Agencies”) to diverse groups as defined in the Request for Proposals. A description of each Agency is provided below:
FSA – Makes direct and guaranteed farm ownership and operating loans to farmers and ranchers who cannot obtain commercial credit from banks or other lenders. FSA also administers farm commodity, crop insurance, environmental, conservation, and emergency assistance programs for farmers and ranchers.
NRCS – The primary federal agency that works with private landowners to help them conserve, maintain, and improve their natural resources.
RD – Provides funding to rural communities in three primary areas: housing and community facilities, business, and utilities, via direct and guaranteed loans and grants.
RMA – Helps producers manage business risk through market-based risk management solutions, operates and manages the Federal Crop Insurance Corporation.
USDA plans to conduct: 1) focus group discussions with USDA customers, potential customers1, and individuals or entities that have applied unsuccessfully for technical or financial assistance (collectively, “customers”); 2) interviews of Community-Based Organizations (CBO); and 3) interviews of Approved Insurance Providers (AIP) employees/brokers-agents. The focus groups and interviews are part of JL’s evaluation of the effectiveness of the Agencies’ programs in reaching diverse populations in a non-discriminatory manner. Jackson Lewis will conduct the focus groups and interviews for this component of the Independent Assessment (“Assessment”). The Assessment will assist in identifying barriers to equal and fair access for customers regardless of race, gender, and other protected categories. The Assessment is a step in the direction of fulfilling Secretary Vilsack’s initiative to usher in a new era at USDA that will work to eradicate discrimination and make USDA a leader among government agencies in civil rights.
A. Justification.
EXPLAIN THE CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY. IDENTIFY ANY LEGAL OR ADMINISTRATIVE REQUIREMENTS THAT NECESSITATE THE COLLECTION.
The primary legal authority for the information collection is the Food, Conservation, and Energy Act of 2008 (2008 Farm Bill). Pub. L. No. 110-246, 122 Stat. 1651 (June 18, 2008). A GAO audit recommended that USDA conduct an independent civil rights assessment. Secretary Vilsack ordered such an independent assessment so that USDA could usher in “a new era on civil rights,” and so that USDA will become “a model in the Federal Government for respecting the civil rights of its employees and constituents.” Honorable Thomas J. Vilsack, Secretarial Memorandum, April 2009. Jackson Lewis was selected through a competitive procurement process to conduct the independent assessment.
In addition to the 2008 Farm Bill, the focus group and CBO and AIP interview information collection is authorized by the 2002 Farm bill. Section 10707 of the Farm Security and Rural Investment Act of 2002 (Pub. L. 107-171) (2002 Farm Bill) (7 U.S.C. 2279) requires the Secretary to:
“...carry out an outreach and technical assistance program to encourage and assist socially disadvantaged farmers and ranchers—
in owning and operating farms and ranches; and
(B) in participating equitably in the full range of agricultural programs offered by the Department.”
This information collection is necessary to determine the effectiveness of USDA’s outreach and technical assistance programs and identify methods for improvement. The collected information will be used to evaluate access to USDA Farm programs and services for minority farmers and ranchers with agricultural interests. These individuals may receive information or personal contact through USDA outreach efforts.
Congressional Mandate for Increased USDA Attention to Civil Rights
On March 7, 2003, USDA established the position of Assistant Secretary for Civil Rights, as required by the Farm Security and Rural Investment Act of 2002 (Public Law 107-171), and gave that position responsibility for:
Ensuring compliance with all civil rights and related laws by all agencies and under all programs of the Department;
Coordinating administration of civil rights laws (including regulations) within the Department for employees of, and participants in, programs of the Department; and
Ensuring that necessary and appropriate civil rights components are properly incorporated into all strategic planning initiatives of the Department and agencies of the Department.
The Assistant Secretary for Civil Rights leads oversight of USDA’s civil rights, equal employment opportunity, alternative dispute resolution, and workforce diversity and inclusion activities. The Office is tasked with ensuring compliance with civil rights related laws, regulations, and policies for USDA’s constituents and employees. Departmental Management of the United States Department of Agriculture is responsible for this collection.
USDA prohibits discrimination in all its programs and activities on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, and marital or family status. The Assistant Secretary for Civil Rights is required to ensure that all programs within USDA comply with this prohibition. This is accomplished by performing the following tasks:
Analyze and review program complaints and participation rates of USDA customers.
Analyze outreach, education and technical assistance programs and service delivery.
Take actions to ensure that civil rights objectives and considerations are an integral part of USDA.
Increase participation levels and involvement in productive farming for socially disadvantaged groups.
Increase economic growth and provide greater opportunities within underserved communities.
Increase socially disadvantaged groups’ positive interaction and exposure to USDA through personalized hands-on assistance with farm loan applications and processes.
Ensure that all USDA programs are presented in such a manner that all eligible customers, particularly socially and economically disadvantaged groups, seeking to participate in USDA programs will receive timely and meaningful assistance on program benefits and application requirements.
To accomplish these objectives, the focus groups and CBO and AIP interviews will assist in determining the perceptions and expectations of USDA customers.2
INDICATE BY WHOM, HOW, 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.
This Information Collected Will Be Used to Provide Anecdotal Qualitative Information to USDA
This is a new data collection. USDA has contracted with Jackson Lewis to conduct the focus groups, CBO interviews, and AIP interviews as part of the Assessment. Each of the information collections is qualitative in nature. The information about the focus groups and CBO interviews will provide direct anecdotal, qualitative information from the Agencies’ customers’ (hereinafter “customers” is defined to include individuals who, during the last three years, have successfully or unsuccessfully applied for technical or financial programs or services from one of the four Agencies) attitudes, understandings, and experiences with the four USDA Agencies and the programs and services they provide. The information from the AIP interviews will provide direct, qualitative information from the AIPs and their agents about AIP programs and services, how AIPs identify and market to potential customers, and AIP practices with respect to women and minority customers and potential customers. These information collections are not intended to be statistical in nature; rather, they provide qualitative anecdotal information. The information collected will be analyzed to identify trends, concerns, best practices, and improvement in recommendations for the relevant State. This information, along with: USDA employee interviews; reviews of USDA policies, procedures and methodologies; review of internal and external complaints and lawsuits; USDA documents and information; regulations; and, statutes, will provide Jackson Lewis with the information needed to analyze the effectiveness of USDA provision of service functioning and identify recommendations and methodologies to assist in ensuring that programs are delivered equitably and that access is afforded to all constituents, with particular emphasis on female and minority farmers, ranchers, and other producers. The Assessment team will produce a final comprehensive report, including a thorough written analysis of its findings and applicable law, and will conclude with specific recommendations to assist USDA Secretary in making the appropriate changes.
USDA will be the primary audience for the information obtained during these information collections. The anecdotes provided by this collection will be one input used by USDA to understand how effectively it provides equitable and fair technical and financial assistance, primarily, to women and minority customers and potential customers. USDA can use these anecdotes to generate ideas for how to reduce discrimination and promote civil rights within the selected Agencies of USDA. The anecdotes will also be useful for shedding light on possible improvements to programs and services to better serve USDA customers and potential customers.
Focus Groups
No pretesting was undertaken.
There are separate Focus Group Questions Documents (“Questions Document,” see App. 2) for each of the four Agencies. The focus groups will explore whether participants understand the programs and services offered by the Agency and whether they have experienced perceptible bias in connection with those programs and services. The focus group Questions Documents will not be distributed or otherwise made available to focus group participants. Each focus group discussion will be recorded by a stenographer.
USDA will provide lists of USDA customers and potential customers for each of the Agencies. This information will be used to select respondents for the focus group discussions. For a full discussion of how these lists are generated and how participants are selected from these lists, see Part B of the Information Collection Request.
The respondents will be drawn from lists of approximately 2250 USDA customers and potential customers. The “2250” number was determined by working backward from the maximum number of customers and potential customers who will participate in the focus groups, which is 450. It is estimated that only one-fifth/twenty percent of the customers and potential customers contacted will agree to participate in the focus groups.3 Thus, to secure a maximum of 450 interviews, that number was multiplied by 5 (450 X 5). The list of 2250 respondents will be spread evenly between 1) RD; 2) NRCS; and 3) FSA and RMA, with the goal of recruiting 150 potential customers per group. As is explained more fully in Part B, the lists will be populated primarily by women and minority customers and potential customers. We estimate the recruitment calls will take about 5 minutes on average. The final number of focus group participants will range from 300-450. As noted, each focus group will have between 10-15 participants. Each focus group session will last approximately two hours.
The collection of information includes an advance letter announcing the upcoming focus group discussions as well as information on the objectives of the study and the focus group logistics. We will also send a reminder postcard and make a follow-up reminder telephone call prior to the event to confirm participation. (See App. 3).
b. CBO Interviews
No pretesting was undertaken.
CBO interviews will be organized based on the Agencies. CBO interviews will be conducted by JL attorneys who have conducted similar interviews with Agency employees. There are separate CBO Interview Questions for each of the four Agencies that contain the questions to be asked of participants. (See App. 4).
The CBO Interview Questions will be used by the field team interviewer to elicit information about the CBOs’ members’ understanding of programs and services offered by the Agency, and experiences with the applicable Agency. The Interview Questions will not be distributed or otherwise made available to the CBOs or the individuals from the CBOs who are interviewed.
Lists of CBOs will be provided by USDA. This information will be used to select the respondents for the interviews. JL will, to the extent possible, attempt to contact CBOs whose members are predominantly women or minorities. The goal is to interview these CBOs roughly in proportion to their representation among women and minority farmers/ranchers within each of the 15 applicable Assessment States.
The respondents will be drawn from a group of up to 270 CBOs. (An explanation of how the numbers of the CBO pool of 270 is explained in Part B of the Information Collection Request).
For the sake of this calculation, we assume up to 33% of those contacted will agree to participate in the CBO interview. One representative of the participating CBOs will be interviewed (“CBO interviewee”). We estimate the recruitment calls will take about 3 minutes on average. The maximum number of CBO interviewee participants will be 90. We expect each interview to last approximately one to two hours.
The collection of information includes an advance letter announcing the upcoming interviews as well as information on the objectives of the study and the interview logistics. A separate letter will be sent to the individual selected by each of the participating CBOs to be interviewed. We will also make follow-up reminder telephone calls and send postcards prior to the interviews to confirm participation. (See App. 5).
AIP Interviews
No pretesting was undertaken. The AIP Interview Questions include the questions that will be asked in each interview. (See App. 6). The Interview Questions will not be distributed or otherwise made available to the AIPs or AIP interviewees.
Lists of the 16 AIPs and individual information about the AIPs are public and readily available on the USDA/RMA website. Individual company information is also public, readily available, and can be found on the internet. Four to six AIPs will be selected to participate in the AIP interviews. They will be selected based on size, geographic location of office(s) and the AIPs’ proximity to large concentrations of women and minority producers.
A sample will be drawn to yield 20 to 60 AIP employee interview participants. As noted, for each selected AIP, we will interview approximately 5 to a maximum of 10 AIP agents. We expect each AIP interview to last between one to two hours.
The collection of information includes an advance letter announcing the upcoming AIP interviews to AIPs, and subsequently AIP agents who are being asked to participate in the interviews, as well as information on the objectives of the study and the AIP interview logistics. We will also make follow-up telephone calls and send postcards prior to the interviews to confirm participation. (See App. 7).
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.
The data will be collected through focus group discussions, CBO interviews and AIP interviews. Since this will be a face-to-face and/or telephonic data collection, the data collection does not involve the use of automated, electronic, mechanical or other technological collection techniques or other forms of information technology. During the recruitment period a toll-free number and an e-mail address may be available to permit the respondents to contact us with questions or requests for assistance.
4. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION. SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN ITEM 2 ABOVE.
This is a one-time study covering a discrete three-year period that will contribute to USDA’s understanding of the fairness in delivery of technical and financial assistance to customers and potential customers. The anecdotes obtained during this collection will be one input to USDA’s evaluation of the effectiveness of the programs and current outreach practices, and to note areas of possible improvement. It does not duplicate any previous or current effort underway. There is no alternative source of information on the experiences of these USDA customers or AIPs.
5. IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESSES OR OTHER SMALL ENTITIES (ITEM 5 OF THE OMB FORM 83-1), DESCRIBE THE METHODS USED TO MINIMIZE BURDEN.
The collection of information does not have a significant economic impact on small business.
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 information collected, USDA would not have direct input from women minority, or dissuaded individuals, or CBOs regarding their views, opinions, and experiences with respect to how effectively USDA is equitably and fairly providing technical and financial assistance to all customers and potential customers, particularly women and minorities. AIP interviews will provide similar information specific to RMA.
In light of the statutory mandates, the Secretary’s commitment to such fairness and equity, and the class action lawsuits brought by minority and female farmers and ranchers that have already resulted in over a billion dollars in payments, it is crucial to collect and analyze customer and AIP input and prepare recommendations to resolve and assist in the elimination of any real or perceived barriers to full equitable and fair participation in USDA programs and services.
This is a one-time collection.
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;
- REQUIRING RESPONDENTS TO PREPARE A WRITTEN RESPONSE TO A COLLECTION OF INFORMATION IN FEWER THAN 30 DAYS AFTER RECEIPT OF IT;
- REQUIRING RESPONDENTS TO SUBMIT MORE THAN AN ORIGINAL AND TWO COPIES OF ANY DOCUMENT;
- REQUIRING RESPONDENTS TO RETAIN RECORDS, OTHER THAN HEALTH, MEDICAL, GOVERNMENT CONTRACT, GRANT-IN-AID, OR TAX RECORDS FOR MORE THAN 3 YEARS;
- 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;
- REQUIRING THE USE OF A STATISTICAL DATA CLASSIFICATION THAT HAS NOT BEEN REVIEWED AND APPROVED BY OMB;
THAT INCLUDES A PLEDGE OF CONFIDENTIALITY THAT IS NOT SUPPORTED BY AUTHORITY ESTABLISHED IN STATUE 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
REQUIRING RESPONDENTS TO SUBMIT PROPRIETARY TRADE SECRET, 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.
There are no special circumstances that would cause this information collection to be conducted in any manner listed above. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.
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.
On February 22, 2010, Vol. No. 75, pages 7561 to 7562, the Department published the notice of information collection and request for comments in the Federal Register that covered a different sample design and method. One general comment was received during this time regarding the perceived inefficient use of taxpayer dollars. (See App. 8).
Since the February 22, 2010 Notice, the customer-input portion of the Independent Assessment has changed from electronic surveys to focus groups. Similar data and opinions from USDA customers will be solicited, but it will all be obtained in-person and/or telephonically rather than by mailed surveys. CBO interviews will provide indirect input from customers in and around the USDA-selected States. AIP interviews will provide valuable information concerning the delivery of RMA insurance products to customers, especially disadvantaged ones.
9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES.
Focus group participants will receive a $50 incentive in appreciation of their participation. We anticipate some difficulties in obtaining a reasonable level of participation and are providing an incentive to address several challenges: (1) the topics of discrimination, racism, sexism, and unfair treatment are sensitive for some and they may be reluctant to participate; (2) the Project Schedule requires the focus groups to take place during planting and harvesting seasons, when participants will be exceptionally busy; (3) many potential participants will be required to travel long distances, especially in the larger Western states; and, (4) the general public expects nominal compensation for focus group participation.
CBO and AIP interviewees will not be provided any payments or gifts.
10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS AND THE BASIS FOR THE ASSURANCE IN STATUTE, REGULATION, OR AGENCY POLICY.
All sampled members will be informed of the following: (1) their participation in the study is completely voluntary; (2) a decision not to participate in the study will not affect their own, their members’, and/or agents, access to technical and/or financial assistance from USDA; and (3) if they choose to participate they may refuse to answer any questions. Focus group participants, CBO interviewees, and AIP interviewees will be told that their individual responses will not be provided to USDA except as unattributed comments and that only aggregate results will be made part of the report of the information collection. In our initial contact with individuals they will be notified that we will take the steps necessary to safeguard their privacy, to the full extent permitted by law.
The privacy of individuals and their attributes will be maintained in accordance with the Privacy Act of 1974, which safeguards individuals against invasion of personal privacy by (1) permitting to determine what personal records are collected, maintained, used or disseminated; and (2) preventing personal records from being used for purposes other than those to which they agreed. All Westat staff members working on the recruitment of focus group participants are required to sign a confidentiality pledge. (See App. 9). All JL Team Members working on the recruitment of CBOs and/or AIP interviewees have signed a confidentiality pledge. (See App. 10).
Data collection and processing will be set up to protect the anonymity of sampled participants and/or their CBOs or AIPs by independently storing personally identifiable information in one database. Respondents will not be referenced by either their name or their position title in any reports. Listed below are the specific steps we will follow with respect to confidentiality:
Identifying information about the respondent (respondent name, address, and telephone number, etc.) will be kept separate from other data and password protected. The identifying information will not be shared with USDA and it will be destroyed once the project has been completed.
A fax machine used to send or receive documents containing confidential information will be kept in a locked field room, accessible only to study team members. When sending faxes, study staff will call ahead to make sure the authorized recipient is waiting for the fax.
In emails, respondents will be referred to by first and last initial. Files containing more information will be password protected.
Confidential materials will be printed on a printer located in a limited access field room. If printing documents that contain confidential information from shared network printers, authorized study staff will be present and retrieve the documents as soon as printing is complete.
All members of the study team will be briefed regarding confidentiality of the data. Each person involved in the study will sign and have notarized an affidavit of nondisclosure attesting to his/her understanding of the significance of the confidentiality requirement.
A control system will be in place, beginning at sample selection, to monitor the status and whereabouts of all hard-copy data collection materials. These include sign-in/sign-out sheets and the hand-carrying of documents by authorized project staff only.
All data will be stored in secure areas accessible only to authorized staff members.
When any hard copies that contain confidential information are no longer needed, they will be shredded. No electronic versions of this information will be created.
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.
The focus group discussions and CBO interviews will contain a few questions about sensitive topics that would try to elicit whether the respondents feel they or others were denied services or technical assistance because they were of a particular group. Our intention is to ask the respondents whether they feel they or others were denied services or technical assistance from one of the four Agencies in this Assessment (FSA, NRCS, RD, or RMA) due to their or others’ race, gender, or ethnicity. This information is asked because it is relevant to the understanding of the perceptions and beliefs of USDA customers and prospective customers and to the identification of barriers to full and equitable participation in USDA programs primarily by women and minorities.
All participants of the information collection will receive an advance letter about the study, including information about the voluntary nature of their participation and telling them that their personal information will be kept private to the extent permitted by law.. They will be told that they can refuse to answer a question if they do not want to answer that question.
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 DIFFERENCE 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.
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.
The time burden of recruitment and the actual focus groups will equal 1102.5 hours.
The maximum length of each of the 90 interviews will be two hours and the maximum total interview burden will be 180 hours (90 X 2).
The time burden of recruitment and the actual CBO interviews will equal 211.5 hours.
The burden cost estimate of $10,169 is based on the 2010 hourly wage data for USDA customers from the average farm family wage rate ($48.08 per hour) from the 2010 Wage and Salary Report from the Economic Research Service Bureau of Labor Statistics. Table 1B summarizes the number of respondents and associated burden estimates and annualized costs to respondents.
The maximum length of an interview will be two hours and there will be a maximum of 60 interviews. The total interview burden will be 120 hours (60 X 2).
The time burden of recruitment and the actual AIP interviews will equal 136.5 hours (16.5 + 120).
The burden cost estimate of $7,057 is based on the Bureau of Labor Statistics’ Occupational Employment and Wages, May 2009, hourly wage data for “Agencies, Brokerages, and Other Insurance Related Activities” using the median wage ($51.70) for the highest Metropolitan Statistical Area (San Francisco-San Mateo- Redwood City, CA) in the United States for the category. Table 1C summarizes the number of respondents and associated burden estimates and annualized costs to respondents.
Table 1D summarized the total costs to all respondents of the focus groups, CBO interviews, and AIP Interviews.
Table 1A. Estimated Annual Reporting Burden for Focus Groups
Data Collection Activity
|
Respondents
|
Annual frequency per response |
Estimated Number of Responses
|
Estimated Burden per Respondent (minutes)
|
Total Burden Estimate (hours)
|
Annualized Cost Estimate (@$48.08 per hour) |
Recruited Respondents |
450 |
1 |
450 |
15 |
112.5 |
$5,409 |
Recruited Non-respondents |
1800 |
1 |
1800 |
3 |
90 |
$4,327 |
Focus Groups |
450 |
1 |
450 |
120 |
900 |
$43,270 |
Total |
|
|
|
|
1102.5 |
$53,006 |
Table 1B. Estimated Annual Reporting Burden for CBO Interviews
Data Collection Activity
|
Respondents
|
Annual frequency per response |
Estimated Number of Responses
|
Estimated Burden per Respondent (minutes)
|
Total Burden Estimate (hours)
|
Annualized Cost Estimate (@$48.08 per hour) |
Recruited Respondents |
90 |
1 |
90 |
15 |
22.5 |
$1,082 |
Recruited Non-Respondents |
180 |
1 |
180 |
3 |
9 |
$433 |
Interviews |
90 |
1 |
90 |
120 |
180 |
$8,654 |
Total |
|
|
|
|
211.5 |
$10,169 |
Table 1C. Estimated Annual Reporting Burden for AIP Interviews
Data Collection Activity
|
Respondents
|
Annual frequency per response |
Estimated Number of Responses
|
Estimated Burden per Respondent (minutes)
|
Total Burden Estimate (hours)
|
Annualized Cost Estimate (@$48.08 per hour) |
Recruit AIPs |
6 |
1 |
6 |
15 |
1.5 |
$78 |
Recruited Respondents |
60 |
1 |
60 |
15 |
15 |
$775 |
Interviews |
60 |
1 |
60 |
120 |
120 |
$6,204 |
Total |
|
|
|
|
136.5 |
$7,057 |
Table 1D. Estimated Annual Reporting Burden for Entire Information Collection
Information Collection |
Annualized Cost Estimate |
Focus Group |
$53,006 |
CBO Interviews |
$10,169 |
AIP Interviews |
$7,057 |
Total Information Annualized Cost Estimate |
$70,232 |
13. PROVIDE AN ESTIMATE OF 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).
- THE COST ESTIMATE SHOULD BE SPLIT INTO TWO COMPONENTS: (a) A TOTAL CAPITAL AND START-UP COST COMPONENT (ANNUALIZED OVER ITS EXPECTED USEFUL LIFE); AND (b) A TOTAL OPERATION AND MAINTENANCE AND PURCHASE OF SERVICES COMPONENT. THE ESTIMATES SHOULD TAKE INTO ACCOUNT COSTS ASSOCIATED WITH GENERATING, MAINTAINING, AND DISCLOSING OR PROVIDING THE INFORMATION. INCLUDE DESCRIPTIONS OF METHODS USED TO ESTIMATE MAJOR COST FACTORS INCLUDING SYSTEM AND TECHNOLOGY ACQUISITION, EXPECTED USEFUL LIFE OF CAPITAL EQUIPMENT, THE DISCOUNT RATE(S), AND THE TIME PERIOD OVER WHICH COSTS WILL BE INCURRED. CAPITAL AND START-UP COSTS INCLUDE, AMONG OTHER ITEMS, PREPARATIONS FOR COLLECTING INFORMATION SUCH AS PURCHASING COMPUTERS AND SOFTWARE; MONITORING, SAMPLING, DRILLING AND TESTING EQUIPMENT; AND RECORD STORAGE FACILITIES.
- IF COST ESTIMATES ARE EXPECTED TO VARY WIDELY, AGENCIES SHOULD PRESENT RANGES OF COST BURDENS AND EXPLAIN THE REASONS FOR THE VARIANCE. THE COST OF PURCHASING OR CONTRACTING OUT INFORMATION COLLECTION SERVICES SHOULD BE A PART OF THIS COST BURDEN ESTIMATE. IN DEVELOPING COST BURDEN ESTIMATES, AGENCIES MAY CONSULT WITH A SAMPLE OF RESPONDENTS (FEWER THAN 10), UTILIZE THE 60-DAY PRE-OMB SUBMISSION PUBLIC COMMENT PROCESS AND USE EXISTING ECONOMIC OR REGULATORY IMPACT ANALYSIS ASSOCIATED WITH THE RULEMAKING CONTAINING THE INFORMATION COLLECTION, AS APPROPRIATE.
- GENERALLY, ESTIMATES SHOULD NOT INCLUDE PURCHASES OF EQUIPMENT OR SERVICES, OR PORTIONS THEREOF, MADE: (1) PRIOR TO OCTOBER 1, 1995, (2) TO ACHIEVE REGULATORY COMPLIANCE WITH REQUIREMENTS NOT ASSOCIATED WITH THE INFORMATION COLLECTION, (3) FOR REASONS OTHER THAN TO PROVIDE INFORMATION OR KEEPING RECORDS FOR THE GOVERNMENT, OR (4) AS PART OF CUSTOMARY AND USUAL BUSINESS OR PRIVATE PRACTICES.
There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.
14. PROVIDE ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT. ALSO, PROVIDE A DESCRIPTION OF THE METHOD USED TO ESTIMATE COST, WHICH SHOULD INCLUDE QUANTIFICATION OF HOURS, OPERATION 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 ALSO MAY AGGREGATE COST ESTIMATES FROM ITEMS 12, 13, AND 14 IN A SINGLE TABLE.
The estimate of annualized cost to the Federal Government includes a quantification of hours for employee programs. The program portion of this estimate is the government cost for labor and materials for analyzing, evaluating, summarizing and reporting on the collected information. These costs are summarized in the table below. In addition to the program costs there is a cost for contractor services that are being used in assisting in the collection of the information. The contract is with Jackson Lewis LLP in the amount of $1,735,585.
Employee Grade |
Activity |
Time Period |
Wage Rate |
Total |
GS-11/4 |
Reviewing Reports |
100 Hours |
32.92 |
$3,292.00 |
GS-14/5 |
Reviewing Reports |
40 Hours |
57.13 |
$2.285.20 |
GS-09/4 |
Administrative Support |
60 Hours |
27.21 |
$1,632.60 |
Total |
|
200 Hours |
|
$7,209.80 |
EXPLAIN THE REASON FOR ANY PROGRAM CHANGES OR ADJUSTMENTS REPORTED IN ITEMS 13 OR 14 OF THE OMB FORM 83-1.
This is a new collection of information resulting in a program change of 1450.5 (1102.5+211.5+136.5=) burden hours.
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.
Focus group, CBO interview and AIP interview data collected will provide anecdotes that will be used in conjunction with administrative data and legal analyses to provide insight into whether USDA is equitably and fairly providing technical and financial assistance primarily to women and minority customers and potential customers, or dissuaded individuals. The anecdotes from this collection, in conjunction administrative data and legal analyses will provide information from which JL will develop recommendations to assist in the elimination of any real or perceived barriers to full equitable and fair participation in USDA programs and services.
Focus Groups
Jackson Lewis will characterize the information collection findings qualitatively and analyze the opinions, views, and experiences offered by participants. After each focus group is completed, the team will debrief and discuss their observations and key topics that emerged. They will make notes of non-verbal communication and when several people in the focus group made similar statements. They will recall points covered and main ideas that emerged on each subject from the focus group Questions Document’s list of questions. This form of data is considered memory-based and can help supplement transcript data.
The transcripts taken by the stenographer can be used to correct inaccurate moderator impressions and to add points overlooked. Using these transcripts, analysts can address the original questions in the focus group guide or themes that arose in the discussions by noting the different points made in the margins. The analysts will record what each group has said in major quotes, key points, or themes on the different issues. The analysts can also make an inventory of points made by participants that can reflect the frequency of certain points made.
After reviewing transcripts for focus groups individually, the analysts can make comparisons between focus groups (reflecting different agencies and states). This stage includes indexing and sifting through data before charting and rearranging to best represent themed content. Analysts can draw conclusions from these findings to present to USDA.
CBO and AIP Interviews
Jackson Lewis will characterize the interview findings and analyze the opinions, views, and experiences expressed by CBOs whose members are also customers and AIP interviewees. After each interview is completed, the interviewer will debrief and document observations and key topics that emerged. The interviewer will make notes of non-verbal communication (as possible) and will recall points covered and main ideas that emerged on each subject from the interview guide list of questions. This form of data is considered memory-based and can help supplement contemporaneous notes taken during the interview.
After reviewing the interview notes from each interview, the analysts can make comparisons between interviewees (reflecting different agencies and states). This stage includes indexing and sifting through data before charting and rearranging to best represent themed content. Analysts can draw conclusions from these findings to present to USDA.
Time Schedule for the Project
Exhibit A-1. Schedule for the data collection component of the study. (TO BE REVISED UPON OMB APPROVAL)
Task |
Dates based on Contract Completion Date |
Deliverable |
|
Focus Groups/CBO & AIP Interviews |
|
|
|
- Revise focus group/CBO & AIP guides |
9/16/10 |
|
|
- Complete guides with USDA input |
9/12/10 |
|
|
- Finalize focus group guide (if required) |
9/16/10 |
|
|
OMB Package |
|
|
|
- Prepare revised package |
9/16/10 |
|
|
- Submit package to USDA for review |
9/16/10 |
X |
|
- Receive comments from USDA |
9/16/10 |
|
|
- Prepare final OMB package |
9/16/10 |
|
|
- Submit package to USDA for submission to OMB |
9/16/10 |
X |
|
- Receive OMB approval |
9/23/10 |
|
|
-Recruitment of Focus Group Participants |
|
|
|
- Obtain lists of all customer/applicants over past 3 years from USDA |
9/16/10 |
|
|
- Draw sample |
9/24/10 |
|
|
Focus Group Preparation |
|
|
|
- Mail advance letter to sampled customers |
10/1/10 |
|
|
- Begin tracing all returned mail |
10/3/10 |
|
|
- Begin preparing weekly data collection status reports |
10/4/10 |
|
|
- Re-mail advance letters to traced cases |
10/5/10 |
|
|
- Begin calling sampled customers |
10/6/10 |
|
|
- Conduct follow-up calls |
10/8/10 |
|
|
Begin Focus Groups |
10/21/10 |
|
|
Complete Focus Groups |
11/8/10 |
|
|
Recruitment of CBO & AIP Participants |
|
|
|
Collect CBO & AIP contact information from USDA |
9/23/10 |
|
|
- Draw sample |
9/28/10 |
|
|
CBO & AIP interview preparation |
|
|
|
- Provide advance letter to CBOs & AIPs |
10/1/10 |
|
|
- Make followup calls to CBOs & AIPs |
10/4/10 |
|
|
- Mail advance letter to CBO & AIP interviewees |
10/4/10 |
|
|
- Make initial follow-up call to CBO & AIP interviewees |
10/7/10 |
|
|
- Make confirmatory follow-up calls to CBO & AIP interviewees |
10/8/10 |
|
|
Begin CBO & AIP interviews |
10/11/10 |
|
|
Complete CBO & AIP interviews |
11/19/10 |
|
|
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.
We will display the OMB control number and expiration date on the focus group, CBO Interview and AIP interview discussion guides under this clearance.
18. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN ITEM 19, "CERTIFICATION FOR PAPERWORK REDUCTION ACT SUBMISSIONS," OF OMB FORM 83-1.
The agency is able to certify compliance with all provisions under Item 19 of OMB Form 83-I.
4848-4415-3095, v. 1
1 “Potential USDA customers” are defined as those who have applied for technical or financial assistance and are awaiting USDA’s decision.
2 A discussion concerning the Legal Background related to question A.1. is included as Appendix 1.
3 Given the challenges of securing attendance by participants during a busy crop season, with required travel, we anticipate that some respondents will not be able to participate.
| File Type | application/msword |
| File Modified | 2010-09-24 |
| File Created | 2010-09-24 |