Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery Part A- clean

Supporting Statement for Paperwork Reduction Act Generic Information Collection
Submissions for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”
A. JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
Executive Order 12862 directs Federal agencies to provide service to the public that matches or exceeds
the best service available in the private sector. In order to work continuously to ensure that our
programs are effective and meet our customers’ needs, the Surface Transportation Board (hereafter
“the Agency”) seeks to obtain OMB approval of a generic clearance to collect qualitative feedback on
our service delivery. By qualitative feedback we mean information that provides useful insights on
perceptions and opinions, but are not statistical surveys that yield quantitative results that can be
generalized to the population of study.
This collection of information is necessary to enable the Agency to garner customer and stakeholder
feedback in an efficient, timely manner, in accordance with our commitment to improving service
delivery. The information collected from our customers and stakeholders will help ensure that users
have an effective, efficient, and satisfying experience with the Agency’s programs. This feedback will
provide insights into customer or stakeholder perceptions, experiences and expectations, provide an
early warning of issues with service, or focus attention on areas where communication, training or
changes in operations might improve delivery of products or services. These collections will allow for
ongoing, collaborative and actionable communications between the Agency and its customers and
stakeholders. It will also allow feedback to contribute directly to the improvement of program
management.

2. Purpose and Use of the Information Collection
Improving agency programs requires ongoing assessment of service delivery, by which we mean
systematic review of the operation of a program compared to a set of explicit or implicit standards, as a
means of contributing to the continuous improvement of the program. The Agency will collect, analyze,
and interpret information gathered through this generic clearance to identify strengths and weaknesses
of current services and make improvements in service delivery based on feedback. The solicitation of
feedback will target areas such as: timeliness, appropriateness, accuracy of information, courtesy,
efficiency of service delivery, and resolution of issues with service delivery. Responses will be assessed
to plan and inform efforts to improve or maintain the quality of service offered to the public. If this
information is not collected, vital feedback from customers and stakeholders on the Agency’s services
will be unavailable.
The Agency will only submit a collection for approval under this generic clearance if it meets the
following conditions:

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Information gathered will be used only internally for general service improvement and program
management purposes and is not intended for release outside of the agency (if released,
procedures outlined in Question 16 wil be followed);
Information gathered will not be used for the purpose of substantially informing influential
policy decisions 1;
Information gathered will yield qualitative information; the collections will not be designed or
expected to yield statistically reliable results or used as though the results are generalizable to
the population of study ;
The collections are voluntary;
The collections are low-burden for respondents (based on considerations of total burden hours,
total number of respondents, or burden-hours per respondent) and are low-cost for both the
respondents and the Federal Government;
The collections are non-controversial and do not raise issues of concern to other Federal
agencies;
Any collection is targeted to the solicitation of opinions from respondents who have experience
with the program or may have experience with the program in the near future; and
With the exception of information needed to provide renumeration for participants of focus
groups and cognitive laboratory studies, personally identifiable information (PII) is collected only
to the extent necessary and is not retained.

If these conditions are not met, the Agency will submit an information collection request to OMB for
approval through the normal PRA process.
To obtain approval for a collection that meets the conditions of this generic clearance, a standardized
form will be submitted to OMB along with supporting documentation (e.g., a copy of the comment
card). The submission will have automatic approval, unless OMB identifies issues within 5 business days.
The types of collections that this generic clearance covers include, but are not limited to:
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Customer comment cards/complaint forms
Small discussion groups
Focus Groups of customers, potential customers, delivery partners, or other stakeholders
Cognitive laboratory studies, such as those used to refine questions or assess usability of a
website;
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web surveys)
In-person observation testing (e.g., website or software usability tests)

The Agency has established a manager/managing entity to serve for this generic clearance and will
conduct an independent review of each information collection to ensure compliance with the terms of
this clearance prior to submitting each collection to OMB.

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As defined in OMB and agency Information Quality Guidelines, “influential” means that “an agency can
reasonably determine that dissemination of the information will have or does have a clear and substantial impact
on important public policies or important private sector decisions.”

3. Consideration Given to Information Technology
If appropriate, agencies will collect information electronically and/or use online collaboration tools to
reduce burden.
4.

Duplication of Information
No similar data are gathered or maintained by the Agency or are available from other sources known to
the Agency.

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Reducing the Burden on Small Entities
Small business or other small entities may be involved in these efforts but the Agency will minimize the
burden on them of information collections approved under this clearance by sampling, asking for readily
available information, and using short, easy-to-complete information collection instruments.

6. Consequences of Not Conducting Collection
Without these types of feedback, the Agency will not have timely information to adjust its services to
meet customer needs.
7. Special Circumstances
There are no special circumstances. The information collected will be voluntary and will not be used for
statistical purposes.

8. Consultations with Persons Outside the Agency
In accordance with 5 CFR 1320.8(d), on December 22, 2010, a 60-day notice for public comment was
published in the Federal Register. No comments were received by the STB.
9. Payment or Gift
The Agency will not provide payment or other forms of remuneration to respondents of its various
forms of collecting feedback. Focus groups and cognitive laboratory studies are the exceptions.
In the case of in-person cognitive laboratory and usability studies, the Agency may provide stipends of
up to $40. In the case of in-person focus groups, the Agency may provide stipends of up to $75. If
respondents participate in these kinds of studies remotely, via phone, or Internet, any proposed stipend
needs to be justified to OMB and must be considerably less than that provided to respondents in inperson studies, who have to travel to the agency or other facility to participate. If such information
collections include hard-to-reach groups and the agency plans to offer non-standard stipends, the

Agency will provide OMB with additional justifications in the request for clearance of these specific
activities.

10. Confidentiality
If a confidentiality pledge is deemed useful and feasible, the Agency will only include a pledge of
confidentiality that is supported by authority established in statute or regulation, that is supported by
disclosure and data security policies that are consistent with the pledge, and that does not unnecessarily
impede sharing of data with other agencies for compatible confidential use. If the agency includes a
pledge of confidentiality, it will include a citation for the statute or regulation supporting the pledge.

11. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.

12. Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents. The annual
burden hours requested (277) are based on the number of collections we expect to conduct over the
requested period for this clearance .

Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Annual Frequency
per Response

Hours per
Response

Total Hours

Focus Group

15

1

2

30

Comment Card/Brief Survey

200

2

.17

67

Surveys

150

2

.6

180

13. Costs to Respondents
No costs are anticipated.
14. Costs to Federal Government

The anticipated cost to the Federal Government is approximately $15, 320.00 annually. These costs are
comprised. These costs are entirely attributable to staff hours to develop and print the collection
instruments and to review the feedback.
15. Reason for Change
Not applicable. This is a new request for a generic ICR.

16. Tabulation of Results, Schedule, Analysis Plans
Feedback collected under this generic clearance provides useful information, but it does not yield data
that can be generalized to the overall population. Findings will be used for general service improvement,
but are not for publication or other public release.
Although the Agency does not intend to publish its findings, the Agency may receive requests to release
the information (e.g., congressional inquiry, Freedom of Information Act requests). The Agency will
disseminate the findings when appropriate, strictly following the Agency's "Guidelines for Ensuring the
Quality of Information Disseminated to the Public.", and will include specific discussion of the limitation
of the qualitative results discussed above.

17. Display of OMB Approval Date
We are requesting no exemption.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
These activities comply with the requirements in 5 CFR 1320.9.