Supporting Statement ESGR FG 062311 final

SUPPORTING STATEMENT

Department of Defense Focus Groups of Employers

A. JUSTIFICATION

A. 1. Need for Information Collection

In accordance with 10 United States Code, Section 2358 (Attachment 1), the Under Secretary of Defense for Personnel and Readiness (USD[P&R]) is required to conduct research of interest to the Department of Defense (DoD). This research of interest to the DoD requires the collection and dissemination of information about the economic impact to U.S. employers of Selected Reserve members who are absent from civilian employment to serve in the military.

The Uniformed Services Employment and Reemployment Rights Act (USERRA) (Attachment 1) protects Service members' reemployment rights when returning from a period of service. The Act requires that persons who serve or have served in the Armed Forces, Reserves, National Guard or other "uniformed services:" (1) are not disadvantaged in their civilian careers because of their service; (2) are promptly reemployed in their civilian jobs upon their return from duty; and (3) are not discriminated against in employment based on past, present, or future military service.

The Act covers members of the Uniformed Services, the commissioned corps of the Public Health Service, any other category of persons designated by the President in time of war or national emergency, and their government and civilian employers. It is the responsibility of the Employer Support of the Guard and Reserve (ESGR) to promote cooperation and understanding between Reserve component members and their civilian employers and to assist in the resolution of conflicts arising from an employee's military commitment. The Department of Defense Focus Groups of Employers are being conducted to examine the effects of using the Reserve Components (RC) as an operational force on employers of Guard and Reserve members and to evaluate the effectiveness of ESGR and DoD programs. Data gathered for this information collection will complement information gathered through the Department of Defense National Survey of Employers. The information collected will be used for overall program evaluation, management, and improvement.

Primary Objectives. The primary objectives of this research are to determine how employers are affected when Guard and Reserve employees are absent serving in the military, to evaluate the impact of DoD policy (covering employment of the Reserve Components as an operational force and Contiguous Pre-Mobilization Training) on employer operations, and to gain insight into unmet employer needs. The Department of Defense Focus Groups of Employers, along with the Department of Defense National Survey of Employers, will provide essential information to help DoD design policies to account for the burden that military duty may have on civilian employers and also provide information on the general attitudes of civilian employers toward National Guard and Reserve employees, the contributions of Guard and Reserve employees to employers and the knowledge of and desired supports for compliance with USERRA.

Reasons the Information is Necessary. This information collection is necessary because previous research in this area is limited, outdated, and/or not specific to the objectives of this information collection request. This information collection will be used in conjunction with data from the Department of Defense National Survey of Employers which is being collected on a statistically random and nationally-representative basis.

The collection of this information will allow informed evaluation of policy, program, and legislative efforts to establish and maintain employer support, and will help the DoD to formulate its recommendations to Congress. The results from the Department of Defense Focus Groups of Employers will provide ESGR with detailed information that enhances and contextualizes the survey results from the Department of Defense National Survey of Employers. This will allow ESGR to evaluate current support programs and potentially design new programs as it continues its mission of maintaining employer support for Guard and Reserve service, increasing awareness of the relevant laws impacting both employer and employee, and resolving, through mediation, potential conflict that may arise from an employee's military commitment.

A. 2. Use of Information

The sponsor of the Department of Defense Focus Groups of Employers is the Office of the Under Secretary of Defense for Personnel and Readiness (USD P&R), and the users of the data will be ESGR, the Office of the Assistant Secretary of Defense (Reserve Affairs), and offices within the Department of Defense and in the Office of the Secretary of Defense.

The respondents for this information collection are U.S. employers. Focus group participants will consist of employers that employ Guard and Reserve members as well as employers that do not.

The focus group discussions will cover past or anticipated experiences with Guard and Reserve employee absences for military duties and the actual or potential challenges resulting from these absences. The focus group moderator will ask about issues related to the effect that an absence has or could have on the business and the factors that could influence the likelihood and magnitude of that effect. The moderator will also ask respondents questions to assess their knowledge of and perspectives on USERRA and support programs provided by Employer Support of the Guard and Reserve (ESGR).

To assist with its research and program evaluation objectives, ESGR will use the focus group results to contextualize and interpret findings from an analysis of responses to the Department of Defense National Survey of Employers and to better understand previously-collected information on the experiences of employers. The focus groups will provide an opportunity for more in-depth exploration of key issues and trends that have emerged from previously collected data. This will inform DoD about the impact on employers when their employees are absent to serve in the military and help shape policy and program initiatives, pre-mobilization planning efforts, and ESGR outreach efforts to employers. More specifically, results will also be used by ESGR to identify areas where the training and assistance it provides can be improved; ESGR will use the results for overall program evaluation, management, and improvement

A. 3. Improved Information Technology

The purpose of the focus groups is to obtain direct, face-to-face interaction with employers in order to obtain more in-depth information on issues that are being addressed on a broader scale via the Department of Defense National Survey of Employers. That survey is accessible on-line to selected employers.

A. 4. Efforts to Identify Duplication

The proposed information collection supplements but does not replicate the Department of Defense National Survey of Employers. The focus groups are designed to elicit information that cannot be obtained through a survey with limited response options. This information will enhance the understanding obtained from an analysis of survey responses.

In order to avoid an excessive burden on individual employers, we will exclude firms that were contacted for the Department of Defense National Survey of Employers from this information collection.

Reserve Affairs conducted a “Survey to Determine Economic Costs to and Impact on Employers of Mobilized Reserve Component Members” in the fall of 2006. This information is limited in that it focused only on employers of reservists who had been mobilized for 30 days or more and is also somewhat outdated. The United States Air Force (USAF) Reserve was considering conducting its own survey of employers which would have had the same stated purpose as the Department of Defense National Survey of Employers. However, after consulting with ESGR, USAF decided against their own survey in favor of using the results that would be generated from the current survey.

A. 5. Methods Used to Minimize Burden on Small Entities

Small businesses, which likely have few employees to spare, have great potential to benefit from the improvements that ESGR intends to make to its programs to be informed by this information collection. The challenges that small businesses face in the event of a Guard or Reserve member’s duty-related absence are among those that are most difficult to track through a general survey with restricted response options and therefore are the most important to explore through semi-structured focus group discussions. As such, the research design involves three focus groups that explicitly target small, private firms (under 50 employees at all locations) so that the discussions can elicit issues of greatest importance to these firms and make the most effective use of their time.

A. 6. Consequences of Not Collecting the Information

This is a single request for information. Not collecting this information will preclude DoD's ability to develop a contextually-based understanding of the responses to the Department of Defense National Survey of Employers and to explore the reasons for observed variation in responses. Supplementing a large-scale survey with a small number of focus groups is a common qualitative research technique that allows for the most effective practical use of survey information. As such, not collecting this information will preclude DoD from achieving the aims of the DoD National Survey of Employers. Those are: 1) identify changes in employment trends of Guard and Reserve personnel; and 2) respond to employers' needs that may jeopardize the DoD's outreach efforts. By creating significant lag times between the identification and response to unmet employer needs, the DoD's ability to gain and maintain employer support may be limited and its planning efforts possibly impeded. In addition, no information collection may result in insufficient numbers of enlistments and reenlistments in the Selected Reserve, which is a critical component of DoD's ability to maintain sufficient forces to fulfill national security requirements.

A. 7. Special Circumstances

There are no special circumstances. This collection will be conducted in a manner consistent with guidelines contained in 5 CFR 1320.5(d)(2) (Attachment 1).

A. 8. Agency 60-Day Federal Register Notice and Consultations Outside the Agency

An agency 60-Day Federal Notice was published in Vol. 75, No. 247, Monday, December 27, 2010, Federal Register, page 81239, as required by 5 CFR 1320.8(d) (Attachment 1). A copy of the 60-Day Federal Notice is included in Attachment 2. One public comment was received in response to the notice; this was a request for additional information on the study, which was provided.

IRB approval was obtained from the RAND Corporation Human Subjects Protection Committee for this data collection activity as well as from Erin M Loos, CIP, for Caroline Miner, Program Manager, Exemption Determination Official for the Office of the Under Secretary for Defense (Personnel & Readiness) Human Research Protection Program, 703-578-8569 (Attachment 3).

Input on the design of the data collection and focus group sampling was provided by Fawzi Al Nassir at the Defense Manpower Data Center, 703 696-5825.

A. 9. Payments to Respondents

Focus group participants will be provided with a meal and/or refreshments during their group session, but will receive no other payments or gifts from ESGR or any other affiliated entity.

A. 10. Assurance of Confidentiality

The information collection does not ask respondents to submit proprietary, trade secret, or confidential information to DoD.

A. 11. Sensitive Questions

The data collection instrument contains no questions of a sensitive nature. The focus groups will be non-intrusive and it will be made clear to respondents that cooperation is voluntary. Researchers conducting the focus groups will not collect or use personally identifiable information except for the purposes of inviting and arranging for participation and no personally identifiable information will be transmitted to any federal agency. Therefore, the information collected is not subject to the Privacy Act of 1974, as amended (Attachment 1).

The focus group will begin with a description of the purpose of the focus group and a clear statement of the voluntary nature of participation. Participants will be asked to orally consent to participation and to the audio recording after this description has been provided and will be invited to leave the discussion at any point if they so choose.

The data collection procedures are not expected to involve any risk to participants. Names are used only in communicating with representatives of employers. These names are kept securely by the focus group coordinator, who is guided by an approved data safeguarding plan (see Attachment 4) for the entire project of which the proposed information collection is one part, and are not linked to response data. Any record of the names of employer organizations and individual participants will be destroyed once the focus groups have taken place. RAND will not reveal the names of employer organizations invited to participate with DoD.

RAND’s network sites are secure and password protected. Security is strictly enabled by using physical and software access restrictions. All servers are physically located in locked rooms with access permitted only to Technical Services staff through the use of a security card system. Access to the network is allowed only through a login account and password. In addition, employees use password protected screen savers at workstations to protect their systems while they are away from their desks.

A. 12. Estimates of Annual Response Burden and Labor Cost for Hour Burden to the
Respondent for Collection of Information

a. Response Burden:

(1) Department of Defense Focus Groups of Employers

Total annual respondents:	120
Frequency of response:	1
Total annual responses:	120
Burden per response:	75 minutes (average across respondents)
Total burden hours:	9,000 minutes/60 = 150 hours

b. Explanation of How Burden was Estimated: The anticipated number of respondents is based on the goal for the number of focus group participants in each focus group (ten, with a range of six to twelve). The estimated hourly wage used to calculate the average cost per response is the OS-9Il hourly rate given that the focus group would likely be attended by a Human Resources representative or a line/site manager. The burden per response of 75 minutes is an estimated average: it is expected that focus groups will last between 60 and 90 minutes. Labor Cost to Respondent:

(1) Department of Defense Focus Groups of Employers

Total annual respondents	120
Frequency of response:	1
Total annual responses:	120
Burden per response:	75 minutes
Average cost per response:	$22.51 ($18.01 * 1.25 (75/60 minutes))
Total cost:	$2701.50 (average cost per response ($22.51) * number of responses (120))

A. 13. Estimates of Other Cost Burden for the Respondent for Collection of Information

a. Total Capital and Start-up Cost: There are no capital/startup costs.

b. Operation and Maintenance Cost: There are no operation and maintenance costs. No outside resources, consultations or record retrieval are required to answer the focus group questions. Any costs borne by the establishment will be minimal.

A. 14. Estimates of Cost to the Federal Government

Defense Manpower Data Center (DMDC) and ESGR Staffing Costs

Paygrade	Months	Rate/Month	Total
GS-15	.4	$11,688	$4,675
GS-13	.4	$8,408	$3,360
Total Staffing Costs			$8,035

Contractor Operations and Maintenance Cost (Includes contractor labor, travel and materials costs to prepare for, conduct and analyze data from the focus groups.)	$200,000
On-Site Contractor Support (Costs for support contracts are based on negotiated risks for similar services.)	$0
Government Staffing Cost (Includes contractor technical oversight, contract administration, consults with ESGR, outreach to stakeholders, costs associated with providing data for sampling)	$8,035 (see above for detail)
Total Cost	$208,035

A. 15. Changes in Burden

This is a new collection. There have been no appreciable changes in burden.

A. 16. Publication Plans/Time Schedule

We expect to publish findings from the analysis of focus group results in conjunction with an analysis of data from the DoD National Survey of Employers approximately six months after the focus groups have been completed.

A. 17. Approval Not to Display Expiration Date

This approval is not being requested.

A. 18. Exceptions to the Certification Statement

No exceptions to the Certification Statement are being requested.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

B. 1. Description of Activity

Employer Support of Guard and Reserve (ESGR) has contracted with the RAND Corporation to conduct focus groups of employers.

The focus group design will involve stratification. Strata will be defined based on three characteristics of the employer establishment: metropolitan statistical area (MSA), employer sector and for private sector firms, employer size.

Employers will be included in a focus group that is specific to their stratum. This approach will allow for maximum generalizability of focus group findings while allowing for comparisons across key strata of employers. Unlike the survey sample, which was designed to be nationally representative, the focus groups will not be nationally representative. Rather, employers will be selected for participation based on whether they meet criteria for inclusion in the stratum. The primary sampling unit for the focus groups is the employer organization. After the sample has been selected, but prior to study enrolment, further validation techniques will be used to ensure that selected employers meet the stratum’s criteria. A key issue will be validation of the size of the private sector employer firm (based on number of employees) since available data reflect the establishment size rather than the firm size including all establishments (which is the characteristic of interest). The strata will be defined according to three key characteristics: metropolitan statistical area, firm sector, and firm size.

Metropolitan statistical area: We will select four to five MSAs where we will conduct the focus groups. Only establishments located in these MSAs will be recruited to participate in the study. Organizing the groups in a single MSA will ensure that it is not overly burdensome for employers to travel to the focus group location. We will select one MSA in each of the four ESGR regions (Northeast, Southeast, Central and West) and may select a fifth MSA in any region. In choosing the specific MSAs, we are reviewing the following data: the number of Guard and Reserve members residing in the MSA, distribution of those Guard and Reserve members across Components, total population of the MSA, and unemployment rate in the MSA. Data on the number of RC members residing in a particular MSA is available from the DoD’s DEERS file. A primary consideration in selecting the group of MSAs is that sites will be selected in such a way as to ensure that the average distribution of Guard and Reserve members across Components in the selected MSAs approximates the national average distribution of Guard and Reserve members across Components. A secondary consideration is that the sites selected are large enough, in terms of both the number of reservists residing in the MSA and in terms of the total population, to ensure a sufficient number of employers who may have had some experience with reservists. Although we do not expect to have trouble recruiting enough employers in each location we select, in the event we do, we would include an additional MSA in that ESGR region and recruit employers for a focus group to be held in that region.

Sector and size: A combination of employer sector and, for private employers only, employer size, will be used to define the strata for focus groups. We will conduct three focus groups with each of the following types of organizations: public sector employers (not first responders), public sector first responders, small private sector employers (under 50 employees at all locations), medium and large private sector employers (50+ employees at all locations). Note that employer size will not be a defining characteristic of the strata involving public sector employers because the notion of the “employer” is more difficult to specify and size is less meaningful for public sector employers. For example, is police officer may be considered to be an employee of the police department, the city, the county or state. As such, the strata for public sector employers will include employers of all sizes. For all focus group participants, we will document the industry and the size of the worksite and consider these characteristics in our data analysis.

There are two distinct populations of interest for this data collection: establishments that have employed Guard or Reserve members in their workforce since June 2007 (CEI) and establishments without Guard or Reserve members in their workforce (Non-CEI)¹. Both CEI and non-CEI firms will be invited to participate in the focus groups. A majority of firms to be recruited for the focus groups will be selected from the CEI sample. RAND will obtain from DMDC data on all CEI firms that were part of their sampling frame for the survey but were not selected to receive the DoD National Survey of Employers. Only establishments that employ or employed Guard or Reserve members on the workforce since June 2007 as full or part-time paid employees were included as part of the CEI sample for the survey. Using these data, we will identify the employers that fall into the strata described above and then randomly select firms in each stratum to participate. Non-CEI employers will be recruited from the large population of all employers that meet the criteria of the stratum and were not invited to participate in the survey. Telephone pre-screening techniques will be used to verify that the employers selected to participate do in fact meet the criteria of the stratum before invitations to participate are extended.

B. 2. Procedures for the Collection of Information

Field Procedures. The following data collection procedures will be undertaken after receipt of OMB approval.

1. Once the initial sample has been identified, we will contact the sampled firms by phone to validate the information in the data file and stratum assignment, confirm the number of employees at the firm in question, identify an appropriate participant for the focus group, obtain their direct contact information, and solicit focus group participation as appropriate. The telephone contact will be guided by a phone script (Attachment 5).

2. After obtaining contact information, we will e-mail or send via regular mail: an invitation to the focus group in the form of a letter from the RAND Corporation, a letter of support from Mr. David L. McGinnis, Principal Deputy Assistant Secretary of Defense for Reserve Affairs (or his successor), and a fact sheet about the focus groups (Attachment 5). The letter from the RAND Corporation would describe the purpose and sponsor of the focus groups and contain contact information in the event of any questions on the part of the firms.

3. We will follow-up by telephone within two weeks of mailing the invitation to confirm participation (again guided by a phone script, included in Attachment 5). If a sampled firm declines to participate, we will move to the next firm on the list according to the approach described above in section B.1. and will repeat steps 1-3 with the newly sampled firm.

4. Participants will be recruited to participate in a specific focus group based on their stratum. One week prior to the focus group, we will email and/or telephone those who have agreed to participate with a reminder about the date, time and purpose of the focus group. This reminder contact will also be guided by an email or phone script, depending on the mode of contact (Attachment 5).

5. Employers that are recruited to participated, are eager to provide input to the study but unable to attend the focus group for which they have been selected may be accommodated through a one-on-one telephone interview with RAND researchers using the same protocol and consents as the focus groups. The same data safeguarding and confidentiality procedures as described for the focus groups would apply to these interviews.

B. 3. Non-response, Maximization to Response Rates, and Accuracy and Reliability

To encourage participation and maximize the response rate, when we send the invitation to participate in the focus groups, we will include a letter of support from Mr. David L. McGinnis, Principal Deputy Assistant Secretary of Defense for Reserve Affairs, or his successor (Attachment 5).

Independent of this effort, ESGR plans on mounting an extensive media campaign to support the Department of Defense National Survey of Employers. Focus group recruitment will benefit from reference to and visibility of this survey. In addition, ESGR local representatives plan to work with local business groups to advertise and encourage participation in the focus groups.

The plan for focus group recruitment provides for RAND to continue recruiting until we reach our target number of participants. We will log any refusals and analyze the data on the characteristics of the employers that decline to participate.

B. 4. Tests of Procedures

RAND utilizes best practices in its design and execution of focus groups and in the subsequent analysis of data. RAND reviewed the results of previous studies of the effect of reserve mobilizations on employers, the instrument to be used in the DoD National Survey of Employers as well as responses from recent DMDC Status of Forces-RC and Quick Compass Surveys in designing the protocol for these focus groups. Both RAND principal investigators have extensive experience conducting focus groups.

B. 5. Personnel/Organizations Responsible for Design, Collection or Analysis of the
Information

ESGR Principal Investigators:	Samantha Walker
RAND Consultants:	Dr. Susan Gates, Principal Investigator (310-393-0411 x7452) Dr. John Winkler Ashley Pierson Geoffrey McGovern

1 In a directive-type memorandum issued 21 March 2003 (Attachment 1), the Under Secretary of Defense for Personnel and Readiness (USD P&R) required military departments to implement a Civilian Employment Information (CEI) Program. The memorandum states the CEI is to have ready employment-related information for mobilization planning purposes of the Services concerned, and this information shall also be used on a recurring basis to help the Department accomplish its employer outreach purposes. The CEI data will be used by RAND to identify employers known to have employed a Guard or Reserve member (CEI employers).