SSFINAL2014GenericQualitativeFeedbackAgencyServiceDeliveryPART-A

Supporting Statement for Paperwork Reduction Act Generic Information Collection Submission for

“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”

National Credit Union Administration

Part A

1. 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 stakeholders’ needs, The National Credit Union Administration (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 stakeholder feedback in an efficient, timely manner, in accordance with our commitment to improving service delivery. The information collected from our stakeholders will help ensure that users have an effective, efficient, and satisfying experience with the Agency’s programs. This feedback will provide insights into 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 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 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:

• 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:

• Comment cards/complaint forms

• Small discussion groups

• Focus Groups of stakeholders

• Cognitive laboratory studies, such as those used to refine questions or assess usability of a website;

• Qualitative satisfaction surveys (e.g., post-transaction surveys; opt-out web surveys)

• In-person observation testing (e.g., website or software usability tests)

The Agency PRA Officer 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.

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.

5. 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 stakeholder 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), notice and request for public comment was published in the Federal Register. NCUA received one comment. The comment expressed “concerns about the usefulness of this information and the accuracy of the burden hours projected given how vague the request for comment is.” This is a request for a new collection of information to garner stakeholder feedback in an efficient, timely manner and the request for this new collection of information stemmed from Executive Order 12862, which directs Federal agencies to provide service to the public that matches or exceeds the best service available in the private sector. NCUA proposed to use a variety of instruments and platforms to collect satisfaction feedback from such stakeholders. Web and paper-based surveys or feedback forms, web-based polls or other interactive responses, comment cards and social media are being considered as a means to collect voluntary qualitative feedback on NCUA’s service delivery, in order to work continuously to ensure that our programs are effective and meet our stakeholders’ needs. Participation in this collection is voluntary and feedback collected will contribute directly to the improvement of program management.

The comment also expressed concern over an increasing regulatory burden for credit unions due to the passage of the Dodd-Frank Act in July 2010. All federal agencies, as well as their regulated entities, are required to adhere to the requirements of the Dodd-Frank Act.

In addition, the NCUA Board has expressed its commitment to reduce regulatory burden where possible.

9. Payment or Gift

The Agency generally speaking does not usually provide payment or remuneration to respondents of its various forms of collecting feedback, but might do so in the case of focus groups or cognitive laboratory studies.

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 in-person 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.

9. 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.

9. Sensitive Nature

No questions will be asked that are of a sensitive nature.

9. Burden of Information Collection

We anticipate using a variety of instruments and platforms to collect satisfaction feedback from respondents, including web- and paper-based surveys or feedback forms, web-based polls or other interactive responses, comment cards, and social media. The response time will vary per form. The total annual response time is estimated at 2,250 hours.

9. Costs to Respondents

No costs are anticipated.

9. Costs to Federal Government

The anticipated cost to the Federal Government is approximately $150,000 annually. These costs are comprised of: operational expenses to print and mail collections; subscription fees to online survey and webinar providers; support staff to tabulate results; contractor payments for conducting surveys, hosting meetings to discuss results and helping to inform program responses.

9. Reason for Change

Not applicable. This is a new request for a generic ICR.

9. 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) and, if so, will follow requirements under those rules.

9. Display of OMB Approval Date

We are requesting no exemption.

9. Exceptions to Certification for Paperwork Reduction Act Submissions

These activities comply with the requirements in 5 CFR 1320.9.

1 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.”