Justification - No material/Nonsubstantive Change

RESPONSE - TERMS OF CLEARANCE:

We acknowledge the terms of clearance we received from OMB on April 21, 2014, and confirm that the survey will use a purposeful convenience sample approach and therefore will not produce broadly generalizable results.

JUSTIFICATION – NONSUBSTANTIAL CHANGES (BASED ON PRE-TESTING):

In February and March, 2014, we asked four individuals from the target respondent population groups to pretest the survey instrument. The feedback from pre-testers indicated that the survey in its original form was too long, too complex, and too repetitive. Specifically:

1. The instructions, guidelines, and definitions were too long and repetitive in some places and should be shortened to clarify.

2. Some of the skill statements for the competencies that respondents are asked to review seemed redundant and the wording was too complex.

3. The binary answer options did not allow for respondents to indicate a neutral response - neither agree nor disagree.

4. Questions about whether workers receive enough training in each area were difficult to answer.

5. The pre-testers spent between 45 minutes and one hour completing the survey instrument, which is longer than the 30 minute time burden we originally estimated.

In response, our team : (1) simplified and shortened the instructions, skill statements and answer choices to lower the reading level, (2) deleted or merged similar skill statements to reduce redundancy and length, (3) moved skill statements from one section of the survey to another to improve organization and allow us to consolidate sections, (4) converted the answer options into a Likert scale, and (5) removed secondary set of redundant questions about whether workers receive enough training associated with each skill statement.

We consider all of the changes to be nonsubstantial since they do not constitute changes to the intent or substance of the survey, but only remove redundancies and simply the content. With the revisions to the survey, we expect it will take 30 minutes for respondents to complete – representing no change to our original burden estimate.

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