1225-0088ssa(20140630)

Supporting Statement for Paperwork Reduction Act Generic Information Collection Submissions for

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

This Information Collection Request (ICR) seeks to extend PRA authorization for the Department of Labor (DOL) Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery. The ICR includes twelve (12) information collection instruments to be continued without changes, one (1) new instrument, and two (2) instruments for which the questions will be changed. The Department notes that the ICR is intentionally submitted as an extension request, without change. The DOL believes this is the most consistent approach to a generic where the terms of the ICR will remain the same. Were the DOL not to have included the updated instruments in this request, then non-material change requests would have been subsequently submitted to incorporate them. The method DOL allows the existing instruments to be used while clearance is obtained.

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 customers’ needs, the U.S. Department of Labor (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:

• 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 will 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 remuneration 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 five (5) business days.

The types of collections that this generic clearance covers include, but are not limited to:

• 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.

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 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 March 28, 2014, the DOL published a notice in the Federal Register to announce a 60-day public comment period. See 79 FR 17578. No comments were received.

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 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.

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 time burden requested (41,461 hours) is based on the number of collections the DOL expects to conduct over the requested period for this clearance, including ongoing and collections submitted as part of this ICR.

Table 1—Estimated Annual Reporting Burden for Upcoming Collections

Type of Collection	No. of Respondents	Annual Frequency per Response	Hours per Response	Total Hours
The DOL estimates 20 new surveys/evaluations will be submitted over the course of the next three years. (DOL cleared 21 ICRs during the last clearance cycle) To account for a three-year clearance and how the ROCIS system accounts for burden, the DOL has tripled that estimate for purposes of this submission. 20 Collections	To ensure an appropriate level of responses and hours is available for collections approved under this package, the DOL estimates each upcoming survey will have 5000 respondents. (DOL submitted ICRs for 301,376 responses during the past 3-year approval cycle.) 15,000 Respondents	Respondents will typically be asked for no more than one response. 1 Response per Respondent	Based on a similar clearance (1225-0059), the DOL anticipates individual response times will vary from 3 to 15 minutes with an average of about 6 minutes per response. 0.100 hours	30,000 hours

The DOL will submit a non-substantive change to adjust the burden accordingly should activity under this clearance increase beyond current projections. With each individual survey instrument/evaluation form submitted to OMB, specific burden estimates will be provided. These estimates will include the total number of respondents, frequency of collection, average minutes/hours per response, and total burden hours and burden hour costs.

As previously noted, the DOL is using this extension request formally to obtain OMB approval to extend twelve (12) previously cleared information collections and obtain approval for changes to one previously cleared collection sets and for one new information collection under this generic ICR. (Note that the reginfo.gov database indicates all instruments are new. This was caused by the system overwriting a previously developed ICR (that had the previously cleared collections) when new collections were subsequently approved by the OMB. Creation of a subsequent ICR did not prepopulate the previously cleared collections.

Table 2—Continuing Information Collections

IC Title	Number of Respondents	Annual Frequency of Response	Responses	Hours per Response	Hours
National Contact Center Email Customer Satisfaction Survey	85,000	1	85,000	0.05000	4,250
ETA Webinar Technical Assistance Customer Feedback Survey	5,250	1	5,250	0.03900	205
WHD Family and Medical Leave Act Customer Experience Survey	1,713	1	1,713	0.16667	286
DOL Paperwork Reduction Act Web Page Comments Link	88	1	88	0.16667	15
ODEP Customer Service Follow-up: Workforce Recruitment Program	100	1	100	.08333	8
OFCCP Customer Experience Survey	13,200	1	13,200	0.08333	1,100
ETA-OFLC Certification Ombudsman Program Stakeholder Feedback	50	1	50	0.10000	5
OSHA Heat Stress Outreach Feedback Survey (2 instruments)	1,000	1	1,000	0.25000	250
EBSA Getting it Right-Know Your Fiduciary Responsibilities Survey	50	1	50	0.04167	2
EBSA Health Benefits Education Outreach Survey	50	1	50	0.04167	2
VETS Off Base Transition Training Participant Survey	250	1	250	0.25000	63
OSHA Participation in National Fall Prevention Safety Stand Down	25,000	1	25,000	0.16667	4,167
Total Burden Requested for Generic ICs Submitted with This ICR:	131,751	NA	131,751	NA	10,353

As previously noted, this ICR seeks to change two (2) instruments cleared under this control number and to add an information collection. Detailed information on the requests is included in the supplemental justification supporting statement for the information collection in the regingo.gov dataset.

Table 3—New or Revised Defined Information Collections

IC Title	Number of Respondents	Annual Frequency of Response	Responses	Hours per Response	Hours
Office of Federal Contract Compliance Programs Event Evaluation Form and Comment Cards (Changed Questions)	7,500	1	7,500	0.10000	750
Occupational Safety and Health Administration QuickTakes Survey (New)	7,000	1	7,000	0.03333	233
Office of Workers' Compensation Programs Services Stakeholder Surveys (Changed Questions)	1,500	1	1,500	0.08333	125
Total Burden Requested for Generic ICs Submitted with This ICR:	16,000	NA	16,000	NA	1,108

Table 4—Burden Summary

Category	Number of Respondents	Annual Frequency of Response	Responses	Hours per Response	Hours
Upcoming Collections	300,000	NA	300,000	NA	30,000
Continuing Information Collections	131,751	NA	131,751	NA	10,353
New or Revised Defined Information Collections	16,000	NA	16,000	NA	1,108
Grand Total	447,751		447,751	NA	41,461

Additional information regarding the burden for each instrument to be extended, changed, or updated may be found in the supplemental justification supporting statement that has been uploaded for each individual collection in the reginfo.gov database.

Respondents can come from any number of occupations; therefore, the DOL has increased the average hourly rate for all non-supervisory employees on private nonfarm payrolls for March 2014, of $24.32 by 40 percent (total rate $34.05), to approximate fringe benefits and overhead costs, to estimate the monetized value of respondent time. See The Employment Situation, May 2014, at 32, Table B-3, DOL, Bureau of Labor Statistics, http://www.bls.gov/news.release/archives/empsit_06062014.pdf. 41,461 burden hours x $34.05 hourly rate = $1,411,747.05 value of burden hours.

13. Costs to Respondents

No costs are anticipated.

14. Costs to Federal Government

The anticipated cost to the Federal Government is approximately $700,000 over the course of this information collection. These costs are comprised of developing and printing paper or developing Web-based instruments and Federal employee or contractor time to develop and to review instruments before they are used and to review answers for each submitted collection. Ongoing and new collections submitted as part of this ICR represent $233,300 in Federal costs. (Additional information regarding the Federal cost for each activity to be extended, changed, or updated may be found in the supplemental justification supporting statement that has been uploaded for each individual collection in the reginfo.gov database.) The DOL has tripled that amount and rounded to the nearest $1,000 for purposes of this ICR, as the number of on-going and new collections represents about a third percent of the volume of anticipated annual activity. 3 x $233,300 = 699,900

15. Reason for Change

Burden changes result from agency experience with the overall information collection since its inception and an anticipated increased use of customer feedback to improve customer service.

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.

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.”

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