Supporting Statement 1660-0107_Part A

January 26, 2021

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 -0107

Title: FEMA Public Assistance Customer Satisfaction Survey

Form Number(s): FEMA Form 519-0-1 T, Public Assistance Customer Satisfaction Survey (Telephone); FEMA Form 519-0-1 INT, Public Assistance Customer Satisfaction Survey (Internet); FEMA Form 519-0-1, Public Assistance Customer Satisfaction Survey (Fill-able)

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary.

Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information. Provide a detailed description of the nature and source of the information to be collected.

The following legal authorities mandate the collection of the information in this request:

The September 11, 1993 Executive Order 12862, “Setting Customer Service Standards,” and its March 23, 1995 Memorandum addendum, “Improving Customer Service,” requires that all Federal agencies ask their customers what is most important to them, and survey their customers to determine the kind and quality of services the customers want and their level of satisfaction with existing services. The 1993 Government Performance and Results Act (GPRA) requires agencies to set missions and goals, and measure performance against them.

The E-Government Act of 2002 includes finding innovative ways to improve the performance of governments in collaborating on the use of information technology to improve the delivery of Government information and services.

The GPRA Modernization Act of 2010 requires quarterly performance assessments of Government programs for purposes of assessing agency performance and improvement, and to establish agency performance improvement officers and the Performance Improvement Council. Executive Order 13571 “Streamlining Service Delivery and Improving Customer Service” and its June 13, 2011 Memorandum “Implementing Executive Order 13571 on Streamlining Service Delivery and Improving Customer Service” sets out guidelines for establishing customer service plans and activities; plus it expands the definition of customer and encourages the use of a broader set of tools to solicit actionable, timely customer feedback to capture insights and identify early warning signals..

On January 29, 2013, President Obama signed into law the Sandy Recovery Improvement Act of 2013 (P.L. 113-2). This law amends Title IV of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.). Specifically, the law adds section 428, which authorizes the new Alternative Procedures for the Public Assistance (PA) Program under sections 403(a)(3)(A), 406, 407 and 502(a)(5) of the Stafford Act. It also authorizes the Federal Emergency Management Agency (FEMA) to implement the Alternative Procedures.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

FEMA’s mission is to support the citizens of the United States and first responders to ensure that as a nation we work together to build, sustain, and improve our capability to prepare for, protect against, respond to, recover from, and mitigate all hazards. FEMA uses the collected information to measure customer satisfaction, to meet objectives, gauge and make improvements to increase customer satisfaction.

This collection is the Public Assistance (PA) Customer Satisfaction Surveys, managed by the Recovery Directorate, through the National Processing Service Center Division, Customer Satisfaction Analysis Section (CSA) of the Federal Emergency Management Agency.

The purpose of the Public Assistance Customer Satisfaction Survey is to assess customer satisfaction with different processes and human performance aspects of FEMA’s Public Assistance Program and to improve the quality of service offered to the applicant from State, Local and Tribal government and eligible private Non-Profit organizations, who have been affected by a disaster and receive funding.

This collection of information enables FEMA Managers to garner customer feedback and satisfaction against standards for performance and customer service in an efficient, timely manner to help ensure that users have an effective, efficient, and satisfying experience with the Agency’s programs. This feedback will provide insights into customer 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. This collection 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.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

All survey responses are stored in the Customer Satisfaction Analysis System for easy retrieval, statistical analyses and reporting.  Collection techniques include phone interviews as well as electronic submission of responses.  The Public Assistance Customer Satisfaction Survey aligns with E-Government Act of 2002 and Executive Order 13571 of 2011 initiatives providing those who prefer electronic communications to complete and submit their survey responses electronically.   The Customer Satisfaction Analysis Section, who administers the surveys, has acquired new survey software that expands functionality and connectivity providing a means for reducing burden through transition to electronic distribution and submission of surveys.

Applicant organizations are contacted by telephone to respond to the FEMA Public Assistance Customer Satisfaction Survey and have a choice of responding via the phone call or an electronic internet link. Telephone and Internet submissions are expected to be 91.35% of this collection based on 81.63% telephone surveys plus 9.72% internet surveys. Other methods, which may also be used at the respondent’s request, that are not considered electronic, are emailing the fill-able form, and faxing or mailing a printed form. Non-electronic methods are expected to be 5.82% of this collection. Focus Groups will be 2.83% of the collection.

The link to this survey in electronic form is below:

Telephone and Internet:

1. FEMA Form 519-0-1T (Telephone) is used for making a phone call to the applicant organization to gather their survey responses by phone. All telephone responses are gathered electronically and are estimated to be approximately 81.63% of the whole collection.

2. FEMA Form 519-0-1INT (Internet) is used for completing the survey via a Internet link. All responses are submitted electronically and are estimated to be approximately 9.72% of the whole collection.

FEMA Public Assistance

Non Electronic:

1. FEMA Form 519-0-1 is used for completing the survey via a fill-able form with responses being submitted by email (4.86%), fax (.48%) or occasionally on paper through the mail (.48%) and collectively is estimated to be approximately 5.82% of the whole collection.

2. Focus Groups may be conducted through various methods; such as, as in-person group interviews, one-on-one interviews, and phone or video conferences. Focus groups are based on a discussion of what is most important to the customer and their communities and comprise 2.83% of the whole collection.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above. 

The information gathered in the survey is not available from any other source.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

There is no impact from this collection of information on small businesses or other small entities.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

If FEMA’s surveys were not conducted, the consequences would be the absence of documentation about customer input on the quality and timeliness of disaster survivor centric service. The survey results serve as a vital tool for measuring customer satisfaction and are a requirement of the Executive Orders 12682 and 13571, and resulting Memorandums for “Streamlining Service Delivery and Improving Customer Service.” The surveys also measure the effectiveness of the Administrator’s Strategic Plan and Intent based on the disaster survivor’s perspective.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

1. Requiring respondents to report information to the agency more often than quarterly.

 (b) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

3. Requiring respondents to submit more than an original and two

copies of any document.

3. Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.

3. In connection with a statistical survey, that is not designed to

produce valid and reliable results that can be generalized to the universe of study.

 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.

 (g) That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use.

 (h) Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

The special circumstances contained in item 7 of the supporting statement are not applicable to this information collection.

8. Federal Register Notice: 

 a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A 60-day Federal Register Notice inviting public comments was published on August 1, 2014, 79 FR 44818-44819)]. No comments were received.

A 30-day Federal Register Notice inviting public comments was published on October 30, 2014,79 FR 64610. No comments were received.

 b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Budget constraints have prevented FEMA from consulting with persons outside the agency.

Recovery Directorate and Public Assistance Program Managers were consulted for input about the data collected in the survey questionnaires and the reporting format. Also, research articles have been studied in an attempt to implement industry standard guidelines for the frequency of collection and the reporting format.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Budget constraints have prevented FEMA from consulting with Public Assistance applicants since FY2004 when FEMA’s Recovery Directorate contracted with a consultant to perform four focus groups to ensure that the information collected was meaningful to customers and the survey questions were clearly understood.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no payments or gifts to respondents for this data collection.

10. Describe any assurance of confidentiality provided to respondents. Present the basis for the assurance in statute, regulation, or agency policy.

A Privacy Threshold Analysis (PTA) was approved by the DHS Privacy office on January 10, 2014.

The collection is covered by the existing System of Records Notice (SORN), DHS/FEMA-009 Hazard Mitigation Assistance Grant Programs System of Records dated July 23, 2012 (Name will be changed to Hazard Mitigation, Public Assistance, and Disaster Loan Programs SORN) and a forthcoming DHS/FEMA Customer Satisfaction Analysis PIA, currently in draft.

11. Provide additional justification for any question of a sensitive nature (such as sexual behavior and attitudes, religious beliefs and other matters that are commonly considered private). This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There is no question of a sensitive nature such as sexual behavior and attitudes, religious beliefs and other matters that are commonly considered private in the surveys.

 12. Provide estimates of the hour burden of the collection of information. The statement should:

 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

The number of respondents is the universe of eligible Public Assistance applicant organizations who received assistance after a presidentially-declared major disaster. The estimate is based on a two year average of 12,380 eligible applicants per year with a two year average of 73 disasters declared per year from FY2011 through FY2012. The entities consist of approximately 81% local, state or tribal governments and 19% private non-profit organizations.

The total estimated respondents by survey instrument is based on the following: 10,399 for the phone survey, 1,238 respondents for the Internet survey, 619 respondents for the fill-able form survey sent and received by email, 62 respondents for the fill-able form survey sent by fax, 62 respondents for the survey form sent by mail, plus 360 focus group participants from the sample.

Estimated survey response time is 15 minutes for the phone survey with a skilled interviewer, 20-minutes per respondent for the Internet survey for the three fill-able survey methods, and 2 hours for the focus group plus 1 hour for round trip travel time to the session.

The total estimated annual burden is 4,341 hours based on following: 2,600 burden hours for the phone survey, 413 burden hours for the Internet survey, 206 burden hours for the fill-able form survey sent and received by email, 21 burden hours for the fill-able form survey sent by fax, 21 burden hours for the survey form sent by mail, and 1,080 burden hours for focus group participants.

 b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

Below is a description of the universe and hour burden by survey instrument:

FEMA Form 519-0-1T (Telephone) may be conducted and gathered by phone and all responses are collected electronically. The number of responses collected by phone is estimated to be 10,399 or approximately 81.63% of the whole collection with an hour burden of 2,600. It has been estimated to take 15 minutes for the applicant to complete the survey with a skilled interviewer.

FEMA Form 519-0-1INT (Internet) may be submitted through an internet link and all responses are collected electronically. The number of responses collected by internet link is estimated to be 1,238 or approximately 9.72% of the whole collection with an hour burden of 413. It is been estimated to take 20 minutes for the applicant to complete the survey.

FEMA Form 519-0-1 is a fill-able form that may be administered by one of three methods:

1) By email, as a fill-able form with responses collected by email. The number of responses collected is estimated to be 619 or approximately 4.86% of the whole collection with an hour burden of 206. It has been estimated to take 20 minutes for the applicant to complete the survey.

2) By fax after printing the fill-able form and completing the questionnaire. The number of responses collected by fax is estimated to be 62 or approximately .48% of the whole collection with an hour burden of 21. It has been estimated to take 20 minutes for the applicant to complete the survey.

3) By mail after completing the paper survey. The number of responses collected by mail is estimated to be 62 or approximately .48% of the whole collection with an hour burden of 21. It has been estimated to take 20 minutes for the applicant to complete the survey.

The estimated time of fifteen minutes for conducting a phone survey through an interviewer, versus a fillable form or the internet form of 20 minutes, is based to the following:

1. The experience of the interviewer asking the questions allows the survey to be completed in less time versus a person reading a questionnaire for the first time.

2. The interviewer leads the respondent through the questions which takes less time than the respondent having to read the instructions and follow along the form and mark the responses.

3. The survey tool is programmed to skip questions that are not applicable based on prior answers and the automated skips takes less time than the respondent having to read the questions and instructions for questions that would have been skipped.

4. The interviewer will read the disaster type, declaration date, state and disaster number that is being surveyed which will take less time than the respondent entering their responses to this general information. 

5. Time trails with experienced interview staff were used to provide a good faith estimate of the burden time of fifteen minutes to respond to the survey by phone.  The mail and internet survey burden time of twenty minutes were the same as approved in previous Information Collections.

Focus Groups will be conducted in person or possibly over the phone or over the internet. The number of participants/respondents is estimated to be 360 or approximately 2.83% of the whole collection with an hour burden of 1,080. The length of the focus group is estimated to be 2 hours and, if conducted in person, an additional 1 hour round trip travel time for a total of 3 hours.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.4 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.4 multiplier to reflect a fully-loaded wage rate.

“Type of Respondent” should be entered exactly as chosen in Question 3 of the OMB Form 83-I

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.4. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.4, and the entry for the “Avg. Hourly Wage Rate” would be $59.51.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for all workers in the Non-Profit professions is $23.34 per hour @ 1.4 multiplier = $32.68 per hour. Therefore, the estimated burden hour cost to respondents for Non-profit institutions is estimated to be $26,913.32.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for state and local officials based on all management occupations is $43.67 @ 1.4 multiplier = $61.14 per hour. Therefore, the estimated burden hour cost to respondents for State, Local or Tribal Government is estimated to be $215,098.59.

Therefore, the total annual respondent cost is $242,011.91.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

The cost estimates should be split into two components:

a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred.

b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.

Annual Non-Labor Cost for travel to Focus Groups is based on US General Services Administration (GSA) mileage rate for Privately Owned Vehicles (POV) effective January 1, 2013 at $0.565 per mile. Maximum travel to the Focus Group not to exceed 30 miles one way or 60 miles round trip. Total number of respondents estimated to be 360 for a total miles per round trip calculated at 60 * = 21,600 miles @ $0.565 per mile = $12,204.00 annual cost for mileage.

14. Provide estimates of annualized cost to the federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing and support staff), and any other expense that would have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

* Note: The “Salary Rate” includes a 1.4 multiplier to reflect a fully-loaded wage rate.

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A "Program increase" is an additional burden resulting from an federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Explain:

The burden change for the surveys gathered by various methods plus focus groups is a program change due to the inclusion of questions regarding the Sandy Recovery Improvement Act, along with an increase in the average number of disasters used to calculate the universe of respondents from 10,740 in the previous collection to 12,740 in this collection submission:

For FEMA Forms 519-0-1T (Telephone) annual hour burden increase of +1,025 is due to increase in preference for phone surveys.

For FEMA Form 519-0-1INT (Internet), the annual hour burden decrease at -112 is due to increased preference for phone surveys.

For FEMA Form 519-0-1, (Fill-able, sent by email) annual hour burden decrease -319 due to increased preference for phone surveys.

For FEMA Form 519-0-1, (Fill-able, sent by fax) annual hour burden decrease -154 due to increased preference for phone surveys.

For FEMA Form 519-0-1, (Fill-able, sent by mail) annual hour burden decrease -154 due to increased preference for phone surveys.

Focus Group burden hours increase of +360 is due to including all 10 Regions in the focus group plan instead of only 5 of the 10 Regions. This is based on holding 3 sessions in the 10 FEMA Regions with 12 participants at each session for a total of 360 participants who will spend approximately 2 hours each in attending the session and 1 hour each in round trip travel for a total of 3 burden hours for each participant.

Total Burden Hours: 3,261 for surveys + 1,080 for focus groups = 4,341 less 3,695 prior collection = 646 increase.

Explain: The total Increase of $106,082.83 is 1) due to an increase in the Hourly Wage Rate Per Hour from $29.06 in the prior Collection to $32.68 for Non- Profit Organization respondents and from $36.51 to $61.14 for State, Local and Tribal Government respondents in this Collection per the Department of Labor and 2) the following adjustments or changes:

The change in the cost for the surveys gathered by various methods plus focus groups is a program change due to the inclusion of questions regarding the Sandy Recovery Improvement Act, along with an increase in the average number of disasters used to calculate the universe of respondents from 10,740 in the previous collection to 12,740 in this collection submission, and wage increase:

For FEMA Forms 519-0-1T (Telephone) cost increase of +$88,530.95 is due to the preference for phone surveys and the wage increase.

For FEMA Form 519-0-1INT (Internet) cost increase of +$4,218.64 due to the wage increase but the hours decreased and therefore the cost due to the preference for phone surveys included above.

For FEMA Form 519-0-1, (Fill-able, sent by email) annual hour burden decrease -$7,280.86 due to increased preference for phone surveys with wage increase.

For FEMA Form 519-0-1, (Fill-able, sent by fax) annual hour burden decrease -$5,112.65 due to increased preference for phone surveys with wage increase.

For FEMA Form 519-0-1, (Fill-able, sent by mail) annual hour burden decrease -$5,112.65 due to increased preference for phone surveys with wage increase.

Focus Group cost increase of +$35,245.01 is due to including all 10 Regions in the focus group plan instead of only 5 of the 10 Regions. This collection is based on holding 3 sessions in the 10 FEMA Regions with 12 participants at each session for a total of 360 participants who will spend approximately 2 hours each in attending the session and 1 hour each in round trip travel with wage increase.

Total Cost Increase: $110,488.44

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

There are no outline plans for tabulation and publication of data for this information collection.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

This collection does not seek approval to not display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

This collection does not seek exception to “Certification for Paperwork Reduction Act Submissions.” :

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