SUPPLEMENTAL
SUPPORTING STATEMENT B
E-VERIFY DATA COLLECTIONS: 2015 SURVEY OF E-VERIFY EMPLOYERS
OMB Control No.: 1615-0127
B. Collection of Information Employing Statistical Methods
We are proposing to use statistical methods for our National Survey of E-Verify Employers, as described in Sections B.1-B.3.
The target population of the National Survey of E-Verify Employers includes all firms that signed a Memorandum of Understanding (MOU) before March 31, 2015 in which they agreed that all or part of the firm would participate in E-Verify. The following companies will not be included in the study:
Companies with no recent involvement in E-Verify. Recent involvement is defined as having taken an action (signing an MOU, submitting cases to E-Verify, or formally terminating participation in the Program) within the six months between October 1, 2014, and March 31, 2015. Excluding companies with no recent involvement in E-Verify helps to ensure that company representatives can accurately recall aspects of their participation and also avoids the possibility of companies responding to a program characteristic that has recently changed.
E-Verify Employer Agents (EEAs) and their clients will be excluded because a 2010 case study revealed extensive variations among the characteristics, operations, and experiences of EEAs and their clients that would be difficult to capture in an online survey.
Employers in Puerto Rico, Guam and other U.S. territories will be excluded primarily for pragmatic reasons (e.g., different time zones require telephone interviewers to follow-up at impractical times, some language barriers). Since this is a very small segment of the employer population, their exclusion should not result in a significant coverage problem.
Employers that participated in the pretesting of the 2015 survey instrument. To minimize response burden, we will exclude these employers from the survey.
The sampling frame will be developed from three databases provided by the contractor responsible for E-Verify operations.
Employer Database containing information provided by employers at the time they registered for E-Verify and any subsequent modifications the employers may have made to the information. The records contain the following fields needed for sample selection: employer name; North American Industry Classification System (NAICS) code; the company’s “parent company”; the number of sites covered by the MOU and the date the employer signed the MOU; and, where relevant, the date the employer terminated participation in E-Verify.
Point of Contact database which contains contact information associated with employers that have enrolled in E-Verify linked to the Employer Database through unique employer IDs
Transaction database which contains information on case submissions to E-Verify, including date of case initiation, ID of the employer submitting the case, and the dates and types of subsequent case actions
The data file to be used for sample selection will be created using the following procedures:
Contact information from the Point of Contact file will be appended to the appropriate employer records;
Unique records will be compiled at the firm level based on the information in the Employer Databases, since the sampling units will be single location companies (a business establishment with no branches or subsidiaries reporting to it) and the headquarters of the companies that have multiple branches. Most of these will be identified as companies without “parent companies” in the employer database. In cases in which it appears that employers may be branch companies of larger companies without a specified parent company (e.g., when there are large numbers of employers with the same name that have not specified a parent company), information will be obtained through Web searches and/or telephone inquiries to determine the appropriate firm level information1;
The Transaction Database will be purged of duplicate records and records that the employer indicates were “submitted in error” (typically records with typographical errors detected by employers after submission);
An outcome variable will be calculated from the Transaction Database information to indicate the final outcome of the case such as immediately found work authorized, found work authorized after a Tentative Nonconfirmation (TNC), etc.
Information on the number of transactions and the number of cases receiving a TNC in this database will be aggregated by employer and appended to the records in the employer file.
Ineligible cases (as defined above) will be excluded from the sampling process.
We plan to select a total sample of approximately 3,700 E-Verify employers for the survey—a number that should provide approximately 2,800 completed surveys based on our experiences with the 2010 and 2013 surveys. This estimate assumes 8 percent of sampled cases are excluded because the intended respondent is ineligible for inclusion and a survey response rate of approximately 80% of eligible respondents.
We propose to stratify the sample based on employer’s E-Verify status as follows.
Active Employers with TNCs: employers that had transmitted one or more cases receiving a TNC between January 1 and March 31, 2015, and had not formally terminated participation in the program before April 1, 2015. These employers are of great interest to policy makers concerned with discrimination and compliance because many of the E-Verify procedures, including many procedures designed to prevent discrimination, are only relevant for employers that have TNC cases. Since experiencing TNCs is relatively rare for companies, creating a separate stratum will help to ensure that a sufficient number of such companies are in the sample to provide reliable estimates.
Active Employers without TNCs: employers that had transmitted one or more cases between January 1 and March 31, 2015, had no cases receiving a TNC, and had not formally terminated participation in the program before April 1, 2015. These employers may well have different experiences from those active employers with TNCs, and these differences may impact both their satisfaction and compliance with E-Verify procedures. Thus, it is not possible to assume that the employers with TNCs are representative of those without TNCs, making the creation of a separate stratum helpful in ensuring that a sufficient number of such companies are in the sample to provide reliable estimates.
Inactive Employers: employers that had signed an MOU to participate in the E-Verify program between July 1 and September 30, 2014, but had not transmitted any cases, or had formally terminated participation in the program between October 1 and March 31, 2015. The insights from these employers are vital to understanding why some employers do not find E-Verify beneficial. Because they are asked a number of questions not asked of active employers, it is important that we have a sufficiently large sample of inactive employers to permit meaningful analyses of the unique questions asked of them.
We further propose dividing each of the above E-Verify status groups into three groups based on the following employer industry classification:
Staffing agencies, i.e., employment agencies and temporary help services. These employers have some experiences and needs that are known to differ from many other employers because of their need to satisfy their clients.
Industries (e.g., hospitality services and food processing) known to have relatively large percentages of undocumented workers.2 The experiences of these employers differ significantly from other employers because participation in E-Verify is relatively likely to affect their ability to attract low-salaried workers.
Other industries. The remaining industries represent the largest industrial subgroup of employers and needs to be a large enough to ensure that overall statistics are reliable.
Cross-classifying E-Verify companies by E-Verify status and industry provides a total of nine strata. These strata, their estimated population sizes (including ineligible cases that cannot be identified prior to sample selection), and proposed sample sizes are included in Table B-1. This table is based on the most recent transaction data that we have, as of May 22, 2013. We will use more recent transaction data in May 2015 to select the sample for the study and we will submit an updated table at that time.
Active/ In- active |
Industry |
Popul-ation |
Sam- ple draw |
Expected eligibility rate (%) |
Expected number of eligible companies |
Expected res- |
Expected/ Desired number of completes |
Per- cent sampled |
Active (TNCs) |
Staffing Agencies |
345 |
258 |
92 |
238 |
80 |
190 |
74.8 |
High percent undocumented workers |
2,492 |
751 |
94 |
706 |
85 |
600 |
30.1 |
|
Other industries |
4,823 |
751 |
94 |
706 |
85 |
600 |
15.6 |
|
Active (No TNCs) |
Staffing Agencies |
275 |
225 |
92 |
207 |
82 |
170 |
81.9 |
High percent undocumented workers |
12,376 |
496 |
96 |
476 |
84 |
400 |
4.0 |
|
Other industries |
34,855 |
468 |
96 |
449 |
89 |
400 |
1.3 |
|
Inactive |
Staffing Agencies |
5 |
5 |
82 |
4 |
70 |
3 |
100.0 |
High percent undocumented workers |
2,155 |
436 |
82 |
357 |
70 |
250 |
20.2 |
|
Other industries |
5,324 |
372 |
85 |
316 |
79 |
250 |
7.0 |
|
Total |
62,650 |
3,762 |
92 |
3,460 |
83 |
2,863 |
6.0 |
|
Notes: Data included in the table are based on information for E-Verify employers as of May 22, 2013. This table will be updated with more recent transaction data in May 2015. The estimates in this table assume that 65 percent of selected cases are eligible employers that respond to the survey (i.e., 20 percent of employers are ineligible and the response rate is 80 percent among eligible respondents).3 Classification of industries by percent undocumented is based on the most recent industry data available at the time this table was created: Jeffrey S. Passel, Senior Demographer, Pew Hispanic Center, and D'Vera Cohn, Senior Writer, Pew Research Center, A Portrait of Unauthorized Immigrants in the United States, 4.14.2009 (http://pewhispanic.org/reports/report.php?ReportID=107). If available, updated data will be used when drawing the survey sample.
Within strata, we propose using probability proportional to size (PPS) sampling, where the square root of the number of transactions submitted between January 1 and March 31, 2015, is the measure of size (MOS) for active E-Verify employers without TNCs and the cube root of the number of employees is the measure of size for inactive employers. PPS sampling to transactions/number of employees/TNCs would be very efficient for making estimates at the transaction/worker/TNC level, while equal probability would be very efficient for making inferences about the characteristics of companies. The proposed PPS sampling provides a good compromise between the two objectives.
The sample design will generate a national probability sample of employers that have enrolled in E-Verify. The survey will utilize a stratified random sample design.
The following data collection approach will be used for the survey of E-Verify employers to collect self-reported data on employers’ experiences with E-Verify. Employers will be asked about their verification procedures, opinions on employment verification, and possible improvements to E-Verify. The statistical methodology for stratification and sample selection of employers was described in Section B-1.
The sampling strategy used will result in unequal selection probabilities for the companies. We therefore will create statistical weights based on the selection probabilities to produce nationally representative statistics. In addition, we will examine the strata for differential rates of response and will statistically adjust for nonresponse, as needed, to provide nationally representative statistics. The analyses will use the final weights adjusted for nonresponse.
Standard statistical software will not produce correct variance estimates when complex sampling schemes are used. We will add replicate weights to the analysis file and use WesVarPC to produce appropriate variance estimates.
To minimize nonresponse, the U.S. Citizenship and Immigration Services (USCIS) contractor will devote considerable resources to developing and implementing approaches likely to achieve good respondent cooperation with the National Survey of E-Verify employers. We expect high levels of cooperation with the evaluation among employers that have enrolled in E-Verify, based on the completion rates for the 2013 survey of employers which obtained an overall unweighted survey response rate of 82 percent and a weighted response rate of 84 percent. These employers have signed MOUs with the Department of Homeland Security (DHS) and have agreed to respond to DHS and Social Security Administration (SSA) designees’ inquiries about E-Verify. Specifically, the MOU states the employer’s responsibilities as follows:
“The Employer agrees to cooperate with DHS and SSA in their compliance monitoring and evaluation of E-Verify, which includes permitting DHS, SSA, their contractors and other agents, upon reasonable notice, to review Forms I-9 and other employment records and to interview it and its employees regarding the Employer’s use of E-Verify, and to respond in a prompt and accurate manner to DHS requests for information relating to their participation in E-Verify.”
The techniques that will be used to ensure high response rates are:
(1)
Pre-testing. Much of
the 2015 questionnaire is based directly on the 2013 Survey of
E-Verify Employers, and thus has been tested through both
pretests and full data collections. Knowledge obtained from
conducting the previous surveys was used to modify the 2015 survey,
including a review of data issues from the previous survey, a review
of responses to open-ended items, a review of the frequencies of the
2013 survey (to identify items lacking sufficient variation or a
sufficient number of responses to be useful), and a review of items
that were not reported in 2010 or 2013. Based on this extensive
review, several survey items have been deleted making the
questionnaire less time consuming to complete. In addition, questions
were added based on feedback from USCIS program administrators
regarding new program features.4
These items replaced some of the questions examining the
implementation of features that were new at the time of the 2013
survey. In addition, in February and March of 2015 we will conduct
online focus groups to examine the 2015 questionnaire, focusing
particularly on items that are new or that have been modified from
2013.5
(2) Motivational material. Information about the E-Verify data collection will be placed on a Web site to be accessed by employers that wish to obtain additional information about the evaluation. Continued care will be taken in the final production of survey materials to:
Create a professional image for the study;
Emphasize the importance of participation towards shaping future directions in Federal immigration policy;
Emphasize the steps that will be taken to ensure respondent privacy; and
Use language appropriate for the target population.
(3) Aggressive follow-up. One of the major factors that increases study response rates is the use of extensive follow-up procedures to gain cooperation with the study. The 2015 National Survey of E-Verify Employers, therefore, includes multiple contacts with selected respondents. More specifically, the data collection procedures consist of the following steps:
A personalized pre-notice letter will be sent to all individuals identified as primary contact persons in USCIS materials. This letter will be from USCIS (Attachment B) and will state that this is part of the evaluation effort the employers authorized when they signed the MOU. The letter will stress both the importance of participation to future employment verification efforts and the fact that USCIS will only use the information for research purposes.
A personalized email will be sent to all contact persons reiterating the importance of the study and providing information on how to log on to the Web site (Attachment C).
At the same time that the emails from Westat are sent out, a “news” message will be placed on the Web site that employers use when verifying employees through E-Verify. It will indicate that the evaluation has started, provide a link to a Web page with additional information about the study, and ask employees who received a survey request to complete the survey.
If the email results in a response indicating the email address is no longer valid, an email will be sent to the alternate contact person, if any.
If no email is provided for the primary contact person or if there is no alternate contact person for a non-valid email address, phone interviewers will research the company’s contact information online to identify a staff person in Human Resources or a similar office who might be knowledgeable about the appropriate contact person.
If calling the Human Resources Department does not result in identifying the correct contact person, a phone interviewer will call the main number of the company to determine who is the correct contact person and, if possible, obtain the name and contact information for an alternate person who will be responsible for the study, if the primary contact person is not available. The phone interviewers will also collect information on important changes in status among the contacted companies to determine if they are out of scope for the study (e.g., the employer now uses an E-Verify Employer Agent to perform all verifications).
A reminder email will be sent to contact persons approximately one week after the initial contact and a second banner message will be placed on the verification Web site at that time.
Approximately two weeks after the reminder email, a second reminder e-mail will be sent to non-respondents.
Approximately two weeks following the second reminder e-mail, phone interviewers will contact non-respondents. Reasons for nonresponse will be requested and participation will be encouraged. If necessary, reluctant respondents will be reminded of the MOU in which the employer had agreed to participate in the evaluation. Information on how to access the survey Web site will be provided, if necessary.
A second phone reminder will be made approximately two weeks after the first phone reminder. At that time, the interviewer will offer to send a hard copy survey if the respondent prefers to answer in this fashion. Again, nonrespondents will be reminded to complete the survey and will receive specific log-in instructions, if necessary.
If necessary, a final contact will be made approximately two weeks after the second phone reminder. The non-respondents will be sent, via Federal Express, another cover letter, log-in information to access the survey Web site, and a hard copy survey. In addition to the above contacts, a thank you email will be sent to respondents that complete the survey.
While the survey data collection is in process, Westat will maintain a help desk (using a toll free telephone number) that companies may call to ask questions about both the mechanics of the survey (such as how to access the survey and enter responses) and the survey content (e.g., if employers are uncertain of the meaning of a particular question).
(4) Training. All individuals working on the study are experienced callers who have worked on earlier versions of the survey. All callers who will be in contact with potential respondents by phone or email will be trained in ways to optimize response without placing undue pressure on potential respondents. In addition to general survey procedures, they will be trained to respond to specific questions that are likely to be raised in this study. This training will include help desk personnel as well as telephone interviewers.
(5) Nonresponse conversion. Experienced interviewers who are particularly skilled and successful in nonresponse conversion will re-contact initial refusals. The major exception to this rule is for hard refusals (i.e., sampled companies who have requested not to be called again).
(6) Unit nonresponse adjustments. Weights will be used to adjust for nonresponse within cells identified by key variables known prior to sample selection (industry, location, and number of verifications).
(7) Editing and data cleaning. A number of editing features will be built into the Web survey. For example, if the respondent attempts to provide multiple answers to a question requiring a single response, the respondent will be asked to select only one response. Additional editing checks will be done subsequent to survey completion to check for completeness, inter-item consistency, extraneous remarks, and, for respondents completing a mail survey, proper adherence to any skip instructions.
(8) Item nonresponse adjustments. Although our procedures are designed to maximize item response rates, the analysis will need to confront the issue of missing data. Experience with previous surveys indicates that some respondents will omit responses to some specific items (e.g., sensitive items), although they may have provided most of the data required. By employing good survey data collection practices, we expect to minimize the amount of missing data on any single variable to a very low level. However, if item nonresponse is unexpectedly high for any of the key analytic variables, hot deck imputation techniques will be used to estimate missing-item values.
For analyses involving just one or two variables that have not been subject to imputation, we will handle the problem by omitting the cases with missing data, or, in the case of categorical response variables, we will use an explicit “missing” or “unknown” category. When multivariate techniques involving several variables are used, analytic techniques for missing values will be used (such as using the variable mean or adding a dummy variable to reflect how the nonrespondents differ from the other companies).
The employer survey instrument submitted in this request for clearance was well pre-tested during prior evaluations. Some changes have been made to accommodate the differences in programs and scope compared to the previous employer data collection activities. New questions will be explored with employers during a series of focus groups.
The following statisticians were consulted on the statistical aspects of the design and analysis of the current study:
Huseyin Goksel, Statistician
Westat
1600 Research Blvd.
Rockville, MD 20850
301-251-4395
Atsushi Miyaoka
Westat, E-Verify Transaction Database Analyst
1600 Research Blvd.
Rockville, MD 20850
301-610-4948
Carolyn Shettle
Westat Consultant and Prior E-Verify Project Director
The following individuals will collect and/or analyze data for the current study:
Basmat Parsad, Senior Survey Manager
Westat
1600 Research Blvd.
Rockville, MD 20850
301-251-8222
Denise Glover, E-Verify Project Director
Westat
1600 Research Blvd.
Rockville, MD 20850
301-251-2269
1 The Employer Database contains a mix of establishments and firms because of the E-Verify enrollment procedures.
2 Information on the percent of undocumented workers is based on information in Jeffrey S. Passel, Senior Demographer, Pew Hispanic Center, and D'Vera Cohn, Senior Writer, Pew Research Center, A Portrait of Unauthorized Immigrants in the United States, 4.14.2009 (http://pewhispanic.org/reports/report.php?ReportID=107).
3 Twenty percent of employers were ineligible in the 2010 data collection because they were no longer in business, were duplicate listings of a company, or were EEAs or clients of EEAs (two groups of employers that were excluded from the study).
4 A full description of new and deleted items for the 2015 survey is provided in Supplemental Statement B.
5 We have submitted a generic OMB package to pretest the 2015 instrument on 30 employers that use E-Verify.
B-
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPLEMENTAL SUPPORTING STATEMENT B |
| Author | S. Tarragon |
| File Modified | 0000-00-00 |
| File Created | 2021-01-25 |