0188GenericClearance_SS_Part A FINAL

0188GenericClearance_SS_Part A FINAL.docx

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

OMB: 3133-0188

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Paperwork Reduction Act Information Collection Submission

SUPPORTING STATEMENT
Generic Clearance for the Collection of Qualitative Feedback

on Agency Service Delivery

3133-0188

2015

Part A



  1. JUSTIFICATION


  1. Necessity of Information Collection

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 National Credit Union Administration (NCUA) is proposing to revise the OMB approval of its 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 NCUA 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 NCUA’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 NCUA and its customers and stakeholders. It will also allow feedback to contribute directly to the improvement of program management.


NCUA 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;

  • 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, NCUA 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:

  • 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); and

  • Usability testing (e.g., website or software usability tests).

NCUA 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.


  1. 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. NCUA 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 NCUA’s services will be unavailable.




  1. Consideration Given to Information Technology

To the extent feasible, NCUA will collect information electronically and/or use online collaboration tools to reduce burden.


  1. Duplication

No similar data are gathered or maintained by NCUA or are available from other sources known to NCUA.


  1. Effect on Small Entities

Small businesses or other small entities may be involved in these efforts. The burden on these entities as a result of the information collections approved under this clearance will be minimized by sampling, asking for readily available information, and using short, easy-to-complete information collection instruments.


  1. Consequences of Not Conducting Collection

Without these types of feedback, NCUA will not have timely information to adjust its services to meet customer needs.


  1. Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

There are no special circumstances. This collection is consistent with the guidelines in 5 CFR 1320.5(d)(2).


  1. Consultations Outside the Agency

Notice and request for comments was published in the Federal Register on January 22, 2015 (80 F.R. 3255) and on May 18, 2015 (80 FR 28305). No public comments were received.


  1. Payment or Gift

NCUA will not provide payment or other forms of remuneration to respondents.

  1. Confidentiality

No assurance of confidentiality is provided.

  1. Sensitive Questions

No questions of a sensitive nature are asked.


  1. Burden of Information Collection

A variety of instruments and platforms will be used to collect feedback from respondents, including web- and paper-based surveys or feedback forms, web-based polls or other interactive responses, comment cards, focus groups and social media. The response time will vary per form. The annual burden hours requested (42,715) are based on the number of collections we expect to conduct over the requested period for this clearance.




  1. Costs to Respondents

There are no costs anticipated for this collection.


  1. 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.


  1. Changes in Burden

This amendment proposes to increase the hours available to obtain feedback on services provided by NCUA offices, in addition to the office that was the subject of the generic information collection submission to OMB in 2014. NCUA anticipates that additional offices within NCUA will use a variety of methods to garner qualitative customer and stakeholder feedback, including, but not limited to, web and paper-based surveys or feedback forms, web-based polling or other interactive responses, comment cards, social media, focus groups, small discussion groups, and usability testing. These collections will allow for ongoing, collaborative, and actionable communications between more offices within NCUA and their customers and stakeholders. This will allow additional feedback in more areas to contribute directly to the improvement of program management.


  1. Information Collection Planned for Statistical Purposes

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 NCUA does not intend to publish its findings, NCUA may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests) and, if so, will follow the requirements under those rules.


  1. Approval to Omit OMB Expiration Date

NCUA is not seeking approval to omit the expiration date.


  1. Exceptions to Certification for Paperwork Reduction Act Submissions

This collection complies with the requirements in 5 CFR 1320.










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