Supporting Statement for OMB Collection 1660-0059,clean

September 17, 2015

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0059

Title: National Flood Insurance Program Call Center and Agent Referral Enrollment Form

Form Number(s): FEMA Form 517-0-1; FEMA Form 517-0-1 (Electronic Version); FEMA Form 512-0-1

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.

Under the Flood Disaster Protection Act of 1973, Section 2(a)(6), 42 U.S.C. 4002(a)(6), Congress finds it is in the public interest for persons already living in flood prone areas to have an opportunity to purchase flood insurance and access to more adequate limits of coverage to be indemnified for their losses in the event of future flood disasters. To this end, FEMA established and carries out a National Flood Insurance Program (NFIP), which enables interested persons to purchase insurance against loss resulting from physical damage to or loss of real or personal property arising from any flood occurring in the United States. 42 U.S.C. 4001. In carrying out the NFIP, FEMA operates a call center, which operates in conjunction with the FloodSmart Web site (www.FloodSmart.gov). Together these methods of marketing outreach provide the mechanism for current and potential policyholders to learn more about floods and flood insurance, contact an agent or assess their risk. The information collected from callers/visitors is used to fulfill requests for published materials, e-mail alerts, policy rates, and agent contact information.

Additionally, FEMA and the NFIP offer resources for agents through Agents.FloodSmart.gov. Upon registering for the site, agents can enroll in the Agent Referral Program to receive free leads through the consumer site or the call center as outlined above. This information collection seeks approval to continue collecting name, address and telephone number information from: a) business and residential property owners and renters who voluntarily call to request flood insurance information and possibly an insurance agent referral and, b) insurance agents interested in enrolling in the agent referral service.

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.

The information collection serves two purposes: 1) FEMA Form 512-0-1, National Flood Insurance Program Agent Referral Questionnaire allows the NFIP to service requests for flood insurance information or agent referral services from potential purchasers. Should the request include an insurance agent referral, the name and business addresses of insurance agents in the caller’s geographic area, who are enrolled in the referral service, are provided. 2) FEMA Form 517-0-1, National Flood Insurance Program Agent Referral Questionnaire allows insurance agents to enroll in the Agent Referral Program. When an agent receives a referral, information about the interested consumer is forwarded to the agent.

Information about the number of calls received and how many calls result in a lead as well as the origin of the calls received will be utilized to measure the activity of the Call Center and the overall effectiveness of the marketing program.

In addition, names and addresses obtained through this information collection are compared against the overall policyholders file for one year after the call is made to track conversion of calls/leads into sales.

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.

Respondents interested in purchasing flood insurance have the option to electronically complete FEMA Form 512-0-1 online at the Flood Smart Website (www.FloodSmart.gov). There isn’t an actual paper type form that can be completed online and faxed, for instance. The form 512-0-1 is an electronic “form” that is imbedded in the FloodSmart website itself. Property owners interested in purchasing NFIP flood insurance complete the “form” and hit the submit button and a list of local insurance agents and their contact information is immediate provided, still on the website. The screenshot provided is the “form” completed by as described above.

Approximately 50 percent of the respondents for whom this form is completed choose to do so themselves online. Respondents enter the required information, and they receive a listing of insurance agents in their area who can assist them with purchasing flood insurance. The other 50 percent of respondents for whom the form is completed choose to contact the NFIP Call Center via a toll-free number by providing the same information to a call center representative to receive a list of insurance agents servicing their area and/or request a brochure be mailed to them.

The collection of information from insurance agents interested in enrolling in the agent referral service, 95 percent will do so via an online registration process using FEMA Form 517-0-1, National Flood Insurance Program Agent Site Registration. However Agents sometimes fax FEMA form 517-0-1 to the FEMA program office.

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.

This information is not collected in any form, and therefore is not duplicated elsewhere.



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.

This information collection does not have an impact 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.

FEMA would be unable to sell flood insurance due to the inability to sign up insurance agents for the program. FEMA would be unable to receive requests from the public for information on flood insurance and to provide insurance purchase referral information to those individuals.

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

The special circumstances contained in item 7(a) thru 7(h) of the supporting statement are not applicable to this information collection.

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.



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 May 28, 2015, 80 FR 30482. No comments were received. See attached copy of the published notice included in this package.

A 30-day Federal Register Notice inviting public comments was published on September 4, 2015, 80 FR 53553. No comments were received. See attached copy of the published notice included in this package.

 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.

The FEMA Mitigation Division, Risk Insurance maintains routine contact with the contractors managing the NFIP Referral Call Center, Palm Coast Data, to assess operations and identify needed changes or updates to improve efficiency and effectiveness. LeapFrog Solutions Inc., the prime contractor for FloodSmart, and Palm Coast Data routinely monitor calls to the NFIP Referral Call Center to ensure consumers are receiving good customer services and accurate transfers to agents or other FEMA departments as necessary. Calls are no longer monitored live, but recorded and then reviewed by FEMA and the contractor responsible for quality assurance.

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.

After the initial collection of data, FEMA does not contact the consumer again regarding FEMA Form 512-0-1.

FEMA performs an outbound call process to agents who receive a prospective insurance sales lead as part of the referral program, FEMA Form 517-0-1. This call allows for information to be gathered regarding the status of the insurance sale as well as allowing for feedback from the insurance agent regarding the program. There is 1 follow-up per referral. However, depending on the number of referrals an agent receives, FEMA may contact the agent several times through the year.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

Calls to the Call Center and enrollment in the Agent Referral Program are strictly voluntary; therefore it is the respondent’s decision to use this resource. Callers can refuse participation at any time by terminating the call or refusing to provide the information. No caller information will be transferred or shared with an agent without the explicit consent of the caller. In addition, callers have the option to call their own insurance agent or look for an agent without FEMA’s assistance.

Names, addresses and telephone numbers collected will be used exclusively for providing information on flood insurance and/or facilitate its purchasing through the agent referral service. The data is strictly for internal use shared by managers and contractors directly involved in marketing activities of the NFIP to monitor sales increase and retention of flood insurance policies.

Callers’ names, addresses and telephone numbers will be entered in a secured database used exclusively by NFIP staff and contractors involved in the marketing effort. Callers’ names will be compared against official agency lists of current policyholders for a year (following the initial call) with the sole purpose of identifying whether the call generated additional policy sales. No other identification of individual respondents in conjunction with other data elements will be conducted.

Direct access to the database server is permitted only to system administrators and the application server and direct database access is provided only to DHS system administrators at CSC/NVITS. A firewall will be in place to separate the web server from the application and database server. To minimize the risk of unauthorized access, the system employs an n-tier architecture separating presentation, logic, and data on separate servers.

A Privacy Threshold Analysis (PTA) was completed by FEMA and adjudicated by the DHS Privacy Office on December 12, 2013.

This collection is covered by an existing Privacy Impact Assessment (PIA), DHS/ALL/PIA-006 Department of Homeland Security General Contact Lists, approved by DHS on June 15, 2007. The existing System of Record Notice (SORN) is DHS/ALL-002 - Department of Homeland Security (DHS) Mailing and Other Lists System, 73 FR 71659; and DHS/ALL-004 - General Information Technology Access Account Records System (GITAARS), 77 FR 70792.

There are no assurances of confidentiality provided to the respondents for this information collection.

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 are no questions of a sensitive nature.

 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.

FEMA Form 512-0-1, National Flood Insurance Program Agent Referral Questionnaire – The number of individuals and households responding to this data collection activity is 50,894 responses. It is estimated that 40 percent (30,536) will use the call center and 60 percent (20,358) will use the online internet service when seeking information on flood insurance. The frequency of calls to the center or visits to the Website per respondent is once, and the estimated time to gather the information from the respondent is .05 hours (3 minutes). Therefore, the estimated burden for this collection is 2,545 hours.

FEMA Form 517-0-1, National Flood Insurance Program Agent Site Registration – The number of insurance sales agents responding to this data collection activity is 8,300 responses. This represents the number of new insurance agents who will seek to become associated with the agent referral database for flood insurance. The frequency of this data collection is once annually, and the estimated time to gather this information is .033 hours (2 minutes). Therefore; the estimated burden for this collection is 274 hours.

 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.

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.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
Individuals or households	NFIP Agent Referral Questionnaire / FEMA Form 512-0-1	50,894	1	50,894	0.05 (3 mins.)	2,545	$22.33	$56,830
Businesses or other for-profit	NFIP Agent Site Registration (Including electronic version) / FEMA Form 517-0-1	8,300	1	8,300	0.033 (2 mins.)	274	$30.58	$8,379
Total		59,194		59,194		2,819		$65,209

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

According to the U.S. Department of Labor, Bureau of Labor Statistics Website (www.bls.gov) the wage rate category for “all occupations” (for individual our household respondents) is estimated to be $22.33 per hour, including the wage rate multiplier, therefore, the estimated burden hour cost to respondents “all occupations” is estimated to be $56,830 annually.

For the second group of respondents, according to the U.S. Department of Labor, Bureau of Labor Statistics Website (www.bls.gov) the wage rate category for “Insurance Sales Agents” is estimated to be $30.58 per hour, including the wage rate multiplier, therefore, the estimated burden hour cost to “Insurance Sales Agents” is estimated to be $8,379 annually.

The total estimated burden hour cost to respondents is estimated to be $65,209.00 annually.

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.)

There are no recordkeeping, capital, start-up or maintenance costs associated with this information collection.

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.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs The contract with the Call Center is time and materials so we are using an estimation of $30,000 per month and $360,000 per year.	$360,000
Staff Salaries* [1-GS 13.6 spending approximately 5% of time annually 104 hours @ 57.21per hour =5,949.84; 1-GS 14.6 spending approximately 1.2% of time annually 25 hours @ 71.48= $1,787	$7,736.84
Facilities [cost for renting, overhead, etc. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel (twice a year to call center)	$5,000
Printing [25,015 pieces at $.59 each]	$14,758
Postage [25,015 pieces mailed for $19,446] Postage is based on bulk rate of 500 pieces per mailing	$19,446
Other
Total	$406,941

* 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 a 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.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
NFIP Agent Referral Questionnaire / FEMA Form 512-0-1				2,545	2,545	0
NFIP Agent Site Registration (Including electronic version) / FEMA Form 517-0-1				190	274	+84
Total(s)				2,735	2,819	+84

Explain:

For FEMA Form 517-0-1, the increase in agent enrollment is attributed to recent trends as well as an expected increase in agent acquisition efforts. There has been no change in the information being collected.

For FEMA Form 512-0-1, there is no change in burden or the data collection itself. However, talking points for the call center have been updated to provide clearer direction for transferring calls to other departments and better customer service to the consumer.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
NFIP Agent Referral Questionnaire / FEMA Form 512-0-1				$54,336	$56,830	+$2,494
NFIP Agent Site Registration (Including electronic version) / FEMA Form 517-0-1				$5,711	$8,379	+$2,668
Total(s)				$60,047	$65,209	$5,162

Explain:

The annual burden cost has since increased due to an increase in wage statistics (according to the U.S. Department of Labor, Bureau of Labor Statistics Website) as well as an overall increase in respondents to FEMA Form 517-0-1.



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.

FEMA does not intend to employ the use of statistics or the publication thereof 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.

FEMA will display the expiration date for OMB approval of this information collection.



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

FEMA does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.



There is no statistical methodology involved in this collection.

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