Generic Clearance Memo

MEMORANDUM

MEMORANDUM TO:

Jennifer Park
Official of Statistical and Science Policy
Office of Management and Budget

THROUGH:

Lynn Murray
Clearance Officer
Justice Management Division
Christopher A. Nicholas
Section Chief
Law Enforcement Support Section
Federal Bureau of Investigation
Amy C. Blasher
Unit Chief
Crime Data Modernization
Federal Bureau of Investigation

FROM:

Cynthia Barnett-Ryan
Survey Statistician
Crime Data Modernization
Federal Bureau of Investigation

DATE:

October 6, 2016

SUBJECT:

Federal Bureau of Investigation (FBI) Request for Office
of Management and Budget (OMB) Clearance for
National Incident-Based Reporting System (NIBRS)
Program’s modernization study activities under the
OMB generic clearance agreement (OMB Number 11100057).

The Federal Bureau of Investigation (FBI) Crime Data Modernization (CDM) Team has begun its
modernization activities to prepare for the Uniform Crime Reporting (UCR) 2021 cutover from the
Summary Reporting System (SRS) to the National Incident-Based Reporting System (NIBRS), which will
add more statistical rigor to its data collection programs.
The NIBRS’s incident-based reporting provides specific details on crime including data about victims,
offenders, property, and arrests, along with information on each offense, depicting a comprehensive
view of crime and criminal activity. Having detailed information is powerful and helps dispel
misperceptions, foster accountability, and promote transparency in how law enforcement personnel are
relating to and supporting the diverse communities they serve.

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This request for approval, under the FBI UCR Generic Clearance (1110-0057) is for activities involved in
the collection of information on the modernization of the NIBRS, and the impact of the 2021 cutover
from SRS to the NIBRS on state, local, federal, and tribal law enforcement agencies, as well as external
stakeholders. These activities are estimated to require 118 burden hours.

Purpose of the Study
The FBI UCR Program is a nationwide, cooperative statistical effort of over 16,000 city, college and
university, county, state, tribal, and federal law enforcement agencies (LEAs) voluntarily reporting crime
data on offenses reported or known. Since 1930, the FBI has administered the UCR Program and
continues to assess and monitor the nature and type of crime in the nation. In addition to being one of
two national crime measures, the program’s primary objective is to generate reliable and valid
information for use in law enforcement administration, operation, and management.
The CDM initiative is an FBI Director’s Priority Initiative (DPI) to generate the pathway to greater crime
data collection and to improve the nation’s crime statistics for reliability, accuracy, accessibility, and
timeliness of the data through the transition of local, state, and tribal LEAs from the SRS to the NIBRS.
The outcome is to sunset the SRS and then replace it with the NIBRS, as the national standard for crime
reporting by 2021.
The purpose of the NIBRS modernization study is to ensure the NIBRS 2021 cutover is successful, to
gauge the technical readiness of the NIBRS, and to increase state, local, and tribal LEAs voluntarily
reporting crime data on offenses to the NIBRS.
Currently, approximately 30% of the crime data submitted to the FBI is in the NIBRS format. Although
several states are reporting 100% of their crime data in this format, there are many states which only
report part of their data in this format, and several states have not begun the transition to the NIBRS.
The modernization study will examine the “health of the NIBRS” and offer potential recommendations
to address challenges surrounding incident-based crime reporting and support technologies in order to
ensure representative reporting. The study will be performed by in-person visits and conference calls to
study participants which will determine the impacts of the NIBRS 2021 cutover on state, local, and tribal
agencies and external stakeholders; the technical readiness for the NIBRS 2021 transition; and provide
potential recommendations for post-2021 improvements to the NIBRS.

Background Research
The NIBRS modernization study team performed a comprehensive review of existing Department of
Justice (DOJ), FBI, and external stakeholder literature to assist in the development of questionnaire
material. The review examined previous crime reporting field assessments, surveys, and questionnaires.
Much of the information was collected from the questionnaires performed by the Bureau of Justice
Statistics (BJS), CDM Team, and their contractors as part of the National Crime Statistics Exchange
Program.
The NIBRS literature review was performed to ensure that the NIBRS modernization study’s field visits
incorporate previously obtained crime reporting information and leverages lessons learned from the
previous crime reporting questionnaires.
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From the literature review and working in concert with crime reporting subject matter experts, the
NIBRS modernization team developed a potential set or “universe” of potential questions that may be
asked during field interviews with NIBRS state, local, or tribal law enforcement agencies. The NIBRS
modernization study’s interviews will focus on three high-level NIBRS modernization assessment areas
related to: 1) the LEA’s crime reporting activities; 2) the LEA’s preparedness for the NIBRS 2021 cutover;
and 3) recommendations for the NIBRS improvements. The NIBRS universe of questions are the list of
potential questions asked to a participating LEA.
The NIBRS modernization study will work in concert with staff from other Federal agencies and
participation in working groups around the topic of crime data reporting. All efforts would be
collaborative in nature, and no duplication in this area is anticipated.

Selection of Participants
The NIBRS modernization study, working in cooperation with state UCR coordinators and CJIS Systems
Officers, will transmit an email (see attachment 2) inviting LEAs to participate in a NIBRS modernization
study. All participants will be volunteers and are self-selected by the LEA leadership.
Agencies will be selected based in part on their size and their current NIBRS reporting status. This
selection process will ensure that we will be able to ascertain the significance and impact of incidentbased crime reporting on small, medium and large agencies. For agencies that have not made the
transition to the NIBRS, we will be able to determine to potential concerns of the agencies. For agencies
that are already reporting NIBRS data, we will be able to determine their overall satisfaction with this
system. As the study progresses, interview participation may focus on a specific subset of organizations
that can provide relevant information related to key-issues or themes that are extracted during early
interviews. As a result, a specific minimum number of agencies in each category has not been
determined. The study does not include a statistical analysis of participation to determine significance.
The following methodology comprised of exploratory interviews and focus groups will be utilized for
interviews that are part of the NIBRS modernization study.

Participant Interview
The NIBRS modernization study participant interviews will be exploratory interviews and focus groups
covering three general areas: 1) the LEA’s crime reporting activities; 2) the LEA’s preparedness for the
NIBRS 2021 cutover; and 3) recommendations for the NIBRS improvements to boost participation. The
universe of questions (Attachment 3) will be used to gather information to be able to report on the
three general areas. With this approach, the study team will ensure that the study does not limit a
participant’s responses. The NIBRS universe of questions comprise the list of potential questions to be
asked of the respondent.

Group Interview
The NIBRS modernization study will interview LEA-oriented groups. Examples could include a group of
individuals working in the LEA’s crime reporting or information technology departments, or groups of
LEAs with similar challenges or concerns. Each group interview will be informal, but will cover the same

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three general areas as a participant interview. The interview will use questions from the universe of
questions (Attachment 3), but not follow a predetermined format to allow the interview to be
adaptable to the priorities of the LEAs. With this approach, the NIBRS study team will ensure that the
study does not limit a participant group’s responses.

Developmental Activity Procedures Language
All interviews and follow-up activities will be conducted in English.

Burden Hours for Developmental Activities
The estimated hour burden for the NIBRS modernization study’s participant and group interviews will
equal approximately 108 burden hours in 2016 and 10 burden hours for potential follow-up reinterviews in 2017. The study’s participant and group interview population is anticipated to need an
approximate total of 72 participants in 2016 and 10 participants in 2017. The estimated total burden
hours across 2016 and 2017 for all proposed NIBRS modernization study activities are estimated to be
118 hours.
The NIBRS modernization study participant and group interviews will be in-person and will primarily
occur at the participant or group’s LEA facilities. A portion of the interviews will occur in conjunction
with attendance at law enforcement conferences (e.g. International Association of Chiefs of Police,
Major City Chiefs of Police, and Association of State Uniform Crime Reporting Programs). As necessary,
the CDM Team will contact law enforcement agencies, UCR state coordinators, and crime reporting
stakeholders.

Table 1: Burden Estimate
Participant Interviews
Year

Participants

2016
2017
(possible reinterview)
3-Year

52

Hrs.
/Participant
1.5

10

1

62

Group Interviews

78

Group
Participants
20

Hrs.
/Participant
1.5

10

0

0

88

20

Hours

30

Total
Hrs.
108

0

10

30

118

Hours

This plan involves conduct of exploratory interviews with individuals at the various agencies. Depending
on the agency, it may be useful to also conduct additional focus groups with agency personnel. The
length of each participant or group interview will be determined by the size of the LEA and LEA staff
availability. As a result, the length of a study interview is not thoroughly known at this time. The
lengths of interviews will be planned and monitored closely and, as the study progresses, the most
critical elements within the study’s three themes will be prioritized to ensure consistency with the
burden estimate. By efficiently managing the scope of the interviews and utilizing best practices for
maintaining the course of the conversation, the estimated likely interview population for the NIBRS
modernization study’s interviews and potential re-interviews are anticipated to fall within burden hour
estimates. The universe of potential NIBRS study questions is included with this request (Attachment 3).

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All modernization study participants will receive the NIBRS modernization study’s public information
sheet (Attachment 1) and will receive a participation email (Attachment 2) introducing the study team
and describing the modernization study.

Estimate of Cost Burden
The NIBRS modernization study will not reimburse participants, groups or agencies for participating in
the modernization study conducted under this clearance.

Analysis Plan
The results of the NIBRS modernization study will be an assessment of current LEA crime reporting
record-keeping; local, state and tribal crime data use habits. The NIBRS modernization study’s
participant and group interviews will collect information that will assist the modernization study team to
gain an understanding of the capabilities and barriers that exist in state, local, federal, and tribal LEAs
with regards to collecting and reporting crime incident data and meeting the 2021 transition to the
NIBRS.
The NIBRS modernization study team will summarize the interview notes and extract common themes
(e.g. common areas of participant agreement and areas of participant disagreement) that will be
summarized in the modernization study to provide the CDM Team the state of the NIBRS in being
prepared for the 2021 cutover from summary reporting to incident-based crime reporting.
The information collected in this effort will not be the subject of estimates or other statistics in FBI UCR
or the NIBRS Program reports. The results of the modernization study may be prepared for
presentation at professional meetings or publication in professional journals. Due to the nature of this
clearance, there is no definite or tentative time schedule at this point. The work is expected to be
conducted more or less continuously throughout the duration of the clearance.

Informed Consent, Data Confidentiality and Data Security
The NIBRS modernization study participation is voluntary and each participant interview will begin with
a review of the NIBRS modernization study informed consent form (Attachment 4). All individuals being
interviewed will receive a copy of the informed consent form. The interview will not be recorded.
The NIBRS modernization study team will protect the privacy of information provided to the extent
permitted by law and will take procedural safeguards such as limiting access to those on the project
team, destroying or encrypting identifiers once the project is complete, and other physical security
measures. Furthermore, when working with other Federal agencies, the NIBRS team will work with its
partners to ensure confidentiality and privacy protections are agreed upon and enforced equally by all
parties.

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Attachments:
Attachment 1 – NIBRS Public Information Sheet
Attachment 2 – Study Participation Email
Attachment 3 – Universe of Potential NIBRS Study Participant Questions
Attachment 4 – NIBRS Participation Consent Form

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