Supplemental Supporting Statement for CCI Survey (Fast Track)

DOL – OFCCP LMS Customer Survey OMB Control No. 1225-0088

December 2019

Request for Approval under Department of Labor Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery

OMB Control Number 1225-0088

TITLE OF INFORMATION COLLECTION

OFCCP Learning Management System (LMS) Account Creation and Customer Survey

PURPOSE

The U.S. Department of Labor’s (DOL) Office of Federal Contract Compliance Programs (OFCCP) administers and enforces three equal employment opportunity laws: Executive Order 11246, as amended; Section 503 of the Rehabilitation Act of 1973, as amended (Section 503); and the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended. These laws prohibit covered federal contractors and subcontractors (hereinafter collectively referred to as “contractors”) from discriminating based on race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran. Additionally, contractors are prohibited from taking adverse employment actions against applicants and employees for inquiring about, discussing, or disclosing information about their pay or the pay of their co-workers, subject to certain limitations.

In early 2020, OFCCP will implement a new publicly facing website for its contractor training. The website will host a new Learning Management System (LMS) that will be used to register participants for OFCCP’s contractor training. The training will include several educational courses intended to inform contractors about the requirements of equal opportunity employment laws and the creation and maintenance of affirmative action programs. OFCCP will collect contact information, and industry information from users in order to create their accounts in the system. Additionally, OFCCP seeks to collect feedback from system users in order to assess the effectiveness of the training by offering them the option to participate in a voluntary survey. The survey will ask respondents to answer six questions regarding their experience with the training. The results of the survey will enable the agency to evaluate the quality of the LMS and improve the process in the future.

OFCCP is not requesting public input on this information collection and approval is sought under OMB Control No. 1225-0088.

DESCRIPTION OF RESPONDENTS

Respondents will be users who create accounts on the LMS and take the customer satisfaction survey.

TYPE OF COLLECTION (Check one)

[ ] Customer Comment Card/Complaint Form [X] Customer Satisfaction Survey

[ ] Usability Testing (e.g., Website or Software) [ ] Small Discussion Group

[ ] Focus Group [ ] Other:

CERTIFICATION

I certify the following to be true:

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the federal government.

3. The collection is non-controversial and does not raise issues of concern to other federal agencies.

4. The results are not intended to be disseminated to the public.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The collection is targeted to individuals who create an account on the LMS and take a customer satisfaction survey.

Name:

Harvey D. Fort

Deputy Director

Division of Policy and Program Development

Office of Federal Contract Compliance Programs

PERSONALLY IDENTIFIABLE INFORMATION

1. Is personally identifiable information (PII) collected? [X] Yes [ ] No

2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act of 1974? [ ] Yes [X] No

3. If applicable, has a System or Records Notice been published? [ ] Yes [ ] No

GIFTS OR PAYMENTS

Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to participants? [ ] Yes [X] No

BURDEN HOURS

Category of Respondents:

[X] Individuals or Households

[X] Private Sector

[X] State, local, or tribal governments

[X] Federal Government

OFCCP anticipates that a maximum of 1,000 respondents will register and take the survey, but this is an overestimation, since it is likely that not all respondents will complete the survey.

The burden for this information collection is broken into two instruments:

• Account creation: 0.25 hours

• Survey: 0.12¹ hours

The total burden is 370 hours and is summarized in the table below:

No. of Respondents	Participation Time	Burden
1,000	0.37 hours	370 hours

FEDERAL COST

OFCCP estimates that agency staff will spend approximately 15 hours each year maintaining the LMS accounts, reviewing the results and drafting a report that summarizes the responses to the survey. The estimated annual cost to the federal government to maintain the LMS accounts and administer this survey to applicants is $1,145 ($76.31² x 15 hours).

The Selection of targeted respondents:

Do you have a customer list or something similar that defines the universe of potential respondents and do you have a sampling plan for selecting from this universe? [ ] Yes [X] No

Administration of the Instrument:

1. How will you collect the information? (Check all that apply)

[X] Web-based or other forms of Social Media

[ ] Telephone

[ ] In-person

[ ] Mail

[ ] Other, Explain

2. Will interviewers or facilitators be used? [ ] Yes [X] No

1 This figure is rounded up from 0.116 (0.116 hours = 7 minutes of estimated burden).

2 The cost reflects the time of federal staff who are GS-13, Step 4. See, “Salary Table 2019-DCB Incorporating The 1.4% General Schedule Increase And A Locality Payment Of 29.32% For The Locality Pay Area Of Washington-Baltimore-Arlington, DC-MD-VA-WV-PA,” available at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/DCB_h.pdf (last accessed December 2019). OFCCP includes an additional 46% to account for overhead.