Supporting Statement A for Generic Clearance Collection of Qualitative Feedback on Agency Services Delivery

Supporting Statement for Paperwork Reduction Act Generic Information
Collection Submissions for “Generic Clearance for the Collection of Qualitative
Feedback on Agency Service Delivery”

A. JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
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 Merit Systems Protection Board (MSPB) seeks to obtain the Office of Management
and Budget’s (OMB) approval of a 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 the Agency 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 MSPB’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 MSPB and its
customers and stakeholders. It will also allow feedback to contribute directly to the
improvement of program management.
2. 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. MSPB 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 MSPB’s services will be unavailable.
MSPB will only submit a collection for approval under this generic clearance if it meets
the following conditions:

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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.1
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, MSPB will submit an information collection request to
OMB for approval through the normal Paperwork Reduction Act (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:
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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.

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As defined in OMB and agency Information Quality Guidelines, “influential” means that “an
agency can reasonably determine that dissemination of the information will have or does have a
clear and substantial impact on important public policies or important private sector decisions.”
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Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out
web surveys).
In-person observation testing (e.g., website or software usability tests).

MSPB has established a manager/managing entity to serve for this generic clearance and
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.
3. Consideration Given to Information Technology
If appropriate, agencies will collect information electronically and/or use online
collaboration tools to reduce burden.
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Duplication of Information
No similar data are gathered or maintained by MSPB or are available from other sources
known to MSPB.

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Reducing the Burden on Small Entities
Small business or other small entities may be involved in these efforts but MSPB will
minimize the burden on them of information collections approved under this clearance by
sampling, asking for readily available information, and using short, easy-to-complete
information collection instruments.

6. Consequences of Not Conducting Collection
Without these types of feedback, MSPB will not have timely information to adjust its
services to meet customer needs.
7. Special Circumstances
There are no special circumstances. The information collected will be voluntary and will
not be used for statistical purposes.
8. Consultations with Persons Outside the Agency
In accordance with 5 CFR 1320.8(d), on April 10, 2014, a 60-day notice for public
comment was published in the Federal Register (79 FR 19929). MSPB did not receive
any comments in response to the notice.
9. Payment or Gift
MSPB will not provide payment or other forms of remuneration to respondents of
its various forms of collecting feedback. Focus groups and cognitive laboratory
studies are the exceptions.
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In the case of in-person cognitive laboratory and usability studies, MSPB may
provide stipends of up to $40. In the case of in-person focus groups, MSPB may
provide stipends of up to $75. If respondents participate in these kinds of studies
remotely, via phone or Internet, any proposed stipend needs to be justified to
OMB and must be considerably less than that provided to respondents in in-person
studies, who have to travel to the agency or other facility to participate. If such
information collections include hard-to- reach groups and the agency plans to offer
non-standard stipends, MSPB will provide OMB with additional justifications in
the request for clearance of these specific activities.
10. Confidentiality
If a confidentiality pledge is deemed useful and feasible, MSPB will only include
a pledge of confidentiality that is supported by authority established in statute or
regulation, which is supported by disclosure and data security policies that are
consistent with the pledge, and that does not unnecessarily impede sharing of data
with other agencies for compatible confidential use. If MSPB includes a pledge of
confidentiality, it will include a citation for the statute or regulation supporting the
pledge.
11. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.
12. Burden of Information Collection
A variety of instruments and platforms will be used to collect information from
respondents. The annual burden hours requested 1,500 are based on the number of
collections we expect to conduct over the requested period for this clearance.

Estimated Annual Reporting Burden
Type of Collection

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

No. of
Respondents

Annual
Frequency per
Response

Hours per
Response

Total
Hours

3,000

One per request

0.5

1,500

13. Costs to Respondents
No costs are anticipated.

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14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $43,250 annually.
These costs are comprised of:
1. Professional staff time designing, reviewing, programming survey
instruments, coordinating participant contacts, and distributing surveys,
recording and checking results, analyzing results, presenting or reporting
results. 150 hours per year at $75.00 per hour for a total of $11,250 per year.
2. Survey software tool and hosting support. License fee and maintenance plus
training and support $32,000 per year. Based on fee for Foresee software
which includes hosting support.
15. Reason for Change
Not applicable. This is a new request for a generic Information Collection Request.
16. Tabulation of Results, Schedule, Analysis Plans
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 MSPB does not intend to publish its findings, we may receive requests to
release the information (e.g., Congressional inquiry, Freedom of Information Act
requests). MSPB will disseminate the findings when appropriate, strictly following our
"Guidelines for Ensuring the Quality of Information Disseminated to the Public," and
will include specific discussion of the limitation of the qualitative results discussed
above.
17. Display of OMB Approval Date
We are requesting no exemption.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
These activities comply with the requirements in 5 CFR 1320.9.

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B. STATISTICAL METHODS
Data collection methods and procedures will vary; however, the primary purpose of these
collections will be for internal management purposes; there are no plans to publish or
otherwise release this information.
1. Universe and Respondent Selection
The activities under this clearance may involve samples of self-selected customers, as
well as convenience samples and quota samples, with respondents selected either to
cover a broad range of customers or to include specific characteristics related to
certain products or services. Results will not be used to make statements
representative of the universe of study, to produce statistical descriptions (careful,
repeatable measurements), or to generalize the data beyond the scope of the sample.
The specific sample planned for each individual collection and the method for
soliciting participation will be described fully in each collection request.
Qualitative surveys are tools used by program managers to change or improve
programs, products, or services. The accuracy, reliability, and applicability of the
results of these surveys are adequate for their purpose.
The samples associated with this collection are not subjected to the same scrutiny as
scientifically drawn samples where estimates are published or otherwise released to
the public.
2. Procedures for Collecting Information
Data collection methods and procedures will vary and the specifics of these will be
provided with each collection request. MSPB expects to use a variety of
methodologies for these collections. For example, MSPB or its contractors may use
commercial survey-specific software to automate its collection and analysis of
feedback. In addition to physical copies, information collection instruments may be
electronically disseminated and/or posted on target pages of MSPB’s website.
Telephone scripts, personal interviews, and focus groups with professional guidance
and moderation may also be used.
3. Methods to Maximize Response
Information collected under this generic clearance will not yield generalizable
quantitative findings; it can provide useful customer input, but it does not yield data
about customer opinions that can be generalized.
4. Testing of Procedures
Pretesting may be done with internal staff, a limited number of external colleagues,
and/or customers who are familiar with the programs and products. If the number of
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pretest respondents exceeds nine (9) members of the public, MSPB will submit the
pretest instruments for review under this generic clearance.
5. Contacts for Statistical Aspects and Data Collection
Each program will obtain information from statisticians in the development, design,
conduct, and analysis of customer/partner service surveys, when appropriate. This
statistical expertise will be available from agency statisticians or from contractors and
MSPB will include the names and contact information of persons consulted in the
specific information collection requests submitted under this generic clearance.

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