Mini-Supporting Statement

Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback” (OMB Control Number 1615-0126)

TITLE OF INFORMATION COLLECTION: National Survey of E-Verify Employers Pretest

PURPOSE AND BACKGROUND: The United States Citizenship and Immigration Services (USCIS) requests OMB approval to conduct a formal pretest of the 2018 National Survey of E-Verify Employers (Attachments A-1 through A-4). The Information Collection Request to conduct the full survey as a continued data collection in 2018 will be submitted to OMB later. USCIS has contracted Westat to conduct this study.

The most recent national survey of E-Verify employers built upon earlier evaluations conducted almost biannually since 2008. These surveys were designed to assess the extent to which E-Verify was meeting its goals, examine how employers understood and complied with E-Verify requirements, and assess the extent to which employers were satisfied with E-Verify features and resources. These surveys focused exclusively on the core group of E-Verify employers that registered to use E-Verify for the sole purpose of verifying their own employees via the E-Verify website.

The 2018 national survey of E-Verify employers will continue to focus on the core research questions of prior evaluations in addition to addressing programmatic changes and examining emerging issues (e.g., identity fraud and hanging Tentative Nonconfirmations (TNCs). For the first time, the study will include three new employer groups:

• E-Verify Employer Agents (EEAs) that verify workers for other companies, usually for a fee;

• Clients of EEAs that hire EEAs to verify their workers; and

• Web services employers that use software to interface with the E-Verify website to verify workers, including Web services EEAs and Web services employers that verify only their own employees

Prior iterations of the national survey of E-Verify employers excluded EEAs, clients of EEAs, and Web services employers because of the cost and challenges associated with including them. However, the increasing role of these employer groups to the verification of U.S. workers makes it important to include them in the 2018 study. For example, the percentage of cases transmitted by EEAs has increased dramatically over time, accounting for about half of all cases transmitted to E-Verify.

Specifically, the 2018 study will address the following research questions:

• What are the characteristics of E-Verify users and what are their motivations for participating in E-Verify?

• To what extent is E-Verify meeting the goals of reducing unauthorized employment, reducing verification-related discrimination, and preventing undue burden on employers?

• How well do employers understand and comply with E-Verify requirements including those designed to protect workers privacy and civil rights liberties?

• How satisfied are employers with current E-Verify features and resources, and how can E-Verify be further improved in the future?

For the first time, the study will examine how EEAs verify their clients’ workers and how they differ from non-EEAs in verifying their own workers. It will also examine the extent to which EEAs adhere to the requirements when verifying clients’ workers.

To draft the questions for the new study, Westat established a working group of USCIS content experts and Westat’s E-Verify evaluation researchers and survey methodologist to identify new topics and assess the relevance, usefulness, and burden of each 2015 survey item in relation to core E-Verify goals, programmatic changes, and new employer types. Westat developed a pretest draft of the 2018 survey by incorporating feedback from two working group meetings to add new items and modify or drop items from the 2015 survey. However, most of the 2018 items were directly adapted from the 2015 survey.

To develop a seamless web survey, Westat created four related pools of items as shown in Attachments A-1 through A-4:

• Attachment A-1 contains the base survey items designed for: (a) the core E-Verify employers registered to use E-Verify for verifying their own workers and (b) EEAs that verified only their own workers in the 12 months prior to being sampled.

• After answering applicable questions to confirm company and respondent eligibility in Section A of Attachment A-1, the following employer types will be routed to:

  • Attachment A-2 for EEAs verifying only their clients’ workers in the 12 months prior to being sampled;

  • Attachment A-3 for EEAs verifying both their clients’ workers and own workers in the 12 months prior to being sampled; and

  • Attachment A-4 for clients of EEAs.

Web services employers will answer relevant questions in Attachments A-1, A-2, and A-3.

Pretesting the Surveys

The primary purpose of the pretest is to identify and correct any potential issues with new and modified items before conducting full-scale implementation of the 2018 survey. Thus, we will use cognitive interviewing techniques to conduct online focus groups with E-Verify employers to assess whether:

• New and substantially modified survey questions are clear;

• Questions convey the intended meaning;

• The information requested is available; and

• Questions require an excessive amount of time to complete.

As in prior years, the research team assigned to the study will conduct these focus groups using WebEx, a Web hosting service for integrated teleconferencing.

There is no other similar information currently available to assess the impact of ongoing E-Verify changes on a changing population of users. As the population changes with federal and state legislation requiring E-Verify participation, the new data collection will track potential shifts in employer perceptions of the program, how it is used, and levels of compliance with E-Verify procedures.

DESCRIPTION OF FOCUS GROUP RESPONDENTS:

The focus group samples will be selected from the most recent E-Verify Transaction Database file that is currently available. Employers will be stratified according to the following focus groups for selection, and callers will confirm the respective status of each employer during recruitment.

• Focus Group 1. To reflect the characteristics of study samples used in previous iterations of the study and allow for analysis of change over time, Westat will select one focus group sample of “regular” employers registered to use E-Verify for the sole purpose of verifying their own employees using the E-Verify website. This group will complete all applicable questions in the base survey (Attachment A-1).

• Focus Group 2. This group will comprise employers that registered to use E-Verify for the sole purpose of verifying their own employees using Web services software to interface with the E-Verify website. The employers will complete all applicable questions from the base survey (Attachment A-1).

• Focus Group 3. This group will comprise EEAs that used the E-Verify website directly to verify only their own workers during the 12 months preceding the pretest. The EEAs will complete all applicable questions from the base survey (Attachment A-1).

• Focus Group 4. This group will comprise both Web services and regular EEAs that verified only their clients’ workers during the 12 months preceding the pretest. The EEAs will complete a few applicable questions from Section A of the base survey (Attachment A-1) and remaining questions in Attachment A-2 for employers that verify only clients’ workers.

• Focus Group 5. This group will comprise both Web services and regular EEAs that verified BOTH their clients’ workers and own their workers during the 12 months preceding the pretest. The EEAs will complete a few applicable questions from Section A of the base survey (Attachment A-1) and remaining questions in Attachment A-3 for employers that verify both their own and clients’ workers.

• Focus Group 6. This group will comprise clients of EEAs. They will answer a few applicable questions from Section A of the base survey (Attachment A-1) and the questions in Attachment A-4.

Pretest participants will be those persons identified as the company’s most knowledgeable user of
E-Verify and they will be recruited via telephone calls from callers experienced in working on prior
E-Verify pretests and/or surveys. Callers will be trained to use the recruitment script to introduce the study and confirm the status of each employer with regard to employer type and company size (Attachment C). Following telephone recruitment, recruiters will email the appropriate pretest draft questionnaire (Attachments A-1 through A-4) and the USCIS cover letter to participating employers (Attachment B).

To minimize respondent burden for the pretest, different employer groups will be asked to complete the respective version of the survey and to examine a specific set of questions that need to be pretested carefully, as identified by the working group members and USCIS Research and Evaluation staff. All participants will be asked to review, complete, and return their paper version of the questionnaire with any additional notes or comments on the questions. They will also be invited to participate in a focus group via WebEx from their own offices to discuss their feedback on the survey items. The moderator guide for the focus groups will be designed to examine questionnaire items that are assigned to each focus group as well as incorporate any relevant issues identified by participants who completed the surveys. A list of all questionnaire items for focus group discussions and the key discussion questions for each item are presented in Attachment D.

TYPE OF COLLECTION: (Check one)

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

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

[X] Focus Group [ ] Other: _____________________

Focus groups will be conducted through online sessions via WebEx.

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 the solicitation of opinions from respondents who have experience with the program or may have experience with the program in the future.

Name:_Amy Ritualo_______________________________________

To assist review, please provide answers to the following question:

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? [X] Yes [ ] No

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

Gifts or Payments:

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

Focus group participants will be offered a $75 incentive to review and complete surveys as assigned and to participate in the focus group.

BURDEN HOURS

Instruments and scripts for the pretest include the following: the 2018 draft questionnaires (Attachments A-1 through A-4), recruitment script (Attachment C), and a list of questionnaire items and questions to guide discussions about these items (Attachment D).

Category of Respondent: Employers: Recruitment: Participation in pretest (Attachment C)	No. of Respondents 50	Participation Time 15 min (.25 hrs.)	Burden 13 hrs.
Review and complete questions (Attachment A1-A4)	40	40 min. (.67 hrs)	27 hrs.
Focus group discussion (Attachment D)	40	60 min. (1 hr.)	40 hrs.
Totals	130		80 hrs.

FEDERAL COST: The estimated annual cost to the federal government for this pretest is about $91,000 to include preparing the pretest materials and generic package, reviewing of the package by the Government, requesting and receiving list of employers from USCIS, training recruiters, recruiting participants, emailing them the pretest package and cover letters and instructions for logging into WebEx, sending confirmatory and reminder emails, reviewing the completed questionnaires, training the moderators, conducting the focus groups, reviewing the transcripts, and preparing and submitting revised surveys and the pretest report.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of your targeted respondents

1. 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? [X] Yes [ ] No

If the answer is yes, please provide a description of both below (or attach the sampling plan). If the answer is no, please provide a description of how you plan to identify your potential group of respondents and how you will select them?

E-Verify employers will be identified from the E-Verify Transaction Database which captures E-Verify usage and provides basic information on employers (point of contact, name of company, email address, phone numbers, etc.). See description of the recruitment of pretest respondents above.

Administration of the Instrument

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

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

[X] Telephone

[ ] In-person

[X ] Mail

[X] Other, Explain: Sampled participants will be recruited via telephone. Surveys will be mailed to participants, completed, and then returned by participants to Westat via mail. Online focus sessions will be conducted through a WebEx webinar. Session moderators will communicate through a coordinated telephone connection and participants will be able to see the questions as they are being discussed. WebEx produces automatic transcripts of the focus group discussions.

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

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