0377 ss Part A 20181129

Animal and Plant Health Inspection Service
Supporting Statement for
Generic Information Collection and Clearance of
“Qualitative Feedback on Agency Service Delivery”
OMB NO. 0579-0377

A. JUSTIFICATION

November 2018

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.

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 Animal and Plant Health
Inspection Service (hereafter “APHIS”) seeks to obtain OMB approval of a generic clearance to
collect qualitative feedback on its service delivery. By qualitative feedback APHIS means
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 APHIS to garner customer and stakeholder
feedback in an efficient, timely manner, in accordance with its commitment to improving service
delivery. The information collected from APHIS’s customers and stakeholders will help ensure
that users have an effective, efficient, and satisfying experience with APHIS’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
APHIS and its customers and stakeholders. It will also allow feedback to contribute directly to the
improvement of program management.
APHIS is asking OMB to approve its use of these information collection activities for an
additional 3 years.
2. Indicate how, by whom, how frequently, 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.

Improving Agency programs requires ongoing assessment of service delivery including 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. APHIS will collect,
analyze, and interpret information gathered through this generic clearance to identify strengths and
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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 APHIS’s services will be unavailable.
APHIS is submitting a collection for approval under this generic clearance - it meets the
following conditions:
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•
•
•
•
•
•
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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 Aagency (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 renumeration 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, APHIS will submit an information collection request to OMB for
approval through the normal 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:
• Customer comment cards/complaint forms.
• Small discussion groups.
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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•
•
•
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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.
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web
surveys).
In-person observation testing (e.g., website or software usability tests)

APHIS 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. 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.

If appropriate, agencies will collect information electronically and/or use online collaboration
tools to reduce burden.
4. Describe efforts to identify duplication. Show specifically why any similar information
already available cannot be used or modified for use for the purpose described in item 2 above.

No similar data are gathered or maintained by APHIS or are available from other sources known
to APHIS.
5. If the collection of information impacts small businesses or other small entities, describe any
methods used to minimize burden.

Small business or other small entities may be involved in these efforts but APHIS 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. Describe the consequence to Federal program or policy activities if the collection is not
conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing
burden.

Without these types of feedback, APHIS will not have timely information to adjust its services to
meet customer needs.

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7. Explain any special circumstances that require the collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5.
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requiring respondents to report information to the agency more often than quarterly;

•

requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;

•

requiring respondents to submit more than an original and two copies of any document;

•

requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than 3 years;

•

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;

•

requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;

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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; or

•

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.

No special circumstances exist that would require this collection to be conducted in a manner
inconsistent with the general information collection guidelines in 5 CFR 1320.5. The information
collected will be voluntary and will not be used for statistical purposes.
8. 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 form, and on the data elements to be recorded, disclosed, or reported. If
applicable, 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.

On Wednesday, August 22, 2018, pages 42459, APHIS published in the Federal Register, a 60day notice seeking public comments on its plans to request a 3-year renewal of this collection of
information. During that time, one comment was received from a concerned citizen which had no
bearing on paperwork burden

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

APHIS 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.
In the case of in-person cognitive laboratory and usability studies, APHIS may provide stipends of
up to $40. In the case of in-person focus groups, APHIS 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 APHIS or other facility to participate. If
such information collections include hard-to-reach groups and APHIS plans to offer non-standard
stipends, APHIS will provide OMB with additional justifications in the request for clearance of
these specific activities.
It should also be noted that APHIS may pay for the postage associated with returning responses
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.

If a confidentiality pledge is deemed useful and feasible, APHIS 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
APHIS includes a pledge of confidentiality, it will include a citation for the statute or regulation
supporting the pledge.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior or 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.
This information collection activity will ask no questions of a personal or sensitive nature.
12. Provide estimates of the hour burden of the collection of information. Indicate the number
of respondents, frequency of response, annual hour burden, and an explanation of how the
burden was estimated.
• Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. 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.

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• Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories.

A variety of instruments and platforms will be used to collect information from respondents. The
annual burden hours requested (17,500) are based on the number of collections APHIS expects to
conduct over the requested period for this clearance.
Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Annual Frequency per
Response

Hours per
Response

Total Hours

Customer Feedback Surveys

70,000

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.25

17,500

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting
from the collection of information (do not include the cost of any hour burden shown in items 12
and 14). The cost estimates should be split into two components: (a) a total capital and start-up
cost component annualized over its expected useful life; and (b) a total operation and
maintenance and purchase of services component.
No annual cost burden is associated with capital and startup costs, operation and maintenance
expenditures, and purchase of services are anticipated.
14. Provide estimates of annualized cost to the Federal government. Provide a description of the
method used to estimate cost and any other expense that would not have been incurred without
this collection of information.

It is unknown at this time what expenses will be incurred by the Federal government in collecting
this information. APHIS will provide an accounting of incurred expenses in individual
submissions.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of
the OMB Form 83-1.
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ICR Summary of Burden:

•

Total Number
of Responses

Program
Change
Requested Due to
New
Statute
70000

0

Program
Change
Change
Change
Due to
Due to
Previously
Due to Adjustment Potential
Approved
Agency in Agency Violation
Discretion Estimate of the PRA
0
0
70000
0

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Total Time
Burden (Hr)
Total Cost
Burden ($)

17500

0

0

0

0

17500

0

0

0

0

0

0

There is no change in burden as there is still a high interest in APHIS for customer feedback and
stakeholder engagement.
16. For collections of information whose results are planned to be published, outline plans for
tabulation and publication.

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 APHIS does not intend to publish its findings, APHIS may receive requests to release
the information (e.g., congressional inquiry, Freedom of Information Act requests). APHIS will
disseminate the findings when appropriate, strictly following APHIS's "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. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain the reasons that display would be inappropriate.
Not applicable. APHIS will display the expiration date.
18. Explain each exception to the certification statement identified in the "Certification for
Paperwork Reduction Act."

These activities comply with the requirements in 5 CFR 1320.9

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