Supporting
Statement for Collecting Data on
U.S. Small Business
Administration
Women’s Business Center Client Outcome
Survey
Part A
Part A: Justification 1
A.1 Circumstances That Make the Collection of Information Necessary 1
A.2 Purpose and Use of the Information Collected 2
A.3 Use of Information Technology and Burden Reduction.. 2
A.4 Efforts to Identify Duplication and Use of Similar Information. 3
A.5 Impact on Small Businesses or Other Small Entities. 3
A.6 Consequence of Collecting the Information Less Frequently. 4
A.7 Special Circumstances Relating to the Guidelines of 5 CFR 1320. 4
A.8 Comments in Response to Federal Register Notice and Efforts to Consult Outside Agency 5
A.9 Explanation of Any Payment or Gift to Respondents 6
A.10 Assurance of Confidentiality Provided to Respondents. 6
A.11 Justification for Sensitive Questions 6
A.12 Estimates of Annualized Burden Hours and Costs 7
A.13 Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers . 9
A.14 Annualized Cost to the Federal Government.. 9
A.15 Explanation for Program Changes or Adjustments. 10
A.16 Plans for Tabulation and Publication and Project Time Schedule. 10
A.17 Reason(s) Display of OMB Expiration Date is Inappropriate. 10
A.18 Exceptions to Certification for Paperwork Reduction Act Submission. 10
Part B. Collections of Information Employing Statistical Methods……..11
B.1 Respondent Universe and Sampling Methods 11
B.2 Procedures for the Collection of Information 12
B.3 Methods to Maximize the Response Rates and to Deal with
Non-Response 14
B.4 Test of Procedures or Methods to be Undertaken 15
B.5 Individuals
Consulted on Statistical Aspects and Individuals Collecting
and/or
Analyzing Data 16
Table 1. Annualized Burden and Cost to Respondents 8
Table 2. Annualized Burden and Cost to Federal Government 9
Table 3. WBC Client Universe, Sample, and Expected Response Rates …....
Table 4. Research Team Contact Information
Appendices
Appendix A1. WBC Client Outcome Survey- English
Appendix A2. WBC Client Outcome Survey- Spanish
Appendix A3. WBC Client Outcome Survey- English Screenshots
Appendix B1. WBC Introductory Letter
Appendix B2. WBC Initial Email
Appendix B3. WBC Client Data Template
Appendix B4. WBC Reminder Email
Appendix B5. WBC Client Introductory Letter
Appendix B6. WBC Client Initial Email
Appendix B7. WBC Client Outcome Survey FAQs
Appendix B8. WBC Client Reminder Email
Appendix B9. WBC Client Reminder Phone Script
Appendix B10. Summary of Nonresponse Bias Analysis, 2018
Appendix C1. Federal Register 60-Day Notice
Appendix C2. Statutes and Regulations Mandating Collection of Information
The Women’s Business Center (WBC) program was established by the Women’s Business Ownership Act of 1988. This authority is now codified in section 29(g) of the Small Business Act (15 U.S.C. 656(g). The WBC program provides one-on-one business assistance counseling and training to help clients start and grow businesses. The program also seeks to level the playing field for all women entrepreneurs (especially women who are economically or socially disadvantaged), who still face unique obstacles in the business world. Women’s Business Centers (WBCs) provide entrepreneurial development services—such as business training, counseling, mentoring, and referrals—through a network of 115 WBCs managed by the Small Business Administration’s (SBA) Office of Women’s Business Ownership.
The purpose of the WBC Client Outcome Survey is to provide the SBA with both national and subgroup performance analyses of the measurable outcomes clients achieve as a result of receiving Women’s Business Center Program services. The information generated through the annual survey is necessary to comply with SBA’s requirement to report program performance, including outcome metrics, to Congress for all its funded programs1. The client information currently collected by WBCs is insufficient to meet this requirement. While WBC Administrators are required to collect client information using SBA Form 641 (collects individual data on counseling clients) and SBA Form 888 (collects aggregate client data on training clients),2 they are not required to systematically follow-up with clients to collect data related to their outcomes such as adoption of new business practices, job creation or revenue growth. Additionally, the annual survey collects client satisfaction information which is otherwise not systematically collected and reported to SBA.
This collection builds upon a previous WBC Client Outcome Survey that was conducted annually from 2015 through 2018 (OMB Control No. 3245-0387). While the survey instrument for this collection has not substantively changed, modifications have been made to the survey methodology. These changes include the use of a single-stage, stratified sampling strategy at the WBC-client level sample and a data collection plan that utilizes an adaptive design approach. This methodology is intended to create a more comprehensive and complete sampling frame, minimize cost, reduce burden on clients, enhance the response rate and provide both national and subgroup performance analyses.
This study will collect information from WBC administrators and WBC clients.3 The study’s data collection activities include collecting WBC client contact information from WBC administrators and administering the WBC Client Outcome Survey to WBC clients, which will be offered in English (Appendix A1) and Spanish (Appendix A2).The information generated by this collection and the resulting report will allow SBA to better understand how training and counseling initiatives are meeting the Agency’s intended goals, to consider lessons learned that may be used to adjust the current initiatives, and to develop future initiatives. Furthermore, because the survey was designed to collect outcome metrics that are specific to the WBC program as well as those that are shared across SBA resource partners (i.e., SCORE, Small Business Development Centers), this collection makes it possible for SBA leadership to analyze and compare performance across the Agency’s entrepreneurial development programs. In addition, SBA will use the data from this information collection to monitor and report the performance of the WBC program to stakeholders (e.g., Congress, WBC leadership).
The survey is not designed to make causal claims about the impact of WBC services on clients. However, it is sufficiently designed to produce representative results of client attitudes and stated changes in business practices and performance after clients receive one or more services from a WBC. Moreover, it provides clients the opportunity to suggest improvements to the program. SBA will monitor these suggestions and performance outcomes over time and may provide the information to the Association of Women’s Business Centers (AWBC) to help facilitate their services to WBCs. The information collected will allow WBC program administrators and SBA to improve the program and identify whether trends correspond to intentional changes in program strategy and implementation.
SBA is committed to complying with the E-Government Act of 2002 to promote the use of technology in order to lessen the burden of data collection on the public. WBC client data will be collected via a web-based survey to reduce client burden. Screenshots of the web surveys are presented in Appendix A3. Web-based surveys are a cost-efficient solution that provide critical information from respondents in real time and allow flexibility in the survey’s format, layout, and navigation. The web-based survey minimizes the respondents’ burden and improves data quality by providing skip patterns for questions that are not applicable, pop-up instructions to questions, easy navigation, and the ability to stop and restart the survey at any time convenient to a respondent, unlike a telephone survey. Web-based surveys also allow respondents to submit the final survey instantly upon completion. Upon request, however, respondents are provided the option to complete the survey over the telephone. Regardless, all responses to data collection instruments are expected to be submitted through electronic systems.
Review of existing studies did not identify any duplication of efforts in this data collection. SBA’s current data collection efforts (Forms 641 and 888) do not provide systematic information on client outcomes and do not contain measures of service satisfaction. The AWBC has collected client data periodically (e.g., 2010) but to our knowledge has no future plans to conduct a client survey. Other identified data collection or analytic efforts of women-owned businesses include those conducted by the National Women’s Business Council using federal administrative data, the Aspen Institute’s MicroTracker survey, and the Kauffman Foundation’s Firm Survey. These sources cannot be used to monitor performance of the WBC program because they do not adequately represent WBC clients. For example, many of the WBCs do not participate in the MicroTracker survey; therefore, their clients are not surveyed, and many WBC clients are not in federal administrative datasets (e.g., Survey of Business Owners, Longitudinal Business Database) because they have not yet started businesses.4
This data collection will obtain information from small and nascent businesses. To minimize the burden on respondents, efforts have been made to simplify and streamline the survey. The estimated burden for completing the survey is approximately 6 minutes per respondent, largely due to the focus on a small number of behavioral questions and business information that do not require the respondent to retrieve data from a secondary source such as a tax return. The survey will be conducted via an online platform5, which will allow small business owners to take the survey at a time that is convenient for them. Additionally, the survey questions are constructed so that respondents need only answer questions that pertain to their experiences. For example, nascent businesses will skip questions that pertain to business performance outcomes. The data collection also uses a sample design to minimize the number of small businesses from whom information is requested.
If the SBA were to forgo this data collection, the Agency would not have systematic information on WBC clients’ post-service outcomes and satisfaction. Consequently, SBA would not have adequate information to monitor annual trends and changes and determine if the program is meeting its goals and effecting change for women-owned businesses.
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 three 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;
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.
Although not directly tied to the circumstances described here, SBA requests review of one special circumstance.6 SBA requests the use of slightly different industry categories than the Office of Management and Budget (OMB) standards in order to improve data quality and lower respondent burden. The survey provides respondents with 8 rather than 20 industry categories to choose from. They are a mix of two-digit and four-digit NAICS codes that are most relevant to sole proprietorships and other microbusinesses operated by WBC clients (see question 18 in Appendices A1, A2, and A3).7 The standard 20 categories do not provide an adequate description of the relevant industries contained in them, which makes it difficult for clients to correctly self-classify. Having clients select from the full list of hundreds of four- or six-digit categories would increase the respondent burden. SBA’s Counseling Information Form 641offers 21 options to this question. The 8 options on the questionnaire represent those most often selected. These eight categories, plus an “other” category, are requested to minimize measurement error and minimize burden.
A.8.a Federal Register notice and comments
Notice of this study was published in the Federal Register (83 FR 55444) on November 5, 2018 (Appendix C1). No public comments were received in response to the notice.
A.8.b Consultations outside the agency
Four respondents were consulted about the burden estimate and other characteristics of the data collection (i.e., frequency, clarity of instructions). Respondents in the pretest included current clients from two WBCs: Old Dominion University Women’s Business Center and Women’s Business Center of Northern Virginia. A respondent that had received WBC services within the past 12 months reported confusion as to the year of focus for the survey. As a result, OWBO added a clarifying statement to the WBC Client Outcome Survey, WBC Client Introductory Letter, and WBC Client Initial Email (see Appendices A1, B5 and B6). Additionally, a respondent reported difficulty selecting their business status from a list of options because definitions of ‘in business’ can vary. In response, OWBO added the SBA definition for ‘in business’ as a pop-up on the web survey question. Instructions for the question inform respondents they may hover over the options for more information (See Appendix A1, Question 11).
The participants in the study will not receive an incentive payment or gift.
Information gathered from respondents participating in this study is for research purposes only and will be kept private to the full extent allowed by law. Data will only be reported in aggregate form, no respondent-level information will ever be made public and individual respondents will not be identified from the data. The survey invitation letter informs the respondent that the survey data will be held in confidence by SBA and the Contractor (Appendix B5). SBA encrypts the client contact list files, copies to a USB and mails to the contractor. All PII is removed from the final dataset the contractor sends to SBA. It states that no survey participants will be identified in any public reports, as the collection is purely for statistical reporting purposes. Assurance of confidentiality, to the extent permitted, is provided by the Privacy Act of 1974, 5 U.S.C. 552a and the Freedom of Information Act, 5 U.S.C. 552, exception (b)(4), which allows SBA to deny Freedom of Information Act (FOIA) requests for information disclosures that could cause substantial competitive harm. The Contractor for this survey is required to adhere to the Privacy Act, as part of their contract with SBA
2M research is responsible for computing estimates. Data from the data collection efforts will be presented in aggregate form and, therefore, cannot be linked back to the response of any individual. Data presented in the reports are weighted and presented as percentage, not counts. We do not anticipate the need for disclosure protection procedures in the resulting report. There is no public use or restricted use data set resulting from this study. To ensure that personal information remains private, the contract executed between SBA and 2M Research Services, LLC (Contractor) requires that the Contractor create and keep data on secure networks and sign confidentiality agreements binding them to protect private information. The Contractor will assign a unique ID number to each respondent and provide the data to SBA by this ID number. A separate file will associate the ID number with personal information. The Contractor will keep this file private. The Contractor will host its statistical software applications (e.g., Statistical Analysis Software [SAS], Stata) on powerful servers in a virtualized environment specifically designed to handle processing large datasets. Once the contract is completed, the Contractor will be required destroy the files that contain private information.
The data collection does not request information typically considered private or sensitive in nature. However, WBC clients will be asked about their businesses’ financial situation, such as total revenue and the value of loans obtained. Although potentially sensitive, these questions are essential to the WBC program’s mission and reporting requirements. A reminder of the survey’s confidentiality statement is provided directly prior to these financial questions. Clients will also be asked for their gender, race, ethnicity, veteran status, disability status, and income in order to determine whether the WBC is fulfilling its mission of serving low-income women, as well as the extent to which SBA services are provided with equal opportunity across different demographic groups. To determine if clients are low-income, the income categories are specially grouped and, when combined with the number of people in the household, can be used to determine poverty status. This is an additional measure taken to limit the sensitivity a client may have about income status.
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, and
provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.
Table 1 shows the estimated annualized burden for the proposed data collection. The total number of burden hours on WBC Administrators and WBC clients is 770.47. The estimate is based on an anticipated total of 2,087 respondents (87 WBC administrators and 2,000 WBC clients). The WBC client burden related to reminder emails was calculated by estimating that up to five email reminders will be required and that each time, approximately 85% of the subset will receive the reminder. Using this method, the first reminder will be sent to 85% of the 4500, the second reminder will be sent to 85 percent of the 3,825 sent the first reminder and so on. The WBC client burden related to telephone call reminders was calculated by estimating that one telephone call reminder will occur after the third email reminder is sent. The estimated number of WBC clients that will complete the collection was calculated by assuming a 50 percent response rate from the sample of 4,000 clients and reflects SBA prior experience with essentially the same data collection.8 More information about these response rate estimates is presented in Part B.
Estimates |
Introduction Mail |
Initial/ Invitation Email |
Reminder Emails |
Reminder Calls |
Completion of Collection |
Total Burden |
WBC Administrative Data Burden |
||||||
Number of WBC administrators |
92 |
92 |
87 |
--- |
87 |
--- |
Frequency of collection |
1 |
1 |
1 |
0 |
1 |
--- |
Average minutes |
1 |
1 |
1 |
0 |
60 |
--- |
Average hourly pay* |
--- |
--- |
--- |
--- |
--- |
--- |
Total burden (in hours) |
1.53 |
1.53 |
1.45 |
0.00 |
87.40 |
91.91 |
WBC Client Survey Burden |
||||||
Number of clients |
4,500 |
4,500 |
14,186 |
2,764 |
2,000 |
--- |
Frequency of collection |
1 |
1 |
5 |
1 |
1 |
--- |
Average minutes |
1 |
1 |
1 |
2 |
6 |
--- |
Average hourly pay |
$19.38 |
$19.38 |
$19.38 |
$19.38 |
$19.38 |
--- |
Total burden (in hours) |
75.00 |
75.00 |
236.43 |
92.13 |
200.00 |
678.56 |
Total Burden and Costs |
||||||
Total burden (in USD) |
$1,453.50 |
$1,453.50 |
$4,581.92 |
$1,785.54 |
$3,876.00 |
$13,150.46 |
Total burden (in hours) |
76.53 |
76.53 |
237.88 |
92.13 |
287.40 |
770.47 |
Table 1 also shows the estimated annualized cost to respondents. This cost has been calculated using average hourly earnings for 2018 obtained from the Current Population Survey (CPS) Annual Social and Economic Supplement (ASEC) estimates for occupational employment wages. The estimated annual costs burden for this data collection is $13,150.47 to clients. The cost estimate is based on the average survey hours and an average hourly wage of $19.38.9
*There are no additional costs associated with the WBC burden, as WBCs are performing this task under an existing grants.
There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.
The annualized cost to the Federal Government for data collection and reporting is $319,378.62 (see Table 2). This figure includes costs associated with the Contractor conducting the project and the project oversight provided by federal staff. Specifically, the cost for the Contractor to complete the study design, instrument design, data collection, OMB supporting documentation, data analysis, and report writing is $313,634.42. The annual cost of federal employee oversight of the project is estimated to be $5,744.20. The estimate is based on one Contracting Officer's Representative (COR) GS-14, step 1, with an hourly wage of $54.91 and 20 hours of administrative oversight. In addition, we anticipate that one Program Analyst, GS-13, step 1, with an hourly wage of $46.46, will spend 100 hours in oversight of the project.10
Estimates |
SBA COR |
SBA Program Analyst |
SBA Contractor |
Total Federal Costs |
Number of employees |
1 |
1 |
--- |
--- |
Total burden (in hours) |
20 |
100 |
--- |
--- |
Average hourly pay |
$54.91 |
$46.46 |
--- |
--- |
Total Cost (in USD) |
$1,098.20 |
$4,646.00 |
$313,634.42 |
$319,378.62 |
Because the prior approved survey (3245-0387) was cancelled, there is no “current” inventory. Nonetheless, SBA notes that changes to the data collection methodology, specifically the strategic initial sample of WBC clients and the release of the backup sample, will result in a decreased cost estimate and respondent burden as compared to the burden for the prior survey, which was estimated at 1,496.00 annualized burden hours. The estimated burden for this submission of the survey is 770.47 hours.
This study will use quantitative methods to analyze the survey data and produce tabulations in a public report. The report will be distributed via email to all WBC directors. The report will not be posted publicly. The descriptive statistics will include frequencies, averages, and ranges for the data elements. Standard errors and 95 percent confidence intervals will be provided for the estimates in a technical appendix. The reported estimates will be weighted, and unweighted estimates will potentially be contained in the technical appendix. If the report includes cross-tabulations, inferential statistics will be used to determine whether or not the group differences are statistically significant at conventional levels. The report is expected to include tables for the descriptive statistics in the technical appendix and graphical elements in the body of the report, such as pie charts and maps that visually represent the data.
Below is a schedule for the proposed study.
Task: Study and Survey Design |
Date |
60-day notice in Federal Register |
10/29/2018 |
Draft OMB Materials |
11/16/2018 |
Final OMB Materials |
2/8/2019 |
SBA sends OMB materials for approval |
4/16/2019 |
30-day notice in Federal Register |
4/16/2019 |
OMB notifies SBA of approval |
9/27/2019 |
Task: Build Sample Frame |
|
Letter and template to WBCs |
10/1/2019 |
Reminder email to WBCs |
10/8/2019 |
SBA sends 2M completed templates for sample frame |
10/29/2019 |
Select sample |
11/4/2019 |
Task: Data Collection |
|
Introductory letter to sampled clients |
11/6/2019 |
Email invitation with web link |
11/11/2019 |
1st email prompt |
11/18/2019 |
2nd email prompt |
11/25/2019 |
3rd email prompt |
12/2/2019 |
Start telephone prompts |
12/9/2019 |
4th email prompt |
12/16/2019 |
Last email prompt |
12/23/2019 |
Data collection ends |
12/31/2019 |
Task: Data Delivery and Report |
|
Clean data and derive estimates |
2/7/2020 |
Draft report |
2/28/2020 |
Final report |
3/23/2020 |
Dissemination of Final Report |
4/13/2020 |
The study team plans to display the expiration date for OMB approval of the information collection on all instruments.
This study does not require any exceptions to the Certificate for Paperwork Reduction Act (5 CFR 1320.9).
1 See Appendix C2: Statutes and Regulations Mandating Collection of Information
2 See OMB Control Number 3245- 0324 (Entrepreneurial Development Management Information System (EDMIS) Counseling Information Form & Management Training Report)
3 WBCs are managed by an administrator known as a “WBC administrator.” A WBC client is the entrepreneurial individual seeking services from a WBC. While the WBC’s main goal is to assist women entrepreneurs, WBCs also support men who own a business or desire to start and own their own business.
4 A previous survey of WBC clients conducted by SBA showed that about 35 percent had not yet started a business: https://www.sba.gov/sites/default/files/files/OED_ImpactReport_09302013_Final.pdf
5 Respondents will be given the option to complete the survey by telephone if that is their preference.
6 These are the same requests that were submitted in the 2014 OMB package and were previously approved.
7 A previous survey of WBC clients conducted by SBA showed that over half did not have any employees: https://www.sba.gov/sites/default/files/files/OED_ImpactReport_09302013_Final.pdf
8 This number includes 4,000 WBC clients in the primary sample frame. An additional sample of 500 WBC clients will only be added if response counts are lower than expected.
9 WBC clients’ hourly wages were estimated from the CPS, 2018 ASEC, Table PINC-07. For self-employed women, the mean annual wage is $40,305 and the mean hourly wage, based on a 2,080-hour work year, is $19.38.
10 Federal employee pay rates are based on the General Schedule of the Office of Personnel Management for 2018 for the Washington, DC, locality and a 2,080-hour work year. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/DCB_h.pdf
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