Supporting Statement
OMB Control Number 1506-0062
Generic Information Collection Submissions
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”
JUSTIFICATION
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 Financial Crimes Enforcement Network (hereafter the Agency) seeks to obtain 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 the Agency’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 the Agency and its customers and stakeholders. It will also allow feedback to contribute directly to the improvement of program management.
Purpose and Use of the Information Collection.
Improving agency programs requires an 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. The Agency 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 the Agency’s services will be unavailable.
The Agency will only submit a collection for approval under this generic clearance if it meets the following conditions:
The collection is voluntary;
The collection is low-burden for respondents (based on considerations of total burden hours, total number of respondents, or burden-hours per respondent) and is low-cost for both the respondents and the Federal government;
The collection is noncontroversial and does 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;
Personally identifiable information is collected only to the extent necessary and is not retained;
Information gathered is intended to be used only internally for general service improvement and program management purposes and is not intended for release outside of the agency (if released, the agency must indicate the qualitative nature of the information);
Information gathered will not be used for the purpose of substantially informing influential policy decisions; 1 and
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.
If these conditions are not met, the Agency will submit an information collection request to OMB for approval through the normal Paperwork Reduction Act process.
To obtain approval for a collection that meets the conditions of this generic clearance, FinCEN will submit a standardized form to OMB along with supporting documentation (e.g., a copy of the comment card). The submission will be automatically approved, unless OMB identifies issues within five business days.
The types of collections that this generic clearance covers include:
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;
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web surveys); or
In-person observation testing (e.g., website or software usability tests).
The Agency has 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.
Consideration Given to Information Technology.
If appropriate, the agency will collect information electronically and/or use online collaboration tools to reduce burden.
Duplication of Information.
No similar data are gathered or maintained by the Agency or are available from other sources known to the Agency.
Reducing the Burden on Small Entities.
Small businesses or other small entities may be involved in these efforts, but the Agency 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.
Consequences of Not Conducting Collection.
Without these types of feedback, the Agency will not have timely information to adjust its services to meet customer needs.
Special Circumstances.
There are no special circumstances. The information collected will be submitted voluntarily and will not be used for statistical purposes.
Consultations with Persons Outside the Agency.
In accordance with 5 CFR 1320.8(d), on June 10, 2020, a 60-day notice for public comment was published in the Federal Register (85 FR 35507). No comments were received.
Payment or Gift.
The Agency 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, the Agency may provide stipends of up to $40. In the case of in-person focus groups, the Agency 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, the Agency will provide OMB with additional justifications in the request for clearance of these specific activities.
Confidentiality.
If a confidentiality pledge is deemed useful and feasible, the Agency will only include a pledge of confidentiality that is supported by authority established in statute or regulation, that 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 the agency includes a pledge of confidentiality, it will include a citation for the statute or regulation supporting the pledge.
Sensitive Nature.
No questions will be asked that are of a personal or sensitive nature.
Burden of Information Collection.
A variety of instruments and platforms will be used to collect information from respondents. The annual burden hours requested (10,000) are based on the number of collections the Agency expects to conduct over the requested period for this clearance.
Estimated Annual Reporting Burden |
||||
Type of Collection |
No. of Respondents |
Annual Frequency per Response |
Minutes per Response |
Total Hours |
Customer Feedback Surveys |
15,0002 |
1 |
40 |
10,0003 |
Costs to Respondents.
No costs are anticipated.
Costs to Federal Government.
FinCEN submits and receives surveys through electronic means. Based on the surveys submitted to date, FinCEN has determined that each survey requires approximately six (6) man-hours to create and distribute the survey, and analyze the survey results. At the GS-11 Step 1 rate, this results in a cost to FinCEN of $207.06.4
Reason for Change in Burden.
The total burden hours continues to be estimated at 10,000 hours. FinCEN revised its estimate of the time it would take to complete the survey from one hour to between 15 and 40 minutes, which is more consistent with the time required per respondent to complete a FinCEN survey in recent years. FinCEN is conservatively using 40 minutes per survey in order to calculate the total burden hours. FinCEN revised the number of respondents from 10,000 to 15,000 due to the revised estimated time to complete one survey.
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 the Agency does not intend to publish its findings, the Agency may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests). The Agency will disseminate the findings when appropriate, strictly following the Agency'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.
Display of OMB Approval Date.
FinCEN is not requesting an exemption.
Exceptions to Certification for Paperwork Reduction Act Submissions.
These activities comply with the requirements in 5 CFR 1320.9.
1 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.”
2 FinCEN anticipates, on average, sending ten surveys per year to approximately 500 respondents per survey. Over the three-year period requested for approval of this OMB control number that equates to 15,000 responses.
3 FinCEN anticipates the surveys will average 15 to 40 minutes to complete, so FinCEN will conservatively approximate 10,000 burden hours are needed for the three-year period requested for approval of this OMB control number (40 minutes multiplied by 15,000 responses converted to hours).
4 The hourly basic pay plus locality increase for Washington, DC for a GS-11 Step 1 in 2020 is $34.51 (six hours multiplied by $34.51 equals $207.06).
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Mar_S |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |