2020_Generic Clearance for Collection of Qualitative Feedback on Agency Service Delivery_ Supporting Statement

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 Consumer Product Safety
Commission (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.
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. 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 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;
Personally identifiable information (PII) is collected only to the extent necessary 1 and is
not retained;
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 2; 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 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:
•
•
•
•
•
•

1

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)
In-person observation testing (e.g., website or software usability tests)

For example, collections that collect PII in order to provide remuneration for participants of focus groups
and cognitive laboratory studies will be submitted under this request. All privacy act requirements will be
met.
2
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.”

The Agency 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, the Agency will collect information electronically and/or use online collaboration
tools to reduce burden.
4.

Duplication of Information
No similar data are gathered or maintained by the Agency or are available from other sources
known to the Agency.

5.

Reducing the Burden on Small Entities
Small business 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.

6. 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.
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 June 15, 2020, a 60-day notice for public comment was
published in the Federal Register. 0 substantive comments were received.
9. 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. If OMB guidance for the
stipend level is adjusted upward, the stipends may also increase accordingly.
10. 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.
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 total burden hours requested, 3,600, are based on the number of collections we expect to
conduct over the requested period for this clearance. (1,200 hours annually x 3 years.)

Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Annual Frequency
per Response

Hours per
Response

Total Hours

Qualitative Surveys (3)

600

1

.25

150

Focus Groups
Customer Satisfaction Surveys
(3)

200

1

4

800

600

1

.25

150

Usability Tests

200

1

.5

100

Based on the above numbers, the total estimated burden for surveys, focus groups, surveys and
usability tests combined is unlikely to exceed 1,200 hours annually. Thus, assuming an hourly
rate of $37.10 (U.S. Bureau of Labor Statistics, “Employer Costs for Employee Compensation,”
All Civilian Workers, Total compensation, Table 1, December 2019) the total burden cost is
unlikely to exceed $44,520 annually.
13. Costs to Respondents

There are no costs to respondents beyond those presented in Section A.12. There are no
operating, maintenance, or capital costs associated with the collection.

14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $47,545 annually. These costs
are comprised of staff time for preparing questions, analyzing the responses, and conducting
focus groups. We estimate the total staff time could be four staff months annually. This is
based on a GS-12 level salaried employee. The average annual wage rate for a mid-level salaried
GS-12 employee in the Washington, DC metropolitan area (effective as of January 2020) is
$97,848 (GS-12, step 5). This represents 68.6 percent of total compensation (U.S. Bureau of
Labor Statistics, “Employer Costs for Employee Compensation,” December 2020, Table 1,
percentage of wages and salaries for all civilian employees, http://www.bls.gov/ncs/). Adding
an additional 31.4 percent for benefits brings average annual compensation for a mid-range
salaried GS-12 employee to $142,636. Assuming that approximately four staff months will be
required annually, this results in an annual cost of $47,545.
15. Reason for Change
There is no change in the estimated hourly burden of this collection.
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 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.
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.