Supporting Statement A--Qualitative Feedback on Agency Service Delivery

Supporting Statement for Request for Extension of Previously Approved 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 U.S. International Trade
Commission (hereafter “the Agency”) seeks to obtain Office of Management and Budget
approval of an extension of the previously approved 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
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 the feedback received. 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:

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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 agency (if released,
procedures outlined in (16) Plans for tabulation and publication 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
Except for 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, 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, 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:
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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);
and
In-person observation testing (e.g., website or software usability tests).

The Agency has established a manager/managing entity to handle 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.
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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(3) Information technology
If appropriate, the Agency will collect information electronically and/or use online collaboration
tools to reduce burden.
(4) Non-duplication
No similar data are gathered or maintained by the Agency or are available from other sources
known to the Agency.
(5) Small businesses

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) Consequence of non-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

In accordance with 5 C.F.R. § 1320.8(d), on September 22, 2020, the Agency published a 60-day
notice for public comment in the Federal Register. The Agency received no comments.
(9) Payments or gifts to respondents
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.
(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
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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.
(11) Sensitive information

No questions will be asked that are of a personal or sensitive nature.
(12) Estimates of burden
A variety of instruments and platforms will be used to collect information from respondents.
The annual burden hours requested are based on the number of collections we expect to
conduct over the requested period for this clearance.
Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Feedback surveys (for
Commission investigation
processes)

Annual
Frequency per
Response

600

Hours per
Response

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Total
Hours

0.5

300

(13) Total annual cost burden

No costs are anticipated.

(14) Annualized cost to the Federal Government

The anticipated costs to the Federal Government total approximately $14,382.
The estimated personnel and operational costs cover survey development (design and field
testing), distribution, and compilation. Personnel costs reflect 180 hours x $79.90/hour for
Commission staff. The hourly rate estimate for Commission staff reflects the FY 2020 average
hourly rate for salaries plus benefits. Other operational expenses are estimated to be minimal
because the Commission anticipates using existing equipment and staff design, program,
distribute, and compile surveys.
(15) Program changes and/or adjustments

Past attempts at service feedback questionnaires have been successful, and the Commission
attempts to not over survey any one program. As such, over time as more programs are being
assessed, the number of response sand total response time have decreased. The commission
will continue to use this generic clearance in the way it has in the past and survey different
programs but has seen a reduction in the total number of burden hours over time for this
generic clearance.

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(16) 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 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) Approval to not display the expiration date for OMB approval

We are requesting no exemption.

(18) Consistency with 5 C.F.R. § 1320.9 guidelines

These activities comply with the requirements in 5 C.F.R. § 1320.9.

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