USAB_Generic ICR Renewal_Supporting Statement_Part A_March 2021

SUPPORTING STATEMENT

Part A

Renewal of Generic Clearance for the Collection of Qualitative Feedback on
Agency Service Delivery

Date: 3/9/2021

United States Access Board

PART A: JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
Executive Orders 12862 and 13571 direct 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. Access Board (hereafter, “Access
Board”) seeks renewal of its existing generic clearance to collect qualitative feedback on the delivery of
agency services and programs. By qualitative feedback, we mean information that provides useful
insights on perceptions and opinions, rather than statistical surveys that would yield quantitative results
that could be generalized to the population of study.
This collection of information is necessary to enable the Access Board to garner customer and
stakeholder feedback in an efficient, timely manner, in accordance with our commitment to improving
our delivery of agency services and programs. The information collected from customers and
stakeholders will help to ensure that our services and programs are delivered effectively and efficiently.
Feedback provided by individuals and entities will provide insights into customer and 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 public-facing agency programs requires ongoing assessment of service delivery in which
feedback from customers and stakeholders plays a key role. The Access Board 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. The solicitation of feedback will target
areas such as: timeliness and efficiency of service delivery; satisfaction with agency programs or delivery
of services; and resolution of service-related complaints or problems. Responses will be assessed to
plan and inform efforts to improve or maintain the quality of service offered to the public. Were this
information not collected, vital feedback from customers and stakeholders would be unavailable and,
thus, could not be used to improve or inform the agency’s delivery of services to the public.
The Access Board will only submit an information collection for approval under this renewed generic
clearance if it meets the following conditions:
•
•
•
•

Information gathered will only be used internally for general service improvement and program
management purposes and is not intended for release outside the agency. (If released,
procedures outlined in Item 16 (below) will be followed.);
Information gathered will not be used for the purpose of substantially informing influential
policy decisions 1;
Information gathered will only be used for qualitative purposes; the information will be neither
designed nor expected to yield statistically reliable results that could be generalized to the
population of study;
Participation is voluntary;

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.”

1

1

•
•
•
•

The collection will be low-burden for respondents (when taking into account total burden hours,
number of respondents, and burden-hours per respondent) and low-cost to both the agency
and respondents;
The qualitative feedback to be collected is non-controversial and will not raise issues of concern
to other federal agencies;
The collection is targeted at gathering feedback from individuals or entities who have
experience with the agency’s public-facing programs/services or may have experience with such
programs in the near future; and
If personally identifiable information (PII) is collected, collection will be minimized to essential
information only and will not be retained beyond applicable agency or federal record schedules.

If a planned information collection fails to meet any of the conditions listed above, the Access Board will
not seek fast-track approval under this generic clearance but will, instead, seek OMB approval through
the normal PRA process.
For information collection requests that do meet the conditions for this renewed generic clearance, the
Access Board will submit an electronic collection request to OMB, along with any needed supporting
materials. Under the fast-track procedures laid out by OMB, these collection requests are automatically
approved after five days, unless OMB identifies issues during this five-day period.
The types of collections that this renewed generic clearance covers include, but are not limited to:
•
•
•
•
•
•

Customer surveys/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 Access Board will designate an agency official to manage this renewed generic clearance, which,
typically, is an attorney within the Office of General Counsel. This individual will independently review
each proposed information collection prior to OMB submission to ensure compliance with the terms of
this clearance.
3. Consideration Given to Information Technology
If appropriate, the Access Board will collect information electronically and/or use online collaboration
tools to reduce the burden to respondents and/or improve accessibility.
4.

Duplication of Information
No similar data are gathered or maintained by the Access Board or 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 information collections but the Access
Board will minimize the burden on them by sampling, asking for readily available information, or using
short, easy-to-complete information collection instruments.

2

6. Consequences of Not Conducting Collection
Without the feedback and other qualitative data collected through this generic clearance, the Access
Board would not have timely and appropriate information from its customers and stakeholders to help
improve or modify its public-facing programs and services.
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 C.F.R. § 1320.8(d), the Access Board published a 60-day notice for public comment
in the Federal Register on December 17, 2020 (86 Fed. Reg. 81875). No comments were received.
9. Payment or Gift
The Access Board does not anticipate providing payment or other forms of remuneration to respondents
for information collections under this generic clearance.
10. Confidentiality
If a confidentiality pledge is deemed useful and feasible, the Access Board will only include a pledge of
confidentiality that is supported by authority established in statute or regulation, has disclosure and
data security policies that are consistent with the pledge, and 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 to appropriate federal law or regulation.
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 under this
generic clearance, including online feedback surveys. The annual burden hours requested (258) are
based on the estimated number of responses we expect to receive annually from collections conducted
under our renewed generic clearance. The estimated total annual time burden is the same as our
existing generic clearance. Presented below in Table A are the estimated annual reporting burdens for
our proposed renewal of this generic clearance:
Table A: Estimated Annual Reporting Burden
Type of Collection
Customer Feedback Surveys:
Office of Technical and
Information Services
Customer Feedback Surveys:
ABA Compliance & Enforcement
Program
Totals:

Number of
Respondents

Response
Frequency

Average Response
Time (mins.)

Total Time
(hours)

3,830

1

4

255

40

1

4

3

3,870

n/a

n/a

258

(Note: Estimates for annual time burdens are rounded to the nearest hour.)
3

13. Costs to Respondents
No costs are anticipated.
14. Costs to Federal Government
We do not anticipate that information collections under this generic clearance will impose costs on the
federal government other than modest staff time for development and administration of the collection
instruments and analysis of results.
15. Reason for Change
Not applicable. This is a request for renewal of an existing generic clearance without change.
16. Tabulation of Results, Schedule, Analysis Plans
Feedback collected under this generic clearance will provide useful information, but will not yield (and is
not aimed at yielding) data that can be generalized to the population of study. Findings will be used for
general service improvement; they are not intended for publication.
Nevertheless, the Access Board may receive requests to release the information (e.g., required federal
reports, congressional inquiries, Freedom of Information Act requests). The Access Board will
disseminate its findings, when appropriate, in compliance with the agency's publicly posted guidelines
for ensuring the quality of information disseminated to the public (https://www.accessboard.gov/about/policy/iq.html). Any such releases will also include specific discussion of the
limitations of the qualitative results.
17. Display of OMB Approval Date
The OMB control number and approval date will be appropriately posted on each approved information
collection that is covered by this generic clearance. We are not requesting an exemption.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
The information collection activities under this generic clearance will comply with the requirements in 5
C.FR. § 1320.9. We do not anticipate seeking any exceptions.

4