Department of Labor Generic Clearance for the Collection of Feedback on Agency Service Delivery.
OMB Control Number 1225-0088
OMB Expiration Date: 1/31/2024
SUPPORTING STATEMENT FOR
Department of Labor Generic Clearance for the Collection of Feedback on Agency Service Delivery
This ICR is requesting the extension of a currently approved data collection.
JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Executive Order 12862 directs Federal agencies to provide service to the public that matches or exceeds the best service available in the private sector. To work continuously to ensure that our programs are effective and meet our customers’ needs, the U.S. Department of Labor (hereafter “the Agency”) seeks to obtain OMB approval of a generic clearance to collect feedback on our service delivery. This collects information that provides useful insights on perceptions and opinions that are not surveys that yield 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. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
Improving agency programs requires ongoing assessment of service delivery which DOL defines as the systematic review of the operation of a program compared to a set of explicit or implicit standards all 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:
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 decisions1;
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
With the exception of information needed to provide remuneration 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 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 five (5) business days.
The types of collections that this generic clearance covers include, but are not limited to:
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 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. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.
If appropriate, agencies will collect information electronically and/or use online collaboration tools to reduce burden.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item A.2 above.
This information collection does not duplicate data collection efforts. No similar data are either gathered or are available from other sources known to the DOL staff.
5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
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. Describe the consequence to federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Without these types of feedback, the Agency will not have timely information to adjust its services to meet customer needs.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
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 statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentially 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 confidentially to the extent permitted by law.
There are no special circumstances. The information collected will be voluntary and will not be used for statistical purposes.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection-of-information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
In accordance with 5 CFR 1320.8(d), on July 26, 2023, the DOL published a notice in the Federal Register (88 FR 48265) to announce a 60-day public comment period. No comments were received.
9. Explain any decision to provide any payments or gifts to respondents, other than remuneration of contractors or grantees.
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. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
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.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
No questions will be asked that are of a personal or sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. General, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
No. of Respondents |
No. of Responses per Respondent |
Total Responses |
Average Burden (Hours) |
Total Burden (Hours) |
Hourly Wage Rate |
Total Burden Cost |
400,000 |
1 |
400,000 |
.100 |
40,000 |
$29.76 |
$1,190,400 |
With each individual survey instrument/evaluation form submitted to OMB, specific burden estimates will be provided. These estimates will include the total number of respondents, frequency of collection, average minutes/hours per response, and total burden hours and burden hour costs.2
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).
The cost estimate should be split into two components: (a) a total capital
and start up cost component (annualized over its expected useful life); and (b) a
total operation and maintenance and purchase of service component.
The estimates should take into account costs associated with generating,
maintaining, and disclosing or providing the information. Include descriptions of
methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
No capital costs or maintenance costs are anticipated.
14. Provide estimates of the annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.
These costs are comprised of developing and printing paper or developing Web-based instruments and Federal employee or contractor time to develop and to review instruments before they are used and to review answers for each submitted collection. Based on an anticipated 60 submissions, the DOL estimates Federal costs will be approximately $360,000. 3 Additional information regarding the Federal cost for each activity to be extended, changed, or updated may be found in the supplemental justification supporting statement that has been uploaded for each individual collection in the reginfo.gov database.
15. Explain the reasons for any program changes or adjustments.
There was an increase in burden hours from 38,000 to 40,000 due to an increase in respondents, from 380,000 to 400,000 and responses from 380,000 to 400,000. Costs to respondents remained 0.
16. For collections of information whose results will be published, outline plans for tabulations, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
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. General purpose statistical methods may be employed for internal purposes in order to help understand the set of responses within themselves.
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. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
This collection is not seeking approval to not display the expiration date for OMB approval of the information collection.
18. Explain each exception to the certification statement.
These activities comply with the requirements in 5 CFR 1320.9.
B. COLLECTIONS OF INFORMATON EMPLOYING STATISTICAL METHODS.
The Supporting Statement Part B is uploaded into the ICR as a separate document.
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 The estimated hourly costs (salary plus benefits) are based on the figures for 2022 posted by the Bureau of Labor Statistics for the Utilities sector (available at https://www.bls.gov/oes/current/oes_nat.htm#00-0000) and updated (issued May, 2022) for benefits information. The hourly estimate for salary plus benefits is $29.76 (Occupation Code: 00-0000).
3 $300,000/50 events = $6,000 per event. $6,000 per event x 60 events = $360,000.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Anthony May |
| File Modified | 0000-00-00 |
| File Created | 2023-12-12 |