0938-1382.Justification of Non-sub Change (Burden Ceiling Increase)-2-20-24

To: Jamie Wilson

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: William Parham

Division of Information Collections and Regulatory Impacts

Office of Strategic and Regulatory Affairs

Date: February 20, 2024

Subject: Non-Substantive Change Request – Generic Clearance for Improving Customer Experience: OMB Circular A-11, Section 280 Implementation (OMB# 0938-1382; CMS-10710)

This memo requests approval of non-substantive changes to the approved information collection, Generic Clearance for Improving Customer Experience: OMB Circular A-11, Section 280 Implementation (OMB# 0938-1382; CMS-10710)

Background

On September 11, 1993, Executive Order 12862, “Setting Customer Service Standards” was issued. This Executive Order expressed the vision that Federal agencies will put the people first. Executive Order 12862 directs Federal agencies to provide service to the public that matches or exceeds the best service available in the private sector. Section 1(b) of Executive Order 12862 requires government agencies to “survey customers to determine the kind and quality of services they want and their level of satisfaction with existing services” and Section 1(e) requires agencies “survey front-line employees on barriers to, and ideas for, matching the best in business.”

On March 30, 2016, the Core Federal Services Council was established. The Council emphasized the need to deliver world-class customer service to the American people. The Council, composed of the major high-volume, high-impact Federal programs that provide transactional services directly to the public, were encouraged “to improve the customer experience by using public and private sector management best practices, such as conducting self-assessments and journey mapping, collecting transactional feedback data, and sharing such data with frontline and other staff.”

In March 2018, the President’s Management Agenda (PMA) and new Cross-Agency Priority (CAP) Goals were launched. Excellent service was established as a core component of the mission, service, stewardship model that frames the entire PMA, embedding a customer-focused approach in all of the PMA’s initiatives. This model was also included in the 2018 update of the Federal Performance Framework in Circular A-11, ensuring ‘excellent service’ as a focus in future agency strategic planning efforts. The PMA included a CAP Goal on Improving Customer Experience with Federal Services, with a primary strategy to drive improvements within 25 of the nation’s highest impact programs. This effort is supported by an interagency team and guidance in Circular A-11 requiring the collection of customer feedback data and increasing the use of industry best practices to conduct customer research.

From 2021­-2023, Executive Order 14058, Transforming Customer Experience and Service Delivery to Rebuild Trust in Government, Memorandum M-22-10, Improving Access to Public Benefits Program Through the Paperwork Reduction Act, and an OIRA Memorandum titled Strategies for Reducing Administrative Burden in Public Benefit and Service Programs were issued. The Executive Order and memoranda, taken as a whole, direct agencies to take specific actions to improve customer experience and enhance public participation and community engagement. Furthermore, the President’s Management Agenda contains a Priority titled Delivering Excellent, Equitable, and Secure Federal Services and Customer Experience, which, among other things, seeks to improve the service design, digital products, and customer-experience management of Federal High Impact Service Providers, including CMS, by reducing customer burden, addressing inequities, and streamlining processes.

These Presidential actions and requirements establish an ongoing process of collecting customer insights and using them to improve services. This new request will enable the Centers for Medicare and Medicaid Services (hereafter “the Agency”) to act in accordance with OMB Circular A-11 Section 280, Executive Order 14058, and the OMB memoranda on burden reduction, to ultimately transform the experience of its customers to improve both efficiency and mission delivery and increase accountability by communicating about these efforts with the public.

This Fast Track information collection request was last approved by OMB on December 13, 2023, and expires December 31, 2026.

Overview of Requested Changes

CMS is not changing any of the burden associated with the active collections (GenICs) currently approved under this OMB control number (see below). However, CMS is requesting that the burden ceiling for this information collection request be raised. The current ceiling is 133,933 hours and the four active GenICs account for all 133,933 hours.

CMS is requesting to add additional burden hours for the activities highlighted in the following table.

Active Collections (as of 01/31/2024)
CMS-10710.GenIC#4. Healthcare.gov Web Satisfaction Survey	1,600
CMS-10710.GenIC#5 - Medicare.gov Web Sat Survey	24,000
CMS-10710.GenIC#6 - Marketplace IVR Customer Sat	25,000
CMS-10710.GenIC#7 - Medicare IVR Customer Sat Survey	83,333
Subtotal (Active)	133,933
CMS-10710.GenIC#8 - High Impact Trust Survey Medicare	500
Information Collection Activities Related to User Testing for Model Notices (currently under development)	20,000
New Total	154,433