Supporting Statement for Paperwork Reduction Generic Information Collection Submissions for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”
OMB Control Number: 1670-0027
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. In order to work continuously to ensure that our programs are effective and meet our customers and stakeholders needs, Cybersecurity and Infrastructure Security Agency (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.
This is an extension request for the existing collection that was initially approved by OMB on 10/05/2014. The evaluation form’s most recent approval obtained on 05/14/2021 and expires on 05/31/2024. There are no substantial changes to the extension request for approval.
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, 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:
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 [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
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 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)
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. Usability Testing will be conducted and will be noted on all generic information collections upon submission to be added. All findings and the mitigations the findings will be noted.
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 2 above.
No similar data are gathered or maintained by the Agency or are available from other sources known to the Agency.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.
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/DHS program or policy activities if the collection of information 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:
There are no special circumstances. The information collected will be voluntary and will not be used for statistical purposes.
8. Federal Register Notice:
a. Provide a copy and identify the date and page number of the publication in the Federal Register of the agency’s notice 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.
b. 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.
c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities 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), a 60-day notice and 30-day notice for public comment was published in the Federal Register.
|
Date of Publication |
Volume # |
Number # |
Page # |
Comments Addressed |
60-Day Federal Register Notice: |
February 15, 2024 |
89 |
32 |
11861-11860 |
0 |
30-Day Federal Register Notice |
May 23, 2024 |
89 |
101 |
45671-45672 |
0 |
A 60-day notice for comments was published in the Federal Register on February 15, 2024. Zero comments were received.
A 30-day notice for comments was published in the Federal Register on 5/23/2024.
9. Explain any decision to provide any payment or gift 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 desired. 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. Generally, estimates should not include burden hours for customary and usual business practices.
A variety of instruments and platforms will be used to collect information from respondents. CISA estimates the total number of annual burden hours for this collection is 125,180, based on the number of collections we expect to conduct over the requested period for this clearance.
Instrument |
Respondents |
Responses per Respondent |
Burden per Response |
Total Burden (hours) |
Loaded Compensation Rate |
Cost |
Customer Satisfaction / Feedback Surveys |
2,500,000 |
1 |
0.05 |
125,000 |
$42.12 |
5,265,562 |
Customer Comment Cards / Complaint |
500 |
1 |
0.1 |
50 |
$42.12 |
2,106 |
Self-Assessment Questionnaire |
80 |
1 |
1 |
80 |
$42.12 |
3,370 |
Small panel/discussion groups |
50 |
1 |
1 |
50 |
$42.12 |
2,106 |
TOTAL |
2,500,630 |
|
|
125,180 |
|
5,273,145 |
NOTES
ON HOUR BURDEN:
*
The above Average Hourly Wage Rate is the May
2022 Bureau of Labor Statistics
average wage for “All Occupations” of $29.76 times the
wage rate benefit multiplier of 1.41551
(to account for fringe benefits) equaling $42.12. The selection of
“All Occupations” (for example) was chosen as the
expected respondents for this collection could be expected to be
from any occupation.
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)
No Costs are anticipated.
14. Provide estimates of 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), and any other expense that would have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.
The anticipated cost to the Federal Government is approximately $ 200,000 annually. These costs are comprised of: contractor payments, printing, postage, staffing salaries, equipment maintenance, focus group incentives. (Explanation of incentives: participants are incentivized based on the amount of time required for full participation in the research. Part of the agreement made with panelists at the time of recruitment is that they will receive small monetary incentives or account credits for completing research. Account credits may be redeemed for products and services of the panelist’s choice, or in some cases may be redeemed in the form of charitable donations to the philanthropy of the panelist’s choice.)
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal government action. These changes that result from new estimates or actions not controllable by the Federal government are recorded as adjustments.
There are no changes to the scope of the generic clearance. The burden calculations were updated to account for changes in loaded compensation rates.
16. For collections of information whose results will be published, outline plans for tabulation 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.
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 reasons that display would be inappropriate.
We are requesting no exemption.
18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.
These activities comply with the requirements in 5 CFR 1320.9.
1 Load factor calculated based on the Employer Cost for Employee Compensation, released on December 15, 2023 (Employer Costs for Employee Compensation News Release - 2023 Q03 Results (bls.gov)), Table 4. Employer Cost for Employee Compensation for Private Industry Workers by Occupational and Industry Group, all private workers. Load Factor (1.4155) = Total Compensation ($41.53) / Wages and Salaries ($29.34).
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement A - Template |
| Author | fema user |
| File Modified | 0000-00-00 |
| File Created | 2024-07-30 |