Supporting Statement
Generic Clearance for the Collection of Qualitative Feedback on
Agency Service Delivery
1651-0136
A. Justification
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’ needs, Customs and Border Protection (CBP) 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 not statistical surveys that yield quantitative results that can be generalized to the population of study.
This collection of information is necessary to enable CBP to garner customer and stakeholder feedback in an efficient, timely manner, in accordance with our commitment to improve service delivery. The information collected from our customers and stakeholders will help ensure that users have an effective, efficient, and satisfying experience with CBP’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 CBP 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, 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. CBP 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 for CBP’s services will be unavailable.
CBP 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 CBP (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, CBP 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)
CBP 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.
When appropriate, CBP collects information electronically and/or use online collaboration tools to reduce burden.
Usability testing is conducted on the “children” surveys of this generic clearance.
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 CBP or are available from other sources known to CBP.
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 CBP 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 consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
Without these types of feedback, CBP will not have timely information to adjust its services to meet customer needs.
Explain any special circumstances.
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.
Public comments were solicited through two Federal Register notices including a 60-day notice published on January 26, 2024 (89, 5251) on which no comments were received, and a 30-day notice published on May 23, 2024 (89, 45670) on which no comments have been received.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
CBP will not provide payment or other forms of remuneration to respondents of its various forms of collecting feedback.
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, CBP 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 CBP 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.
There are no questions of a personal or sensitive nature on this collection.
12. Provide estimates of the hour burden of the collection of information.
A variety of instruments and platforms will be used to collect information from respondents. The annual burden hours requested (51,667) are based on the number of collections we expect to conduct over the requested period for this clearance.
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Type of Collection |
Total Annual Burden Hours |
No. of Respondents |
Responses per Respondent |
Time per Response |
|
Customer Feedback |
51,667 |
620,000 |
1 |
5 minutes/ .0833 hours |
|
Total |
51,667 |
620,000 |
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|
|
Public Cost
The estimated cost to the respondents is $1,054,007. This is based on the estimated burden hours (51,667) multiplied by the average hourly wage rate for all-purpose car travelers ($20.40). CBP used the U.S. Department of Transportation’s (DOT) recommended hourly values of travel time savings for intercity, all-purpose travel by surface modes, which are provided in 2015 U.S. dollars. CBP assumes an annual growth rate of 0 percent; the 2015 U.S. dollar value is equal to the 2023 U.S. dollar value.2
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no record keeping, capital, start-up or maintenance costs associated with this information collection.
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 not have been incurred without this collection of information.
The estimated annual cost to the Federal Government associated with the review of these submissions is $4,557,000. This is based on the number of responses that must be reviewed (620,000) multiplied by the time burden to review and process each response (15 minutes or .25 hours) = 75,000 hours multiplied by the average hourly loaded rate for other CBP employees ($60.76)3 = $4,557,000.
15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13.
There has been an increase in the estimated annual burden hours previously reported for this information collection. The number of respondents and responses has increased to accommodate the additonal requirements for usability testing, burden reduction efforts and customer experience (CX) outreach.
Number of respondents has increased from 300,000 to 620,000 and the burden hours increased from 24,990 to 51,667 hours.
16. For collection of information whose results will be published, outline 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 CBP does not intend to publish its findings, CBP may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests). CBP will disseminate the findings when appropriate and will include specific discussion of the limitation of the qualitative results discussed above.
17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate.
We are requesting no exemption.
18. “Certification for Paperwork Reduction Act Submissions.”
These activities comply with the requirements in 5 CFR 1320.9.
No statistical methods were employed.
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 Source: U.S. Department of Transportation, Office of Transportation Policy. The Value of Travel Time Savings: Departmental Guidance for Conducting Economic Evaluations Revision 2 (2016 Update), “Table 4 (Revision 2 - 2016 Update): Recommended Hourly Values of Travel Time Savings for Intercity, All Purpose Travel by Surface Modes (except High-Speed Rail).” September 27, 2016. Available at https://www.transportation.gov/sites/dot.gov /files/docs/2016%20Revised%20Value%20of%20Travel%20Time%20Guidance.pdf. Accessed August 30, 2023.
3 CBP bases this wage on the FY 2023 salary and benefits of the national average of other CBP positions, which is equal to a GS-11, Step 4. Source: Email correspondence with CBP’s Office of Finance on September 26, 2023.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement |
| Author | Shade Williams |
| File Modified | 0000-00-00 |
| File Created | 2024-07-23 |