Supporting Statement for Fast Track Generic Clearance Extension 2024

U. S. OFFICE OF GOVERNMENT ETHICS

SUPPORTING STATEMENT FOR FAST TRACK GENERIC CLEARANCE FOR THE

COLLECTION OF QUALITATIVE FEEDBACK ON AGENCY SERVICE DELIVERY

September 2024

A. Justification

1.-2. Explain the circumstances that make the collection of information necessary.

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.

Executive Order 12862 (Sept. 11, 1993) directs Federal agencies to provide service to the public that matches or exceeds the best service available in the private sector. To ensure that the agency is effective and meeting our users’ needs, the U.S. Office of Government Ethics (OGE) seeks to obtain OMB approval to extend a Generic Clearance to collect qualitative feedback on our products and services. If this information is not collected, vital feedback from stakeholders on the agency’s services will be unavailable.

OGE expects to use various methods (e.g., focus groups, satisfaction surveys) to solicit feedback. Responses will be assessed to plan and inform efforts to improve or maintain the quality of service offered to the public and other agency stakeholders. This feedback will provide insights into stakeholder perceptions, experiences, and expectations, provide an early warning of issues with service, and 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 stakeholders. It will also allow feedback to contribute directly to the improvement of program management.

The agency will only submit a collection for approval under this Generic Clearance if it meets the following conditions:

• 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 noncontroversial;

• The collections are focused on the awareness, understanding, attitudes, preferences, or experiences of the public or other stakeholders in order to improve existing or future services, products, or communication materials;

• Personally identifiable information (PII) is collected only to the extent necessary;

• Information gathered will be used only internally for general service improvement and program management purposes and is not intended for release to the public;

• Information gathered will not be used for the purpose of substantially informing influential policy decisions; and

• Information gathered will yield qualitative information, and 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.

If these conditions are not met, OGE 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 new generic information collection will be submitted to OMB along with supporting documentation (e.g., a copy of the comment card). Under OMB’s Fast Track Process, approval will be automatically granted within five business days from receipt unless OMB raises concerns.

OGE currently has one collection approved under this Generic Clearance and is resubmitting it for re-approval with this Generic Clearance. This information collection is a voluntary user feedback survey directed at individuals who have visited the webpage for the OGE Form 201 Request for Ethics Records and/or submitted a request.

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.

If appropriate, OGE will collect information electronically and/or use online collaboration tools to reduce burden. For example, website feedback surveys would be collected electronically. OGE attempts to collect and manage information electronically whenever possible to reduce the burden on the public and its other stakeholders, as well as for administrative efficiency.

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 information is gathered or maintained by OGE or is available from other sources known to OGE.

5. If the collection of information impacts small businesses or other small entities,

describe any methods used to minimize burden.

It is unlikely that small businesses or other small entities will be involved in these efforts. OGE will minimize burden resulting from information collections approved under this clearance through 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 the burden.

If this information is not collected, vital feedback from stakeholders on the agency’s services will be unavailable, and OGE will not have timely information to adjust its services to meet stakeholder 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 3 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 a statistical data classification that has not been reviewed and approved by OMB;

• That includes a pledge of confidentiality 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 that unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secrets or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

No such special circumstances exist.

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.

OGE published a first round Federal Register notice soliciting comments on this information collection on June 17, 2024. See 89 FR 51344. OGE did not receive any comments in response. OGE published a second round Federal Register notice soliciting comments to be directed to reginfo.gov on September 10, 2024. See 89 FR 73419.

9. Explain any decision to provide any payment or gift to respondents, other than

remuneration of contractors or grantees.

Not applicable. Respondents receive no payments or gifts.

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, OGE 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 consistent with the pledge, and that does not unnecessarily impede sharing of data with other agencies for compatible confidential use. If OGE 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.

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.

OGE estimates an average of approximately 91,555 responses each year for the next three years, totaling an estimated annual 4030 burden hours for all types of anticipated activities. This was calculated based on the anticipated number of respondents to potential small discussion groups, in-person and web feedback surveys, and requests for feedback related to OGE’s Strategic Plan and E.O. 13985 activities, which are the types of collections anticipated to be covered under this Generic Clearance.

Based on industry web survey response rates, OGE estimates that 90,000 website visitors per year will respond to web surveys. The average time per response is estimated to be 2 minutes, which means the annual burden hours is estimated to be 3,000 hours.

OGE estimates an average of 30 responses per year to outreach soliciting feedback on OGE Form 201 Request for Ethics Records, with an average of 60 minutes per response. Therefore, OGE estimates an annual burden of 30 hours for this type of information collection.

OGE estimates an average of 100 responses per year to outreach soliciting feedback on OGE’s 2027-2031 Strategic Plan, with an average of 60 minutes per response. Therefore, OGE estimates an annual burden of 100 hours for this type of information collection.

OGE estimates an average of about 300 responses per year to feedback surveys regarding its International Program, with an average of 5 minutes per response. Therefore, OGE estimates an annual burden of 25 hours for this type of information collection.

OGE estimates an average of about 125 responses per year to feedback surveys and/or discussion groups regarding the activities of its Institute for Ethics in Government, with an average of 180 minutes per response. Therefore, OGE estimates an annual burden of 375 hours for this type of information collection.

With regard to collecting feedback related to Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, OGE estimates an average of 5 activities a year with an average of 200 participants each, which equals an average of about 1,000 responses a year. The average time per response is estimated to be 30 minutes, which means the annual burden hours is estimated to be 500 hours.

The frequency for all these information collections will be occasional.

The total annual burden estimated for all of these activities is 4030 hours.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers

resulting from the collection of information.

No costs are anticipated.

14. Provide an estimate of annualized costs to the Federal Government.

No additional expenses that would not have been incurred without this collection

of information are anticipated.

15. Explain the reasons for any program changes or adjustments reported in items

13 or 14.

OGE continues to estimate that this collection of information will not impose any costs on respondents, recordkeepers, or the Federal Government that otherwise would not have been incurred.

16. For collections 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 any larger populations. Findings will be used for general service improvement and are not for publication or other public release. Although OGE does not intend to publish its findings, OGE may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests). OGE will disseminate the findings when appropriate, strictly following OMB’s "Standards and Guidelines for Statistical Surveys,” 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.

OGE is requesting no exemption.

18. Explain each exception to the topics of the certification statement identified in

Certification for Paperwork Reduction Act Submissions.

Not applicable.

B. Collections of Information Employing Statistical Methods

Not applicable. This collection of information does not employ statistical methods.