Supporting Statement A for Generic Clearance (06-27-24)

Supporting Statement for Paperwork Reduction Act Generic Information Collection
Submissions for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service
Delivery”
PART A
A. JUSTIFICATION
1. Circumstances Making the Collection of Information Necessary
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. Equal Employment Opportunity
Commission (hereafter “the Agency”) seeks to obtain OMB approval, under the Paperwork
Reduction Act of 1995 (PRA), of a revision to the current 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.
2. Purpose and Use of the Information 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, course materials, course instructor, 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.
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The Agency will only submit a collection for approval under this generic clearance if it meets the
following conditions:
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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 the only way to collect information; there are no alternative existing
sources
The collections are noncontroversial 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;
Personally identifiable information (PII) is collected only to the extent necessary and is not
retained;
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;
Information gathered will not be used for the purpose of substantially informing influential
policy decisions; and
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.

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., copies
of the surveys). The submission will have automatic approval unless OMB identifies issues
within five business days.
The types of collections that this generic clearance covers include, but are not limited to:
•

Qualitative customer feedback surveys (e.g., post-transaction surveys; opt-out web
surveys)

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. Consideration Given to Information Technology
The Agency plans to collect information electronically and/or use online collaboration tools to
the greatest extent possible to reduce burden. The agency anticipates most respondents will
provide feedback electronically.

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4. Duplication of Information
No similar data are gathered or maintained by the Agency or are available from other sources
known to the Agency.
5. Reducing the Burden on Small Entities
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. Consequences of Not Conducting Collection
Without these types of feedback, the Agency will not have timely information to adjust its
services to meet customer needs.
7. Special Circumstances
There are no special circumstances. The information collected will be voluntary and will not be
used for statistical purposes.
8. Consultations with Persons Outside the Agency
In accordance with 5 CFR § 1320.8(d), on March 22, 2024, a 60-day notice for public comment
was published in the Federal Register (See 89 FR 20473). No comments were received from the
public in response to the 60-day notice published in the Federal Register. Accordingly, no
changes have been made to the Generic Clearance.
9. Payment or Gift
The Agency will not provide payment or other forms of remuneration to respondents of its
various forms of collecting feedback.
10. Confidentiality
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. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.
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12. Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents.
The annual burden hours requested (1,250) are based on the number of collections we expect to
conduct over the requested period for this clearance.
Type of Survey

Respondent

Questionnaire:
FEPA-TERO
National Training
Conference
Survey.

Employees of the state
and local Fair
Employment Practices
Agencies and Tribal
Employment Rights
Offices.

550

Number of
Responses /
Respondent
1

Questionnaire:
EXCEL Training
Conference
Evaluation Survey.

Private sector, state, and
local government sector
EEO managers,
supervisors,
practitioners, HR
professionals, attorneys,
ADR specialists and
other interested parties.

310

1

10 minutes
per response

52

Questionnaire:
EEOC Training
Institute Respectful
Workplace Course
Evaluation.

Private sector, state, and
local government sector
employers and
employees

5,000

1

5 minutes per
response

417

Questionnaire:
EEOC Training
Institute Course
Evaluation.

Private sector human
resources staff, business
owners, managers,
supervisors, state and
local government
employers and
employees.
Private sector human
resources staff, business
owners, managers,
supervisors, state and
local government
officials, employment
agency staff, union
officials, attorneys, and
others interested in EEO
issues.
Private sector human
resources staff, business
owners, managers,
supervisors, state and
local government
officials, employment

6,000

1

2 minutes per
response

200

2,170

1

2 minutes per
response

72

2,170

1

2 minutes per
response

72

Questionnaire:
EEO In-Person
Workshop
Evaluation Survey.

Questionnaire:
EEO Virtual
Workshop
Evaluation Survey.

Number of
Respondents

4

Participation
Time
3 minutes per
response

Response
burden
(in hours)
27.5

Type of Survey

Questionnaire:
National External
Engagement
Program Survey.

Respondent
agency staff, union
officials, attorneys, and
anyone else interested
in EEO issues.
Attendees at Outreach
and Training educational
events.

Number of
Respondents

Number of
Responses /
Respondent

2,500

1

5 minutes per
response

208

Participation
Time

Response
burden
(in hours)

Questionnaire:
Federal Course
and Customer
Specific Training
Feedback Survey.
Questionnaire:
Federal Education
Consortium
Registration.
Questionnaire:
Request for
Federal Training
and Outreach
services.

Non-federal learners in
federal courses and
customized customerspecific training.

225

1

2 minutes per
response

7.5

Non-federal Education
Consortium registrants.

50

1

2 minutes per
response

2.0

Non-federal entities
requesting outreach or
fee-based training.

20

1

2 minutes per
response

<1

EEOC Website
Satisfaction
Survey.
Future Training
Assessments.

Individuals or
Households.

3,270

1

2 minutes per
response

109

Future Training
Attendees.

1,000

1

5 minutes per
response

83

Total

23,265

1,250

13. Costs to Respondents
No costs are anticipated.
14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $72,633 annually. These costs
are comprised of: staff time related to production and dissemination of the survey materials and
analysis of responses, and for costs related to survey software.
15. Reason for Change
In addition to clearance hours for the previously approved customer feedback forms, the EEOC
is also requesting an additional 1,000 clearance hours as a reserve to cover any additional
feedback forms that may be developed over the next three years for new trainings offered by the
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EEOC. The EEOC anticipates any new potential feedback forms will be similar in length and
content to existing feedback forms. The EEOC plans to seek clearance for the additional hours so
the EEOC can use the existing clearance number if the need arises for additional training and
feedback forms.
16. Tabulation of Results, Schedule, Analysis Plans
Feedback collected under this generic clearance provides useful information, but it does not yield
data that can be generalized to the population of study. 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 in response to such requests when appropriate under
applicable federal privacy and confidentiality laws.
17. Display of OMB Approval Date
We are requesting no exemption.
18. Exceptions to Certification for Paperwork Reduction Act Submissions
These activities comply with the requirements in 5 CFR § 1320.9.

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