Supporting Statement A

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Supporting Statement for
“Generic Clearance for the Collection of Qualitative Feedback on Agency Service
Delivery”
(OMB Control No. 3095-0070)

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 aid in this effort, we must collect
feedback from the public. We seek OMB clearance for this generic information collection, which
allows us to gather qualitative customer and stakeholder feedback in an efficient, timely manner
as part of our commitment to continuously improve service delivery. By qualitative feedback, we
mean information that provides useful insights into customers’ or stakeholders’ perceptions and
opinions, but not statistical surveys that yield quantitative results that we could generalize to the
population. The information collected from our customers and stakeholders will help ensure that
users have an effective, efficient, and satisfying experience with our programs, in compliance
with E.O. 12862.
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. This
feedback provides insights into perceptions, experiences, and expectations, provides an early
warning of issues with service, or focuses attention on areas where communication, training, or
operational changes might improve delivery of products or services. We will not use this
qualitative generic clearance for quantitative information collections designed to yield reliably
actionable results, such as monitoring trends over time or documenting program performance.
We 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 our services will be unavailable.
We will submit a specific information collection for approval under this generic clearance only if
it meets the following conditions:
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·
The collection is voluntary;
·
The collection is low-burden for respondents (based on considerations of total
burden hours, total number of respondents, or burden-hours per respondent) and is
low-cost for both the respondents and the Federal Government;
·
The collection is non-controversial and does not raise issues of concern to other
Federal agencies;
·
It is targeted to solicit opinions from respondents who have experience with the
program or may have experience with the program in the near future;
·
Personally identifiable information (PII) is collected only to the extent necessary[1]
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
(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 [2]; 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, we will submit an information collection request to OMB for
approval through the normal PRA process.
As a general matter, information collections under this generic collection request will not result
in any new system of records containing privacy information and will not ask questions of a
sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that
are commonly considered private.
To obtain approval for a collection that meets the conditions of this generic clearance, we will
submit a standardized form 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 five 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);
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·

In-person observation testing (e.g., website or software usability tests);

We have established an internal review process in which the PRA Clearance Officer conducts an
independent review of each information collection proposed by a program office or function
under this generic clearance umbrella. The PRA Clearance Officer reviews the proposed
collection to ensure it is compliant with the terms of this clearance prior to submitting it to OMB.
3. ​

Consideration given to information technology

We collect information electronically or use online collaboration tools for nearly all of our
current information collections cleared under previous versions of this generic clearance. If the
information collection is not being collected in either of the said processes, then it is solely being
collected in a paper-based format. We will continue to do so with new information collections
under this generic clearance whenever possible.
4. ​

Duplication of information

We do not otherwise gather or maintain similar data, nor are we aware of other sources that
would provide it.
5. ​

Reducing the burden on small entities

Primarily, respondents to collections under this generic clearance will be individuals. However,
some small businesses or other small entities may also make use of our services or facilities and
thus may be asked for information as well. We 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, we will not have timely information to adjust our services to
meet customer needs and improve their use of our records, programs, and facilities.
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 July 23, 2026, we published a 60-day public comment
notice in the Federal Register (91 FR 46487). We received one comment that was not applicable
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to the information collection NARA proposed for renewal because it is not relevant to the
proposed information collection or the agency.
9. ​

Payment or gift

We will not provide payment or other forms of remuneration to respondents of the various forms
of collecting feedback under this clearance, except focus groups and cognitive laboratory studies.
10. Confidentiality
If we deem a confidentiality pledge to be useful and feasible, we will include only 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.
11. Sensitive nature
We do not ask questions that are of a personal or sensitive nature.
12. Burden of information collection
We will use a variety of instruments and platforms to collect information from respondents and
expect to conduct about 26 surveys or other collection activities over the next three years. The
annual burden hour estimate is based on the number of collections we expect to conduct over the
requested period for this clearance. We anticipate about 81,000 respondents to the estimated 26
collections we might conduct over the next three years, with an estimated average of 1,038
respondents per collection each year. Respondents would likely only participate in one
collection.

Type of collection

Qualitative customer
satisfaction surveys

Estimated Annual Reporting Burden
No. of
Annual
Hours per
respondents
frequency per
response
response
81,000

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13. Costs to respondents
We anticipate no costs to respondents other than time.
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10 minutes

Total hours

13,500
(81,000 x 10
mins)

14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $109,000 annually. These costs
comprise staff and overhead.
15. Reason for change
The reason for the decrease is a streamlining of surveys. Many of the surveys were refined in
anticipation of the ICR renewal. With the use of the NARA enterprise tool we were able to
accurately gauge the number of respondents over the last three years and reduce the burden to the
public.
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 overall population. Findings will be used for general service
improvement and may be included as supplemental information in annual reports to Congress.
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.

B.

​ STATISTICAL METHODS

Data collection methods and procedures will vary; however, the primary purpose of these
collections will be for internal management purposes; there are no plans to publish or otherwise
release this information.
1. ​Universe and respondent selection
The activities under this clearance may involve samples of self-selected customers, as well as
convenience samples, with respondents selected either to cover a broad range of customers or
to include specific characteristics related to certain products or services. Results will not be
used to make statements representative of the universe of study, to produce statistical
descriptions (careful, repeatable measurements), or to generalize the data beyond the scope of

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the sample. The specific sample planned for each individual collection and the method for
soliciting participation will be described fully in each collection request.
Qualitative surveys are tools used by program managers to change or improve programs,
products, or services. The accuracy, reliability, and applicability of the results of these
surveys are adequate for their purpose.
The samples associated with this collection are not subjected to the same scrutiny as
scientifically drawn samples where estimates are published or otherwise released to the
public.
2. ​Procedures for collecting information
Data collection methods and procedures will vary and the specifics of these will be provided
with each collection request. We expect to use a variety of methodologies for these
collections. For example, we or our contractors may use commercial survey-specific software
to automate collection and analysis of feedback. In addition to physical copies, information
collection instruments may be electronically disseminated or posted on target pages of our
web site. Telephone scripts, personal interviews, and focus groups with professional guidance
and moderation may also be used.
3. ​Methods to maximize response
Information collected under this generic clearance will not yield generalizable quantitative
findings; it can provide useful customer input, but it does not yield data about customer
opinions that can be generalized. However, we have migrated the National Personnel
Records Center (NPRC) Customer Satisfaction Survey from a paper-based to online survey,
which we believe will cause a significant increase in responses, and we are conducting other
feedback efforts in similar ways to maximize responses.
4. ​Testing of procedures
Pretesting may be done with internal staff, a limited number of external colleagues, or
customers who are familiar with the programs and products. If the number of pretest
respondents exceeds nine members of the public, we will submit the pretest instruments for
review under this generic clearance.
5. ​Contacts for statistical aspects and data collection
Each program will obtain information from statisticians in the development, design, conduct,
and analysis of customer/partner service surveys, when appropriate. This statistical expertise
will be available from agency statisticians or from contractors and we will include the names
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and contact information of people we consult in the specific information collection requests
submitted under this generic clearance.

[1] For example, collections that collect PII in order to provide remuneration for participants of
focus groups and cognitive laboratory studies will be submitted under this request. All Privacy
Act requirements will be met.
[2] 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.”

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