PBGC Response to OMB Qs

RE OMB comments on PBGC generic clearance request.htm

Customer Service Focus Groups and Surveys

PBGC Response to OMB Qs

OMB: 1212-0053

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From: Klion Catherine [Klion.Catherine@pbgc.gov]
Sent: Wednesday, December 20, 2006 11:51 AM
To: Potter, Rachel F.
Cc: Gabriel Tom; Hanley John; Forbes Deborah; O'Donnell Megan
Subject: RE: OMB comments on PBGC generic clearance request

Follow Up Flag: Follow up
Flag Status: Red

Attachments: Generic Clearance Template ver 21 Dec 06.doc
Rachel,
Per our conversation yesterday, following are PBGC's responses to your questions on PBGC information collection 1212-0053.  If you want to discuss this matter further, please call me at 202-326-4223, ext. 3041, or Tom Gabriel at the same number, ext. 3898.  Happy Holidays!
Cathy
 

QUESTION 1:

 

Please provide a few examples of previous surveys and focus groups that you have received approval for under PBGC's generic clearance authority.

 

RESPONSE:

 

  • November 2006.  Survey of new premium filers to determine customer satisfaction levels relating to sponsors of newly established defined benefit pension plans.  No incentives. 
  • May 15, 2006Series of one-on-one usability tests of the MyPBA Ariel Integration Application to help PBGC evaluate whether the proposed enhancement to the MyPBA on-line program meets its intended purpose of allowing PBGC customers to generate an estimated benefit statement using PBGC’s web site. $75 + light refreshments. 
  • July 2005 and January 2006Two telephone surveys to obtain customer satisfaction opinions from pension plan participants who filed appeals with PBGC during calendar year 2005.  No incentives.  
  • October 28, 2004Focus group with 13 pension practitioners (e.g., plan administrators or actuaries) to obtain their opinion on a variety of documents used to communicate account status in PBGC’s Premium and Practitioner System.  The October 28 focus group followed-up the session held in January 2003.  Light refreshments but no stipend.
  • May 2004.  Six focus groups with participants in the Bethlehem Steel and National Steel pension plans to help PBGC improve its level of customer service to participants in these and other PBGC-trusteed plans.  The focus group members were drawn from non-pay status hourly workerspay status hourly workers, and salaried employees (pay status or non-pay status).  $50 stipend + light refreshments.
  • November 2002.  Six focus groups with participants in the LTV Steel pension plans to provide customer feedback on service and communications issues that were used to drive improvements in service delivery processes. Four focus groups were held with participants not yet in pay status (non-pay status), one with participants currently in pay status but whose benefits had been adjusted, and one with participants currently in pay status who remember receiving a letter stating that their benefit were not being adjusted at that time.  One of the non-pay status focus groups consisted of management employees; the other three were made up of union/hourly wage employees.  $50 stipend + light refreshments.
  • July 2001.  Customer service opinion survey of vendors who submitted invoices to PBGC from 10/1/00 to the survey approval date. No incentives. 
  • January 2001.  Survey of PBGC web site users to determine customer satisfaction levels with web pages that provide information to participants and beneficiaries about their pension plans and their benefits.  Respondents were anonymous; the survey did not request names or other personal identifiers and did not involve use of a "cookie." No incentives.
  • March 27, 2000.  Focus group on customer service topics with 14 actuaries selected from among attendees at the 25th annual "Enrolled Actuaries Meeting" hosted by the American Academy of Actuaries and the Conference of Consulting Actuaries (on-site at the Meeting). No stipend; light refreshments likely provided by hosts.

QUESTION 2:

 

The supporting statement (p. 1) indicates that PBGC is requesting approval of "an extension and an expansion" of this OMB number.  Please explain how this request is an expansion.

 

RESPONSE:

 

The supporting statement’s reference to “an expansion” was an editing error resulting from the use of a previous supporting statement as a template for the current version.  The “expansion” approved in 2000 allowed the 1212-0053 collection to (a) encompass a broader range of surveys than those approved to date (i.e., surveys only as an adjunct to focus groups, and (b) subsume the collections approved under OMB Control Numbers 1212-0056 (expired 6/30/00) and 1212-0058 (expired 11/30/01), which provided for customer service mail surveys.

 

QUESTION 3: 

 

In working with other agencies, I have found it effective to have the agency submit the supporting statement information in a generic template format.  A complete generic submission would generally include the template and the instrument.  This expedites our review by ensuring upfront that the agency has submitted all of the information we will require for the generic request.  I have attached a sample generic template used by another agency.  Please review, make any necessary accommodations to tailor to PBGC's needs, and send back to me.  Note that any policy decisions we agree to at this stage (e.g., incentive amounts) should be included in the template.

 

RESPONSE: 

 

See PBGC's proposed changes (attached).

 

QUESTION 4:

 

OMB and PBGC have previously discussed incentive amounts for generics surveys.  What level of incentives (and for whom) have you requested in the past?  What is the range? 

 

RESPONSE: 

 

See response to question # 1, above.

 

QUESTION 5:

 

Note that OMB will only approve generics that gauge customer satisfaction on services directly (or in very limited cases indirectly) provided by PBGC.  To give you a sense of what the appropriate scope for generics is, I have attached below a draft of the terms of clearance that I plan to include with this collection.  Let me know if you have specific questions.

 

Conditions of clearance stated by Rachel Potter:

 

This generic clearance for PBGC customer service surveys is approved under the following conditions:

 

1. PBGC shall use the generic clearance only for customer satisfaction and web site user surveys where the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions. 

 

2. PBGC shall use the generic focus group authority only for customer satisfaction and web site user feedback when the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions.  Focus groups should be of limited size and scope.

 

3. For individual surveys or focus groups, PBGC shall submit a generic clearance request in ROCIS along with an abbreviated supporting statement in the template agreed to by OMB and PBGC.  This statement shall include all relevant information, including a statement of need, intended use of information, description of respondents, information collection procedures, expected response rate, justification for incentive, estimated burden.

 

4. OMB will respond with clearance or questions within 10 working days.

 

RESPONSE: 

 

We propose that item one be revised to read as follows: 

 

PBGC shall use the generic clearance to collect customer satisfaction data (via surveys, focus groups or software usability testing sessions) where the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions.  PBGC may consider customer satisfaction data among other relevant factors in formulating policy or allocating resources. 

 

We also suggest deleting the first sentence in item 2 as unnecessary.

 


From: Potter, Rachel F. [mailto:Rachel_F._Potter@omb.eop.gov]
Sent: Thursday, December 14, 2006 12:58 PM
To: Klion Catherine; Gabriel Tom
Subject: OMB comments on PBGC generic clearance request

Cathy and Tom,
 
Attached below please find OMB's comments on PBGC's generic clearance request (1212-0053).  Let me know if you have any questions.
 
Thanks,
Rachel
  1. Please provide a few examples of previous surveys and focus groups that you have received approval for under PBGC's generic clearance authority.
  2. The supporting statement (p. 1) indicates that PBGC is requesting approval of "an extension and an expansion" of this OMB number.  Please explain how this request is an expansion.
  3. In working with other agencies, I have found it effective to have the agency submit the supporting statement information in a generic template format.  A complete generic submission would generally include the template and the instrument.  This expedites our review by ensuring upfront that the agency has submitted all of the information we will require for the generic request.  I have attached a sample generic template used by another agency.  Please review, make any necessary accommodations to tailor to PBGC's needs, and send back to me.  Note that any policy decisions we agree to at this stage (e.g., incentive amounts) should be included in the template.
  4. OMB and PBGC have previously discussed incentive amounts for generics surveys.  What level of incentives (and for whom) have you requested in the past?  What is the range?         
  5. Note that OMB will only approve generics that gage customer satisfaction on services directly (or in very limited cases indirectly) provided by PBGC.  To give you a sense of what the appropriate scope for generics is, I have attached below a draft of the terms of clearance that I plan to include with this collection.  Let me know if you have specific questions.

This generic clearance for PBGC customer service surveys is approved under the following conditions:

1) PBGC shall use the generic clearance only for customer satisfaction and web site user surveys where the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions.
2) PBGC shall use the generic focus group authority only for customer satisfaction and web site user feedback when the agency seeks to gather information for general service improvement, not for publication or for the purpose of informing significant policy or resource allocation decisions.  Focus groups should be of limited size and scope.
3) For individual surveys or focus groups, PBGC shall submit a generic clearance request in ROCIS along with an abbreviated supporting statement in the template agreed to by OMB and PBGC.  This statement shall include all relevant information, including a statement of need, intended use of information, description of respondents, information collection procedures, expected response rate, justification for incentive, estimated burden.
4) OMB will respond with clearance or questions within 10 working days.

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