Mini-Supporting Statement

Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback” (OMB Control Number 1615-0126)

TITLE OF INFORMATION COLLECTION:

National Survey of E-Verify Employers Pretest

PURPOSE:

The United States Citizenship and Immigration Services (USCIS) requests OMB approval to conduct a formal pretest of the revised 2013 questionnaire for the 2015 National Survey of E-Verify Employers (Attachment A). The Information Collection Request to conduct the full survey as a continued data collection in 2015 will be submitted to OMB at a later date. USCIS has contracted Westat to conduct this biennial study.

USCIS has been conducting national surveys of employers enrolled in E-Verify and its predecessor programs almost biennially since 2000. The most recent surveys conducted in 2010 and 2013 were designed to:

• Provide a profile of E-Verify employers and describe why they use E-Verify;

• Assess the extent to which E-Verify is meeting its goals to reduce unauthorized employment, reduce verification-related discrimination, prevent undue burden on employers, and protect privacy and workers’ civil liberties;

• Examine how well employers understand and comply with E-Verify requirements;

• Assess the extent to which employers are satisfied with E-Verify features and resources and communication with USCIS; and

• Examine the impact of ongoing enhancements to E-Verify and describe how E-Verify can be further improved in the future.

As a continued data collection, the 2015 survey will build upon the earlier evaluations and address major programmatic changes since 2013. To draft the questionnaire for the new study, Westat established a working group of USCIS content experts, our in-house survey methodologist, and USCIS’ E-Verify evaluation researchers to identify new topics and assess the relevance, usefulness, and burden of each 2013 survey item in relation to the core goals of E-Verify and changes in the Program. Westat developed a pretest draft of the 2015 survey by incorporating feedback from two working group meetings to add new items and modify or drop a significant number of items from the 2013 survey. However, most of the 2015 items were directly adapted from the 2013 survey (See Attachment A for the 2015 pretest draft of the survey).

The primary purpose of the pretest is to identify and correct any potential issues with new and modified items before conducting full scale implementation of the 2015 survey. Thus, we will use cognitive interviewing techniques to conduct focus groups with E-Verify employers to assess whether:

• New and substantially modified survey questions are clear;

• Questions convey the intended meaning;

• The information requested is available; and

• Questions require an excessive amount of time to complete.

The research team assigned to the study will conduct these focus groups using WebEx, a Web hosting service for integrated teleconferencing.

There is no other similar information currently available to assess the impact of ongoing E-Verify changes on a changing population of users. As the population changes with federal and state legislation requiring E-Verify participation, the new data collection will track potential shifts in employer perceptions of the Program, how it is used, and levels of compliance with E-Verify procedures.

DESCRIPTION OF RESPONDENTS:

Westat will conduct a pretest of the paper version of the survey with up to 30 companies in the United States that enrolled in E-Verify, transmitted cases to E-Verify within six months preceding the pretest, and ever received Tentative Nonconfirmations (TNCs). Using employer-level background data from the E-Verify Transaction Database, Westat will select different types of employers to reflect characteristics that are critical to the study: that is, company size, whether the company had federal or state requirements to use E-Verify, and whether the company recently received a TNC for workers. To select the pretest sample, employers will be grouped into employment agencies and non-employment agencies and into four categories of company size: (small, medium-sized, large, and very large companies). ¹ Among non-employment agencies, employers will be further grouped by whether they have state or Federal mandates to use E-Verify and whether they received a TNC since September 2013.

We expect to select employers for up to five focus groups, each with no more than 6 to 7 employers each for a total of about 30 employers. Groups will be fairly homogeneous, with four groups comprised of non-employment agencies of different sizes, and one group of employment agencies only, regardless of size. (Each group may include both mandated and voluntary E-Verify users as well as those who received a TNC since September 2013 and those who received one before then.²)

Pretest participants will be recruited via telephone calls from a few experienced interviewers and will be those persons who are identified as the company’s most knowledgeable user of E-Verify. Callers will recruit participants for the focus groups using the recruitment scripts in Attachment C. Following telephone recruitment, interviewers will email the pretest draft questionnaire and cover letter to participating employers (Attachments A and B).

To minimize respondent burden for the pretest, different groups will be asked to complete selected portions of the survey and to examine a specific set of questions that need to be pretested carefully. However, to assess the overall burden of completing the entire questionnaire, two participants from each group will be asked to complete the entire questionnaire. All participants will be asked to review, complete, and return their paper version of the questionnaire with any notes or comments on the questions. They will also be invited to participate in a focus group via WebEx from their own offices to discuss their feedback on the survey items. The moderator guide for the focus groups will be designed to examine questionnaire items that are assigned to each focus group. A list of questionnaire items for all focus groups and the baseline discussion questions for each item is presented in Attachment D.

TYPE OF COLLECTION: (Check one)

[ ] Customer Comment Card/Complaint Form [ ] Customer Satisfaction Survey

[ ] Usability Testing (e.g., Website or Software) [ ] Small Discussion Group

[X] Focus Group [ ] Other: _____________________

Focus groups will be conducted through online sessions via WebEx.

CERTIFICATION:

I certify the following to be true:

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the Federal Government.

3. The collection is non-controversial and does not raise issues of concern to other federal agencies.

4. The results are not intended to be disseminated to the public.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The 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 future.

Name:________________________________________________

To assist review, please provide answers to the following question:

Personally Identifiable Information:

1. Is personally identifiable information (PII) collected? [X] Yes [ ] No

2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act of 1974? [] Yes [X ] No

3. If Applicable, has a System or Records Notice been published? [ X] Yes [ ] No

Gifts or Payments:

Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to participants? [] Yes [] No

Focus group participants will be offered a $50 incentive to review and complete surveys as assigned and to participate in the focus group.

BURDEN HOURS

In order to recruit 30 participants for the pretest, we expect to contact about 100 employers. On average, we expect that recruitment calls with respondents who agree to participate in the pretest will take about 15 minutes each to explain the purpose of the pretest, discuss the pretest materials, and set up the focus group session to discuss the questionnaire. Recruitment calls to employers that decide not to participate in a focus group are expected to take about 5 minutes each. To assess the total time taken to complete the entire survey and the overall burden to respondents, Westat will ask two respondents from each focus group to review selected questions and complete the entire questionnaire while the others will be asked to review selected questions and complete selected sections of the questionnaire. Reviewing selected questions and completing the entire questionnaire is expected to take an average of 45 minutes while reviewing selected questions and completing selected sections of the survey is expected to take about 30 minutes. Respondents will be asked to complete these “assignments” before the focus groups. The focus group session is expected to take about one hour.

Table showing burden hours for recruitment, review of and response to survey questions, and participation in focus group discussion

Category of Respondent	No. of Respondents	Participation Time		Total Burden Hours
Employers not participating in pretest	70	10 min.		11.9 hr.
Employers participating in pretest	30	15 min.		7.5 hr.
Reviewers of selected sections of survey	15	30 min.		7.5 hr.
Reviewers of entire survey	6	45 min.		4.5 hr.
Participants in focus group discussion	30	60 min.		30.0 hr.
Total 151			62 hrs.

FEDERAL COST: The estimated annual cost to the Federal government for this pretest is about $50,000 to include preparing the pretest materials and generic package, reviewing of the package by the Government, requesting and receiving list of employers from USCIS, recruiting participants, emailing them the pretest package and cover letters and instructions for logging into WebEx, sending confirmatory and reminder emails, reviewing the completed questionnaires, training the moderators, conducting the focus groups and reviewing the transcripts, preparing and submitting the pretest report.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of your targeted respondents

1. Do you have a customer list or something similar that defines the universe of potential respondents and do you have a sampling plan for selecting from this universe? [X] Yes [ ] No

If the answer is yes, please provide a description of both below (or attach the sampling plan). If the answer is no, please provide a description of how you plan to identify your potential group of respondents and how you will select them?

E-Verify employers will be identified from the Transaction Database (TDB), which captures E-Verify usage and provides basic information on employers (point of contact, name of company, email address, phone numbers, etc.). See description of the recruitment of pretest respondents above.

Administration of the Instrument

1. How will you collect the information? (Check all that apply)

[ ] Web-based or other forms of Social Media

[X] Telephone

[..] In-person

[ ] Mail

[X] Other, Explain: Sampled participants will be contacted via telephone. Online focus sessions will be conducted through WebEx. Session moderators will communicate through a coordinated telephone connection and participants will be able to see the questions as they are being discussed.

2. Will interviewers or facilitators be used? [X] Yes [ ] No

Please make sure that all instruments, instructions, and scripts are submitted with the request.

Instructions for completing Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback”

Instruments and scripts for the pretest include the following: the 2015 draft questionnaire (Attachment A), USCIS letter authorizing the conduct of the pretest (Attachment B), recruitment script (Attachment C), a list of questionnaire items and questions to guide discussions about these items (Attachment D), and Westat’s confirmation letter to employers that agree to participate in the pretest (Attachment E).

1 Small companies are defined as having fewer than 100 workers, medium-sized companies have 100 to 999 workers, large companies have 1,000 to less than 4,999 workers, and very large companies have 5,000 or more workers.

2 To select focus groups that reflect the employer characteristics that are critical to the study (company size, whether the company had federal or state requirements to use E-Verify, and whether the company recently received a TNC for workers) we will first select a base sample for each focus group and several replacement samples for recruitment purposes.

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