CPEP_Justification_A

Supporting Statement
Compensation and Pension Examination Program (CPEP)
Veterans Satisfaction Survey
OMB 2900-0774 VA Form 10-0480

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify legal or administrative requirements that necessitate the collection of information.

In response to Executive Order 12862, the Veterans Health Administration (VHA) conducts both centrally and locally administered surveys to determine the level of satisfaction with existing services among VHA's customers. The surveys solicit voluntary opinions and are not intended to collect information required to obtain or maintain eligibility for a Department of Veterans Affairs (VA) program or benefit. The Compensation and Pension Examination Program (CPEP) is constantly striving to improve the service we provide to our nation’s Veterans. 

2. Indicate how, by whom, and for what purposes the information is to be used; indicate actual use the agency has made of the information received from current collection.

CPEP’s goal is to gather and report information about Veterans’ compensation and pension experiences at individual exam sites to provide feedback to the sites in order to improve this experience for all Veterans.  CPEP will allow Veterans an opportunity to provide anonymous feedback on how well the exam process is perceived by Veterans undergoing these exams.  CPEP uses this feedback to improve the compensation and pension exam processes. VA uses the information gathered to determine where and to what extent services are satisfactory, and where and to what extent they are in need of improvement. The information may lead to policy changes, which improve Veteran satisfaction with VA Healthcare benefits. In addition, voluntary customer surveys will not be used as substitutes for traditional program evaluation surveys that measure objective outcomes. To maximize the voluntary response rates, the information collections will be designed to make participation convenient, simple, and free of unnecessary barriers.

Baseline data obtained through the CPEP Satisfaction Survey information collection will be used to measure performance in the specific areas of the program. The data collected will consist of the minimum amount of information necessary to determine customer needs and to evaluate performance. The areas of concern to VHA and its customers change rapidly and it is essential to have the ability to evaluate customer concerns in a timely manner.

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, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The CPEP Veterans’ Satisfaction Survey will be given to Veterans inviting them to participate in a survey that addresses VHA’s Compensation & Pension exam process. This will be an ongoing survey that will be offered to Veterans on a monthly basis. The probability of Veterans having access to the public internet is unknown; therefore the Veterans will have an option to receive a paper copy of the survey to complete. The survey will be distributed through Compensation & Pension departments at the time of their exams. Veterans will be given an opportunity to complete the survey and return it to the Compensation & Pension clerk, or they can mail the survey to our collection center. There will be an online opportunity to fill out a survey as well, and Veterans choosing that option will be provided with a web-link to the survey site.

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.

VA will use its internal review process at the Office of Quality and Performance (OQP) Durham Office to examine the information collection to prevent duplication of effort or redundancy in all information collected. The information to be gathered from the survey as a whole is unique and not available from any other sources with the appropriate level of specificity required.

Local surveying was designed to obtain patient perceptions of care at discreet levels of the organization (i.e. specific clinic, specific bed section, special program, etc.). VA does conduct nationwide surveys (Survey of Healthcare Experiences of Patients, 2900-0712), which permit comparisons between various VA facilities, and with facilities in the private sector. However, the results of the nationwide surveys do not reach individual facilities for quite some time and they do not focus on specific small clinical areas. This prevents immediate changes to improve quality of care.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

No small businesses or other small entities are impacted by this information collection.

6. Describe the consequences 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 burden.

Most of the customer satisfaction surveys are recurring so that VHA can create ongoing measures of performance and determine how well the agency meets customer service standards. The burden consists only of that information which is essential to maintain the validity and support the goals of the Executive Order. The results of these information collections should lead to improvements in the quality of VHA service delivery by helping to shape the direction and focus of specific programs and services. If the survey was not conducted or conducted less frequently, VA would not be responsive to the needs of the patient, be able to quickly correct quality of care issues or meet the needs of the veteran by quickly improving service.

7. Explain any special circumstances that would cause an information collection to be conducted more often than quarterly or require respondents to prepare written responses to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three 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 and require the use of a statistical data classification that has not been reviewed and approved by OMB.

There are no special circumstances that require the collection of information to be conducted in a manner that is inconsistent with the guidelines in 5 CFR 1320.6.

8. a. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the sponsor’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the sponsor in responses to these comments. Specifically address comments received on cost and hour burden.

The notice of Proposed Information Collection Activity was published in the Federal Register on ___________, 20___, page ______. VA received no comments in response to this notice.

b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, clarity of instructions and recordkeeping, disclosure or reporting format, and on the data elements to be recorded, disclosed or reported. Explain any circumstances, which preclude consultation every three years with representatives of those from whom information is to be obtained.

VA, through OQP, has expert staff available for advising, consulting, and working with individual facilities regarding local survey efforts. In addition, there are a number of private sector and educational institutions that concentrate on satisfaction surveying which are available as external resources to all agency employees. These are utilized whenever necessary. Every three years, when extension of the OMB approval is sought, outside consultation is conducted with the public through the 60- and 30-day Federal Register notices.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There are no plans to provide payments or gifts to respondents.

10. Describe any assurance of privacy, to the extent permitted by law, provided to respondents and the basis for the assurance in statue, regulation, or agency policy.

The survey is anonymous.  No personally identifiable information will be collected.

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; include specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. Estimate of the hour burden of the collection of information:

a. CPEP survey: VA Form 10-0480

Number of respondents is estimated at	1055
Frequency of response is annually	1.53
Number of responses is estimated at	1614
Average estimated response time is	Avg. 5.7 min.
Annual burden is estimated at	153 hours

b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB 83-I.

This request covers one form.

c. Provide estimates of annual cost to respondents for the hour burdens for collections of information. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

The cost to the respondents for completing these forms is $2,295 (153 hours x $15 per hour). We do not require any additional recordkeeping.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

a. There is no capital, start-up, operation or maintenance costs.

b. Cost estimates are not expected to vary widely.

c. There are no anticipated capital start-up cost components or requests to provide information.

14. Provide estimates of annual cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

VA will incur minimal internal administrative costs in developing, printing, and mailing the small low burden survey instruments, and in data analysis and reporting results. These costs will be approximately $3,500 per year.

15. Explain the reason for any program changes or adjustments reported in Items 13 or 14 of OMB 83-I

This is a new collection and all burden hours are considered a program increase.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Differences in methods in both facilities and locations within a specific facility preclude meaningful aggregation and grouped analyses. Primary utility is for local quality improvement and not for formal publication or comparison between facilities.

17. If seeking approval to omit the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

VA also seeks to minimize its cost to itself of collecting, processing and using the information by not displaying the expiration date. VA continues to seek an exemption that waives the displaying of the expiration date on the VA Forms.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB 83-I.

There are no such exceptions.