Justification for Non-sub Change

TO: Jennifer Park,

Statistical and Science Policy,

Office of Information and Regulatory Affairs,

Office of Management and Budget

FROM: Timothy Wojan DATE: 11/22/2013

Economic Research Service

SUBJECT: Request for a Non-substantive change in recruitment protocol for the CAPI of U.S. business establishments by ERS Rural Establishment Innovation Survey (REIS) (OMB Control No. 0536-0071).

The ERS Rural Establishment Innovation Survey (REIS) (OMB Control No. 0536-0071) began its CAPI data fielding on November 18, 2013. Our data collection team has discovered that our current approach for communicating the informed consent and confidentiality pledge was ineffective, and furthermore, it had an adverse effect on survey response rates. For example, one of our experienced interviewers, who has a very nice phone voice and good rapport with respondents, was only able to complete one interview after 80 call attempts. Many of those contacted potential respondents were not willing to stay on the phone long enough until the completion of the recitation for the full informed consent and confidentiality pledge. Our research on relevant survey literature and OMB guidelines¹ as well as our consultation with other federal statistical agencies that are experienced in conducting telephone surveys indicates a better way to communicate the pledge of confidentiality: in telephone surveys, interviewers typically include a few summary sentences to potential respondents, and may refer to an advance letter that was sent.

We request for a non-substantive change in recruitment protocol for the REIS CAPI fielding in order to reduce respondents’ burden and increase the quality of the data collection. We request for adopting a CATI recruitment protocol that was used by the U.S. Census Bureau in administering the American Time Use Survey. Under this revised REIS CAPI recruitment protocol, respondents will be asked if they received an advance letter containing the informational materials about the REIS upon first successful contact by a telephone interviewer. If no, then an electronic copy of this information can be sent to them in real time at their email addresses which they provide to the interviewers. Once it is confirmed that a potential respondent has received and read the advance letter, the telephone interview will proceed with an abbreviated version of the informed consent and confidentiality pledge. The original script and the proposed change for the informed consent and confidentiality pledge in the REIS CAPI are provided below.

Informed Consent and Confidentiality Pledge in REIS CATI

The original script is below:

According to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0536-0071. The time required to complete this information collection is estimated to average 30 minutes per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. YOUR RESPONSE IS VOLUNTARY. The information you provide will be used for statistical purposes only. In accordance with the Confidential Information Protection provisions in Public Law 107-347, your responses will be kept confidential and will not be disclosed in identifiable form. By law, everyone working on this ERS survey is subject to a jail term, a fine, or both if he/she discloses any information that could identify any confidential survey response. For quality purpose only, this interview may be monitored by my supervisor. If I come to any question you would prefer not to answer, just let me know and I will skip over it. Okay?

The proposed script is:

Did you receive the letter we sent in the second week of November (2013) for the National Survey of Business Competitiveness explaining the importance of the survey and requesting your participation?

{font color = "blue"}(IWR: If R says "No, Don’t know, or Don’t remember" then say,{/font} "Would you like for me to send you an email of this letter and the Paperwork Reduction Act disclaimer?"{font color = "blue"}){/font}

{font color="#0000FF"} (IWR Note If they would like an email of this click "Prior Letter" hot key and send email) {/font}

I would like you to know that all information you provide for this survey is voluntary. Your answers to all questions are confidential. All information that is provided will only be used for statistical research purposes and reported in summary form. Your name and that of the business you represent will not be connected to your answers in any way. This survey is authorized under OMB Control Number 0536-0071. The time required to complete this survey is estimated to average 30 minutes per response. This interview may be monitored or recorded by my supervisor to check my work. If I come to any question you would prefer not to answer, just let me know and I will skip over it. Okay?

1 Guidance on Agency Survey and Statistical Information Collections (January 20, 2006)

2