Supporting Statement (final 5-8-2014)

Office of the Comptroller of the Currency

Supporting Statement

Generic Information Collection

Qualitative Feedback on OCC Service Delivery

OMB Control No. 1557-0248

1. 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. In order to work continuously to ensure that our programs are effective and meet our customers’ needs, the Office of the Comptroller of the Currency (OCC) seeks renewal OMB approval of a generic clearance to collect qualitative feedback on our service delivery. Qualitative feedback is information that provides useful insights on perceptions and opinions, but does not include statistical surveys or quantitative results that can be generalized to the population of study.

This collection of information is necessary to enable the OCC to garner customer and stakeholder feedback in an efficient and timely manner, in accordance with our commitment to improving delivery of services. The information collected from our customers and stakeholders helps ensure that users have an effective, efficient, and satisfying experience with the OCC’s programs. This feedback offers insights into customer or stakeholder perceptions, experiences, and expectations and can provide an early warning of issues with service and/or focus attention on areas where communication, training or changes in operations might improve delivery of products or services. These collections allow for ongoing, collaborative, and actionable communications between the OCC and its customers and stakeholders and the resulting feedback contributes directly to the improvement of program management.

2. Purpose and Use of the Information Collection

The improvement of OCC programs requires the ongoing assessment of service delivery, meaning the 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. The OCC will analyze and interpret information collected through this generic clearance to identify strengths and weaknesses of current services and to 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. The information in the responses will be used 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 the OCC’s services will be unavailable.

The OCC will only submit a collection for approval under this generic clearance if it meets the following conditions:

• Information gathered will be used only internally for general service improvement and program management purposes and is not intended for release outside of the OCC (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 ¹;

• 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 able to be generalized to the population of study ; 

• The collections are voluntary;

• The collections are low-burden for respondents (based on considerations of total burden hours, total number of respondents, or burden-hours per respondent) and are low-cost for both the respondents and the Federal Government;

• The collections are non-controversial and do not raise issues of concern to other Federal agencies;

• Any 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 near future; and

• With the exception of information needed to provide remuneration for participants of focus groups and cognitive laboratory studies, personally identifiable information (PII) is collected only to the extent necessary and is not retained.

If these conditions are not met, the OCC will submit an information collection request to OMB for approval through the normal PRA process.

To obtain approval for a collection that meets the conditions of this generic clearance, a standardized form will be submitted to OMB along with supporting documentation, including a copy of the instrument. 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)

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

The OCC has established a managing entity for this generic clearance, which will independently review of each information collection before submission to OMB to ensure compliance with the terms of this clearance.

3. Consideration Given to Information Technology

If appropriate, agencies will collect information electronically and/or use online collaboration tools to reduce burden.

4. Duplication of Information

No similar data are gathered or maintained by the OCC or are available from other sources known to the OCC.

5. Reducing the Burden on Small Entities

Small business or other small entities may be involved in these efforts but the OCC will 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, the OCC will not have timely information to adjust its services to meet customer needs.

7. Special Circumstances

There are no special circumstances. The information collected will be on a voluntary basis and will not be used for statistical purposes.

8. Consultations with Persons Outside the OCC

On February 28, 2014, the OCC published a notice concerning this collection for 60 days of comment. 79 FR 11500. No comments were received.

9. Payment or Gift

The OCC will not provide payment or other forms of remuneration to respondents of its various forms of collecting feedback. Focus groups are the exceptions.

In the case of in-person usability studies, the OCC may provide stipends of up to $40. In the case of in-person focus groups, the OCC may provide stipends of up to $75. If respondents participate in these kinds of studies remotely, via phone, or Internet, any proposed stipend needs to be justified to OMB and must be considerably less than that provided to respondents in in-person studies, who have to travel to the OCC or other facility to participate. If such information collections include hard-to-reach groups and the OCC plans to offer non-standard stipends, the OCC will provide OMB with additional justifications in the request for clearance of these specific activities.

10. Confidentiality

The information will be kept confidential to the extent permitted by law.

11. Sensitive Nature

Not applicable. No personally identifiable information is requested.

12. Burden of Information Collection

A variety of instruments and platforms will be used to collect information from respondents. The annual burden hours requested (1,600) are based on the number of collections we expect to conduct over the requested period for this clearance.

Estimated Annual Reporting Burden
Type of Collection	No. of Respondents	Annual Frequency per Response	Hours per Response	Total Hours
Feedback on OCC Issuances	3,000	1	.25	750
Focus Groups	25	1	4	100
Usability Testing	3,000	1	.25	750
Total Burden				1,600

13. Costs to Respondents

No costs are anticipated.

14. Costs to Federal Government

The anticipated annual cost to the Federal government is minimal. There is no identifiable increase in OCC’s current operational expenses due to under this collection.

15. Reason for Change

There is no change in burden.

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. The OCC will us findings for general service improvement, but not for publication or other public release.

Although the OCC does not intend to publish its findings, the OCC may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests). The OCC will disseminate the findings when appropriate, strictly following all applicable statutes, rules, and guidelines.

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 releaseinformation obtained under these collections.

1. Universe and Respondent Selection

The activities under this clearance may involve samples of self-selected customers, as well as convenience samples, and quota 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 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. The OCC expects to use a variety of methodologies for these collections. For example, the OCC or its contractors may use commercial survey-specific software to automate its collection and analysis of feedback. In addition to physical copies, information collection instruments may be disseminated electronically and/or posted on target pages of the OCC’s 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 quantitative findings that may be generalized; it can provide useful customer input, but it does not yield data about customer opinions that can be generalized.

4. Testing of Procedures

Pretesting may be done with internal staff, a limited number of external colleagues, and/or customers familiar with the programs and products. If the number of pretest respondents exceeds nine members of the public, the OCC 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 OCC statisticians or from contractors and the OCC will include the names and contact information of persons consulted in the specific information collection requests submitted under this generic clearance.

1 As defined in OMB 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.”