(Supp Statement A) Stakeholder Survey PRA Justification 07 17 2014

Supporting Statement for HUD Stakeholder Survey

PART A: JUSTIFICATION

1. Circumstances that Make the Collection of Information Necessary

The Department of Housing and Urban Development (HUD) hosts events with a variety of groups nationwide designed to educate stakeholders about HUD initiatives and policies. Stakeholder groups include (but are not limited to) public housing authorities, congressional members and staff, local government officials, assisted housing residents, HUD grantees, civil rights organizations, homeless advocacy organizations, the legal community, academics, organized labor representatives, HUD grantees, and members of the housing, nonprofit, philanthropic, business and faith-based sectors. Presenters include the HUD Secretary, Deputy Secretary, Assistant Secretaries, Deputy Assistant Secretaries, Special Advisors, Regional Administrators, Field Office Directors and other principal staff.

Currently, the Department relies on informal feedback from participants and has no way of systematically assessing the impact of these activities.

HUD is committed, as articulated in its FY 2010 – 2015 Strategic Plan, to “transforming the way HUD does business.”¹ Within this goal, the Strategic Plan contains a sub-goal to “focus on results—create an empowered organization that is customer centered, place based, collaborative, and responsive to employee and stakeholder feedback.” ² One of the strategies to meet this sub-goal is to “incorporate field and regional staff knowledge and customer input into policy decisions and implementation strategies.” This information collection clearly aligns with the goals and strategies outlined in the HUD Strategic Plan, as it would create an unprecedented opportunity for HUD to systematically solicit stakeholder feedback on key initiatives and policies. The feedback would also help improve and maximize the impact of HUD stakeholder events, to which HUD already devotes considerable time and resources.

2. How and By Whom the Data Will Be Used

This data collection will allow HUD to collect feedback from a wide range of stakeholder groups using a brief, optional survey to be completed in person at the end of each stakeholder event. The events range in size from roughly 10 to 200 participants, and there are approximately 20 to 100 events per year. The expected response rate is between 30 and 70%.

HUD staff will organize events, administer and collect surveys, compile the results, and distribute to the appropriate parties.

• Purpose of the Data Collection

The information produced by the stakeholder surveys will allow HUD to measure the effectiveness of the stakeholder sessions and collect feedback on policy initiatives.

• Who Will Use the Information

The stakeholder survey findings will be used by HUD management and program staff. HUD will compile survey results and distribute to the appropriate offices, including those involved with delivering the presentations, drafting presentation materials, and administering the programs discussed at the sessions.

• Survey Instrument

The survey instrument is 8 questions, several of which ask participants to rate certain metrics along a scale of 1 – 5, and several of which ask participants for free-form responses. Some of the questions ask respondents for an assessment of the session itself, and some ask respondents for feedback on the HUD initiative or policy discussed at the event.

3. Use of Improved Technologies

N/A

4. Efforts to Identify Duplication

Discussions with knowledgeable HUD officials and others outside the Department indicate that there are no similar surveys which allow for HUD to engage in a sustained, systematic collection of feedback from stakeholders on of a broad range of HUD initiatives and events.

5. Involvement of Small Entities

The information being collected will be collected from individuals on a voluntary basis and will have no impact on small businesses or other small entities.

6. Consequences of Less Frequent Data Collection

This information collection is essential to HUD’s FY 2010 – FY 2015 Strategic Plan goal to transform the way HUD does business by creating an environment responsive to stakeholder feedback. HUD currently has no means by which to formally and systematically assess the effectiveness of HUD stakeholder events and solicit feedback on HUD initiatives from stakeholders other than informal feedback.

7. Special Circumstances

The proposed data collection activities are consistent with the guidelines set forth in 5 CFR 1320.6 (Controlling Paperwork Burden on the Public--General Information Collection Guidelines). There are no special circumstances that require deviation from these guidelines.

8. Identify the date and page number of the Federal Register Notice (and provide a copy) soliciting comments on the information. Summarize public comments and describe actions taken by the agency in response to these comments. Describe all efforts to consult with persons outside the agency to obtain their views.

The proposed information collection was published in the Federal Register, Volume 79, on July 25, 2014, Page Number 43499. A request to see a copy of the survey was received and HUD provided a copy. No other comments were received.

9. Payments to Respondents

Participants voluntarily agree to participate in this data collection and do not receive any payment or gifts.

10. Arrangements and Assurances Regarding Confidentiality

Survey responses will be anonymous.

11. Sensitive Questions

The questions being asked are not considered sensitive.

12. Estimate of Annualized Burden Hours

It is estimated that the project will result in 367.5 burden hours per year for all respondents, based on projections below.

HUD stakeholder events generally draw between 10 and 200 participants, and will likely hold between 20 and 100 events per year. Survey respondents will likely spend between 2 and 10 minutes completing the survey, and each respondent will only fill out one survey (frequency).

1 minute is used for non-respondents. The number of stakeholders is the average number of participants per event times the average number of events: 105 x 60 = 6,300. The minutes per response are the average number of minutes per respondent.

Exhibit 1A: Burden Hours for Respondents

	No. of Stakeholders	Frequency	Response Count	Frequency x Count	Min./ Response	Burden Hours
Low Estimate 30 % Response Rate	6,300	1	1,890	1,890	6	189
High Estimate 70% Response Rate	6,300	1	4,410	4,410	6	441

Exhibit 1B: Burden Hours for Non-Respondents

	No. of Stakeholders	Frequency	Non-Response Count	Frequency x Count	Min./ Response	Burden Hours
Low Estimate	6,300	1	4,410	4,410	1	73.5
High Estimate	6,300	1	1,890	1,890	1	31.5

Exhibit 1C: Total Burden Hours (Respondents and Non-Respondents)

	Responses	Non-Responses	Total
Low Estimate	189	73.5	262.5
High Estimate	441	31.5	472.5
Average	315	52.5	367.5

13. Estimated Recordkeeping and Reporting Cost Burden on Respondents

There will be no additional cost to respondents.

14. Estimated Cost to the Federal Government

Exhibit 2 shows the burden hours for HUD staff involved in processing survey results. It will likely take one HUD staff between 2 and 5 minutes to enter, compile, and analyze each survey result. The minutes per response in Exhibits 2 and 3 below is the average amount of time HUD staff will spend processing each survey result.

Exhibit 2: Burden Hours for HUD Staff

	No. of Employees	Response Count	Min./Resp.	Burden Hours
Low Estimate	1	1,890	3.5	110.25
High Estimate	1	4,410	3.5	257.25
Average	1	3,150	3.5	183.75

Exhibit 3 shows the total cost to HUD of entering, compiling and analyzing the survey response data. The total cost to HUD is the burden hours HUD staff will spend processing the survey results times the HUD staff’s hourly salary. A GS-09 will likely be processing the survey results.

Exhibit 3: Total Cost to the Federal Government

	No. of Employees	Response  Count	Min./Resp.	Burden Hours	Hourly Rate (GS-09)	Total Cost
Low Estimate	1	1,890	3.5	110.25	$24.74	$2,727.59
High Estimate	1	4,410	3.5	257.25	$24.74	$6,364.37
Average	1	3,150	3.5	183.75	$24.74	$4,545.98

Exhibit 4 shows the total burden hours for the project, combining the total burden hours for HUD staff and respondents.

Exhibit 4: Total Burden Hours for Project

	Burden Hours - Respondents	Burden Hours – HUD Staff	Burden Hours Per Year – Project Total
Low Estimate	262.5	110.25	372.75
High Estimate	472.5	257.25	729.75
Average	367.5	183.75	551.25

It is estimated that this information collection will result in 551.25 burden hours per year and a total cost of $4,545.98.

15. Explain any program changes or adjustments reported in Item 13 and 14.

This is a new collection.

16. Tabulation Plans

The results of this survey will not be published. HUD staff will tabulate the survey results without sophisticated statistical methodology and with the understanding that the results are non-scientific.

17. Explain any requests to not display the expiration date.

The expiration date will be displayed on all instruments and documents associated with this collection.

18. Exceptions to Certification

There are no exceptions to the certification statement identified in item 19.

1 HUD FY 2010 -2015 Strategic Plan, Goal 5

2 HUD FY 2010 -2015 Strategic Plan, Sub-goal 5b