Sptg Stmt Part A 2017 revised

Supporting Statement for Paperwork Reduction Act Generic Information Collection
AGENCY:

Pension Benefit Guaranty Corporation

TITLE:

Generic Clearance for the Collection of Qualitative Feedback on
Agency Service Delivery

OMB CONTROL NUMBER:

1212-0066

CONTACT:

Jo Amato Burns (326-4400 ext 3072)
(burns.joamato@pbgc.gov)

A. JUSTIFICATION
1. Need for the Collection of Information. 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, Pension Benefit Guaranty Corporation (“PBGC”) seeks to obtain OMB approval of a generic
clearance to collect qualitative feedback on its service delivery. By qualitative feedback we mean
information that provides useful insights on the public’s perceptions and opinions. However,
because the results obtained are not from statistical surveys, they are not quantitative results that can
be generalized to the population of interest.
This collection of information is necessary to enable PBGC to obtain customer and stakeholder
feedback in an efficient, timely manner, in accordance with our commitment to improving service
delivery. The information collected from our customers and stakeholders will help ensure that users
have an effective, efficient, and satisfying experience with PBGC’s programs. This feedback will
provide insights into customer or stakeholder perceptions, experiences and expectations, provide an
early warning of issues with service, or focus attention on areas where communication, training or
changes in operations might improve the delivery of products or services or enhance their utility.
These collections will allow for ongoing, collaborative and actionable communications between

PBGC and its customers and stakeholders. It will also allow feedback to contribute directly to the
improvement of program management.
2. Use of the Information. Improving agency programs requires ongoing assessment of service
delivery, by which we mean 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 Agency will collect, analyze, and interpret information gathered through this generic
clearance to identify strengths and weaknesses of current services and make improvements in service
delivery and quality based on feedback. The solicitation of feedback will target areas such as:
timeliness, appropriateness, accuracy and comprehensiveness of information, courtesy, efficiency of
service delivery, and resolution of issues with service delivery. Responses will be assessed to
improve or maintain the quality of services offered to the public. If this information is not collected,
vital feedback from customers and stakeholders on PBGC’s services will be unavailable.
PBGC 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 PBGC (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
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As defined in OMB and agency 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.”

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•

Information gathered will yield qualitative information; the collections will not be designed
or expected to yield statistically reliable results or be used as though the results are
generalizable to the population of interest;

•

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

•

It informs respondents of the information called for under 5 CFR 1320.8(b)(3).

If these conditions are not met, PBGC 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 (e.g., a copy of
the comment card). The submission will have automatic approval, unless OMB identifies issues
within 5 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
PBGC’s website;
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•

Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web
surveys);

•

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

PBGC has established a manager/managing entity to serve for this generic clearance and will
conduct an independent review of each information collection to ensure compliance with the terms
of this clearance prior to submitting each collection to OMB.
3. Reducing the burden. If appropriate, PBGC will collect information electronically and/or use
online collaboration tools to reduce burden.
4. Duplicate or Similar Information. No similar data are gathered or maintained by PBGC or are
available from other sources known to PBGC.
5. Reducing the Burden on Small Entities. Small business or other small entities may be
involved in these efforts but PBGC 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 reduced collection. Without these types of feedback, PBGC will not have

timely or adequate information to adjust its services to better meet customer needs.
7.

Consistency with guidelines. This collection of information is conducted in a manner

consistent with 5 CFR § 1320.5(d)(2).
8.

Outside Input. In accordance with 5 CFR 1320.8(d), PBGC published a 60-day notice on

June 21, 2017, 82 Fed. Reg. 28363. No public comments were received in response to the 60-day
notice.
9.

Payments to respondents. PBGC will not provide payment or other forms of remuneration

to respondents of its various forms of collecting feedback. Focus groups and cognitive laboratory
studies are the exceptions.
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In the case of in-person cognitive laboratory and usability studies, the Agency may provide
stipends of up to $40. In the case of in-person focus groups, the Agency 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 for in-person studies where respondents have to travel to an agency or other facility to
participate. If such information collections include hard-to-reach groups and the agency plans to
offer non-standard stipends, PBGC will provide OMB with additional justifications in the request for
clearance of these specific activities.
10.

Confidentiality. If a confidentiality pledge is deemed useful and feasible, PBGC will only

include a pledge of confidentiality that (a) is supported by authority established in statute or
regulation, (b) is supported by disclosure and data security policies consistent with the pledge, and
(c) does not unnecessarily impede sharing of data with other agencies for compatible confidential
use. If PBGC includes a pledge of confidentiality, it will include a citation for the statute or
regulation supporting the pledge.
11.

Personal questions. The information collection does not include any questions of a personal

or sensitive nature.
12.

Hour burden on the public. A variety of instruments and platforms will be used to collect

information from respondents. Annually, over the next three years, PBGC estimates that it will
conduct three activities involving about 1,630 respondents, each of whom will provide one
response. The number of respondents will vary by activity: 40 for usability testing, 90 for focus
groups (nine groups of ten respondents), and 1,500 for customer satisfaction surveys. PBGC
estimates the annual burden of this collection of information as 635 hours: 2 hours per response for
usability testing (total 80 hours); 2 hours per response for focus groups (total 180 hours); and 15
minutes per response for customer satisfaction surveys (total 375 hours).
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13. Costs to Public. No costs are anticipated.
14. Costs to Federal Government. The estimated total annual cost to PBGC is $190,000 for
contractor annual costs.
For the three activities, contractor costs are as follows:

Function
Materials
development,
facilitation,
videography,
transcription,
reporting
Materials
development,
facilitation,
transcription,
reporting
Materials
development,
fielding, data
analysis, reporting

Activity

Details

Rate

Projects
or
responses
annually

Focus
group

In-person
sessions

$25,000/project

1

$25,000

Usability
testing

Online
sessions

$15,000/project

1

$15,000

Customer
satisfaction
survey

Telephone
interviews

$100/response

1,500

$150,000

TOTAL

$190,000

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Total
Annual
Cost

15. Adjustments in Burden. The hour burden on the public has increased by 112 hours due to an
increase in the number of surveys that will be conducted (each taking an estimated 15 minutes) from
1,050 to 1,500. The cost burden on PBGC now reports only the contractor costs incurred by PBGC,
not the PBGC staff costs (previously estimated at an annual cost of about $25,000). However, the
contractor costs have increased by about $20,000, from $170,000 to $190,000 due to an increase in
estimated number of surveys that will be conducted, with each survey costing about $100. The
revision in the number of surveys to be conducted is unrelated to program changes.
16. Publication plans. PBGC has no plans for publication of the results of this information
collection. Findings will be used for general service improvement, but are not for publication or
other public release.
Although PBGC has no specific plans to publish its findings, PBGC may receive requests to
release the information (e.g., congressional inquiry, Freedom of Information Act requests). PBGC
will release findings when appropriate, and may disseminate general findings when relevant. In the
event this occurs, PBGC will strictly follow its "Guidelines for Ensuring the Quality of Information
Disseminated to the Public" and will include specific discussion of the limitation of the qualitative
results discussed above.
17. Display of OMB Approval Date. No exemption is requested.
18. Exceptions to certification statement. The information collection is consistent with
5 CFR § 1320.9.

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