2020 Generic Clearance for Qualitative Feedback Supporting Statement (Supplemental Version)

Federal Trade Commission
Supporting Statement for Paperwork Reduction Act Generic Information Collection
Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery
(OMB Control No. 3084-0159)
A. 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. To ensure that agency programs are
effective and meet customer needs, the Federal Trade Commission (“FTC”) is requesting OMB
approval for an additional three (3) years for its generic information plan to obtain qualitative
feedback on agency programs. “Qualitative feedback” denotes information that provides useful
insights on perceptions and opinions, but does not include statistical surveys that yield
quantitative results that can be generalized to the population of study.
This collection of information is necessary to enable the FTC to garner 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 the FTC’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 delivery of products or
services. These collections will allow for ongoing, collaborative and actionable communications
between the FTC and its customers and stakeholders. It will also allow feedback to contribute
directly to the improvement of program management.
2. Purpose and Use of the Information Collection
The FTC 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 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. Responses will be assessed 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 FTC’s services will be unavailable.
The FTC will only submit a collection for approval under this generic clearance if it meets the
following conditions:
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Information gathered will be used only internally for general service improvement and
program management purposes and is not intended for release outside of the agency (if
released, procedures outlined in Question 16 will be followed);

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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
generalizable 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 FTC 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.

If these conditions are not met, the FTC 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:
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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)

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.”

The FTC 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. Consideration Given to Information Technology
If appropriate, the FTC 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 FTC or are available from other sources
known to the FTC.
5. Reducing the Burden on Small Entities
Small business or other small entities may be involved in these efforts but the FTC 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. Additionally, all collections will be voluntary and low burden.
6. Consequences of Not Conducting Collection
Without these types of feedback, the FTC 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 voluntary and will not be
used for statistical purposes.
8. Consultations with Persons Outside the Agency
In accordance with 5 CFR 1320.8(d), the FTC published a notice in the Federal Register
allowing the public 60 days to comment on the proposed extension of this information collection.
See 84 FR 70972 (Dec. 26, 2019). One relevant comment was received from an interested
person. The commenter stated that he believed the collection and analysis of these qualitative
statistics will be useful in improving the delivery of the many services of the FTC.
9. Payment or Gift
The FTC 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.
In the case of in-person cognitive laboratory and usability studies, the FTC may provide stipends
of up to $40. In the case of in-person focus groups, the FTC 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 agency or other facility to participate.
If such information collections include hard-to-reach groups and the FTC plans to offer nonstandard stipends, it 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, the FTC will only include a pledge of
confidentiality that is supported by authority established in statute or regulation, that is supported
by disclosure and data security policies that are consistent with the pledge, and that does not
unnecessarily impede sharing of data with other agencies for compatible confidential use. If the
FTC includes a pledge of confidentiality, it will include a citation for the statute or regulation
supporting the pledge.
11. Sensitive Nature
No questions will be asked that are of a personal or sensitive nature.
12. Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents. The
annual burden hours requested (1,759) are based on the number of collections we expect to
conduct over the requested period for this clearance. This yields an estimated three-year burden
of 5,277 hours.
Estimated Annual Reporting Burden
Type of Collection

No. of
Respondents

Annual
Frequency per
Response

Hours Per
Response

Total Hours

Customer Satisfaction
Surveys
Focus Groups

5,500

1

.25

1,375

120

1

2.0

240

Usability Testing

144

1

1.0

144

Total Annual
Burden

5,764

1,759

Total Three-Year
Burden

17,292

5,277

13. Costs to Respondents
No costs are anticipated.

14. Costs to Federal Government
The anticipated cost to the Federal Government is approximately $399,250 annually. These costs
are comprised of costs for contractor payments and participant stipends ($379,250), computer
software ($15,000), and printing ($5,000).
15. Reasons for Any Change or Adjustments on Burden Worksheet
The FTC’s existing clearance for 3084-0159 expires on May 31, 2020. As described in Section
12 above, the FTC requests approval for a total of 5,277 burden hours over the course of the
three-year renewal period.
Summary of Burden Changes
Total 3-Year
Burden Requested
Current OMB
Inventory
Difference (+/-)

Responses
17,292

Burden Hours
5,277

Cost Burden
0

8,040

3,465

0

(+ 9,252)

(+ 1,812)

0

The change in burden hours requested results from an increase in the anticipated number of
collections expected over the requested three-year period for this clearance. FTC staff
anticipates increased utilization of the generic clearance to obtain qualitative feedback on agency
service delivery over the course of the renewal period.
16. Plans for Tabulation, Statistical Analysis, and Publication
Feedback collected under this generic clearance provides useful information, but it does not yield
data that can be generalized to the overall population. The information gathered is intended to be
used only internally for general service improvement and program management and is not
intended for publication or other public release.
Although the FTC does not intend to publish its findings, it may receive requests to release the
information (e.g., congressional inquiries, Freedom of Information Act requests). The FTC will
disseminate the findings when appropriate, strictly following the FTC’s “Guidelines for Ensuring
and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by
the Federal Trade Commission,” and will include specific discussion of the limitation of the
qualitative results discussed above.
17. Display of OMB Approval Date
We are requesting no exemption.

18. Exceptions to Certification for Paperwork Reduction Act Submissions
The FTC certifies that this collection of information is consistent with the requirements in 5 CFR
§ 1320.9, and is not seeking an exception to those certification requirements.