1205-0436 Supporting Statement Part A_FINAL 6.1.17

Employment and Training Administration Quick Turnaround Surveys

OMB Control No. 1205-0436

June 2017

SUPPORTING STATEMENT

QUICK-TURNAROUND SURVEYS, Part A

OMB Control No. 1205-0436

ETA seeks to revise the current Office of Management and Budget (OMB) clearance for a series of quick turnaround surveys in which data will be collected from State workforce agencies, local workforce investment areas, and other entities involved in employment and training and related programs. The surveys will focus on a variety of issues concerning the very broad spectrum of programs administered by ETA including but not limited to the governance, administration, funding, service design, and delivery structure of workforce programs authorized by the Workforce Innovation Opportunities Act of 2014 (WIOA) and other statutes.

A.       JUSTIFICATION.

1.  Explain the circumstances that make the collection of information necessary.  Identify any legal or administrative requirements that necessitate the collection.  Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

This submission requests an extension of OMB approval to conduct eight (8) to twenty (20) surveys over the next three years.  Section 169 of the Workforce Innovation and Opportunity Act (WIOA) is the authority by which ETA will collect the majority of the information proposed in this Information Collection Request (ICR) for the Quick Turnaround Surveys. Individual requests will provide the authority to collect information.

ETA, in its role of providing broad program oversight and policy development, needs accurate, timely information on all of its programs.  Only in this way can it properly discharge its obligations to issue policy clarifications, regulations and technical assistance. 

However, much of the information available to ETA on key operational issues is impressionistic or anecdotal in nature, based on hearsay or unsystematic observations, and not accurate as to the incidence or scope nationally.  When accurate nationwide information is available, as from long-term in-depth evaluation studies, it is often not timely.  Thus ETA has a need for accurate and timely information that can be found only with systematic quick turnaround studies.

According to the plan, eight (8) to twenty (20) surveys would be administered over the next three years, with each survey being simple and relatively short (10-30 questions).  Depending on the nature of the questions, the surveys would be administered at the state level or at the local workforce area level or some combination of both together, and might entail surveys of state workforce agencies, local Workforce Boards, American Job Centers, Employment Service offices, and offices of other local-area partners.  Each survey will be designed on an ad hoc basis over the three-year period, and will focus on emerging topics of pressing policy interest.  Questions would build on areas raised by ETA National Office and Regional Staff, OMB itself or Congress. 

Examples of broad topic areas include:

        Local Management Information System developments

        New processes and procedures

        Services to different target groups

        Integration and coordination with other programs

        Local Workforce Investment Board membership and training

In accordance with the existing terms of clearance, DOL follows the clearance process below for each individual survey:

(1) ETA submits the following materials to OMB for review:

        Description & purpose

        Burden estimates & federal costs

        Statistical methodology, if any

        BLS review and clearance in the event of statistical methodology

        Survey instrument

        A current inventory of surveys approved under the OMB control number assigned to this data collection, displaying the number of respondents, burden hours and response rates for those approved.

 

(2) OMB will review the materials and submit any questions or comments to ETA within 15 working days of the submission to OMB. 

(3) OMB and ETA will then work collaboratively to resolve any outstanding issues. 

2.       Indicate how, by whom, and for what purpose the information is to be used.  Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Quick turnaround surveys fill a critical gap in ETA’s information needs about how the workforce system is unfolding and inform development of legislation, regulations and technical assistance.  

Information from the planned survey of services and outreach to business and industry (now in process) will be used by a number of offices in ETA both for planning technical assistance and for identifying baseline levels.

The availability of this quick turnaround mechanism has generated significant activity within ETA as knowledge of its availability as a resource and its possible uses has expanded. The following is a sample of past uses of this generic clearance by ETA:

Quick Turnaround Survey of Feasibility Study, Eligible Training Provider List

Quick Turnaround Survey of State Workforce Agencies on Call Center Operations

Readiness and Technical Assistance Consultation Tool

Technical Assistance (Feasibility Study)

Site Selection for Grants Serving Young Offenders (EGYO)

Site Selection for Evaluation of Youth CareerConnect (YCC)

The passage of the Workforce Innovation and Opportunity Act, and subsequent implementation by the States in accordance with the new regulations, increases the need for rapid information collection and the likelihood of surveys conducted under this clearance.

3.       Describe whether, and to what extent, the collection of information involves use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection.  Also describe any consideration of using information technology to reduce burden.

Consistent with the quick-turnaround basis underlying this data collection, surveys will be administered either via electronic submission on the Internet or by telephone.  The Internet will be used as a way of reducing respondent burden and increasing the efficiency of data collection and processing.  It is anticipated that at least 15 percent of the respondents will reply electronically.

4.       Describe efforts to identify duplication.  Show specifically why any similar information already available cannot be used or modified for use for the purposes described in item 2 above.

The information being requested is not otherwise available.  Other research and evaluation efforts, including case studies or long-range studies, either cover only a limited number of sites or take many years for data to be gathered and analyzed.  Administrative information and data are too limited:  The five-year Workforce Investment Plans, submitted by states and local areas, are too general in nature to meet ETA’s informational needs and need to be updated only once every five years; mandated quarterly or annual reporting requirements of states and local areas provide some information, but primarily about cost outlays and the number and characteristics of clients served and their outcomes; and participant outcome data does not provide information on key operational practices and issues.  Thus, ETA has no alternative mechanism for collecting information that both identifies the scope or magnitude of emerging issues in its programs and provides the information on a quick-turnaround basis.

ETA will make every effort to coordinate the quick-turnaround surveys with other studies.  ETA will make sure there will be properly drawn samples of local sites but will avoid, where possible local areas that have already been previously contacted in other studies.  ETA will also make efforts to ease the burden on the universe of state level respondents and will make sure that interim data and information from each study will be shared and used to inform the other studies. The proposed quick turnaround surveys will provide “just-in-time” information that responds to specific issues that arise and will supplement and complement but not duplicate other ETA evaluation efforts and program reporting requirements.

5.       If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The collection of information has no impact on small businesses or other small entities. 

6.       Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles in reducing burden.

Without the information it will collect through the proposed surveys, ETA will be less effective in carrying out its oversight and technical assistance functions and informing the legislative development process.  These functions depend on ETA’s staying abreast of emerging challenges or impediments in its various programs.  Only with such information can it effectively issue policy guidance or clarifications, and redress technical assistance needs that states, local areas, or other entities may have. 

7.       Explain any special circumstances that would cause an information collection to be conducted in a manner that requires further explanation pursuant to regulations 5 CFR 1320.5.

There are no special circumstances that would cause this information collection to be conducted in any manner listed above.  DOL may issue surveys more frequently than quarterly, but each survey will focus on separate issues and be administered to different respondents.  This collection of information complies with the requirements of 5 CFR 1320.5.

8.       If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB.  Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.  Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods.  There may be circumstances that may preclude consultation in a specific situation.  These circumstances should be explained.

The public was given sixty days to comment on this information collection request by way of a Federal Register Notice published on September 13, 2016 (81 FR 62923). No public comments were received.

9.       Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts to respondents are made.

10.    Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Persons to whom the questionnaire is distributed will be assured that their cooperation is entirely voluntary and that their responses will be held in confidence.  Data collection will be carried out by ETA’s contractors and will be released to the public at large in aggregated form only, so that no specific state or local area agency will be identified.  ETA’s contractors will be instructed to follow rigorous procedures for assuring and keeping data private.  In keeping with this, access to any data with identifying information will be limited only to ETA staff and contractor staff directly working on the survey.

In keeping with the Confidential Information Protection and Statistical Efficiency Act of 2002, when applicable the following statement will be displayed on each questionnaire:

“The Employment and Training Administration, its employees and agents, will use the information you provide for statistical purposes only and will hold the information in confidence to the full extent permitted by law. In accordance with the Confidential Information Protection and Statistical Efficiency Act of 2002 (title 5 of Public Law 107-347) and other applicable Federal laws, your response will not be disclosed in identifiable form without your informed consent.”

11.     Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.  This justification should include the reasons why the agency considers these questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

None of the questionnaire items will involve sensitive content, such as the topics referenced in this question.

12.     Provide estimates of the hour burden of the collection of information. 

This clearance package represents an umbrella clearance for 8-20 separate surveys to be conducted over a three-year period to a range of potential respondents, including (depending on the survey) state workforce agencies, local workforce development boards, American Job Center operators, Employment Service offices, and others.  Although each survey conducted under this clearance will be short, the exact number of questions will generally vary, within the range of approximately 10-30 questions per survey.  In general, the total sample size will vary by survey averaging between 54 to 250 respondents for up to 20 surveys.  Please note that while the high end estimate of 250 respondents is an average, it is expected that an occasional survey may exceed that upper limit.

Because of this variability in both the targeted number of respondents and questionnaire length, burden estimates for each survey will vary widely.  As a way of bounding the estimates for this ICR, two scenarios are presented here. 

The first scenario, representing a low estimate of burden, assumes a universe of all state workforce agencies.  For surveys to be administered to state agencies, sampling will not be conducted; instead, all members of the universe will be surveyed.  Doing so would yield 54 as the targeted sample, representing all 50 states, the District of Columbia, Puerto Rico, Guam, and the Virgin Islands.  For the low estimate, we also assume that the survey will be one of the shorter ones envisioned under this clearance (with no more than 10 separate questions).  We assume further that each question will take no more than 1 minute to answer, which we take to be ample if informed respondents are asked questions of a simple factual nature about state policy.  These types of surveys will thus take 10 minutes per respondent; with 54 respondents, each survey would have a burden of 540 minutes or 9 hours.  If 8 surveys used these low estimate assumptions, the total burden would be 72 hours over three years (or 24 hours averaged over each year).

The second scenario, representing the high estimate of burden, assumes that the maximum number of questions would be 30, and that the maximum amount of time for each question to be answered would be 3 minutes on average, assuming that some questions might require the respondent to either consult written documents (e.g., policy issuances) or consult with colleagues.  In this case, each survey would take 90 minutes per respondent and with 250 respondents, would take 22,500 minutes or 375 hours.  If all 20 surveys over the 3-year clearance period of this ICR used the assumptions for the high estimate, the total burden would be 7,500 hours (375 x 20).  (The average annualized burden would be 2,500 hours.)

Using the two scenarios above, total respondent cost burden over the 3 years for 8-20 survey ranges from $2,239.20 to $233,250, as shown below:

Low Estimate:  

54 respondents x 8 surveys x 10 minutes (10 questions @ 1 minute/question)/60 = 72 hours

72 hours x $31.10 = $2,239.20 over 3 years or $746.40 annualized.

High Estimate:

250 respondents x 20 surveys x 90 minutes (30 questions @ 3 minutes/question)/60 = 7,500

7,500 hours x $31.10 = $233,250 over 3 years or $77,750.00 annualized.

The $31.10 per hour represents the median hourly wage based on the Bureau of Labor Statistics hourly and weekly earnings of “Community and Social Services Manager Occupations” (May 2016 National Industry-Specific Occupational and Wage Estimates, from the U.S Department of Labor, available at https://www.bls.gov/oes/current/oes119151.htm on the Department’s website).

13.     Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.  (Do not include the cost of any hour burden shown in Items 12 and 14).

The proposed information collection plan will not require the respondents to purchase equipment or services or to establish new data retrieval mechanisms. 

(a) We do not expect any total capital and start-up costs.

(b) We do not expect extensive time spent on generating, maintaining, and disclosing or providing the information.

The proposed information collection plan will not require the respondents to purchase equipment or services or to establish new data retrieval mechanisms.  These costs are not expected to vary.

We do not expect responding agencies to purchase equipment or services in order to respond to this information collection plan effort.

14.     Provide estimates of annualized costs to the Federal government.  Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.  Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The Federal government’s costs for this effort will derive from the contractors who will conduct the surveys.  To compute these costs, we assume that data collection and analysis would cost between $40,000 and $80,000 based on estimates developed by ETA’s contractor for the first survey we are developing.  These estimates take into account all expenses, including variable hours for different professionals (research director, analyst and writer, and interviewers), as well as equipment and overhead.  

The cost of conducting 8 to 20 surveys, would therefore range between $320,000 to $1.6 million over three years, or $106,667 to $533,333 annualized costs.  A detailed cost to the Federal government for each collection of data will be provided for in each survey.

15.     Explain the reasons for any program changes or adjustments reported on the burden worksheet.

There is no change in burden hour estimates. ETA does seek to revise the scope of the collection to include the spectrum of agency programs, as opposed to just one statute; however, the nature of individual requests is not intended to change.

16.     For collections of information whose results will be published, outline plans for tabulation and publication.  Address any complex analytical techniques that will be used.  Provide the time schedule for the entire project, including beginning and end dates of the collection of information, completion of report, publication dates, and other actions.

The surveys will be administered on an as-needed basis over the three-year period covered by this clearance.  Results from the data collection will be presented to ETA by the contractor through a series of briefing papers, displaying tabular presentations of results, such as the number and percentage of states or local agencies who gave each of the various responses. 

17.  If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

ETA will display the OMB control number and expiration date for any individual surveys under this clearance. 

18.     Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions to the certification statement.

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