5.20 Supporting Statement Part A NCS Coronavirus Pandemic

National Compensation Survey (NCS) – Supplemental questions related to sick leave policies during the Coronavirus pandemic

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Emergency Collection request

Supporting Statement for the Supplemental Questions to the National Compensation Survey related to sick leave policies during the Coronavirus pandemic

Emergency Information Collection Request (ICR)

Justification, Part A.

Overview

This request is for a 180-day approval of an emergency Information Collection Request for supplemental questions to the National Compensation Survey to measure changes to private industry sick leave policies during the coronavirus pandemic. This collection will be coordinated with the National Compensation Survey (NCS) ICR #1220-0164 expiring April 2021. The NCS is an ongoing national design survey of compensation and benefit data. Benefit information collected and produced under the NCS includes sick leave plan usage and key provisions.

This emergency ICR will collect the following data to supplement NCS sick leave data. These data are not currently collected by any BLS program.

The benefit information to be collected is:

• Whether a company has made changes to its paid and unpaid sick leave plans due to the Coronavirus pandemic

• Whether the changes are permanent or temporary

• Range of days added to paid and unpaid sick leave plans

• Range of time used by employees (plan usage) for paid and unpaid sick leave

Attachment A – Form NCS-CV provides the specific questions and response categories.

1. Necessity of the Information Collection

Data on the various types and usage of sick leave plans is required to meet the needs of multiple public and private sector data users. The recent coronavirus pandemic has generated a need for reliable statistical data on private industry polices and changes made in response to the situation.

Currently collected NCS sick leave data do not capture the information needed as temporary policies are excluded from collection. The NCS data collection scope cannot quickly be expanded because those data are used to calculate the Employment Cost Index (ECI), a principal Federal economic indicator. The new questions are intended to supplement existing estimates and provide this detail.

BLS has received data requests from various sources seeking additional details to existing published estimates. These data are desired by researchers for establishing public policy as well as employers for evaluation and formation of company benefit plans. The following agencies have contacted BLS seeking this information that is not available from other public or private sources:

• Congress – The original text of the Families First Coronavirus Response Act indicates that BLS should produce as much data as possible on employer provided sick leave.

• Council of Economic Advisers (CEA) – Since the start of the current COVID-19 situation, BLS has received multiple requests from CEA seeking the most recent data available on access to employer-provided sick leave. Due to the timing of BLS benefit data collection, data is possibly already dated. This additional collection will allow BLS to determine by how much sick leave benefit access may have changed.

• Census – The current Census “Household Pulse Survey” provides a household perspective during the Coronavirus pandemic and contains one question that provides limited information on whether the individual is able to take leave through their employer. This question was requested by BLS. The NCS data collection will complement this information.

The collection of employee compensation data is authorized and mandated by several laws and regulations. BLS is the only agency that collects comprehensive data on employer-provided benefits. The relevant regulation for this data collection request is:

The Bureau of Labor Statistics is authorized to make “... continuing studies of ... labor costs in manufacturing, mining, transportation, distribution, and other industries” under Title 29 of the U.S. Code (29 USC 2b). http://law.onecle.com/uscode/29/2b.html

For additional information, see currently approved ICR collection for 1220-0164.

2. Uses of Information

The purpose of the additional sick leave data is to facilitate policy analysis and formation at all levels.

Some existing and proposed legislation on benefits used NCS data for cost and benefit analysis. These include various paid sick leave legislation initiatives introduced in State legislatures and city councils. Estimates from data collected under this emergency collection request will provide a view at the National level of how companies are modifying their policies.

For additional information on the uses of information, see currently approved ICR collection for 1220-0164.

3. Uses of Improved Information Technology

BLS obtains data from respondents through personal interview, telephone, e-mail, fax, and website contacts. For data that are typically collected in person, BLS is limiting in-person collection and focusing on phone, email, and internet. This emergency collection request is focused on using email as the primary method of contact. Respondents will be able to use a fillable pdf to provide data and automatically submit their form. This requires the least action on the respondent to provide a response. This data may be encrypted or password protected to maintain confidentiality.

Respondents can use any of the methods described above for replying to allow them to choose the least burdensome option. Regardless of the method of collection, BLS will enter the data into a database for additional processing.

For additional information on use of information technology please see currently approved ICR collection 1220-0164.

4. Effort to Identify Duplication

The NCS data collection under ICR #1220-0164 already collects data on company sick leave policies. The emergency data collection request uses these responses to identify companies where sick leave policies already exist, reducing the number of respondents contacted and eliminating an initial screening question.

In developing the emergency data collection request, the BLS has undertaken efforts to coordinate the new questions with other surveys and other Federal data needs. BLS has coordinated this data collection between the NCS and a new, proposed business survey by BLS. Duplication was identified and questions were dropped by NCS.

NCS staff have also consulted with Office of Survey Methods Research staff within BLS, as well as Census staff, to coordinate new questions and avoid unneeded duplication of collection.

For additional information on efforts to identify duplication in the NCS see currently approved ICR collection 1220-0164.

5. Minimizing the Burden to Small Establishments

There are no changes from the currently approved collection for the NCS.

For further information on the efforts to minimize burden on small establishments see currently approved ICR collection for 1220-0164.

6. Consequences of Not Collecting the Data or Less Frequent Data Collection

This is a one-time data collection request to respond to a current data need. If this data is not collected, BLS would not be able to produce detailed information about changes to sick leave policies during this time.

7. Special Circumstances

There are no special circumstances for this collection.

8. Federal Register Notice/Outside Consultation

Because this is a request for emergency clearance, BLS asks that the 60-day comment period be waived. However, a 60-day Federal Register Notice will be published within 30 days of clearance approval of this package announcing the emergency request and seeking comments on the additional questions. That 60-day FRN will also announce the NCS renewal of ICR #1220-0164 currently expiring on April 30, 2021.

9. Payments to Respondents

No payments or gifts will be provided to any respondents.

10. BLS Confidentiality Policy

Data collected for these questions will be protected in the same manner as other data collected in the NCS.

For additional information see currently approved ICR collection for 1220-0164.

11. Sensitive Questions

No sensitive questions are asked during the survey.

12. Estimated Reporting Burden

Estimates of respondent burden are provided in this section for all activities associated with the emergency collection request.

The emergency collection sample is a subset of private industry establishments already providing data for the NCS under ICR #1220-0164. It is not necessary to collect basic information about the establishment.

The burden for this emergency collection is limited to the time to introduce the purpose of the new questions and collect limited categorical data. The BLS estimates 3 minutes of respondent time will be required for collection of the emergency request sick leave questions.

These units are covered by quality assurance processes under the NCS collection program. Given the limited scope of the data, and to be sensitive to the current pressures on respondents, there is no additional quality assurance contact for the emergency collection questions.

For the NCS survey collected quarterly, in March 2020, 82 percent of viable establishments provided data.

Table 1. Anticipated private sector sample burden for FY 2020 (annual figures)

Collection Activity	Number of Respondents	Responses Per Respondent	Total Annual Responses	Minutes Per Response	Total Hours
Collection of Coronavirus related Sick Leave policies – Private Sector	7539	1	7539	3	377
Non-response re-contact effort	754	1	754	3	38

The NCS collection form containing the new sick leave collection questions is included in this clearance package. See Attachment A – Form NCS-CV.

BLS staff will enter provided data into an electronic database. NCS considers the establishment data in the electronic database the official copy of the establishment data for survey purposes.

Table 2. Functions and uses of NCS forms

Information collected	Purpose/Activity	Forms	Time
Private Industry Collection of new sick leave policies	Benefit initiation	NCS-CV	3 minutes

Type of Respondents	Form Name	Responses Per Respondent	Total Annual Responses	Minutes Per Response	Total Hours	Respondent Cost	Total
Professional and related specialty	NCS-CV	1	5805	3	290	$57.48	$16,669
Office and administrative support	NCS-CV	1	2488	3	125	$28.23	$3,529

Estimated annualized cost to all respondents for all activities is $20,198 for 2020

Individual respondent cost per year (for all responses) is expected to be an average of $2.44 for 2020. This amount is based on an average cost of $48.70 per hour per respondent.

Hourly costs of pay and benefits measured by the Employer Cost for Employee Compensation data series for Civilian workers in December 2019. http://www.bls.gov/news.release/pdf/ecec.pdf .

13. Cost Burden to Respondents

There are no capital and start-up costs, nor operation, maintenance and purchase of service costs resulting from the collection of this information.

14. Estimated Cost of the Survey

There are no additional costs for this collection. Existing funding for the NCS includes survey improvement efforts that cover the design, collection, estimation, and dissemination for these additional questions. See the estimated costs for the NCS under currently approved ICR collection 1220-0164.

15. Program Changes or Adjustments

This is a new collection request.

16. Plans for Tabulation, Statistical Use, and Publication

The data collected under this emergency request are categorical and at the establishment level.

Data is adjusted for non-response. Establishments may refuse to provide any data or may refuse to provide data for certain benefit questions. The adjustment consists of revising the weights used to aggregate the individual establishments. Nationwide percentage estimates will be tabulated and those that meet publication criteria will be disseminated in September 2020.

All published estimates from the NCS are available on the BLS internet site, www.bls.gov.

A detailed description of the statistical procedures used in compiling the data is in Part B.

17. Approval to not Display the OMB Expiration Date

Approval to not display the expiration date for OMB approval is not being sought.

18. Exceptions to the Certification Statement

There are no exceptions to the certification statement.

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