2015 Museums for All Justification A

Approval is requested to conduct information collection for the

Museums for All Program

Section A. Justification

A.1. Necessity of the Information Collection

The Institute of Museum and Library Services (IMLS) is the primary source of federal support for the nation's 123,000 libraries and 35,000 museums. IMLS' mission is to create strong libraries and museums that connect people to information and ideas. IMLS works at the national level and in coordination with state and local organizations to sustain heritage, culture, and knowledge; enhance learning and innovation; and support professional development.

As detailed in the IMLS Strategic Plan 2012-2016, IMLS is committed to promoting inclusive and accessible learning services for the American people and is uniquely positioned to facilitate and highlight the work that libraries and museums do in addressing a wide variety of learning needs and providing services to increasingly diverse communities. IMLS plays a leadership role in promoting inclusive services that address the needs of the increasingly diverse populations of our country as well as the accessibility requirements of all users. Further, IMLS promotes museums and libraries as strong community anchors that enhance civic engagement, cultural opportunities, and economic vitality.

The Museums for All program is designed to invite museums to allow Electronic Benefit Transfer (EBT) card holders to receive reduced-price admission to their facilities. In order to administer the program effectively, IMLS will need to collect registration data from participating museums, to include basic institutional location contact information. In addition, IMLS wishes to measure the impact of the program by requiring participating museums to report the number of visitors receiving reduced-price admission through this program. Because this is a new program, additional information will be collected to assess the implementation of the program resources and components during the first year.

Legislative authority

IMLS is responsible for identifying national needs for, and trends of, museum and library services funded by IMLS. IMLS must also report on the impact and effectiveness of programs conducted with funds made available by IMLS. IMLS must identify and disseminate information on the best practices of such programs.

20 U.S.C. Subchapter III – Museum Services

Section 9173. Museum services activities

1. In general

Subpart 7: supporting museums in providing services to people of diverse geographic, cultural, and socioeconomic backgrounds and to individuals with disabilities

Subpart 8: supporting museums in developing and carrying out specialized programs for specific segments of the public, such as programs for urban neighborhoods, rural areas, Indian reservations, and State institutions

20 U.S.C. Section 9108. Policy research, analysis, data collection, and dissemination

(a) In general

The Director shall annually conduct policy research, analysis, and data collection to extend and improve the Nation’s museum, library, and information services.

(b) Requirements

The policy research, analysis, and data collection shall be conducted in ongoing collaboration (as determined appropriate by the Director), and in consultation, with –

(1) State library administrative agencies;

(2) National, State, and regional library and museum organizations;

(3) Other relevant agencies and organizations.

(c) Objectives

The policy research, analysis, and data collection shall be used to –

(1) Identify national needs for and trends in museum, library, and information services;

(2) Measure and report on the impact and effectiveness of museum, library, and information services throughout the United States, including the impact of Federal programs authorized under this chapter;

(3) Identify best practices; and

(4) Develop plans to improve museum, library, and information services of the United States and to strengthen national, State, local, regional, and international communications and cooperative networks.  

(d) Dissemination

Each year, the Director shall widely disseminate, as appropriate to accomplish the objectives under subsection (c), the results of the policy research, analysis, and data collection carried out under this section.

A.2. Purposes and Uses of the Data

IMLS is working with the Association of Children’s Museums (ACM) through a cooperative agreement to conduct a pilot phase of the Museums for All program. During this pilot phase, children’s museums will be targeted as the initial audience to participate in the program. During this pilot program (extending through May 2016), ACM will develop tools and resources to support participation in Museums for All. These resources will include a website, participation guidelines, logo and branding guidelines, webinars, marketing collateral, and access to national and local partners. Museums interested in participation will be required to complete a registration form with basic contact information, and they also agree to file a quarterly reporting form to document the impact of attendance on their institution through participation in the program. No personal data will be collected relating to audience participation—only total attendance numbers at each participating institution. Additionally, during this pilot phase, participating museums will complete a program assessment form (customer service feedback) to assist IMLS and ACM in evaluating the effectiveness of the resources described above as plans are made to launch the Museums for All program to the entire museum community.

The information collected through these three forms will be used by IMLS and ACM in the administration of the program and the internal evaluation of the effectiveness of resources. Reporting data may be consolidated to share the potential success of the program in reaching the target audiences.

IMLS and ACM will publish a list of participating museums on the Museums for All website.

No information will be collected regarding museum attendance other than total aggregate numbers of museum visitors, and total aggregate number of museum visitors admitted at reduced-prices by presenting an Electronic Benefits Transfer card. Visitor information will be reported only in aggregate form or in a manner that will not specifically identify the reporting organization.

Information collected to assess the implementation of the program resources and components during the first year will be used internally by IMLS and ACM to improve these materials to support the expansion of the program to museums of all kinds nationwide.

The name and contact information (email and phone number) for a key contact person at each museum will be collected at registration, but will only be used for program implementation purposes.

A.3. Use of Information Technology

IMLS and ACM will create electronic forms to simplify the data collection process. These simple forms can also be manually completed for those few museums unable to utilize the electronic process.

A.4. Efforts to Identify Duplication

This is a new program and a new collection that will not duplicate any previously collected information.

A.5. Methods Used to Minimize Burden on Small Businesses

For all institutions, both small and large, participation in Museums for All is entirely voluntary.

A.6. Consequences of Less Frequent Data Collection

The Museums for All Program is an initiative to improve access to a high-quality museum experience for underserved audiences. Without implementation of this data collection, the potential for this program to increase access to museums for low-income families would be diminished.

A.7. Special Circumstances

No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.

A.8. Consultations Outside the Agency

Public comments solicited through Federal Register

IMLS published a notice in the Federal Register with a 60-day public comment period to announce this proposed information collection on November 21, 2014, Volume 79, Number 225, pages 69538 - 69539. A copy of the Federal Register Notice is provided in the attachment. One comment was submitted.

IMLS published a notice in the Federal Register on April 2, 2015 (Volume 80, Number 63, page 17789-17790), with a 30-day public comment period to announce forwarding of the information collection request to OMB for approval.

Consultants outside the agency

As part of the cooperative agreement referenced above, IMLS has closely consulted with the Association of Children’s Museums in the development of the data collection instruments/forms. In addition, IMLS and ACM have worked closely with representatives from children’s museums in cities where similar programs have already been developed to gather insight and suggestions regarding program implementation and support.

A.9. Payments or Gifts to Respondents

N/A

A.10. Assurance of Confidentiality

Any personally identifiable data collected (e.g., the name of the person who responded on behalf of the museum) will be kept confidential to the extent permitted by law.

A.11. Justification for Sensitive Questions

There are no sensitive questions on the Museums for All forms.

A.12. Estimates of Hour Burden to Respondents

The number of respondents anticipated during the pilot phase of the program is 125. The burden per respondent is estimated to be an average of 60 minutes. The estimated total annual burden is 125 hours (that is 60 minutes per respondent times 125 respondents equals 7,500 minutes or 125 hours).

A.13. Estimates of Annualized Cost Burden to Respondents

According to the Department of Labor, the mean annual wage rate for a museum technician is $21.31 based on full time work, 40 hours/week, 52 weeks/year (May 2013):

	No. of Respondents	Annual Frequency per Respondent	Hours per Response	Total Hours	Hourly Rate per Respondent	Total Cost
Museums for All respondent	125	4	0.25	1	$ 21.31	$ 21.31
TOTALS	125	500	025	125	$ 21.31	$ 2,663.75
25-4013 Museum Technicians and Conservators

The Estimated Total Cost Burden is $2,663.75 (125 hours burden times $21.31 average wage).

A.14. Estimates of Annualized Cost to Federal Government

The cost of the cooperative agreement with the Association of Children’s Museums (ACM) is $126,445. Most of this cost is for program development, implementation, and management for the pilot phase. Approximately $10,000 will be spent on data collection efforts.

A.15. Reason for Program Changes or Cost Adjustments

There are no changes from the OMB Form 83-I. This is a new submission.

A.16. Project Schedule

Because this is a new, voluntary program, museums will be enrolled into the program on a rolling, on-going basis.

May 2015 Launch program, begin registration (registration form)

July 2015 First data collection (reporting form)

October 2015 Second data collection (reporting form)

January 2016 Third data collection (reporting form)

April 2016 Fourth data collection (reporting form)

May 2016 Feedback (Customer Service form)

Not all museums anticipated will be registered at the beginning, so not all museums will report at all occasions. We anticipate fluctuations in attendance numbers due to seasonality and due to implementation and dissemination of the program (e.g., anticipate number of program eligible visitors to increase as program grows within a market).

A.17. Request to Not Display Expiration Date

No exemption from the requirements to display the expiration date for OMB approval of the information collection is being requested for the Museums for All program. The OMB approval number and expiration date will be displayed on all data collection materials and documentation.

A.18. Exceptions to the Certification

No exceptions to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I apply to the Museums for All program.