FINAL Part A SS for generic customer satisfaction fast-track

FINAL SUPPORTING STATEMENT

FOR

GENERIC CLEARANCE FOR THE COLLECTION OF QUALITATIVE FEEDBACK ON AGENCY SERVICE DELIVERY

(3150-0217)

EXTENSION

1. 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, U.S. Nuclear Regulatory Commission (hereafter “the Agency”) seeks to obtain OMB approval of a generic clearance to collect qualitative feedback on our service delivery. By qualitative feedback we mean information that provides useful insights on perceptions and opinions, but are not statistical surveys that yield quantitative results that can be generalized to the population of study.

This collection of information is necessary to enable the Agency 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 Agency’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 Agency and its customers and stakeholders. It will also allow feedback to contribute directly to the improvement of program management.

2. Agency Use and Practical Utility of 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 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 Agency’s services will be unavailable.

The Agency 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 the agency (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;

• 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 renumeration 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 Agency 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 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)

The Agency 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. Reduction of Burden Through Information Technology

There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. If appropriate, agencies will collect information electronically and/or use online collaboration tools to reduce burden. It is estimated that approximately 90% of the potential responses are filed electronically.

4. Effort to Identify Duplication and Use Similar Information

No sources of similar information are available. There is no duplication of requirements.

5. Effort to Reduce Small Business Burden

Small business or other small entities may be involved in these efforts but the Agency 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 to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently

Without these types of feedback, the Agency will not have timely information to adjust its services to meet customer needs.

7. Circumstances Which Justify Variation from OMB Guidelines

There are no special circumstances. The information collected will be voluntary and will not be used for statistical purposes.

8. Consultations Outside the NRC

In accordance with 5 CFR 1320.8(d), a 60-day notice for public comment was published in the Federal Register on February 28, 2024 (89 FR 14725). The NRC staff contacted five members of the public who had previous experience with NRC services, such as the provision of documents in the public document room or through the Freedom of Information Act process. No comments or responses were received as a result of these consultations. In response to the FRN, one comment expressing general support was received.

9. Payment or Gift to Respondents

The Agency 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.

10. Confidentiality of Information

Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b). However, no information normally considered confidential or proprietary is requested.

11. Justification for Sensitive Questions

No questions will be asked that are of a personal or sensitive nature.

12. Estimated Burden and Burden Hour Cost

A variety of instruments and platforms will be used to collect information from respondents. The annual burden hours requested (2,708)) and responses (13,300) are based on the number of collections the agency expects to conduct over the requested period for this clearance. The annual burden hour cost is estimated to be $812,400 (2,708 hours x $300/hr).

Estimated Annual Reporting Burden
Type of collection	Number of Responses	Annual Frequency of Response	Minutes per response	Total hours
Focus groups	200	1	60	200
Flash customer satisfaction surveys, live (in-meeting)	6000	1	1	100
Customer satisfaction surveys, brief	3,000	1	10	500
Customer satisfaction surveys, long	200	1	60	200
Class or event presentation evaluation	2,000	1	15	500
Panels	50	1	60	50
Post transaction	0	1	0	0
Online surveys	1,000	1	20	333
Comment cards	300	1	10	50
Remote usability	450	1	90	675
Survey test	100	1	60	100
Total	13,300			2,708

The $300 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commission’s fee for hourly rates as noted in 10 CFR 170.20 “Average cost per professional staff-hour.” For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2023 (88 FR 39120, June 15, 2023).

13. Estimate of Other Additional Costs

There are no additional costs.

14. Estimated Annualized Cost to the Federal Government

The anticipated cost to the Federal Government is approximately $205,300 and include the following:

600 hours professional staff time x $300/hr = $180,000

Postage =$300

Contractor support = $25,000

15. Reasons for Change in Burden or Cost

This generic clearance was approved in Febraury 2023 with 4,200 responses. The NRC staff had used almost all of these responses within one year of the clearance approval. As a result, this request approximately triples the number of requested responses to 13,300 (an increase of 9,100 responses) in order to cover the full three year clearance period. The burden has been increased from 1087.5 to 2,708 (an increase of 1,620.5 hours). Most of the increase in responses are for very low burden requests.

The largest increases are for the following activities:

• Agency program offices have begun to use mobile technology to get immediate feedback to promote discussion during meetings. These “flash” customer feedback surveys typically take less than one minute and the results are immediately available to meeting facilitators. The NRC staff has added burden for this type of feedback, which tends to have high response rates and low burden. 100 hours and 6,000 responses have been added for this activity.

• Burden estimates for class or event presentation evaluations has increased. In the last clearance cycle, 690 responses and 138 hours were used for feedback on classroom evaluations in the first year alone. The NRC staff anticipates additional burden in this area and has estimated 2,000 responses and 500 hours for these activities.

• In anticipation of future remote usability studies, the staff added 450 responses and 650 hours for this type of activity. In the previous renewal, no burden was estimated for these type of studies.

Finally, cost estimates have increased due to a change in the agency’s fee rate from $288/hr to $300/hr.

16. Publication for Statistical Use

Feedback collected under this generic clearance provides useful information, but it does not yield data that can be generalized to the overall population. Findings will be used for general service improvement, but are not for publication or other public release.

Although the Agency does not intend to publish its findings, the Agency may receive requests to release the information (e.g., congressional inquiry, Freedom of Information Act requests). The Agency will disseminate the findings when appropriate, strictly following the Agency's "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. Reason for Not Displaying the Expiration Date

The expiration date will be displayed.

18. Exceptions to the Certification Statement

There are no exceptions. These activities comply with the requirements in 5 CFR 1320.9.

1 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.”