ML22347A317
| ML22347A317 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/2022 |
| From: | NRC/OCIO, NRC/OGC |
| To: | |
| References | |
| OMB 3150-0217 | |
| Download: ML22347A317 (7) | |
Text
FINAL SUPPORTING STATEMENT FOR GENERIC CLEARANCE FOR THE COLLECTION OF QUALITATIVE FEEDBACK ON AGENCY SERVICE DELIVERY
(3150-0217)
EXTENSION
A. JUSTIFICATION
- 1. Need for the Collection of Information
Executive Order 12862 directs Federal agencies to provide servi ce to the public that matches or exceeds the best service available in the private se ctor. In order to work continuously to ensure that our p rograms are effective and meet our customers needs, U.S. Nuclear Regulatory Commission (hereafter the Agency) see ks to obtain OMB approval of a generic clearance to collect qualitative feedback on our service delivery.
By qualitative feedback we mean information that provides usefu l 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 Agenc y to garner customer and stakeholder feedback in an efficient, timely manner, in accorda nce with our commitment to improving service delivery. The information collected from our customers and stakeholders will help ensure that users have an effective, eff icient, and satisfying experience with the Agencys programs. This feedback will prov ide insights into customer or stakeholder perceptions, experiences and expectatio ns, provide an early warning of issues with service, or focus attention on areas whe re communication, training or changes in operations might improve delivery of pro ducts or services. These collections will allow for ongoing, collaborative and actionabl e communications between the Agency and its customers and stakeholders. It will also al low 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 servic e delivery, by which we mean systematic review of the operation of a program compare d to a set of explicit or implicit standards, as a means of contributing to the contin uous improvement of the program. The Agency will collect, analyze, and interpret infor mation gathered through this generic clearance to identify strengths and weaknesses of current services and make improvements in service delivery based on feedback. The s olicitation of feedback will target areas such as: timeliness, appropriateness, accura cy of information, courtesy, efficiency of service delivery, and resolution of issues with s ervice delivery. Responses will be assessed to plan and inform efforts to improve or maint ain the quality of service offered to the public. If this information is not collected, v ital feedback from customers and stakeholders on the Agencys services will be unavailable.
The Agency will only submit a collection for approval under thi s 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 wil l be followed);
- Information gathered will not be used for the purpose of subst antially 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 consi derations of total burden hours, total number of respondents, or burden-hours per respondent) and are low-cost for both the respondents and the Federal Governmen t;
- 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 fro m respondents who have experience with the program or may have experience with th e program in the near future; and
- With the exception of information needed to provide renumerati on for participants of focus groups and cognitive laboratory studies, personally id entifiable information (PII) is collected only to the extent necessary and is not retained.
If these conditions are not met, the Agency will submit an info rmation collection request to OMB for approval through the normal PRA process.
To obtain approval for a collection that meets the conditions o f this generic clearance, a standardized form will be submitted to OMB along with supportin g documentation (e.g.,
a copy of the comment card). The submission will have automati c approval, unless OMB identifies issues within 5 business days.
The types of collections that this generic clearance covers inc lude, but are not limited to:
- Customer comment cards/complaint forms
- Small discussion groups
- Focus Groups of customers, potential customers, delivery part ners, or other stakeholders
- Cognitive laboratory studies, such as those used to refine que stions or assess usability of a website;
- Qualitative customer satisfaction surveys (e.g., post-transact ion surveys; opt-out web surveys)
- In-person observation testing (e.g., website or software usabi lity tests)
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.
The Agency has established a manager/managing entity to serve for this generic clearance and will conduct an independent review of each inform ation collection to ensure compliance with the terms of this clearance prior to sub mitting 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 t echnology when it would be beneficial to them. If appropriate, agencies will col lect 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 d uplication 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 app roved 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 timel y 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 w ill 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 May 9, 2022 (87 FR 27664). In addit ion, the NRC staff contacted five members of the public by email to invite them to comment on this information collection renewal. These five stakeholders had re cently interacted with NRC staff through their use of the public document room or as a result of a Freedom of Information Act request. No responses or comments were receive d as a result of these consultations.
- 9. Payment or Gift to Respondents
The Agency will not provide payment or other forms of remunerat ion to respondents of its various forms of collecting feedback. Focus groups and cog nitive laboratory studies are the exceptions.
- 10. Confidentiality of Information
Confidential and proprietary information is protected in accord ance 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 (1,087.5) and r esponses (4,200) are based on the number of collections the agency expects to co nduct over the requested period for this clearance. The annual burden hour co st is estimated to be
$313,200 (1,087.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> x $288/hr).
Estimated Annual Reporting Burden Annual Frequency Number of of Minutes per Type of collection Respondents Response response Total hours Focus groups 50.0 1 60.0 50.0 Customer satisfaction surveys, brief 2,500.0 1 10.0 416.7 Customer satisfaction surveys, long 200.0 1 60.0 200.0 Class or event presentation evaluation 750.0 1 15.0 187.5 Panels 50.0 1 60.0 50.0 Post transaction 0.0 1 0.0 0.0 Online surveys 450.0 1 20.0 150.0 Comment cards 200.0 1 10.0 33.3 Remote usability 0.0 1 0.0 0.0 Survey test 0.0 1 0.0 0.0 Total 4,200.0 1,087.5
The $288 hourly rate used in the burden estimates is based on t he Nuclear Regulatory Commissions 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 202 1 (86 FR 32146, June 17, 2021).
- 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 $111,700 and include the following:
300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> professional staff time x $288/hr = $86,400 Postage =$300 Contractor support = $25,000
- 15. Reasons for Change in Burden or Cost
The burden estimate remains unchanged from the last renewal. T he NRC estimates that burden on respondents under this clearance will be 1,087.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 4,200 responses. This is based on a review of ongoing customer satis faction surveys, input from program offices, and projections about the use of su rveys for upcoming projects.
Cost estimates have increased due to a change in the agencys f ee rate from
$275/hr to $288/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 popu lation. Findings will be used for general service improvement, but are not for publicati on or other public release.
Although the Agency does not intend to publish its findings, th e Agency may receive requests to release the information (e.g., congressional inquir y, Freedom of Information Act requests). The Agency will disseminate the fin dings when appropriate, strictly following the Agency's "Guidelines for En suring the Quality of Information Disseminated to the Public," and will include speci fic 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 requ irements in 5 CFR 1320.9.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Data collection methods and procedures will vary; however, the primary purpose of these collections will be for internal management purposes; there are no plans to publish or otherwise release this information.
- 1. Universe and respondent selection
The activities under this clearance may involve samples of self -selected customers, as well as convenience samples, and quota samples, with respondents sel ected either to cover a broad range of customers or to include specific characteristics related to certain products or services. Results will not be us ed to make statements represen tative of the universe of study, to produce statistical descriptions (careful, repeatable measurements), or to generalize the data beyond the scope of the sample. The specif ic sample planned for each individual collection and the method for soliciting participati on will be described fully in each collection request.
Qualitative surveys are tools used by program managers to chang e or improve programs, products, or services. The accuracy, reliability, and applicab ility of the results of these surveys are adequate for their purpose.
The samples associated with this collection are not subjected t o the same scrutiny as scientifically drawn samples where estimates are published or o therwise released to the public.
- 2. Procedures for collecting the information
Data collection methods and procedures will vary and the specif ics of these will be provided with each collection request. The Agency expects to use a varie ty of methodologies for these collections. For example, the Agency or its contractors m ay use commercial survey-specific software to automate its collection and analysis of fe edback. In addition to physical copies, information collection instruments may be electronicall y disseminated and/or posted on target pages of the Agencys web site. Telephone scripts, p ersonal interviews, and focus groups with professional guidance and moderation may also be us ed.
- 3. Methods to maximize response rates and to deal with statisti cal issues of non-response
Information collected under this generic clearance will not yie ld generalizable quantitative findings; it can provide useful customer input, but it does not yield data about customer opinions that can be generalized.
- 4. Tests or procedures
Pretesting may be done with internal staff, a limited number of external colleagues, and/or customers who are familiar with the programs and products. If the number of pretest respondents exceeds nine members of the public, the Agency will submit the pretest instruments for review under this generic clearance.
- 5. Contacts for Statistical Aspects and Data Collection Each program will obtain information from statisticians in the development, design, conduct, and analysis of customer/partner service surveys, when appropri ate. This statistical expertise will be available from agency statisticians or from c ontractors and the Agency will include the names and contact information of persons consulted in the specific information collection requests submitted under this generic clearance.