ML24032A076

Draft Supporting Statement for Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery (OMB 3150-0217)

ML24032A076
Person / Time
Issue date:	02/20/2024
From:	NRC/OCIO
To:
References
OMB 3150-0123
Download: ML24032A076 (8)

Text

DRAFT 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 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 Agencys 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 Agencys 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)

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 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.

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 expect s to conduct over the requested period for this clearance. The annual burden hour cost is estimated to be

$812,400 (2,708 hours0.00819 days <br />0.197 hours <br />0.00117 weeks <br />2.69394e-4 months <br /> x $300/hr).

Estimated Annual Reporting Burden Annual Frequency Minutes Number of of per Total Type of collection Responses Response response hours Focus groups 200 1 60 200 Flash customer satisfaction surveys, 6000 1 1 100 live (in-meeting)

Customer satisfaction surveys, brief 3,000 1 10 500 Customer satisfaction surveys, long 200 1 60 200 Class or event presentation 2,000 1 15 500 evaluation 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 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 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 $205,300and include the following:

600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> professional staff time x $300 /hr = $180,000 Postage =$300 Contractor support = $25,000

15. Reasons for Change in Burden or Cost

The burden estimate remains unchanged from the last renewal. The 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 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 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />). 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 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> 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 hours0.0016 days <br />0.0383 hours <br />2.281746e-4 weeks <br />5.2509e-5 months <br /> 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 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> for these activities.

• In anticipation of future remote usability studies, the staff added 450 responses and 650 hours0.00752 days <br />0.181 hours <br />0.00107 weeks <br />2.47325e-4 months <br /> 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 agencys 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.

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 selected either to cover a broad range of customers or to include specific characteristics related to certain products or services. Results will not be used to make statements representative of the universe of study, to produce statistical descriptions (careful, repeatable measurements), or to generalize the data beyond the scope of the sample. The specific sample planned for each individual collection and the method for soliciting participation will be described fully in each collection request.

Qualitative surveys are tools used by program managers to change or improve programs, products, or services. The accuracy, reliability, and applicability of the results of these surveys are adequate for their purpose.

The samples associated with this collection are not subjected to the same scrutiny as scientifically drawn samples where estimates are published or otherwise released to the public.

2. Procedures for collecting the information

Data collection methods and procedures will vary and the specifics of these will be provided with each collection request. The Agency expects to use a variety of methodologies for these collections. For example, the Agency or its contractors may use commercial survey-specific software to automate its collection and analysis of feedback. In addition to physical copies, information collection instruments may be electronically disseminated and/or posted on target pages of the Agencys web site. Telephone scripts, personal interviews, and focus groups with professional guidance and moderation may also be used.

3. Methods to maximize response rates and to deal with statistical issues of non-response

Information collected under this generic clearance will not yield 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 6.

Each program will obtain information from statisticians in the development, design, conduct, and analysis of customer/partner service surveys, when appropriate. This statistical expertise will be available from agency statisticians or from contractors and the Agency will include the names and contact information of persons consulted in the specific information collection requests submitted under this generic clearance.