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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any

legal or administrative requirements that necessitate the collection. Attach a copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information.

This is an extension of a currently approved submission.

On September 11, 1993, President Clinton issued Executive Order 12862, “Setting Customer 

Service Standards” which established a need to reform government practices and operations with 

the result that, when dealing with Federal agencies, all people would receive services that match 

or exceed the best service available in the private sector. 

Section 1(b) of that Order required agencies to “survey customers to determine the kind and 

quality of services they want and their level of satisfaction with existing services”. Section 1 (e) 

requires agencies to “survey front-line employees on barriers to, and ideas for, matching the best 

in business.” These Presidential requirements established an ongoing need for the Department of 

Education (ED) to be engaged in an interactive process of collecting information and using it to 

improve program services and processes. Agencies are therefore authorized to measure customer 

satisfaction and report results. In addition, the March 22, 1995 Presidential Memo “Improving 

Customer Service,” states that customer views should be obtained to determine whether 

standards have been met on those matters which most concern the customer. This Master Plan 

represents the Department’s continued commitment to improve products and services.

Surveys to be considered under this generic will only include those surveys that improve a 

customer service or collect feedback about a service provided. The results of the customer 

surveys will help ED managers plan and implement program improvements and other customer 

satisfaction initiatives. Focus groups that will be considered under the generic clearance will 

assess customer satisfaction with a direct service, be of limited size or scope, and/or will be 

designed to inform a customer satisfaction survey ED was considering. Surveys that have the 

potential to influence policy will not be considered under this generic clearance. 

The types of surveys to be included in this clearance include customer surveys and focus groups. 

Program offices will submit a generic information collection that shall include all relevant 

information, including a statement of need, intended use of information, description of 

respondents, information collection procedures, expected response rates, justification for 

incentives and estimated burden.
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ED has included Appendix A which contains the listing of all currently approved ED surveys to 

date and new surveys to be submitted during the next 3 years. 

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new 

collection, indicate the actual use the agency has made of the information received from the 

current collection.

The primary objective in the Executive Order was that all entities and individuals directly served 

by ED will receive the highest quality of service comparable to private organizations. These 

individual and entities are defined as our “customers.” 

In ED, senior management has clearly defined our ultimate customer as the learner of all ages. 

This ultimate customer might be classified in four primary groups: pre-school children, 

elementary and secondary students, postsecondary and graduate students, and adult learners. 

Besides these customers, ED also provides funds and services directly to: parents, teachers, 

principals, local education agencies, state education agencies, Governors and those committees 

and agencies which report directly to them, institutions of higher education, accreditation 

agencies, lenders, guarantee agencies, national special interest groups with an interest in 

education, contractors, grantees, and individuals seeking employment with ED. Each of these 

groups, while often also a partner in the education process, is to be considered an ED customer. 

As such, the expectations and requirements of each of these groups will need to be understood. 

The array of customer satisfaction surveys to be conducted by ED will assess these needs to help 

develop proposals to meet the needs at a level that matches or exceeds the best service available 

in the private sector.

In order to continue to meet these objectives, ED will establish an internal process where 

customer satisfaction is regularly monitored and measured. The results will be “fed back” into 

the ED programs’ planning and decision-making processes to improve the quality of ED 

program’s products and services. To do this, ED program offices will continue to conduct 

customer service focus groups and surveys.

Results from some surveys and focus groups will be used to establish customer-defined goals 

and standards for measuring ED progress toward those goals. Other surveys and focus groups 

will clarify those standards and evaluate ED performance. This will be an ongoing process of 

measuring customer satisfaction and then using that information to refine or redefine ED’s 

programs and processes. The survey results will be used to fulfill customer satisfaction reporting 

requirements in Executive Order #12862 and to improve ED’s services and products and their 

use. Without this institutionalized process, ED managers will have little basis for planning and 

implementing program improvements and other customer satisfaction initiatives.

Surveys that produce prevalence estimates or official statistics of any kind do not fall within the 

scope of this generic clearance for customer satisfaction surveys and focus groups.
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3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis for the 

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

The determination to use technology, and which technology to use, will be based on the type of 

information collected and the utility and the availability of specific technology to each set of 

potential respondents in each proposed customer satisfaction survey. Many programs will utilize 

and have utilized Internet home pages to seek public comment and suggestions. Others may

propose the submission of comments with electronic submission of application and reports. 

Many of the approved customer satisfaction surveys have utilized electronic collection and 

submission technology.

4. Describe efforts to identify duplication. Show specifically why any similar information 

already available cannot be used or modified for use for the purposes described in Item 2 above.

The information to be supplied on these surveys will not be duplicated on any other information 

collection. The Regulatory Information Management Service (RIMS) will review the proposed 

ED surveys to verify that the information sought is not already available and that the survey fits 

into a coordinated department-wide customer satisfaction program. Since the initial OMB 

approval of ED’s umbrella clearance for customer satisfaction surveys, ED has been careful to 

ensure the streamlining in number of surveys, number of questions, and type of questions 

proposed for approval. In addition to these reviews, RIMS routinely runs reports of ED 

customer surveys to determine that there is no duplication among surveys.

There is no information available from any other source, which will enable ED to evaluate the 

satisfaction of our customers under the provisions of the Executive Order.

5. If the collection of information impacts small businesses or other small entities, describe any

methods used to minimize burden.

The information collected in these surveys will represent the minimum necessary to evaluate 

customer satisfaction with ED programs. It is expected that most survey instruments will be 

designed to take less than thirty minutes of the respondent’s time.

The frequency for individual respondents is one time. Without a regular program of customer 

satisfaction surveys, the Department of Education will not be able to attain the commitment to 

“best in business” practices.
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6. Describe the consequences to Federal program or policy activities if the collection is not 

conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing 

burden.

These customer satisfaction measurement activities will be conducted only when specific 

information is required. The question of frequency is not an issue. There are no legal or 

technical obstacles to the use of technology in these information collection activities. 

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, 

grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

the information’s confidentiality to the extent permitted by law.

These surveys will be consistent with all the guidelines in 5 CFR 1320.5(d)(2), and more 

specifically the guidelines in 5(d)(2)(v) which require that a statistical survey be designed to 

produce results that can be generalized to the universe of study. There are no special 

circumstances that would cause this information collection to be conducted in an unusual or 

intrusive manner. All participation will be voluntary. Should ED need to deviate from the 

requirements outlined in 5 CFR 1320, individual justification will be provided to OMB on a 

case-by-case basis.
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8. If applicable, provide a copy and identify the date and page number of publication in the 

Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments 

on the information collection prior to submission to OMB. Summarize public comments 

received in response to that notice and describe actions taken by the agency in response to 

these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.

Consultation with representatives of those from whom information is to be obtained or those 

who must compile records should occur at least once every 3 years – even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may

preclude consultation in a specific situation. These circumstances should be explained.

Program offices are responsible for monitoring and implementing public comments for 

improvement. These surveys are consistent and comply with the guidelines in 5 CFR 1320.8(d). 

Feedback from individuals and organizations served by ED are available upon request. Notices 

covering the 60 day and 30 day comment periods will be published.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees.

No payment or gift will be provided to respondents in these customer satisfaction or focus group 

surveys. If any are proposed for use, they will be small and ED will submit specific justification 

for each proposed use as part of the package submitted to OMB. 

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy.

These surveys and focus groups will provide all necessary assurances of confidentiality to the 

respondents, when needed. Although there is no requirement for such assurances in statute, the 

quality of this type of information requires respondent candor and anonymity. Customer 

surveys don’t request personal identifiable information. If they do, justification will be provided 

with the individual customer survey according to the Privacy Act. In addition, NCES may assure 

confidentiality under The Education Sciences Reform Act of 2002, Title I, Part E, Section 183, 

as necessary. In most cases, collection of information will be voluntary and will originate from 

customers who have experience within the program that is the subject of each collection. Surveys 

that collect personally identifiable information must provide a confidentiality statement that cites 

the authority to collect the information. 
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11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

There will be no questions of a sensitive nature in these customer satisfaction surveys. If any are 

used, ED will submit justification for each question used as part of the individual survey

submission.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector, business or other for profit, not-for-profit 

institutions, farms state, local or tribal government), frequency of response, annual 

hour burden, and an explanation of how the burden was estimated, including 

identification of burden type: recordkeeping, reporting or third party disclosure. 

Unless directed to do so, agencies should not conduct special surveys to obtain 

information on which to base hour burden estimates. Consultation with a sample 

(fewer than 10) of potential respondents is desirable. If the hour burden on 

respondents is expected to vary widely because of differences in activity, size, or 

complexity, show the range of estimated hour burden, and explain the reasons for the 

variance. Generally, estimates should not include burden hours for customary and 

usual business practices.

 If this request for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burden.

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

The respondent burden averages from five (5) minutes to 1 hour per response for each survey, 

depending on the individual survey. This estimation has been based on previous surveys 

submitted. The respondents are estimate to average 60-90 minutes in each focus group 

discussion.

Each survey respondent will most likely submit one response per survey. The Department 

estimates 451,512 responses with a total burden of 115,194. 
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Each member of a focus group is expected to spend an average of 75 minutes per group. If four 

focus groups were held over the next year with an average of 10 participants per group, the total 

burden is estimated to be 50 hours (4 groups x 10 participants x 1.25 hours). 

Burden for both activities is estimated at 115,344 hours and 451,632 responses.

The average hourly cost per respondent is estimated to be $30.00. 

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government, or (4) as part of customary and 

usual business or private practices.

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There are no costs to respondents except for those costs provided under number 12.
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14. Provide estimates of annualized cost to the Federal government. Also, provide a description 

of the method used to estimate cost, which should include quantification of hours, operational 

expenses (such as equipment, overhead, printing, and support staff), and any other expense that 

would not have been incurred without this collection of information. Agencies also may

aggregate cost estimates from Items 12, 13, and 14 in a single table.

The cost required to read and evaluate the surveys and focus groups discussions by ED, 

including the time taken by individuals under contract to ED, is estimated to be 31,256 hours. 

Given an average hourly rate of $35 per hour, the total cost to the Department is estimated to be 

$1,093,964.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion) and include both changes in burden hours and 

changes in cost burden.

This is an extension of a currently approved submission. Therefore, the Customer Survey 3-year 

total number of responses will be 451,632 and the total burden hours will be 115,344 hours. This 

estimate also includes 26,212 burden hours and 76,871 responses for new surveys anticipated 

during the next 3 years.

16. For collections of information whose results will be published, outline plans for tabulation 

and publication. Address any complex analytical techniques that will be used. Provide the time 

schedule for the entire project, including beginning and ending dates of the collection of 

information, completion of report, publication dates, and other actions.

The responsibility to measure customer satisfaction is not a “project” with an assigned 

completion date. Instead, it is an interactive process, which is becoming incorporated into the 

fabric and culture of the department. The process will continue with the attached survey

proposals for collecting information. There is no projected completion date.

As the information is collected, it will be evaluated by the sponsoring program offices and by the 

Regulatory Information Management Service and shared with any other program and support 

service managers and employees to whom it is relevant. 

Customer satisfaction surveys employ statistical methods according to the OMB guidance. 

Experienced and trained ED researchers will be sought from the Principal Offices such as NCES 

in ED to serve as advisors to evaluate the methodological strengths and weaknesses of the 
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proposed survey instruments and plans. These experts will make recommendations, as needed, 

to improve the research initiative. These recommendations will be implemented in each 

approved collection activity. 

OMB statistical experts, information collection experts, program specialists will be invited to 

participate with and advise the ED clearance office as their time permits. ED will consult with 

OMB about the expectations and standards of this important activity and will incorporate the 

OMB guidance in the ongoing internal clearance process. This feedback will enable ED to 

continuously improve the usefulness of these collection activities.

17. If seeking approval to not display the expiration date for OMB approval of the information 

collection, explain the reasons that display would be inappropriate.

The expiration date will be displayed on all surveys. 

18. Explain each exception to the certification statement identified in the “Certification of 

Paperwork Reduction Act Submissions”.

There are no exceptions to the certification.

Attachments:

Appendix A includes ED listings of all individual customer surveys and focus groups for to date. 

This appendix also includes the new surveys expected to be submitted during the next 3 years.