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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised 3/4/2014

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 hard copy of the 

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

information, or you may provide a valid URL link or paste the applicable section. Please limit 

pasted text to no longer than 3 pages. Specify the review type of the collection (new, revision, 

extension, reinstatement with change, reinstatement without change). If revised, briefly specify 

the changes. If a rulemaking is involved, make note of the sections or changed sections, if 

applicable.

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, the Department of Education 

(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. 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.

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, 
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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 wil 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:

 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)

 

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.”
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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. 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.

If appropriate, agencies will collect information electronically and/or use online collaboration 

tools to reduce burden.

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 Question 2 above.

No similar data are gathered or maintained by the Agency or are available from other sources 

known to the Agency.

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

methods used to minimize burden. A small entity may be (1) a small business which is deemed to 

be one that is independently owned and operated and that is not dominant in its field of operation; 

(2) a small organization that is any not-for-profit enterprise that is independently owned and 

operated and is not dominant in its field; or (3) a small government jurisdiction, which is a 

government of a city, county, town, township, school district, or special district with a population 

of less than 50,000.

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. 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.

Without these types of feedback, the Agency will not have timely information to adjust its 

services to meet customer needs.

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

a manner:
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

 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.

There are no special circumstances. The information collected will be voluntary and will not be 

used for statistical purposes.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as 

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.

In accordance with 5 CFR 1320.8(d), 60-day and 30-day notices for public comment will be 

published in the Federal Register. 

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

contractors or grantees with meaningful justification.
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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.

In the case of in-person cognitive laboratory and usability studies, the Agency may provide 

stipends of up to $40. In the case of in-person focus groups, the Agency may provide stipends of 

up to $75. If respondents participate in these kinds of studies remotely, via phone, or Internet, 

any proposed stipend needs to be justified to OMB and must be considerably less than that 

provided to respondents in in-person studies, who have to travel to the agency or other facility to 

participate. If such information collections include hard-to-reach groups and the agency plans to 

offer non-standard stipends, the Agency will provide OMB with additional justifications in the 

request for clearance of these specific activities.

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

in statute, regulation, or agency policy. If personally identifiable information (PII) is being 

collected, a Privacy Act statement should be included on the instrument. Please provide a citation 

for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as 

indicated on the ICRAS’ Part 2 IC form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided. Requests for this information are in 

accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A-108 

– Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 Appendix 

I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 –

OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, 

OMB M-06-15 – Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 

1974 (Collection, Use and Protection of Personally Identifiable Information). If the collection is 

subject to the Privacy Act, the Privacy Act statement is deemed sufficient with respect to 

confidentiality. If there is no expectation of confidentiality, simply state that the Department 

makes no pledge about the confidentiality of the data.

If a confidentiality pledge is deemed useful and feasible, the Agency will only include a pledge of 

confidentiality that is supported by authority established in statute or regulation, that is supported 

by disclosure and data security policies that are consistent with the pledge, and that does not 

unnecessarily impede sharing of data with other agencies for compatible confidential use. If the 

agency includes a pledge of confidentiality, it will include a citation for the statute or regulation 

supporting the pledge.

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.

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

12. Provide estimates of the hour burden of the collection of information. The statement should:
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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

or households, private sector – businesses or other for-profit, private sector – not-for-profit 

institutions, farms, state, local or tribal governments), 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. All narrative should be 

included in Question 12. 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. (The table should at minimum include Respondent types, Number 

of Respondents and Responses, Hours/Response, and Total Hours)

 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 Question 14.

A variety of instruments and platforms will be used to collect information from respondents. The 

annual burden hours requested (75,000) are based on the number of collections we expect to 

conduct over the requested period for this clearance. 

 Estimated Annual Reporting Burden

Type of Collection No. of 

Respondents

Annual 

Frequency per 

Response

Hours per 

Response

Total

Annual 

Hours

Customer Satisfaction 

Surveys and compliant forms

149,900 Once .5 hours 74,950

Focus Groups and usability 

testing

100 (ten focus 

groups 

averaging 10 

participants per 

group)

Once .5

50

Totals: 150,000 75,000

 The estimated three-year burden total is 75,000 x 3 equals 225,000 hours. 
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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 

Questions 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 preOMB 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. Also, these estimates should not include the hourly costs (i.e., 

the monetization of the hours) captured above in Question 12.

Total Annualized Capital/Startup Cost:

Total Annual Costs (O&M): 

Total Annualized Costs Requested:

No costs are anticipated. 

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 Questions 12, 13, and 14 in a single table.

The anticipated cost to the Federal Government is approximately $24,500 annually. These costs 

include time to read and evaluate the surveys and focus group discussions and other minimal 

operational costs. 

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 
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ICRAS ICR ID and OMB Number: (1795.66) 1880-0542

Revised: 3/04/2014

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), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

This is an extension of a previously approved information collection request. There are no 

program changes or adjustments resulting in burden of 225,000 hours and 450,000 responses.

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.

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. 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.

We are requesting no exemption.

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

collection, explain the reasons that display would be inappropriate.

These activities comply with the requirements in 5 CFR 1320.9.

19. Explain each exception to the certification statement identified in the Certification of Paperwork 

Reduction Act.

There are no exceptions.