Supporting Statement for Paperwork Reduction Act Generic Information Collection 

Submissions for 

“Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery”

A. JUSTIFICATION

1. Circumstances Making the Collection of Information Necessary

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 Environmental Protection Agency (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. Purpose and Use of the Information 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, 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:

 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. 

 

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.”
3. Consideration Given to Information Technology

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

reduce burden.

4. Duplication of Information

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

the Agency.

5. Reducing the Burden on Small Entities

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 of Not Conducting Collection 

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

meet customer needs.

7. Special Circumstances

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

statistical purposes.

8. Consultations with Persons Outside the Agency

In accordance with 5 CFR 1320.8(d), on April 24, 2014, a 60-day notice for public comment was 

published in the Federal Register (79 FR 22816). The Agency received no comments in response to the 

60-day notice. 

9. Payment or Gift

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 inperson 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. Confidentiality 

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. Sensitive Nature

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

12. Burden of Information Collection

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

burden hours requested (1,500) 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 Hours

Qualitative Survey 6,000 1 0.25 1,500

13. Costs to Respondents

No costs are anticipated. 

14. Costs to Federal Government

The anticipated cost to the Federal Government is approximately $18,000 annually. These costs are 

comprised of: support staff and contractor payments.

15. Reason for Change
Adjustment. We have increased the burden hours by 114 and the total responses by 760 to match the 

increased use of the generic clearance that we have seen over the past few years.

16. Tabulation of Results, Schedule, Analysis Plans

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. Display of OMB Approval Date

We are requesting no exemption.

18. Exceptions to Certification for Paperwork Reduction Act Submissions

These activities comply with the requirements in 5 CFR 1320.9.
B. 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 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

Agency’s web site. Telephone scripts, personal interviews, and focus groups with professional 

guidance and moderation may also be used.

3. Methods to Maximize 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. Testing of 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 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.