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From: Klion Catherine [Klion.Catherine@pbgc.gov]
Sent:
Wednesday, December 20, 2006 11:51 AM
To: Potter, Rachel
F.
Cc: Gabriel Tom; Hanley John; Forbes Deborah; O'Donnell
Megan
Subject: RE: OMB comments on PBGC generic clearance
request
Follow Up Flag: Follow up
Flag Status:
Red
Attachments: Generic Clearance Template ver 21 Dec 06.doc
Rachel,
Per our conversation
yesterday, following are PBGC's responses to your questions on PBGC
information collection 1212-0053. If you want to discuss this matter
further, please call me at 202-326-4223, ext. 3041, or Tom Gabriel at the same
number, ext. 3898. Happy Holidays!
Cathy
QUESTION
1:
Please provide a few examples of previous surveys and focus groups
that you have received approval for under PBGC's generic clearance authority.
RESPONSE:
- November 2006.
Survey of new premium filers to determine customer satisfaction
levels relating to sponsors of newly established defined benefit pension
plans. No incentives.
- May 15, 2006. Series of one-on-one usability tests of the
MyPBA Ariel Integration Application to help PBGC evaluate whether the proposed
enhancement to the MyPBA on-line program meets its intended purpose of
allowing PBGC customers to generate an estimated benefit statement using
PBGC’s web site. $75 + light
refreshments.
- July 2005 and January 2006. Two telephone surveys to obtain customer satisfaction opinions from
pension plan participants who filed appeals with PBGC during calendar year
2005. No incentives.
- October
28, 2004. Focus group with 13 pension practitioners
(e.g., plan administrators or
actuaries) to obtain their opinion
on a variety of documents used to communicate account status in PBGC’s Premium
and Practitioner System. The
October 28 focus group followed-up the session held in January 2003. Light refreshments but no stipend.
- May 2004. Six focus groups with participants in the
Bethlehem Steel and National Steel pension plans to help PBGC improve its level of customer
service to participants in these and other PBGC-trusteed plans. The focus group members were drawn
from non-pay status hourly workers, pay status hourly workers, and salaried employees (pay status or
non-pay status). $50 stipend +
light refreshments.
- November
2002. Six focus groups with participants in
the LTV Steel pension plans to
provide customer feedback on service and communications issues that
were used to drive improvements in service delivery processes. Four focus
groups were held with participants not yet in pay status (non-pay status), one
with participants currently in pay status but whose benefits had been
adjusted, and one with participants currently in pay status who remember
receiving a letter stating that their benefit were not being
adjusted at that time. One of the non-pay status focus groups
consisted of management employees; the
other three were made up of union/hourly wage employees. $50 stipend + light refreshments.
- July
2001. Customer service opinion survey of vendors who
submitted invoices to PBGC from 10/1/00 to the survey approval date. No
incentives.
- January
2001. Survey of PBGC web site users to determine
customer satisfaction levels with web pages that provide information to
participants and beneficiaries about their pension plans and their
benefits. Respondents were anonymous; the survey did not request names or other personal
identifiers and did not involve use
of a "cookie." No incentives.
- March 27, 2000. Focus group on customer service topics with 14
actuaries selected from among attendees at the 25th annual "Enrolled Actuaries Meeting"
hosted by the American Academy of Actuaries and the Conference
of Consulting Actuaries (on-site at the Meeting). No stipend; light
refreshments likely provided by hosts.
QUESTION 2:
The supporting statement (p. 1)
indicates that PBGC is requesting approval of "an extension and an expansion" of
this OMB number. Please explain how
this request is an expansion.
RESPONSE:
The supporting statement’s
reference to “an expansion” was an editing error resulting from the use of a
previous supporting statement as a template for the current version. The “expansion” approved in 2000 allowed
the 1212-0053 collection to (a) encompass a broader range of surveys than those
approved to date (i.e., surveys only as an adjunct to focus groups, and (b)
subsume the collections approved under OMB Control Numbers 1212-0056 (expired 6/30/00) and 1212-0058 (expired 11/30/01), which provided for customer service
mail surveys.
QUESTION 3:
In working with other agencies, I
have found it effective to have the agency submit the supporting statement
information in a generic template format.
A complete generic submission would generally include the template and
the instrument. This expedites our
review by ensuring upfront that the agency has submitted all of the information
we will require for the generic request.
I have attached a sample generic template used by another agency. Please review, make any necessary
accommodations to tailor to PBGC's needs, and send back to me. Note that any policy decisions we agree
to at this stage (e.g., incentive amounts) should be included in the template.
RESPONSE:
See PBGC's proposed changes
(attached).
QUESTION 4:
OMB and PBGC have previously
discussed incentive amounts for generics surveys. What level of incentives (and for whom)
have you requested in the past?
What is the range?
RESPONSE:
See response to question # 1,
above.
QUESTION 5:
Note that OMB will only approve
generics that gauge customer satisfaction on services directly (or in very
limited cases indirectly) provided by PBGC. To give you a sense of what the
appropriate scope for generics is, I have attached below a draft of the terms of
clearance that I plan to include with this collection. Let me know if you have specific
questions.
Conditions of clearance stated by Rachel
Potter:
This generic clearance for PBGC
customer service surveys is approved under the following conditions:
1. PBGC shall use the generic
clearance only for customer satisfaction and web site user surveys where the
agency seeks to gather information for general service improvement, not for
publication or for the purpose of informing significant policy or resource
allocation decisions.
2. PBGC shall use the generic
focus group authority only for customer satisfaction and web site user feedback
when the agency seeks to gather information for general service improvement, not
for publication or for the purpose of informing significant policy or resource
allocation decisions. Focus groups
should be of limited size and scope.
3. For individual surveys or
focus groups, PBGC shall submit a generic clearance request in ROCIS along with
an abbreviated supporting statement in the template agreed to by OMB and
PBGC. This statement shall include
all relevant information, including a statement of need, intended use of
information, description of respondents, information collection procedures,
expected response rate, justification for incentive, estimated
burden.
4. OMB will respond with
clearance or questions within 10 working days.
RESPONSE:
We
propose that item one be revised to read as follows:
PBGC
shall use the generic clearance to collect customer satisfaction data (via
surveys, focus groups or software usability testing sessions) where the agency
seeks to gather information for general service improvement, not for publication
or for the purpose of informing significant policy or resource allocation
decisions. PBGC may consider
customer satisfaction data among other relevant factors in formulating policy or
allocating resources.
We also suggest deleting
the first sentence in item 2 as unnecessary.
From: Potter, Rachel F.
[mailto:Rachel_F._Potter@omb.eop.gov]
Sent: Thursday, December 14,
2006 12:58 PM
To: Klion Catherine; Gabriel Tom
Subject: OMB
comments on PBGC generic clearance request
Cathy and Tom,
Attached below please
find OMB's comments on PBGC's generic clearance request (1212-0053). Let
me know if you have any questions.
Thanks,
Rachel
- Please provide a few examples of previous surveys and focus groups
that you have received approval for under PBGC's generic clearance
authority.
- The supporting
statement (p. 1) indicates that PBGC is requesting approval of "an extension
and an expansion" of this OMB number. Please explain how this request
is an expansion.
- In working with
other agencies, I have found it effective to have the agency submit the
supporting statement information in a generic template format. A
complete generic submission would generally include the template and the
instrument. This expedites our review by ensuring upfront that the
agency has submitted all of the information we will require for the generic
request. I have attached a sample generic template used by another
agency. Please review, make any necessary accommodations to tailor to
PBGC's needs, and send back to me. Note that any policy decisions we
agree to at this stage (e.g., incentive amounts) should be included in the
template.
- OMB and PBGC have
previously discussed incentive amounts for generics surveys.
What level of incentives (and for whom) have you requested in the
past? What is the
range?
- Note that OMB will only approve generics that gage customer
satisfaction on services directly (or in very limited cases indirectly)
provided by PBGC. To give you a sense of what the appropriate scope
for generics is, I have attached below a draft of the terms of clearance that
I plan to include with this collection. Let me know if you have specific
questions.
This generic clearance for PBGC customer
service surveys is approved under the following conditions:
1) PBGC shall use the generic clearance
only for customer satisfaction and web site user surveys where the agency seeks
to gather information for general service improvement, not for publication or
for the purpose of informing significant policy or resource allocation
decisions.
2) PBGC shall use the generic focus group authority only for
customer satisfaction and web site user feedback when the agency seeks to gather
information for general service improvement, not for publication or for the
purpose of informing significant policy or resource allocation decisions.
Focus groups should be of limited size and scope.
3) For individual surveys
or focus groups, PBGC shall submit a generic clearance request in ROCIS along
with an abbreviated supporting statement in the template agreed to by OMB and
PBGC. This statement shall include all relevant information, including a
statement of need, intended use of information, description of respondents,
information collection procedures, expected response rate, justification for
incentive, estimated burden.
4) OMB will respond with clearance or questions
within 10 working days.
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