Office of the Chief Information Officer &
High Performance Computing and Communications

The Paperwork Reduction Act and Customer Surveys

As stated elsewhere in the NOAA PRA guidance, the normal clearance process for information collections takes from 2-5 months, depending upon whether a proposed rule is involved. In an effort to reduce this delay for certain types of customer surveys, NOAA has obtained a "generic clearance" for them. The clearance makes it possible to get approval, within a few weeks, for eligible surveys. You cannot use any of the "cleared questions" linked below without going through this fast-track clearance process.

NOAA's OMB Desk Officer has set some new parameters for use of the generic clearance process. The questions in the generic clearance fall into two categories, quantitative and qualitative. The quantitative questions ask the respondents to rank services or products on some number scale. A number of NOAA offices have requested approval for including quantitative-type questions on their surveys without planning to conduct a survey that follows a statistical sampling plan. The results of the quantitative questions could not therefore be extroplated (in a valid way) to the overall customer population. Offices got around this by saying in their justifications that they did not intend to extrapolate that data, but planned to just use it to indicate problem areas, places where there should be improvements, etc. OMB will not longer accept this approach, since despite these statements the data can easily be misused to represent a program's/office's customers.

Future requests seeking to use quantitative questions will need some description of a statistical sampling plan in order to get approval.

The Surveys:

  • There are two sets of cleared questions, one with quantitative (ranking) questions about satisfaction levels, and one with questions about uses of products, suggested formats, and other issues.
  • You do not have to use either questionnaire in its entirety - you can select only those questions that fit your needs.
  • You can adapt the questions to fit your particular program needs as long as the basic objectives of the surveying effort are consistent with the approved questionnaires. You can consult with the NOAA Clearance Officer about how much you can vary from the examples.
  • OMB does not regard Web-based surveys as an acceptable method of sampling a broad population (because it is only sampling people with Web access). Web-based surveys must be limited to services provided by Web.

How You Use the Generic Clearance:

  • Select and adapt the survey questions to fit your needs.
  • Provide a copy of the draft survey to the NOAA Clearance Officer for review. The survey must provide certain PRA information to respondents. See the last page of the cleared questions for an example. On Web surveys, only the OMB number and expiration date have to appear on the survey screen; the rest of the information can be provided via a link.
  • If told by the NOAA Clearance Officer that the survey does properly fit under the generic clearance, you need to prepare a clearance request.
  • The first page of the request is a form. You need to fill out the following fields: NOAA subagency (e.g. your Line Office), the title of your survey, an estimated annual number of respondents, the estimated hours or minutes per response, a contact point for questions about the survey, and the signature of a program official. Leave the other fields blank.
  • The second page of the request is a narrative answering the four questions provided in the request guidance.
  • As of July 2005, with the approval of the renewal request for 0648-0342, Part B (Statistical analysis) of the supporting statement for regular PRA submissions now also needs to be completed even if you are not going to perform statistical analysis on your data. Part B questions overlap with the questions in the clearance request – covering more than statistical analysis per se -  so some copying and pasting can be done, but you need to read each question carefully to be sure you are answering all parts of it. See Supporting Statement Instructions for information on responding to the Part B questions. As noted in those instructions, ALL survey requests now need to include answers to Part B, regardless of actual use of statistical analysis.
  • You then send your request to the NOAA Clearance Officer, who sends it to DOC to forward to OMB.
  • OMB has two weeks (but may take longer) to approve or reject the request.

Please note - you cannot just use the questions from the generic surveys without obtaining OMB approval through the 2-week review process.

Problems with Customer Surveys:

When people learn of the need to get OMB approval for customer surveys, a common reaction is that the requirement is an unnecessary piece of bureaucracy when an office just wants to get feedback from its customers. Experience, however, has shown that some plans for customer surveys are among the worst in the agency. Part of the problem is that people doing customer surveys often aren't familiar with surveying techniques and how to analyze the resulting data. They often do not think out how the information will be used, and if it will be valid for that use. The most common reason for OMB rejection of plans is that the data produced will have little or no value.

Let's look at an example. An office wants to survey its customers for a product. There are 100 customers and the office expects 15 of them to actually respond to the survey. The questions in the survey are numerical rankings of satisfaction with the product or related service. The question here is what the resulting information will mean. Will the office produce a report that says 60% of customers are happy with the product? But if it was really only 9 people (60% of the 15 responding) who were happy, how do you know that you can extrapolate the results to all of the customers? Usually saying that 60% of respondents were happy doesn't necessarily mean much either if the response rate is low. Even questions that don't have numerical answers may produce little of value for these reasons.

So how do you avoid this problem? Generally you should look at one of three approaches:

  1. Plan to get a response rate of 65-70% of your customers. The data obtained can then usually be extrapolated to all of your customers. The problem, of course, is that unless you have a close relationship with your customers it can be hard to get this high a response rate.
  2. Statistically sample your customers. This allows you to focus on a smaller number of people and still obtain useful results. The problem with this approach is that you need a firm basis in statistics to use it, and you need to know a good bit about your customers in advance to properly formulate a sampling plan.
  3. Don't ask questions that need to be extrapolated to all customers. For example, don't use numerical rating questions. You can ask customers about things like what additional formats or features they might like to see, or similar questions where a certain level of interest could justify action even if you aren't sure what the overall customer population wants.

The bottom line is that you really need to think about these issues and consult with the NOAA Clearance Officer to avoid clearance problems with a customer survey.