Streamline Ways to Collect Customer Information

Streamline Ways to Collect Customer Satisfaction and Other
Information from the Public

BACKGROUND

Drawing on authority granted in the Paperwork Reduction Act of 1980, as
amended in 1986, the Office of Management and Budget (OMB) currently
reviews and approves Information Collection Requests (ICRs) from federal
agencies to the public. Several recommendations from the National
Performance Review (NPR) depend on a greater input of public opinion.
For example, the first step in the recommended program to improve
customer service (ICS01) is for agencies that deal with the public to
identify their customers and survey them on services desired and levels
of satisfaction. With this NPR recommended program, frequent surveys of
customer opinions would be used to set directions and measure
performance.

NPR recommendation REG04, part of the accompanying report on Improving
Regulatory Systems, encourages greater use of focus groups and small
surveys of the public to test new rulemaking ideas early in the process.
The goal is to avoid complicated mid-course program corrections.

The Mission-Driven, Results-Oriented Budgeting NPR accompanying report,
in its recommendation BGT02, proposes surveys of the public as a basic
performance measurement method. The findings and purposes section of the
Government Performance and Results Act of 1993 also makes specific
reference to customer satisfaction as a necessary performance criterion.

Each of these NPR recommendations seeks to get more public input for a
similar reason. Directly asking the public what it wants and how its
government is doing will be much more accurate than current practices of
making best estimates or using second- or third-hand information about
the needs of the public. None of the recommendations for more public
input would make their input mandatory. In all cases the public's
response would be voluntary.

The primary objectives of the Paperwork Reduction Act are to minimize
the federal paperwork burden on those outside the federal government, to
minimize the government's cost in collecting information, and to
maximize the usefulness of the information collected.  Departments and
agencies have the primary responsibility for meeting these goals, but
may not collect information without OMB approval.[Endnote 1 The act
covers all ICRs to ten or more people. The Office of Information and
Regulatory Affairs (OIRA) administers the act within OMB.

Under the act, OMB may delegate ICR review and approval authority to
agencies that commit sufficient resources to carry out the
responsibilities of the act effectively and that assign the task to a
senior official who is independent of program responsibility.2 Review
and approval authority has been delegated to the Federal Reserve Board,
but that is the only instance to date of delegation.

NEED FOR CHANGE

Requirements in the Government Performance and Results
Act, added to NPR recommendations on customer service, regulatory
improvement, and performance measurement, would produce a major increase
in workload for OIRA. The staff currently working on all ICRs numbers
about 35.

rogram staff in agencies often describe the process of getting out a
survey as already being a significant barrier.[Endnote 3] The goals of
the Paperwork Reduction Act to reduce burden on the public and improve
quality are unquestionably excellent ones.  But NPR's concern is that
the process of getting clearance is itself enough of a burden to
discourage attempts to get customer opinions.

The most common complaint among agency staff is that the survey approval
process takes too long. OIRA's most recent annual report estimates that
it takes 65 days to process the average request it receives, including
time for public comment.[Endnote 4] Some agency ICR offices agree with
that estimate and say they can get expedited processing when needed, but
most agencies estimate that the process takes much longer. When agency
program staff comment that the process is lengthy, they are typically
looking at the time spent preparing the package for review, plus the
time spent in agency review, added to the time spent by OIRA.

Whatever the precise cause, clearly OIRA is under pressure to do the job
faster. As NPR's recommendations for more frequent customer surveys
become reality, the requirement to do a lot more reviews will be added.
If ICRs continue to be processed the way they are today and OIRA staff
levels are not increased, performance can only decline. But many
agencies now have staff experienced in designing packages that can pass
OIRA standards-- in effect they now represent another review layer-- and
this staff represents a resource that could speed the clearance process
if they were given approval responsibility for at least some portion of
the ICRs.

Besides the general interest in speeding up the overall clearance
process, there are two proposals that home in on specific types of ICRs
and seek to reduce the work involved. The first concerns group
discussions. Agency interest is growing in the use of focus groups or
group discussions of interested individuals brought together to discuss
a particular topic. The reason is that focus groups or group discussions
represent a potentially simple way of getting customer input. However,
the need for ICR clearance on group discussions could be clarified by
OIRA.

Focus groups are reviewed in the same ICR process as conventional
surveys, although agencies often view them only as a way to get quick,
preliminary inputs early in a program's development. OIRA has informally
offered the opinion that other forms of group discussion, those without
a required script of focus questions, are outside the coverage of the
PRA, and thus do not require OIRA review. OIRA should clarify the
distinctions between various forms of group discussions and streamline
the review process for formal focus groups to reduce the disincentive
against using the more structured method.

The second proposal to save time and work concerns renewals of
previously approved ICRs, where the questions to be asked and the
targets for those questions are unchanged. The agencies' argument is
that in these cases it would be appropriate to have special procedures
for a quick review, or even an outright delegation of approval
authority.

The administrator of OIRA has already begun to improve OIRA management
of the overall ICR approval process, including simplifying the tasks
agencies face in making applications to OIRA. For example, she has
directed her staff to streamline and simplify the ways that agencies
must submit materials in support of their requests. The NPR
recommendations that follow urge specific actions as part of the
Administrator's overall initiative.

Cross References to Other NPR Accompanying Reports

Improving Regulatory Systems, REG04: Enhance Public Awareness and
Participation.

Mission-Driven, Results-Oriented Budgeting, BGT02:  Effectively
Implement the Government Performance and Results Act of 1993.

Small Business Administration, SBA01: Allow Judicial Review of the
Regulatory Flexibility Act.

Executive Office of the President, EOP01: Delegate Routine Paperwork
Review to Agencies and Redeploy OMB Resources More Effectively.


Endnotes

1. See U.S. Office of Management and Budget, Information Collection
Review Handbook (Washington, D.C., January 1989).

2. See paragraph 3507e of the Paperwork Reduction Act.

3. See various agency/Vice President town hall transcripts; in addition,
see notes on NPR discussions with agency staff who submit information
collection requests.

4. See U.S. Office of Management and Budget, Managing Federal
Information Resources, Tenth Annual Report (Washington, D.C., August
1992).