Supporting Statement A for GSA Touchpoints_A 11 Section 280 Improving Customer Experience v 8 7 25

SUPPORTING STATEMENT A

FOR PAPERWORK REDUCTION ACT SUBMISSION

3090-0321 Generic Clearance for Improving Customer Experience Central Survey Tool

(OMB Circular A-11, Section 280 Implementation)

1. Explain the circumstances that make the collection of information necessary.

Under the Government Service Delivery Improvement (GSDI) Act¹ and the 21^st Century Integrated Digital Experience Act², along with OMB guidance, agencies are obligated to continually improve the services they provide the public and to collect qualitative and quantitative data from the public to do so.

The General Services Administration (hereafter “the Agency”) has developed a survey collection tool (https://touchpoints.digital.gov/) that Federal agencies may use to collect this customer feedback. The purpose of this request is to facilitate federal agencies’ ability to collect feedback from the public using this GSA Touchpoints survey tool, or any subsequent GSA survey tool that uses a different name. Collecting feedback from the public will allow agencies to continue to improve federal services, thereby facilitating compliance with statutory requirements and general principles of good governance.

2. Indicate how, by whom, and for what purpose the information is to be used.

Surveys to obtain feedback immediately following a transaction – limited to 15 questions and 5 minutes of burden maximum: These are surveys that are distributed immediately after a member of the public completes a transaction – for example, after submitting an application, after speaking with a call center representative, after receiving correspondence from an agency, etc. It is imperative that these surveys be extremely short and in no circumstances longer than 15 questions and 5 minutes of burden maximum. The results of these surveys are to be submitted to OMB, using the instructions set forth in relevant OMB guidance.

An agency using the Touchpoints collection tool will only submit under this generic clearance if it meets the following conditions:

• The collections are voluntary;

• The collections are low-burden for respondents (based on considerations of total burden hours or burden-hours per respondent) and are low-cost for both the respondents and the Federal Government;

• The collections are non-controversial, meaning they do not raise issues that warrant public comment;

• 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;

• Personally identifiable information (PII) is collected only to the extent necessary and the agency will comply with applicable legal and policy requirements to ensure its protection;

• Information gathered is intended to be used for general service improvement and program management purposes;

• The agency will follow the procedures specified in any relevant OMB guidance for the required reporting to OMB of data from surveys;

• Outside of the reporting mentioned in the bullet immediately above, if the agency intends to release journey maps, user personas, reports, or other data-related summaries stemming from this collection, the agency must include appropriate caveats around those summaries, noting that conclusions should not be generalized beyond the sample, considering the sample size and response rates. The agency must submit the data summary itself (e.g., the report) and the caveat language mentioned above to OMB before it releases them outside the agency. OMB will engage in a passback process with the agency.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection.

There are neither legal nor technical obstacles to the use of technology in these information collection activities. The determination to use technology, and which technology to use, will be based on the type of information collected and the utility and the availability of specific technology to each respondent in a proposed activity.

For example, the Touchpoints survey may be administered at a kiosk on an ipad, as a tab on webpage, or as an embedded form displaying at the end of an application process.

4. Describe efforts to identify duplication.

The agency will ensure all surveys under this clearance include the minimum number of questions necessary to obtain relevant data about the agency’s services. The information to be supplied on these surveys will not be duplicated on any other information collection.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information collected in these surveys will represent the minimum burden necessary to evaluate the public’s experience with the agency’s programs and processes. The agency will minimize the burden on respondents by sampling as appropriate, 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 regular mechanisms for collecting and generating customer insights, the agency is not able to provide the public with the highest level of service. These activities will be coordinated to ensure that most individual respondents will not be asked to respond to more than one survey instrument per transaction or to participate in more than one session.

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

• 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.

These surveys will be consistent with all the guidelines in 5 CFR 1320. There are no such special circumstances that would cause this information collection to be conducted in an unusual or intrusive manner. All participation will be voluntary. Should the agency need to deviate from the requirements outlined in 5 CFR 1320, individual justification will be provided to OMB on a case-by-case basis.

8. Describe efforts to consult with persons outside the agency.

The 60-day public comment notice was published in the Federal Register at 90 FR 27018 on June 25, 2025. The Agency did not receive comments.

The 30-day public comment notice was published in the Federal Register on August 28, 2025 at 90 FR 42013.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification.

The standard will be no payments or gifts to respondents for participation. If any payments are proposed, the agency will submit specific justification for each proposed use as part of the completed package submitted to OMB.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Activity and survey instructions will provide all necessary assurances of confidentiality to the respondents. Although there is no requirement for such an assurance in statute, the quality of this type of information requires respondent candor and anonymity.

11. Provide additional justification for any questions of a sensitive nature.

In general, agencies’ generic clearances under this OMB control number will not contain any questions of a sensitive nature. If the agency identifies a question of a sensitive nature for a specific clearance, the agency will discuss this in the clearance request.

12. Provide estimates of the hour burden of the collection of information.

Surveys to obtain feedback immediately following a transaction - Limited to 15 questions and 5 minutes max. The agency will specify the total possible number of respondents based on estimated annual volume, but this information collection sets a ceiling estimate of 2,000,000 annually.

Average Expected Annual Number of Activities: Approximately 50 customer feedback surveys.

Average Number of Respondents per Activity: Range varies greatly depending on Federal Service.

Annual Responses: Approximately 40,000,000.

Average Minutes per Response: 3 minutes

Burden Hours: 2,000,000

The Agency will keep track of the above activities in order to accurately update burden calculations year to year.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.

No costs for respondents are anticipated.

14. Provide estimates of annualized cost to the Federal government.

The Agency will use existing FTE time to maintain the system and analyze the data.

15. Explain the reasons for any program changes or adjustments.

There are no changes to the collection.

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.

No attempt will be made to generalize the findings from these surveys to be nationally representative or statistically valid. They are meant to compliment and help to contextualize performance and evaluation data.

Data from feedback surveys will be submitted to OMB for review and publication in the manner set forth in relevant OMB guidance.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The agency will include the OMB Control Number and collection expiration date on all instruments.

18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act.

The Agency is not requesting an exception to the certification statement identified in Item 20, “Certification for Paperwork Reduction Act Submissions, “ of OMB Form 83-I.

1 5 U.S.C. Sections 321-24.

2 44 U.S.C. Section 3501 note.

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