1. Generic Fast-Track Clearances
Washington Headquarters Services Executive Services Directorate
Office of Information Management DoD Directives Division
Good morning, and thank you all for joining me for this webinar training on generic fast-track clearances. My name is Emily Leighty, I’m an information management analyst with the Office of Information Management, and I will be your trainer today. Before we move forward, I’d like to ask everyone to go ahead and mute your phones so we can maintain the best quality throughout the call.

2. History of Generic & Fast Track Clearance Options
Before we get into today’s discussion, let me give a quick primer on the Paperwork Reduction Act for anyone on the call who may not be familiar with it. In a nutshell, the Paperwork Reduction Act (or the PRA, as you’ll hear me refer to it from here on out) is a federal statute which requires federal agencies to obtain approval before collecting information from the public. The Office of Management and Budget, under the Executive Office of the President, is responsible for vetting all of the requests across the federal government to collect information from the public. The purpose, of course, is to avoid overburdening the public with these collections. If anyone on the call today is interested in learning more about the PRA, please send an to our org box and we will happily share more information with you.
So, now that we are all on the same page with the PRA, let’s go back in time to the year 2010 to discuss how the idea of a generic clearance came about.
Let’s travel in time back to 2010…

3. PRA – Generic Clearances
January 21, 2009 memo issued by the President calling for the establishment of “a system of transparency, public participation, and collaboration”
May 28, 2010 memo from Office of Management and Budget (OMB) with subject “Paperwork Reduction Act – Generic Clearances”
Establishes the use of generic information collections as a way of meeting obligations of the PRA while also “eliminating unnecessary burdens and delays”
Goes on to define the generic clearance and the corresponding process for approval
In January of 2009, newly inaugurated President Obama issued a memorandum on the subject of “Transparency and Open Government.” In the memo, he calls for the establishment of “a system of transparency, public participation, and collaboration.” As a result of some of the requirements set in that memorandum, the Office of Management and Budget issued a memo on May 28, 2010 to establish the generic clearance option under the Paperwork Reduction Act. OMB explains that a generic clearance eliminates unnecessary burdens and delays while still allowing agencies to adhere to the requirements of the PRA. In the memo, they define the generic clearance and outline the process for seeking approval, which we will talk about in more detail in a few minutes.

4. New Fast-Track Process for Collecting Service Delivery Feedback Under the PRA
June 15, 2011 memo from Office of Management and Budget (OMB) with subject “New Fast-Track Process for Collecting Service Delivery Feedback Under the Paperwork Reduction Act”
Establishes the fast-track category of generic information collections
Purpose is to “allow agencies to obtain timely feedback on service delivery while ensuring that the information collected is useful and minimally burdensome for the public”
Slightly more restrictive than a standard generic collection
Now let’s jump forward to June of OMB issues another memo, this time called “New Fast-Track Process for Collecting Service Delivery Feedback Under” the PRA. In this memorandum, OMB defines the new fast-track category of generic information collections which they established in May of They give the fast-track slightly more restrictive parameters than the standard generic, but they’re again trying to provide agencies a streamlined way to collect information while still adhering with the PRA and ensuring the least burden on the public. Just as they did in the previous memo, OMB goes into detail about what types of collections may qualify as fast-tracks and they outline the process of seeking approval.

5. What’s a Generic Fast-Track?
And here we go. Let’s talk about the definition of a generic clearance and take a look at the parameters for fast-track collections.
Definition of a generic clearance and parameters for fast-track collections

6. Generic Information Collection Definition
“A generic ICR is a request for OMB approval of a plan for conducting more than one information collection using very similar methods when (1) the need for and the overall practical utility of the data collection can be evaluated in advance, as part of the review of the proposed plan, but (2) the agency cannot determine the details of the specific individual collections until a later time.”
This is OMB’s definition of a generic information collection, what they call a generic information collection request (or ICR). The text on this slide is pulled directly from that May 2010 memo.
A generic ICR is a request for OMB approval of a plan for conducting more than one information collection using very similar methods when:
The need for and the overall practical utility of the data collection can be evaluated in advance, as part of the review of the proposed plan, but
The agency cannot determine the details of the specific individual collections until a later time

7. Generic Information Collection Definition
Three important traits:
Voluntary
Low-burden
Overall burden
Total respondents
Burden per respondent
Uncontroversial
Additionally, OMB points out three important traits of generic clearances and their collections. First, the collection must be voluntary. Second, the collection must be low-burden. When you think about burden, remember that OMB views burden in terms of both time and money; so we want these collections to be low-cost and take up little of our respondents’ time. Last, the collection must be uncontroversial. In past trainings we’ve talked a little bit about some of the topics that could be considered controversial. Oftentimes, this is going to require us to follow our collective gut and be mindful of hot topics in the current environment. For example, collections relating to immigration or sexual orientation would probably err on the side of controversial right now.

8. Fast-Track Collection Parameters
In addition to the three traits of a generic, fast-tracks must also adhere to the following parameters:
Collection is focused on the awareness, understanding, attitudes, preferences, or experiences of customers or stakeholders
Simple survey or survey-like instrument
Statistical rigor is not required to process responses
Policy or funding decisions will not be made as a direct result of collection findings
Results of the collection will not be published or disseminated to the public
Now let’s dig in a little deeper and talk about what specifically qualifies an individual collection as a fast-track. Remember, we are still working in the framework of a voluntary, low-burden, and uncontroversial collection. In addition, a fast-track collection will be focused on the experience or attitudes of a group of customers or stakeholders. To collect that information, we’ll be using a survey or survey-like instrument (like a focus group or a comment card). After we’ve gotten responses back, there won’t be any statistical rigor involved in processing the responses, and the agency conducting the collection won’t use the findings to make policy or funding decisions. Findings or results also will not be made available for the public.
I’m going to highlight this one again, because this parameter trips us up sometimes. [CLICK] Your instrument must be a survey or survey-like. Run-of-the-mill forms, for example, are not eligible as generic fast-tracks.

9. Clearance Process
Now that we have a better understanding of what a generic clearance is and what qualifies as a fast-track collection, let’s walk through the process of getting this type of collection approved.
Seeking OMB approval for a generic clearance and fast-track collections

10. Example Scenario Customer Satisfaction Surveys
The Department of Veterans Affairs wants to ask patients at different facilities about their satisfaction with different parts of their health care experience in order to identify early warning signs of customer dissatisfaction. They would like to be able to vary the questions asked by situation and service site as new/different services are made available to customers throughout the year.
I’ve created an example scenario to help us navigate through the generic clearance process. A quick note, this is 100% imaginary, as far as I know. Any resemblance to real-life collections is entirely a coincidence.
In this scenario, Veterans Affairs wants to survey patients about their satisfaction with their health care experiences.
Now, let’s go deeper. Say the questions on the survey need to vary by service site, and we want to switch up the questions throughout the year as we start to incorporate different services or treatments or benefits. We aren’t sure what exactly those questions will look like, but they’re all in the same vein. We just want to know if we are keeping our patients happy. Let’s assume these are really short surveys – maybe 5 to 10 questions – and maybe we are asking patients to just rate on a satisfaction scale of 0 to 5.
This fits the generic framework because we want to clear a series of collections with the same general purpose. We don’t know all of the specific questions in advance, but we know they all have the same purpose. Since the surveys will be voluntary and low-burden (maybe 5 minutes to complete), and we’re not asking anything controversial, this would be a great option for a generic clearance.

11. Step 1: Generic Clearance Approval
Prepare the generic collection package and comply with the PRA’s public notice requirements
Supporting statement addresses the need for the generic strategy, the method of collection, the types of respondents, the estimated burden cap, and agency’s intended use of the information collected
Publication of 60-Day Federal Register Notice
Publication of 30-Day Federal Register Notice
Submit the package to OMB
OMB approves the generic collection
So what’s the first thing we need to do to get our customer satisfaction surveys cleared? I’m going to break the process down into two big steps. The first step is getting OMB approval for the generic clearance.
If you have ever gone through our normal public collection process to have an OMB Control Number assigned to your collection, this should feel very similar. We need to prepare a supporting statement to justify the overall collection; to do this, we have to be sure to demonstrate the need for the generic strategy. Think back to our VA example: We have a series of surveys, all for the same purpose and all low-burden, voluntary, and non-controversial. However, we don’t know exactly what questions will be asked on every single survey because we want to develop new surveys throughout the year to respond to changes in the services we provide to patients. That is our demonstrated need for the generic strategy. The supporting statement is also going to address some of the other things you’re used to seeing in a supporting statement. We’ll talk about the method of collection – in our example scenario, a survey. We’ll also estimate our burden cap – how much time and money do we predict will be taken up by all of these surveys we might conduct throughout the year? And we’ll discuss the agency’s intended use of the information after it’s been collected. So the big picture here is: We are putting together an overarching supporting statement to cover all of these little surveys that don’t really exist yet.
Next, we’re going to go through the typical process of publishing the 60- and 30-Day Federal Register Notices. This will give the public the opportunity to review the plan for our surveys and give us feedback.
As long as we’ve put together a solid supporting statement, after the 60- and 30-day notice periods end, OMB will review our plan and approve it. Just like any other collection, they’ll assign an OMB Control Number which is valid for 3 years. We can expect this step to take about as long as your typical public collection process.

12. Step 2: Fast-Track Collection Submission
Develop the fast-track collection instrument
Prepare the “one-pager” justification
Submit the instrument and one-pager to OMB
Receive approval for the instrument
Expect a 5-day turn-around!
Repeat as necessary
This brings us to step 2, submitting fast-track collections.
Let’s do a quick recap of what we have so far. First, we’ve got an idea for a series of surveys. They’re low-burden, voluntary, and they’re not controversial. They’re all related to the same topic but the questions will vary from survey to survey. We’ve determined this collection qualifies as a generic. We wrote out the supporting statement, we published both the 60- and 30-Day collections, and OMB approved the collection and gave us an OMB Control Number.
Now, returning to our VA customer service survey scenario, let’s say a few weeks or a month after OMB approves the collection, one of our physical therapy centers is thinking about buying some new exercise equipment. They’ve installed a few new machines and they want to see how the patients are liking them. So we put together a survey. It’s short, it’s simple. We will also prepare what’s called a “one-pager.” The one-pager is like a mini-justification statement for the individual survey; it’s going to explain how this individual survey fits into the overall generic plan we submitted to OMB in step 1. It’s also going to tell OMB how much of the overall generic clearance burden we expect to eat up with this collection. For example, if we said in the supporting statement in step 1 that we are asking OMB to approve approximately 100 hours of public burden, we may tell them in the one-pager that we are expecting this particular survey to use up about 1 of those 100 hours.
When the one-pager and the instrument are ready for OMB’s review, my office – the Office of Information Management – will submit both documents to OMB under your generic clearance control number. OMB will then review your instrument and make an approval decision. When they approve the instrument, it inherits the OMB Control Number of its corresponding generic clearance.
OMB’s guidance tells us this review process should only take about 5 business days, and in our experience they’re usually pretty close to that.
So now OMB has approved our customer satisfaction survey to get feedback on our new exercise equipment. In a few weeks, maybe another rehab facility wants to gauge customer satisfaction with the ease of their check-in and check-out processes. We’ll follow the exact same process for that individual fast-track survey and we will take maybe one more hour from our overall request for 100 hours of burden for the big generic. Over the next three years – for the duration of the generic’s OMB Control Number’s lifetime and until the burden cap is met – the Department of Veteran’s Affairs can continue to submit these customer service surveys under their generic clearance.

13. Step 3: Extend Clearance
If needed, before the OMB Control Number expires you may extend the generic clearance by going through the regular extension process
Continue to submit one-pagers for the fast-track collections corresponding with the generic clearance
When expiration for the OMB Control Number is coming up, just like any other collection you may choose to extend that clearance by going through the initial approval process again. So all of those actions we took in Step 1 – preparing the supporting statement, publishing in the federal register – we’ll do all of that again and submit it to OMB so they can approve the control number for another 3 years. Then, we’ll just continue to submit our one-pagers for the individual collections falling under that generic.

14. Generic Clearance 0704-XXXX
Fast-Track Collection
Fast-Track Collection
Fast-Track Collection
Fast-Track Collection
Alright, I want to do one more quick recap and illustrate this in a different way.
When we identify collection that we can use the generic framework to clear, we take that to OMB with our proposed plan and they approve the generic clearance and assign it an OMB control number. [CLICK] Think of this like an umbrella. Our generic clearance is approved without any specific collection instruments; it’s just an idea for a series of collections that are all similar, low-burden, voluntary, and non-controversial.
As we begin to create instruments that fall under the generic clearance, we submit those to OMB as they are developed along with a one-pager justification. OMB will provide approval for the instruments within about 5 business days. [CLICK] All of these instruments then inherit the same OMB Control Number as the generic and draw burden away from the overall generic’s approved burden.

15. Department-Wide Generic
Hopefully this presentation has shown you the long-term benefit of pursuing a generic clearance. Although it does require the full investment up-front to get the generic cleared, your component is then able to get a super-quick turn-around on any fast-track collections that can be approved under your generic clearance’s umbrella over the course of the next three years.
Maybe you’re thinking, “Emily, this sounds great, but I want immediate gratification!” Well… I’ll take this opportunity to encourage you to look into an existing DoD-wide generic owned by the OCMO. This is a generic my office worked to have cleared back in Our fast-track is approved for customer satisfaction-focused collections and is available to all of you for any one-off collections you may want to conduct. To put it another way, we have already taken care of Step 1 for you – we’ve got OMB approval for the generic clearance – and you’re now free to jump in at Step 2, as long as your collections meet the criteria. We’ve made our scope as broad as possible and we have a ton of burden built in; I don’t want to say we are begging you to use it, but please, please, please take advantage of this generic clearance. As a reminder, we will only require a copy of your instrument and completion of the one-pager justification to get approval from OMB for the collection in about 5 business days.

16. Thank you!
Office of Information Management
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Okay, if there are no further questions I would like to thank everyone for attending today’s webinar. My office values your feedback, both positive and constructive, so please don’t hesitate provide your thoughts anonymously via ICE or send us your comments and suggestions at the org box listed on this slide.
Again, thank you for taking the time to join me today and I look forward to hearing from you all again in next month’s session.