The Supporting Statement is a set of required questions that help provide a clear rationale for the why, what, how, and who of the information collection. All Supporting Statements have a Part A - a standard list of 18 questions - which shows compliance with the PRA requirements and other associated laws. Collections that require statistical methods, like surveys or program evaluations, have additional requirements, called Part B.
What makes a good Supporting Statement?
A clear supporting statement will help OMB and the public better understand your collection and reduce the need for questions aimed at simply trying to understand the overall collection. Be sure to give information about the authority your agency has to collect the type of information in your proposal.
A few of the criteria covered in the Supporting Statement include:
- Agency purpose
- Practical utility
- Avoidance of unnecessary duplication
This describes the general purpose of the collection to the sponsoring agency’s goals, and how the collection will achieve a stated results. A collection may have more than one purpose; each should be described in the Supporting Statement.
The agency must have a need for the information or data to be collected, based on program or policy requirements. As the Federal government, we need to help ensure we are careful when we impose burden on the public and it should be for very specific reasons.
While “purpose” is how the collection fits with the agency goals, “need” involves how the results will help program operation or policy development.
Does the information being collected meet the stated goals? Ask yourself, is the information accurate, adequate, and reliable enough for the agency to use for this purpose? Proposals should consider how an agency can use the information in ways that are reasonable, practical, workable, timely, and reliable.
The practical utility of a collection needs to serve both the purpose and need. Requests must only collect information that’s needed for the stated purpose(s).
A collection does not have practical utility if it cannot serve both the given purpose and need. Some reasons include:
- Unable to process and analyze information, or provide resources to do so, within a timely manner.
- Design or method won’t achieve appropriate results.
- Collection will give unclear or non-generalizable results due to ambiguous survey questions, unduly-biased methodology, or ineffective disclosure methods.
Collections should maximize practical utility. Some examples of this include:
- Redrawing a sample in a survey to reduce a high sample variance to produce more precise and useful data.
- Revising the selection of a control group to make analytical comparisons more meaningful.
- Clarifying questions to improve reliability of responses.
Avoidance of unnecessary duplication
Before collecting more information, see if there’s already accessible information that could serve the same purpose or need. This can include information collected for another purpose, such as administrative records, other federal agencies and programs, or other public and private sources.
If existing information sources don’t have the level of detail needed to meet the purpose and need, can’t be meaningfully analyzed together with other collected responses, or are not legally available for your purpose and need, then the information gathered is necessary and not duplicative.