Compliance Assistance Measurement in FY 2009
01/14/2009 03:55 PM
The purpose of this memo is to notify you that, although EPA’s compliance assistance program does not have an Office of Management and Budget (OMB) approved Generic Information Collection Request (ICR)1 in FY2009, for conducting outcome measurement activities through surveys, EPA compliance assistance providers should still measure outcomes from activities, including activities in support of the Compliance Assistance ACS Commitment,2 using other methods. The loss of a Generic ICR means the survey mechanism that has historically been used for follow-up measurement activities for compliance assistance activities on a program-wide basis is no longer available. This is a significant change in practice for our assistance program, so please share this memo with those in your office who provide compliance assistance to either regulated entities or to other assistance providers such as states, tribes or local governments. Despite the loss of this method for collecting outcome measurement data, it is imperative that assistance providers continue to collect measures for compliance assistance activities using other available methods. This memo outlines the remaining methods for collecting data.
The three primary measures for the compliance assistance program are: (1) percentage of entities reporting increased understanding as a result of the assistance provided; (2) percentage of entities reporting improved environmental management practices as a result of the assistance provided; and (3) percentage of entities reporting they reduced, eliminated or treated pollution as a result of the assistance provided. All three measures are reported into the Integrated Compliance Information System (ICIS), the Compliance Assistance database of record. The first measure is an internal EPA measure, and the second and third measures are the Government Performance Results Act (GPRA) measures for the compliance assistance program.
Data to support the three outcome measures listed above can be collected without an OMB-approved survey mechanism, and must be collected during the activity. The attached Reference Guide summarizes other methods for measuring the impacts of assistance activities. For example, observed behavior changes during a facility visit demonstrating improved environmental management practices can be documented, or pre and post-tests at workshops can be conducted to measure increased understanding. Furthermore, surveys may still be used if an office receives OMB approval on its own ICR. For information on how to submit your own ICR for OMB approval, consult EPA’s internal website at: http://intranet.epa.gov/icrintra/learn.html. Finally, measurement activities for Drinking Water Sanitary Surveys and assistance provided to Federal Facilities can continue to be as broad in their scope as they have been, since they do not require and ICR for information collection.
Since 1998, OECA has had a Generic ICR in place to expedite individual EPA requests to conduct surveys for purposes of collecting outcome measures related to compliance assistance activities. Without an ICR, EPA cannot conduct any follow up measurement activities after the compliance assistance activity has occurred. We recognize the value of being able to follow up in an efficient, program-wide way through a Generic ICR. However, while OMB has not agreed to approve a subsequent Generic ICR for the program, we are working closely with them this year to develop an alternative approach for FY2010 that can be used for measuring results from multiple compliance assistance activities across the country.
In the interim, please continue to encourage those in your office who conduct compliance assistance activities to continue to measure the results of those activities. We recognize that the outcomes collected and reported into ICIS this fiscal year will not tell the complete story of the results we achieve with assistance because we do not have the generic survey as a tool for data collection. It is critically important that we continue to collect information that allows us to assess the value and impact of our assistance work. If you have any questions, please don’t hesitate to contact me, or Karin Koslow, (202-564-0171), the Associate Director of the Compliance Assistance and Sector Programs Division.
1Pursuant to the Paperwork Reduction Act of 1995, an OMB approved Information Collection Request is generally required if a federal agency wishes to collect the same information from more than 9 non-federal entities.
2 While EPA does not have a Generic ICR in FY09 for conducting surveys to collect data in support of the Compliance Assistance ACS commitment, this commitment is met by conducting any type of measurement activity; the data does not have to be collected through a survey mechanism. ACS ASST01: “Conduct outcome measurement for 100% of all compliance assistance workshops/training, on-site visits and revisits, which support the OECA national priorities and report the results of these outcomes into ICIS. Report on exceptions to the 100% and provide brief explanations in the ACS.” Note: OECA will evaluate whether the 100% commitment should be reduced to a lower percentage, to reflect the challenges presented by the loss of this important measurement tool.
cc: Granta Y. Nakayama, AA, OECA
Catherine McCabe, Deputy AA, OECA
OECA Office Directors
OC Division Directors
Rick Westlund, OEI
Attachment 1: Reference Guide for Measurement of Compliance Assistance Outcomes in FY2009