FACE is back! The Federal Agency Customer Experience Act (FACE), that is.
The bill, now called The Federal Agency Customer Experience Act of 2021 (S. 671), has been introduced in the U.S. Senate. A companion bill in the U.S. House of Representatives, as of this writing, has yet to surface.
If the bill eventually develops into law, it will apply to U.S. federal government agencies as a complement to other policies and laws that now steer agencies in doing their CX work.
Third Time is the Charm?
I say FACE is “back” because this is the third time this bill has been introduced in the U.S. The original went through some revisions and failed twice before in previous sessions of Congress. Frank Konkel first wrote about FACE back in 2017 when it first came into the government CX spotlight. I tracked the bill in 2017 and in 2019.
What’s Up with FACE?
FACE is about getting U.S. federal agencies to collect customer feedback. But there is more. And this is where it really starts to matter.
The bill also calls for amendments to a law that has been a thorn in the side of CX agency executives for a long time: The Paperwork Reduction Act (PRA). PRA sometimes requires agencies to go through a complex, interagency process that can take up to a year before surveys can be administered to customers.
Essentially, FACE is saying, “Yes on the customer feedback. But let’s cut the complex approvals process for agencies.”
The costs of ineffective surveys can be quite high. For example, you can’t make good decisions based on data from bad surveys. Reputations and trust in government are also at stake.
But Here Is the Rub.
Full disclosure: I wasn’t a fan of PRA during my time in government. But it forced me to manage expectations internally, plan, and collaborate with other survey development experts across government.
I agree that it would be great for agencies to no longer have speed bumps and red tape to navigate before they can send out customer surveys. However, there is something to be said for the integrity of that interagency process. It can help keep wasteful, confusing, redundant, ineffective customer satisfaction surveys out of the picture for citizens and agencies.
Survey development, writing, and administration is a skill not everyone just magically has. That reality hits home every time an awful customer feedback survey hits my inbox. You, too, maybe?
FACE standardizes some questions (in harmony with other directives currently out there for agencies) and leaves room for agencies to develop their own, in addition to the standardized questions.
What is the cost of an ineffective survey?
The U.S. Congressional Budget Office (CBO) issued a report on the potential cost of this bill. Unfortunately, that report doesn’t take into account what can happen if PRA rules no longer apply and ineffective surveys hit customers’ inboxes.
I would argue the costs of ineffective surveys can be quite high. For example, you can’t make good decisions based on data from bad surveys. Reputations and trust in government are also at stake.
FACE doesn’t call for internal controls to be in place. Absent an interagency collaborative process, an agency’s own internal controls, survey governance, and expertise, there is no guarantee customer surveys will be effective.
Maybe it should, and it's possible that it could, but then you'd just be trading one form of red tape for another.
It is possible that anyone could create and send out a survey to customers.
There have been some super strides in government CX over the past few years. Big kudos to OMB and the agencies that have pushed ahead on setting goals of their own, implementing Circular A-11 Section 280, and working in harmony with Inspectors General and the GAO, for example.
If FACE develops into law, I hope it will be in a way that harmonizes with the realities of the customer experience work that has unfolded, and has yet to unfold, in the U.S. government.