Using data from customer research and feedback can actually reduce the public burdens the PRA seeks to regulate. OMB recently published additional guidance on reducing burden that reminds federal agencies of their responsibilities to not only measure burden, but actively work to reduce it.1 The DHS Burden Reduction Initiative also requires usability testing on all DHS Information Collections.
Research is not a violation of the Paperwork Reduction Act
Interviews/Ethnographic Research
The PRA applies to collections of information using identical questions posed to ten or more people.2 This means that you can interview 9 or fewer participants using identical questions. This also means that if you are having unstructured conversations with open-ended questions, there may not be a limit on participants.3
Prototype Testing
If you are having an unstructured conversation in front of a clickable screen or some paper forms, you can talk to your customers. Open-ended questions, such as these, are not a violation of the PRA:
“Could you please take a look at this form and tell me what you think?”
“How do you think you would complete this task?”
Surveys
Open-ended questions do not violate the PRA. So, if you are doing a one or two question “Tell us how we’re doing” survey, please move forward.
However, some surveys DO need to have a clearance. DHS has several existing clearances that may apply to your survey, such as an Agency-wide Generic Clearance for Customer Feedback, or other clearances like A-11 Part 6 Section 280. Please work with your Agency’s PRA Liaison to determine the appropriate clearance and process for your needs.
Additional Authorities
- M-22-10 Improving Access to Public Benefits Programs Through the Paperwork Reduction Act, April 13, 2022 (18 Pages, 602 KB)
- Flexibilities under the Paperwork Reduction Act for Compliance with Information Collection Requirements, July 22, 2016 (7 pages, 2,551 kb)
- Reducing Reporting and Paperwork Burdens, June 22, 2012 (3 pages, 280 kb)
- Testing and Simplifying Federal Forms, August 9, 2012 (2 pages, 85 kb)
1 Strategies for Reducing Administrative Burden in Public Benefit and Service Programs (December 15, 2022) (10 pages, 124 KB)
3 Please check with your Agency/Office PRA Liaison if you have any questions.
