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.
