ISG Playbook
APIs
What is the Paperwork Reduction Act (PRA)?
The Paperwork Reduction Act (PRA) is a federal law intended to ease the data reporting burden imposed by the government. The law pertains to data collection regardless of form or format (including digital, paper-based, and standardized interviews). The PRA governs most research and feedback collection mechanisms done by or on behalf of the federal government. Any federal agency requesting responses from the public is required to estimate the time and cost burden for citizens to respond and the burden on the federal agency to compile and synthesize the data. Authorizations for PRA approval of data collection come from the Office of Management and Budget (OMB), and PRA officers in each agency coordinate the effort.
How it applies to HCD
It is essential and mandatory that CCSQ comply with the PRA when applying human-centered design (HCD) processes and methodologies. However, the PRA should not limit HCD best practices to improve the customer experience. If the information you are collecting is subject to clearance, most agencies estimate six to nine months from agency development to approval. We encourage you to take advantage of the flexibilities and requirements that exist for compliance. You can learn more about the basic information related to the PRA at A Guide to the Paperwork Reduction Act.
PRA Flexibilities
Compliance requires an understanding of when the PRA applies. Generally, if you collect the same information from ten or more people or entities within 12 months, the PRA applies. Applicable members of the public governed by the PRA are vast. It includes individuals (including non-US citizens), businesses and associations, non-federal and foreign governments, and more. Ultimately, the only excluded individuals or groups are within the federal government and military (and even then, the PRA can sometimes be applicable).
However, there are many exclusions to when the PRA applies, such as:
- Generally, requesting the same information from fewer than ten people. There are some exceptions to this rule.
- Direct observation, such as qualitative usability tests and field studies.
- Open-ended requests for comments or feedback.
- Discussions and questions at public hearings or meetings (whether in person or online).
- Collecting information from federal employees related to their role or function.
Planning Research
Your research objectives, target users, protocols, and timeframes play an essential role in determining which research method(s) you will implement. That, in turn, determines whether the PRA applies. The number of people needed to complete a study for insight generation may be under the PRA threshold or because a technique is not subject to the PRA since it employs direct observation and non-standardized conversation.
For example, with HCD, the goal is to understand people (end-users and other stakeholders) and their interactions with everything or a particular product or service during their daily lives. If that is your goal, you may select observational and ethnographic research methods to learn about people to extract valuable insights from the research. The PRA may not apply since exclusions include direct observation and non-standard oral communication, which is the essence of ethnographic research.
Ultimately, the number of participants depends on what researchers need to know, the purpose of the inquiry, the business problem, what lends credibility to the study, and available resources. There are best practices you can apply as a rule of thumb to begin research in some instances. Some studies will require more individuals and some fewer.
Navigating HCD and PRA
Navigating HCD and PRA is a summary document that can help you determine if the PRA applies to your study. It includes high-level steps to get started, HCD research methods and PRA quick reference guide, and a decision tree to help you understand if you need clearance. The job aid is a general reference and should not be confused with official guidance from the Office of Strategic Operations and Regulatory Affairs (OSORA). Always follow your group’s guidelines about research and PRA guidelines.
Decision Tree: Do I Need Clearance?
Common HCD Research Methods and PRA Clearance
| Method | PRA clearance needed? | Rationale |
|---|---|---|
| Qualitative | ||
| Contextual Inquiry | No | Contextual interviews are often non-standardized, conversational, and based on observation. The PRA exempts direct observation and non-standardized conversation (5 CFR 1320.3(h)3). In a Flexibilities under the Paperwork Reduction Act memo it states that “OMB does not generally consider facts or opinions obtained through direct observation by an employee or agent of the sponsoring agency or through non-standardized oral communications in connection with such direct observations to be information under the PRA." |
| Diary study | No | If nine or fewer participants the PRA does not apply. If ten or more participants and the diary is free-form, the PRA does not apply. If ten or more participants and the diary is structured, the PRA applies. |
| Field study | No | Field studies are often non-standardized, conversational, and based on observation. If nine or fewer participants the PRA does not apply. If ten or more participants and uses non-standardized conversation and observation, the PRA does not apply. |
| Focus group | Yes | Assumes 10 or more participants. |
| Interview - scripted | Yes | Assumes 10 or more participants. |
| Interview - non-standardized | No | Non-standardized questions. |
Listening sessions | No | PRA does not apply since discussion and questions at public hearings or meetings are excluded. |
| Persona - qualitative | No | If nine or fewer participants the PRA does not apply. If ten or more participants and uses non-standardized conversation, the PRA does not apply. If ten or more participants and the diary is structured, the PRA applies. |
| Usability study - think aloud | No | Does not require ten or more participants; generally, anything beyond five to eight participants does not yield new information. |
| Quantitative | ||
| A/B testing | Yes | Assumes 10 or more participants. |
| Card sorting | No | PRA exempts direct observation and non-standardized conversations. |
| Persona - statistical | Yes | Large sample size. |
| Surveys, such as website satisfaction, customer satisfaction, or system usability scale | Yes | Large sample size. Consider the GSA shared service survey resource called Touchpoints that leverages an existing PRA clearance. |
| Tree testing | No | Tree testing often has 50 or more participants however direct observation and non-standardized conversations are exempt. |
| Usability study, such as task completion or satisfaction survey | Yes | Large sample size. |
How to Use this Information
This information is meant to be for general reference and should not be confused with official guidance from Office of Strategic Operations and Regulatory Affairs (OSORA). Always follow your group’s guidelines about research and PRA guidelines.