Paperwork Reduction Act

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 on its citizens. The law pertains to digital data collection as well as collection done with paper. The PRA governs most research and feedback collection mechanisms done by or on behalf of the federal government, including CMS. Any federal agency requesting responses from citizens is required to estimate the time it will take citizens to respond. PRA approval of data collection is granted by the Office of Management and Budget (OMB) and is coordinated by OMB-designated PRA officers in each agency.

How it applies to HCD

For groups smaller than 10 people, the PRA explicitly exempts direct observation and non-standardized conversation (5 CFR 1320.3(h)3). It also specifically excludes tests of knowledge or aptitude, 5 CFR 1320.3(h)7, which is essentially what a usability test tests.

When to use it for HCD

Seek PRA approval when you:

• Use more than 9 participants for a usability test
• Use standardized, scripted interactions for interviews or other conversations
• Use standardized scripts for usability testing
• Use a survey

PRA process

Be aware if you choose a HCD method subject to the PRA that even the “Fast-Track” PRA approval process often takes longer than a month. You should in general be able to use HCD methods that don’t invoke the PRA. However, contact the PRA officer for the CMS operational division (OpDiv) you are working with if you have questions.