Find out if you need PRA clearance

If you still need to find out whether you need PRA clearance, you've come to the right spot. We can walk you through relevant considerations and help you get an answer.

What do you think you might need PRA clearance for?

PRA clearance for RECRUITMENT vs. RESEARCH activities

You may need separate clearances for recruitment and research activities.

This is because both recruitment activities and research activities could constitute different kinds of "information collections". Find out more below or jump down to look at examples.

What factors determine if you need PRA clearance?

Because PRA governs the collection of information of the public, whether or not you need PRA clearance for your research activities hinges on the definition of "information", what constitutes an "information collection" and how PRA applies. Below are relevant excerpts from the text of the law and other official guidance:

  • An information collection means "obtaining, soliciting, or requiring the disclosure to third parties or the public of information (facts or opinions) by or for an agency by means of identical questions posed to, or identical reporting, record keeping, or disclosure requirements imposed on 10 or more persons, whether such collection of information is mandatory, voluntary, or necessary to obtain or retain a benefit.

    5 CFR 1320.3(c)

  • It is worth emphasizing that agencies may ask for facts and opinions of Federal employees without triggering the PRA.

    Information Collection Under the Paperwork Reduction Act

  • The PRA applies to collections of information using identical questions posed to, or reporting or recordkeeping requirements imposed on, "ten or more persons." For the purpose of counting the number of respondents, agencies should consider the number of respondents within any 12 month period.

    Information Collection Under the Paperwork Reduction Act

  • OMB regulations specify a number of items that are generally not "information" under the PRA. Important examples are...facts or opinions that are (1) submitted in response to general solicitations of public comments, (2) addressed to a single person, (3) obtained or solicited at or in connection with public hearings or meetings, (4) obtained through direct observation by the agency (e.g., through visual inspection to determine how long it takes for people to complete a specific transaction), or (5) obtained from participants in clinical trials (which typically do not involve answers to "identical questions").

    Exclusions to the regulatory definition of "information" under Paperwork Reduction Act

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Collectively translated into plain English, these excerpts tell us that whether you need PRA clearance depends on:

WHO you will collect information from

  • Whether you will have 10 or more participants (over a 12 month period)
  • Whether participants are members of the public or federal employees

HOW you will collect information

  • Whether your research activities are "standardized" (i.e posing a set of "identical questions")
  • Whether your research activities involve "direct observation" (i.e. "visual inspection" of participant activities)

Keep reading to find out how these considerations apply to your recruitment and research activities!

PRA clearance for RECRUITMENT activities

Recruiting participants for your research may require PRA clearance because it could involve collecting information from members of the public.

Find out if you will need PRA clearance for RECRUITMENT

Answer the following questions about your RECRUITMENT activities:

Over the course of 12 months will you be recruiting 10 or more participants? (OR is it possible that 10 or more people will respond to your call for recruitment?)
Are you planning to recruit any members of the public (including contractors)?
Will you be collecting Personally Identifiable Information (PII) from participants during the recruitment process? PII includes, but is not limited to: name, SSN, DoB, email address, home address, phone number, and demographic characteristics.

Guidance will appear here

Recruiting through third-party services

If you are using a third-party tool to recruit participants (i.e. UserTesting.com, Optimal Workshop, etc.), you do NOT need PRA clearance. However, you may still need it for research activities; please refer to the research section below.

Recruiting federal employees ONLY

If you are planning to recruit federal employees and federal employees ONLY, you do not need PRA clearance.

PRA clearance for RESEARCH activities

Depending on the nature of the research method(s) you are using, you may need PRA clearance. Keep reading to find out more.

Find out if you will need PRA clearance for RESEARCH

Answer the following questions about your RESEARCH PARTICIPANTS:

Over the course of 12 months will you be conducting research with 10 or more participants?
Will ANY of your research participants be members of the public (including contractors)?

Answer the following questions about your RESEARCH METHODS:

Will you be posing a set of standardized questions to participants during your research?
Will you be directly observing research participants during the research activities?

Guidance will appear here

Standardized questions

This refers to a set of identical (word for word) questions that are posed to participants.

  • For example, a screener survey asking for demographic information would be considered "standardized".
  • Asking participants to think aloud while they try to navigate a website prototype would not be considered "standardized".

Direct observation

Direct observation involves "visually inspecting" a participant during research.

  • For example, a moderated usability test would involve direct observation, while an unmoderated usability test would not.
  • Conducting a survey does not involve direct observation.

Conducting research with federal employees ONLY

If your research participants will be federal employees and federal employees ONLY, you do not need PRA clearance for your research activities.

Collecting research from public meetings or hearings

Research in these settings is exempt from PRA.

Common research methods and PRA implications

If a method you plan to use is not listed here, please consult OMB's CX PRA Desk Officer for more information.

Discovery methods

These methods likely do NOT require PRA clearance. Click the link to view the 18F Method card for more information.

Validation methods

These methods likely do NOT require PRA clearance. Click the link to view the 18F Method card for more information.

Examples

The following are examples of common research activities that would likely need PRA clearance for recruitment, research, neither, or both.

Description of research activitiesNeeds PRA clearance for recruitment?Needs PRA clearance for research?
[Name] is recruiting a few participants through word of mouth by connecting with a community organization they had previous contact with. They are planning to have unstructured conversations with 4-5 participants about whether they might find a new website feature useful or not.NONO
[Name] needs to recruit 20-30 people that are representative of the US population and will send out a screener survey to some email listservs. They are planning to conduct moderated, non-standardized (open-ended) card sorting tests to get a better sense of people’s mental models.YESNO
[Name] is conducting an anonymous customer satisfaction survey (meaning they won’t collect any Personally Identifiable Information) and expects between 50-100 participants to fill it out.NOYES
[Name] needs to test the accessibility of their website and wants to recruit participants with and without disabilities. They are planning to conduct 12-15 moderated interviews and usability tests.YESYES