Determining if you need PRA clearance

Take a quiz

If you are unsure whether your research activities will require PRA clearance, you can take the following quiz below to find out.

Take a quiz to find out if you need PRA clearance.

What do you think you might need PRA clearance for?

Find out if you will need PRA clearance for RECRUITMENT

Answer the following questions about your RECRUITMENT activities:

Will you be recruiting 10 or more participants for your research?
(Regardless of how many will actually participate in the research.)
Are you planning to recruit any members of the public?
Will you be collecting Personally Identifiable Information (PII) other than a participant's contact information (email address or phone number)?
PII includes (but is not limited to), demographic characteristics like age, gender, race/ethnicity, etc. Learn more about Personally Identifiable Information (PII).

Guidance will appear here

Find out if you will need PRA clearance for RESEARCH

Answer the following questions about your RESEARCH PARTICIPANTS:

Will you be conducting research with 10 or more participants (per "round" of research)?
For example, if you are interviewing participants, conducting usability testing and then sending out a post-launch feedback survey in the course of developing a new product, each of these activities would be considered different "rounds" of research because they are intended to collect different information.
Will ANY of your research participants be members of the public?
A member of the public is anyone who is not a federal employee or contractor acting within the scope of their employment.

Answer the following questions about your RESEARCH METHODS:

Will your research involve direct observation?
That is, will you or someone on your team gather information by observing participants in person, virtually or on a recording?
Will you be posing a set of close-ended questions to participants?
Close-ended questions have a limited range of answers (for example, "How would you rate your experience on a scale of 1-5?"), while open-ended questions do not limit participant answers (for example, "Please provide feedback on your experience using this website.")

Guidance will appear here

PRA exemptions

You do not need PRA clearance if:

Federal employees and contractors (acting in their official capacity) are excluded from the definition of "persons" under the PRA, so you do not need clearance to conduct research with them about matters regarding their work. (Citation)

The PRA does not apply when you are conducting research with less than 10 members of the public. This limit applies per "round" of research, over a 12 month period. For example, if you are interviewing participants, conducting usability testing and then sending out a post-launch feedback survey in the course of developing a new product, each of these would be considered different "rounds" of research because they are intended to collect different information. (Citation)

PRA for recruitment

Screener surveys for recruitment will need PRA clearance (if 10+ people will respond).

Never fear! You can get PRA clearance for a screener in 7-14 business days.

Simply follow the process to get Fast Track PRA clearance.

Please note that collecting Personally Identifiable Information (PII) has privacy implications.

Collecting and storing this information can be as simple as locking a folder with appropriate Controlled Unclassified Information (CUI) labels, but please work with GSAIT's Privacy Office (privacy.office@gsa.gov) or your supporting counsel in OGC's Tech Law Division to address these implications.

PRA for research

The following research methods do not need PRA clearance (regardless of the number of participants).

Each of these methods involve direct observation of participants (in-person, virtual, or on a recording) and/or use open-ended questioning, making them exempt from needing PRA clearance regardless of the number of participants.

Close-ended UX/CX feedback surveys will need PRA clearance and are eligible for the Fast Track process.

Quantitative feedback surveys

This could include, for example, feedback surveys that are based on a Likert scale and/or any other questioning that will produce numerical data for analysis.

Close-ended, qualitative feedback surveys

This could include surveys that ask a set of identically worded questions with close-ended responses to participants.

Learn how to get Fast Track clearance for your research.

Larger-scale surveys are not eligible for the Fast Track process.

Any larger-scale research that implies statistical rigor or relates to the development of surveys, program effectiveness metrics, or outcome measures and program-level decision-making

This kind of research will need PRA clearance, but will not be covered by the Fast Track process.

Please contact GSARegSec@gsa.gov and consult pra.digital.gov for more information.

Other methods

If you are planning to use another method not listed, please contact tts-research@gsa.gov.

You can also consult the OMB CX Team's page "What type of CX research does not require PRA approval?" (Requires login with PIV card.)

Example scenarios

Common research scenarios and PRA implications

Description of research scenarioNeeds PRA clearance for recruitment?Needs PRA clearance for research?
A TTS UX Researcher 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.NO
(recruiting <10 people)
NO
(<10 people, unstructured conversation)
A TTS Content Designer needs to recruit 20-30 people that are representative of the US population and will send out a screener survey asking demographic questions to some email listservs. They are planning to conduct moderated card sorting tests to get a better sense of participant's mental models.YES
(recruiting 10+ people w/ structured survey)
NO
(direct observation, unstructured conversation)
A TTS Product Manager 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.NO
(not collecting PII)
YES
(10+ members of the public, no direct observation, structured)
A TTS UX Designer has to test the accessibility of their website and needs to recruit participants with and without disabilities. They are planning to conduct 12-15 usability tests (which will not require PRA clearance) and send a follow-up survey to participants afterwards (which will require PRA clearance).YES
(recruiting 10+ people)
YES
(for the structured survey, not for usability testing)