Getting started
Introduction to PRA
PRA is a law that governs how federal agencies collect information from the American public.
True to its name, the Paperwork Reduction Act of 1995 is intended to reduce the amount of government paperwork the public must fill out. It ensures that when the government collects information from the public, it's for a good reason and that employees are not asking for anything unnecessary, thus causing undue burden.
Goals of the PRA include:
- Reducing public burden: It prevents the federal government from collecting redundant information or information that they don't actually need to provide a service.
- Better use of data: It makes sure that the information the federal government collects is used effectively to make informed policy decisions and improve government services.
- Giving the public a voice: It gives the public a chance to weigh in on how the government is collecting information.
For more general PRA information, please visit pra.digital.gov.
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.
Thus, WHO you collect information from and HOW you collect that information determines whether your research needs PRA clearance.
WHO you collect information from
PRA only applies after a certain number of research participants (per 12 month period) is reached and only to those defined as "persons". Thus, WHO you will collect information from is a factor in determining whether you need PRA clearance:
Whether you will have 10 or more participants (over a 12 month period)
- If the information collection is posed to 9 or fewer participants, no matter who they are, PRA does not apply.
Whether participants are federal employees or not
- Federal employees are not included in the definition of "persons", thus PRA does not apply. 5 CFR 1320.3(c)
- Contractors are considered federal employees if they are participating in research within the scope of their employment. Otherwise, they are considered "persons" and PRA does apply. 5 CFR 1320.3(c)
- Federal employees are not included in the definition of "persons", thus PRA does not apply. 5 CFR 1320.3(c)
HOW you collect information
If what you are collecting during the course of your UX/CX research does not constitute "information," then PRA does not apply. Some of the exclusions to the definition of "information collection" include: direct observation, general solicitations, public meeting and non-standardized follow up. Thus, HOW you collect information is a factor in determining whether you need PRA clearance:
Whether your research activities are "standardized" (i.e posing a set of "identical questions") or "non-standardized"
- 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 via an identical set of questions would be considered "standardized".
- Asking participants to think aloud while they try to navigate a website prototype would be considered "non-standardized".
- This refers to a set of identical (word for word) questions that are posed to participants.
Whether your research activities involve "direct observation" or not
- 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.
- Direct observation involves "visually inspecting" a participant during research.
Find out if your UX/CX research activities need PRA clearance.
Usability testing does not need PRA clearance.
Please review OIRA's usability testing guidance for more information.
Many other UX/CX research activities do not need PRA clearance:
- User interviews
- Cognitive walkthrough
- Contextual inquiry
- Card sorting
- A/B or multivariate testing
- Visual preference testing
These UX/CX research activities do need PRA clearance:
- Recruiting more than 9 members of the public (i.e. screener surveys)
- Making updates to materials that have prior or current PRA clearance
- Translating materials that have prior or current PRA clearance to languages other than EnglishÂ
Find out if your UX/CX research activities need PRA clearance.
The Fast Track (A-11) PRA clearance process is designed for smaller-scale UX/CX research.
The standard PRA clearance process that you may have heard about typically takes 6-9 months...however, there is good news! Researchers can request PRA clearance under generic "umbrella" clearances that are already in place, which allows for a much faster turnaround time. GSA has several types of PRA clearances that are designed specifically for UX/CX research:
Generic Clearance
Designed for larger-scale UX/CX surveys that will involve statistical analysis.
This clearance covers:
- Customer satisfaction surveys
- Website usability surveys
Fast Track (A-11)
Designed for smaller-scale UX/CX research activities.
This clearance covers:
- Discovery research
- User testing of services and digital products
- Customer feedback
Most UX/CX research activities at TTS can use the Fast Track (A-11) PRA clearance.
If you are conducting larger-scale UX/CX surveys that will involve statistical analysis or any other kind of research that may be a better fit for a different type of clearance, please contact tts-research@gsa.gov for guidance on how to proceed.
The OMB CX Desk oversees the Fast Track PRA clearance process. For more information, please consult the Customer Experience Collection Central on MAX.gov (requires login with PIV card).
Overview of PRA considerations for UX/CX research
Create your research plan
First, you need to plan your user research! Consider your goals and whether the research will be generative (defining direction or shape of a product) or evaluative (defining improvements and opportunities). To get started, 18F offers some useful guidance for planning your research.
Recruit participants. If you already have participants, you can skip this step. Decide who your participants will be and how you will recruit them.
Learn more about PRA implications for recruitment.
Decide on research method(s). 18F offers guidance on how and when to use specific research methods. In general, qualitative user research methods that involve direct observation and non-standardized conversations will likely NOT require PRA clearance.
Determine if you need PRA clearance
Depending on the nature of your research activities, you may need PRA clearance. The need for PRA clearance is determined by several factors, including:
Who you will collect information from: whether you will have 10 or more participants (per instance of research, over a 12 month period) and whether participants are considered members of the public or not.
How you will collect that information: whether your research activities are "standardized" (i.e posing a set of "identical questions") and whether your research activities involve "direct observation" (i.e. "visual inspection" of participant activities).
Get PRA clearance (if needed)
If you do need to get PRA clearance, never fear! Qualitative user research activities at TTS will be able to go through the Fast-Track process (also known as A-11 Section 280), which generally takes 7-14 business days.
Process overview
- Documentation. Complete "Generic A-11 Information Collection Review (ICR)" template for your project and attach all instruments. All documentation must be complete before proceeding.
- Pre-review. OMB CX Team offers pre-review of the completed Generic Information Collection (Gen IC) package to minimize rejection later: you can send the completed documentation to the OMB CX Team to receive feedback (cc'ing GSA PRA Desk for awareness).
- Submission. Submit finalized documentation to GSA PRA Desk for review.
- Review. OMB CX Team receives Gen IC package, reviews it, and notifies you of decision.
- Approval. If approved, you are free to proceed with research. If denied, you must repeat the process.
Do research!
Once you get PRA clearance, you are free to proceed with your research. Thank you for what you do to improve government digital services, and happy connecting with the public!