A guide to the Paperwork Reduction Act

Not every request or collection falls under the PRA’s scope, and you may not need clearance at all. Voluntary collections are not automatically exempt.

When figuring out if PRA clearance is needed, consider the following:

• What type of information are you collecting,
• Who are you collecting it from,
• How will you be collecting it, and
• Why you are collecting this information.

Voluntary collections are not automatically exempt. This is just a starting point to see if your collection needs PRA clearance. We encourage getting in touch with your agency’s PRA contact to answer more in-depth questions.

Who are you collecting information from?

Members of the public

Generally, this means people or groups outside of the federal government. Some groups that are considered members of the public include:

• Individual people (including federal contractors)
• Businesses and associations
• State, territorial, tribal, and local governments
• Foreign governments, businesses, and individual people

In general, the PRA applies even when information is collected from non-US citizens, residences, or businesses as those entities are considered “persons” under the Act. If you are only collecting information from federal employees or military personnel as part of their job, then you do not need PRA clearance. If the information is not part of their work-related duties, you may need PRA clearance.

Ten or more people or groups

Over a 12-month period, if you are requesting the same information from ten or more people or entities, you need PRA clearance. If you are only seeking 9 respondents, but more than 10 people can respond, you may also need clearance.

If you are requesting information from fewer than ten people or groups, but they represent the majority or all of an industry or sector, you may need PRA clearance.

Voluntary or Mandatory Collection

Regardless whether your collection is voluntary (i.e., the public is not required by law to provide information) or mandatory, the Paperwork Reduction Act treats the collection the same.

What type of information are you collecting?

The type of information you are collecting will help determine if you need PRA clearance.

Needs PRA clearance:

Asking for information to be sent to the government, for example:

• Forms, such as the IRS 1040.
• Written reports, such as grantee performance reports.
• Surveys, such as customer satisfaction or behavioral surveys.
• Recordkeeping requirements, such as small businesses keeping all tax-related documents for 3 years.
• Third-party or public disclosures, such as nutrition labeling requirements for food.
• Program evaluations, such as looking at the outcomes of a subsidized housing initiative for seniors.
• Research studies and focus groups with a set of the same questions or tasks.
• Applications for benefits and grant programs.

Does not need PRA clearance:

• Direct observation, such as watching how long it takes someone to complete a transaction, or how someone uses a new website to find answers.
• General requests for public input and comments, such as a "Tell Us About Your Experience" sheet with open-ended space for someone to respond.
• Usability Testing in most circumstances (see OIRA's 2024 guidance (PDF, 341 KB, 6 pages)).
• Information for voluntary commercial transactions, like payment and delivery details.
• Information asked for or received in connection with a public hearing or meeting.

Some information collections are generally not subject to the PRA, including: certain federal investigations and civil actions, antitrust actions, and intelligence activities.

Information at public meetings and online

The discussion and conversation at a public meeting is exempt from PRA clearance, and many online or interactive communications fall under this exemption. Interactive meeting tools like public conferences calls, webinars, discussions board and forums, and chat sessions are considered the electronic equivalent of in-person public meetings and do not need clearance.

Converting forms from paper to digital

Many existing, PRA-approved paper-based forms can benefit from a conversion to an interactive form, like a web-based form or an editable PDF.

As long as the approved form fields and questions are not changed and the digital materials collects the same information, OIRA would likely consider conversion to an electronic format a non-substantive change to an already approved collection, and it would not need additional public comment.

However, many agencies find that a form conversion will spark other, more substantive changes in what information is collected and how questions are written. This may change or increase burden, or trigger questions regarding practical utility, resulting in the need for additional public comment under the PRA.

Get in touch with your agency’s PRA contact to discuss the changes you would like to make.

PRA and the web

Using technology is an excellent way to reduce costs to the public while providing a useful service. Some social media and web-based technologies are not subject to the PRA, and do not need approval; broader clarifications are in the Social Media Guidance Memo (PDF, 83 KB, 7 pages).

Email or text subscriptions to alerts and publications

The collection of mailing addresses, email addresses, or mobile numbers for newsletters, text alerts, agency updates, and other publications does not need PRA approval.

Wikis and collaborative drafting platforms

Web-based collaboration tools that facilitate interactions between the agency and the public and essentially provide a technology-based equivalent to in-person collaboration generally do not need PRA approval.

If they are used to collect information that an agency would otherwise gather by asking for responses to identical questions, however, they would need PRA approval.

Social networks, blogs, webinars, and other public meetings

Covered under the “public meetings” exclusion, these generally do not need PRA approval, as long as the public is not surveyed or asked identical questions:

• Public conference calls
• Webinars
• Blogs
• Discussion boards
• Forums
• Chat sessions
• Social networks
• Online communities

User account creation

Profiles and accounts that only request an email address, username, password, and geographic location (e.g., state, region, or ZIP code) do not need PRA approval. If more information is requested, it may need PRA approval, because the information requested likely goes beyond the scope of what is needed to create an account.

Similarly, if the account is created to collect information for agency program purposes, like the online Free Application for Federal Student Aid (FAFSA), it needs PRA approval.

Website display customization

Allowing users to customize or influence the look of an agency website, such as filtering navigation menu items and saving their preferences, does not need PRA approval.

Ratings and rankings

Social media tools that let users vote on, rank, sort, organize, or otherwise rate the value of ideas, questions, and comments do not need PRA approval. For example, you generally do not need PRA clearance to solicit a user rating for an agency’s mobile app. If the results of the ratings can be used for policy or planning purposes, however, this would need PRA approval.

Voluntary commercial sales orders

Information about choosing, paying for, and delivering an item sold by the U.S. Government does not need PRA approval. For example the payment information and delivery address collected to allow a member of the public to order a national park pass online.

Filtering agency data

Methods that let users sort and filter agency data, like drop down menus and standardized text or numeric entries, do not need PRA approval.

Data calculation

Information collected to help users get details from a table or formula does not need PRA approval, as long as that information is not used for another purpose. The IRS’s Withholding Calculator or GSA’s Per Diem Lookup are good examples.