1. BLS U.S. Bureau of Labor Statistics www.bls.gov The Paperwork Reduction ACT (PRA) What You Need to Know for Government UX Work Jean Fox Presented to the User Experience Community of Practice January 22, 2015

2. BLS www.bls.gov Introduction BLS collects lots of data  Our Clearance Officers know the process I got feedback from our Clearance Officers and OMB  But I don’t know everything about the process  Every agency may be different 2

3. BLS www.bls.gov Overview PRA Basics Types of PRA, and the process for each  Traditional  Generic  Fast Track 3

4. BLS www.bls.gov Goal Give you enough information to get through most of the process You can do it! 4

5. BLS www.bls.gov PRA Basics The Paperwork Reduction Act (PRA) requires federal agencies to submit proposed collections of information for review and approval by the Office of Management and Budget (OMB)  When collecting the same data from more than 9 people (including contractors, but not federal employees) over 12 months. Purpose is to  Protect the public from inappropriate data collection and unnecessary burden  Maximize the practical utility of information collected

6. BLS www.bls.gov When does PRA Apply? PRA Applies…  To all kinds of data collection – From income tax forms to regulatory information, to user experience and other research efforts.  Regardless of the type of data – Personally Identifiable Information (PII), other sensitive data, or any other data  To the TOTAL sample size – Across all evaluation efforts run over 12 months (you can’t just run separate, smaller, slightly- different studies) 6

7. BLS www.bls.gov When does PRA Apply? PRA may not apply:  A recent OMB memo has exempted from the PRA or clarified PRA applicability for social media and web 2.0 uses.recent OMB memo 7

8. BLS www.bls.gov PRA Definitions Clearance Officer  The person at your agency who handles OMB submissions  To find your Clearance Officer, start with your CIO. OMB Desk Officer  The person at OMB who reviews your submission 8

9. BLS www.bls.gov PRA Definitions Office of Information and Regulatory Affairs (OIRA)  The group at OMB responsible for reviewing submissions Burden hours  The total amount of time needed for participants in a study (including recruiting and screening)  (Hours per participant) * (number of participants) 9

10. BLS www.bls.gov PRA Definitions Information Collection Request (ICRs)  The materials you submit to OMB to get your data collection approved.  Also called a “PRA Submission” or “OMB Clearance Package”  Includes the sampling method, protocol, any materials, etc. 10

11. BLS www.bls.gov PRA Definitions ICRs are publicly available at Reginfo.gov Reginfo.gov  FYI…The OMB Control number for UX work at BLS is 1220-0141. 11

12. BLS www.bls.gov PRA Definitions Federal Register notice Federal Register  Allows the public to review and comment  Submission includes the ICR plus a summary. 12

13. BLS www.bls.gov Types of OMB Clearance Traditional  For large data collection efforts Generic  Sometimes called “umbrella” clearance  For a variety of studies, quantitative analysis, and publishing Fast Track for Service Delivery Feedback  For quick qualitative studies Customer Satisfaction  Just a type of Generic Clearance 13

14. BLS www.bls.gov Traditional Process Step 1. Develop a plan for data collection. Step 2. Submit a 60-day notice to the Federal Register Federal Register  Must include the protocol for data collection Step 3. Receive and address public comments 14

15. BLS www.bls.gov Traditional Process Step 4. Submit for Department Review Step 5a. Submit a 30-day notice to the Federal Register  Same as 60-day notice, with changes as appropriate Step 5b. Submit ICR to OMB Step 6. OMB reviews submission 15

16. Develop Study Plan May take weeks, months, or years, depending on the project. Includes writing ICR and FR material FR 60-day notice Includes FR notice plus supporting statements Revision and Department Review Departmental review time may be unpredictable FR 30-day notice OMB Review of ICR Note the unpredictable time in developing the study plan, departmental review, and OMB review Traditional Process

17. BLS www.bls.gov Traditional Process Approval renewed every 3 years. Note that FR notices and ICRs are publicly available and may need agency approval. 17

18. BLS www.bls.gov Traditional Process Appropriate for very large data collection efforts  Some government surveys collect data from hundreds of thousands of respondents or more Small, short user experience studies may be able to use the generic process 18

19. BLS www.bls.gov Generic Clearance Covers studies that are voluntary, low- burden, and uncontroversial  Studies with vulnerable participants or risky methods may not be eligible. 19

20. BLS www.bls.gov Generic Clearance Process is basically the same. An agency:  Submits 60-day FR notice (Sample BLS notice)Sample BLS notice  Revises notice and gets departmental approval  Submits a 30-day FR notice and an ICR to OMB – Template for OMB submission Template for OMB submission  Gets OMB approval for Generic Clearance 20

21. BLS www.bls.gov Generic Clearance Additional Step: Agency submits separate proposal for each study  Review is typically an expedited process based on an agreement with OMB during clearance approval  Depends on the nature of the research.  For BLS, it is typically 2-4 weeks. Approval renewed every 3 years. 21

22. BLS www.bls.gov Generic Clearance Federal Register notices and the ICR address information such as  Types of studies done  Methods used  Environments in which studies are done  Maximum burden hours to be used  Consent form 22

23. BLS www.bls.gov Generic Clearance ICs (Information Collection) are basically, a proposal for the effort. They include  Goals  Protocol  Participants  Data to be collected  Analysis plan  Burden hours, etc. 23

24. BLS www.bls.gov Fast Track Process Another option for UX work Applies when  The data collection is focused on improving existing or future services, products, or communication materials  The data collection is voluntary  Statistical rigor is not required  The burden on participants is not high, AND  Public dissemination of results is not intended 24

25. BLS www.bls.gov Fast Track Process Methods covered:  Usability tests  Focus groups  Customer satisfaction qualitative surveys  Online surveys  Comment cards or complaint forms  Other similar methods 25

26. BLS www.bls.gov Fast Track Process Follows the same basic steps OMB submitted the 60-day notice to the FR on behalf of many agencies Each agency submitted their own 30- day FR notice and ICR. 26

27. BLS www.bls.gov Fast Track Process The agency then submits each study to OMB for approval.  Submission form Submission form OMB replies within 5 business days. 27

28. BLS www.bls.gov Fast Track Process OMB Submitted the 60-day notice on Dec 22, 2010 Agencies / Departments then submitted their own 30-day notice To find out if your agency is eligible, check with your Clearance Officer  Agencies included in the 60-day notice are in the Fast Track FAQ document.Fast Track FAQ document  Agencies not listed have to complete the entire clearance process independently. 28

29. BLS www.bls.gov Fast Track Process Most original Fast Track Clearances have expired  Check on reginfo.gov or with your Clearance Officer  To renew, agencies must do the whole process on their own. 29

30. BLS www.bls.gov Other Notes Benefits of Generic over Fast Track  With the Generic approval, you can publish results  The generic process covers a wider range of work (e.g., studies purely for research)  You can use more rigorous statistical analyses with the generic process Compensation for participants  Statistical agencies can pay $40, per OMB.  Other agencies seem able to pay more. 30

31. BLS www.bls.gov Data Confidentiality Follow laws/regulations for storing, managing, and protecting data for your agency Also follow ethical guidelines about what data you store (see the UXPA and HFES codes of ethics)UXPA HFES In the informed consent, state how you will handle all their data, including video Don’t use data in any other way without the participant’s written consent 31

32. BLS www.bls.gov References From OMB:  Paperwork Reduction Act of 1995 Paperwork Reduction Act of 1995  PRA Primer (Overview of the PRA), 2010 PRA Primer (Overview of the PRA), 2010  Memo on Generic Clearances, 2010 Memo on Generic Clearances, 2010  Fast Track Memo, 2011 Fast Track Memo, 2011  Fast Track FAQs Fast Track FAQs  Guidance from OMB on surveys for statistical purposes, 2006 Guidance from OMB on surveys for statistical purposes, 2006  Social Media and the PRA Social Media and the PRA  Template for OMB submission for generic clearance package Template for OMB submission for generic clearance package From Digitalgov.gov:  Blog on Fast Track Process Blog on Fast Track Process Regulations about data collection  5 CFR Part 1320 5 CFR Part 1320 32

33. BLS www.bls.gov Questions? 33 Jean E. Fox Fox.Jean@BLS.gov