CDC Paperwork Reduction Act Compliance: Ensuring Quality and Reducing Public Information Collection Burdens

The Paperwork Reduction Act (PRA) is the law that requires Federal agencies (1) to seek public comment on proposed information collections and (2) to obtain approval from the Office of Management and Budget (OMB) before collecting information from the public. The PRA grants authority to the OMB to review and approve federally conducted and sponsored data collections involving ten (10) or more respondents. Thus, the law and its implementing regulation (5 CFR 1320) also seek to reduce the burden placed upon non-Federal entities (the public) and prevent Federal agencies and their programs from collecting unnecessary information.

Goals of the PRA are to:

1. Minimize the burden on the public when collecting information, especially by using technology
2. Maximize the practical use of the information collected
3. Ensure that an Information Collection does not duplicate already existing information, or duplicate effort
4. Maximize the cooperation amongst Federal program areas and agencies
5. Promote openness and accountability in the collection and use of information
6. Improve integrity, quality, security, and utility of information to all users within and outside the Federal Government
7. Improve Federal responsibility and accountability

Paperwork Reduction Act Clearance

The PRA states that “an agency shall not conduct or sponsor the collection of information unless… [OMB] has approved the proposed collection of information.”1 OMB approval is required prior to voluntary and mandatory collections, as well as collections required to obtain a Federal benefit (e.g., a job, a grant, a permit). Thus, agencies must submit a set of documents known as an Information Collection Request (ICR), sometimes called a “clearance package,” to seek OMB approval of an information collection. The clearance package or ICR includes a description of the information collection (its need, planned use, collection method, and how much time, money, and effort it will take for the respondents to provide the requested information and the government to collect the information). In essence, the clearance package provides the justification for collecting information. The clearance package also includes copies of all data collection instruments, supporting documents such as consent forms, letters, and telephone scripts, as well as other information and supporting documents that demonstrate that the agency has met the requirements of the PRA.

The PRA requires agencies to first seek public comment concerning proposed collections of information through a published 60-day Federal Register Notice (FRN). The 60-day FRN allows the public and affected agencies 60 days to:

• Solicit public comment/or suggestions about a proposed collection of information before it is submitted to OMB for their review
• Evaluate whether the proposed collection is necessary (including practical utility)
• Evaluate accuracy of burden estimates
• Enhance the quality, utility, and clarity of the information to be collected

Following the conclusion of the 60-day public comment period and after Department of Health and Human Services approval, the agency must publish a second FRN. This second notice, also known as a 30-day FRN, notifies the public that the agency has submitted the clearance request to OMB for review and that the public has an opportunity to provide comment to OMB concerning the final version of the clearance package.

During the OMB review, discussions or negotiations may occur between the agency and OMB concerning the proposed clearance package. OMB review considerations include underlying statutory, regulatory, budgetary, privacy and policy issues and information quality, statistical design and methodology concerns. OMB pays particular attention to the practical utility of the data to the federal government.

Information collection activities may not begin before OMB approves the clearance package. When OMB approves an information collection, it assigns an OMB control number that the agency must display on all approved information collection instruments. OMB may approve collections for a maximum of three years.

Any changes or revisions to the approved information collection package (e.g., to the data collection instruments, to the number or type of respondents, to the burden hours or methods, etc.) require further OMB approval before implementation of the changes or revisions.

To access Federal agencies’ and their internal program offices’ active and inactive information collection “clearance packages,” go to RegInfo.gov, which is a United States Government website produced by the OMB and the General Services Administration.

HHS Information Collection/Paperwork Reduction Act Website