The Paperwork Reduction Act (PRA) and usability testing

Last Updated: January 22, 2025

The Paperwork Reduction Act (PRA) ensures that the Federal Government collects information in a way that reduces unnecessary burdens on the public. This article explains how PRA is applied in the context of usability testing at VA.

In 2021, the Biden-Harris Administration issued an Executive Order to improve the customer experience and make service delivery simple, seamless, and secure for Americans. A clarifying memo states that the Office of Information and Regulatory Affairs (OIRA) encourages agencies to test their forms, websites, and other services. The primary purpose of the PRA is to minimize paperwork burdens for individuals—especially those who are vulnerable or disadvantaged—and to ensure the greatest possible public benefit from the information collected. Usability testing is a key tool that helps agencies fulfill the PRA’s primary purpose.

Do I need PRA clearance?

The type of information you collect will determine whether you need PRA clearance or not.

Doesn’t 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.

• Information for voluntary commercial transactions, like payment and delivery details.

• Information asked for or received in connection with a public hearing or meeting.

Needs PRA clearance:

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

• Surveys, such as customer satisfaction or behavioral surveys

• Research studies and focus groups with a set of the same questions or tasks (not related to usability testing of a digital form, website, or service)

• Applications for benefits and grant programs

Key takeaways

PRA clearance is not required for the following types of testing:

Unmoderated research (including card sorts, tree testing, or surveys)

• PRA clearance is not required when you ask structured, semi-structured, or open-ended questions when conducting tests to improve a paper or digital form, website, or service.

• There are no PRA limits on the number of participants you recruit through Perigean (cohorts of 10 or less are not needed).

Usability tests

• PRA clearance is not required when you directly observe participants interacting with a paper or digital form, website, or service.

Official memos

• Customer Experience Research, Usability Testing, and the Paperwork Reduction Act

• Exclusions to the regulatory definition of "Information"

• Social media guidance

• "Like items" guidance

• De minimis guidance

• Data Search Tools

• Web Based Interactive Technologies and the PRA

• PRA primer from OMB

Common Scenarios with Examples

Scenario 1: Creating/modifying forms that are entirely used by government employees to complete their official duties

Fact: If you are working on a form that will be used by a federal employee or contractor to complete their official duty, you do not need OMB PRA approval.

Example A: You are completing a system for disability claims processing, used by the VA to enter, track and review data about VA disability claims. This does not require PRA approval, because the information is not being collected from the public, but by federal employees to do their jobs.

Example B: You are modifying the SF-86 form (which federal employees and potential employees complete to be considered for positions requiring a security clearance). This form IS NOT automatically exempted from PRA even though it is completed by citizens seeking government employment. However, your changes may be exempted for other reasons (for example, if the changes are de minimis).

Scenario 2: Changing the look, feel and/or language of an existing online form

Fact: You do not need OMB PRA approval for "de minimis" changes. De minimis changes are changes to a form that affect the look and feel of a collection but do not change the nature or type of information (e.g., data elements) collected. In addition, de minimis changes do not increase the burden of a collection, though they might reduce its burden (i.e. eliminating fields). An example of a de minimis change is exclusively cosmetic (e.g., changing colors, visual layouts, field sizes). See this memo for details.

Example A: You are changing how an online form collects social security numbers and birthdates to make the data easier for users to type into the system. This is a de minimis change and does not require PRA approval because it does not change the nature of the information collected.

Example B: You are changing the web form to be a simpler "wizard" that guides users through the required fields throughout multiple screens, rather than putting all fields on one long screen. This is a de minimis change because it affects the look and feel of the collection, but not the nature or type of information collected.

Example C: You are adding demographic information fields to the online form because the agency realized it would like more information about the citizens using a given service. This is NOT a de minimis change because it is changing the data elements being collected.

Scenario 3: Conducting User Research using Direct Observation techniques

Almost no type of user research requires PRA approval.

Fact: Nothing gathered via "direct observation" research techniques such as in-person interviews or usability tests is subject to the PRA.

Example A: Watching a citizen trying to apply for VA HealthCare and observing their reactions, asking about their experience, and getting feedback is exempted from PRA because it is Direct Observation.

Example B: Showing a group of high school students wireframes of a potential application and asking for their reaction does not require OMB PRA approval.

Scenario 4: Conducting user research on government employees

Fact: PRA does not apply to surveys of government employees if the questions are related to their official duties.

Example A: When asking a USCIS adjudicator about their job and how they complete it, their pain points, etc., PRA does not apply.

Example B: Conducting a large-scale survey of Department of Education employees about their own experiences guiding their children through a student loan application process would not be automatically exempted from PRA requirements because the topic is not about their official duty (though this may be exempted for other reasons).

Scenario 5: Creating a "wizard" or "calculator" that helps users understand how a service might impact them based on their personal situation

Fact: The PRA does not apply to items collected to allow users to obtain information from an agency formula or table, even if citizens enter data about themselves to use the tool or calculator. This exception only applies if the items collected are solely those necessary for the user to obtain such information and will not be used by the agency for other purposes, such as to inform research and statistics or to determine program funding.

Example A: You are building a tool to help individuals learn what type of student loan repayment program they might qualify for. The tool asks the individual about their income level, job type, and type of student loans. The tool uses this information to calculate which repayment programs the user is eligible for based on this input and displays details of these programs to the user. The tool does not store the data submitted by the user, or use it for any other purpose. Using the tool is not a prerequisite for applying to one of the programs. This tool does not require OMB PRA approval because the tool allows users to obtain information from an agency "formula" and does not use the information for any other purpose.

Example B: The Department of Health and Human Services' National Heart, Lung, and Blood Institute offers users a Body Mass Index (BMI) calculator. To obtain a BMI output, a user must provide height and weight inputs. This tool does not ask the user for any items beyond what is necessary to calculate the BMI and the items are not used for other purposes, such as to inform research or statistics. The PRA does not apply to the BMI calculator.

Example C: The Department of Transportation and the Department of Housing and Urban Development jointly offer a transportation cost calculator that allows users to obtain location-specific data by asking for income, housing, and travel inputs. These items are necessary for the formula that calculates the transportation cost calculator output, and they are not used for any other purpose, such as to determine area funding or programmatic needs. The PRA does not apply to the agencies' joint transportation cost calculator.

Tactics for overcoming PRA roadblocks:

• When developing a usability test question guide, refer to it as a "conversation guide" not a "script" to make it obvious that this is just a guide to a conversation, not a structured survey.

• If your change gets classified as "non-substantiative change" you will have to go through the process. You will have to personally guide the process. Create deadlines, artificial meetings, etc. There is no standard timeline for non-substantive change reviews.

Key Citations from OMB Guidance

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