PRA Frequently Asked Questions

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This FAQ addresses the following questions:

What is the Paperwork Reduction Act (PRA)?
The PRA was designed, among other things, to “ensure the greatest possible public benefit from and maximize the utility of information created, collected, maintained, used, shared and disseminated by or for the Federal Government” and to “improve the quality and use of Federal information to strengthen decision-making, accountability, and openness in Government and society." Federal agencies play a critical role in collecting and managing information in order to promote openness, reduce burdens on the public, increase program efficiency and effectiveness, and improve the integrity, quality, and utility of information to all users within and outside the government.
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Who is the public (or respondent)?
The public refers to individuals, partnerships, corporations, universities, nonprofit organizations, state, local, and tribal governments and agencies, and other associations and organizations, whether foreign or domestic.
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What is Burden?

Burden is the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency, including: reviewing instructions; developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information; developing, acquiring, installing, and utilizing technology and systems for the purpose of processing and maintaining information; developing, acquiring, installing, and utilizing technology and systems for the purpose of disclosing and providing information; adjusting the existing ways to comply with any previously applicable instructions and requirements; training personnel to be able to respond to a collection of information; searching data sources; completing and reviewing the collection of information; and transmitting, or otherwise disclosing the information.
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What does collection of information mean?
OMB regulations define “information” as “any statement or estimate of fact or opinion, regardless of form or format, whether in numerical, graphic, or narrative form, and whether oral or maintained on paper, electronic or other media.” This category includes:
(1) requests for information to be sent to the government, such as forms (e.g., the IRS 1040), written reports (e.g., grantee performance reports), and surveys (e.g., the Census);
(2) recordkeeping requirements (e.g., OSHA requirements that employers maintain records of workplace accidents); and
(3) third-party or public disclosures (e.g., nutrition labeling requirements for food).

The PRA applies to collections of information using identical questions posed to, or reporting or record-keeping 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. If a collection of information is addressed to all or a substantial majority of an industry or sector in a 12 month period, that collection is presumed to be addressed to ten or more persons.
The requirements of the PRA apply to voluntary collections as well as to mandatory collections and collections required to obtain a Federal benefit (e.g., a job, a grant, a contract). In implementing program activities, agencies should be aware of the applicability of the PRA and address PRA compliance in sufficient time to solicit and respond to public comment.
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What is not an Information Collection?
OMB regulations specify a number of items that are generally not “information” under the PRA. Important examples are:
  • Affidavits, receipts, changes of address, or consents;
  • Tests of the aptitude, abilities, or knowledge of persons; and
  • Facts or opinions that are (1) submitted in response to general solicitations of public comments, (2) addressed to a single person, (3) obtained or solicited at or in connection with public hearings or meetings, (4) obtained through direct observation by the agency (e.g., through visual inspection to determine how long it takes for people to complete a specific transaction), or (5) obtained from participants in clinical trials (which typically do not involve answers to “identical questions”).
It is worth emphasizing that facts or opinions obtained in connection with public meetings do not count as “information.” This “public meeting” exception allows agencies to engage with the public on the Internet so long as the engagement is the functional equivalent of a public meeting (i.e., not a survey). In addition, it is important to underline that general solicitations, such as Federal Register notices, do not trigger the PRA. It follows that agencies may offer the public opportunities to provide general comments on discussion topics through the Internet. More generally, agencies may use social media and web-based technologies in a variety of specific ways without triggering the PRA.
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Are there exempt collections?

Exempt collections include:
  • Federal criminal prosecution/investigation
  • Civil action
  • Administrative action,
  • Audit with respect to a specific party
For full details on how the Federal government implements the PRA, please see the Office of Management and Budget Memorandum entitled Information Collection Under the Paperwork Reduction Act.
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