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PRA for user research

Please note that this is not official guidance outside of TTS. The following information and process have been used at TTS to obtain Fast Track (A-11 Section 280) PRA clearance under , external,GSA's Generic Clearance for Improving GSA's Customer Experience (OMB Circular A-11, Section 280 Implementation) for UX/CX research activities. If you are outside of GSA, please confirm your own agency processes.

This information is a product of the Voice of the Public (VoP) program, which supports research operations at TTS. Please contact VoP with any questions or feedback on this information at , external,tts-research@gsa.gov.

Introduction

Many teams at TTS must conduct small-scale UX/CX research to better understand their users' needs and determine how to better serve them. Often, teams must navigate the PRA (, external,Paperwork Reduction Act) during this process.

Fortunately, there is a Fast Track (A-11 Section 280) PRA clearance process that is designed for exactly this kind of research (see , external,OMB Circular A-11 Section 280). Teams can obtain this kind of clearance under the , external,Generic Clearance for Improving GSA's Customer Experience. However, many still get confused by this process, which delays their research and prevents them from being able to properly serve the public.

The goal of this information is to empower teams at TTS to conduct the research they need to deliver excellent digital government products and services by providing the following information on how to easily and efficiently navigate the Fast Track (A-11 Section 280) process.

Determining whether you need PRA clearance

Research activities that DO NOT need PRA clearance

You do not need PRA clearance if:

  • You are conducting research with federal employees or contractors acting within the scope of their employment. (, external,Citation)
  • You are conducting research with 9 or fewer participants over a period of 12 months.
    (, external,Citation)
    • This refers to one "instance" of research. For example, if you are conducting interviews, usability testing and a survey during the course of one larger project, each of these activities would each be considered different "instances" of research.
  • You are gathering information at a public hearing, meeting or online equivalent.
    (, external,Citation)

Usability testing does not require PRA clearance.

Additionally, the following research methods do not require PRA clearance:

For more information, please consult the OMB CX Team's page ", external,What type of CX research does not require PRA approval?". To view this page, click the link and sign in using your PIV card.

Research activities that DO need PRA clearance

The following methods do need PRA clearance AND are eligible for the Fast Track (A-11 Section 280) process at GSA:

  • Screener surveys for recruitment
    • These are forms used to collect information about potential research participants (such as demographic information).
  • Feedback surveys

If your research does not fall into one of these categories covered by , external,GSA’s generic clearance (customer research or feedback), it will not be eligible for the Fast Track (A-11 Section 280) process.

Getting help determining whether you need PRA clearance

If you are still unsure whether you need PRA clearance, please consult the Voice of the Public program by emailing , external,tts-research@gsa.gov for assistance.

You can also view the , external,OMB CX Team’s Guide to A-11 Umbrella Clearance Process for more information, or contact the , external,OMB CX Team to help make this determination. To view either of these pages, click the link and then sign in using your PIV/CAC card (see screenshot below).

Getting Fast Track PRA clearance

The Fast Track (A-11 Section 280) clearance is specifically designed for research activities that aim to improve the customer experience (, external,more information here). Once you have determined that your recruitment or research activities are eligible for this type of PRA clearance, you can follow the steps outlined below to get clearance.

Prior to starting the clearance request process, please contact , external,tts-research@gsa.gov with any outstanding questions.

Contacts

Note: Additional OCE review is not required when using the Fast Track (A-11 Section 280) process. You do not need to contact OCE.

Role Responsibilities Contact information
Researcher This is you! You are responsible for documenting your research plans and working with PRA Desk Officers to get the appropriate clearance. n/a
OMB CX Team The primary contact for the A-11 Section 280 process. They are responsible for overseeing all information collection requests under the A-11 Generic Information Collection (A-11 Gen IC) Umbrellas. They also work with the assigned OIRA Desk Officer to approve CX research. , external,View contact information for the OMB CX Team here. (Login with PIV card required.)
GSA PRA Desk Officer Please note that the role of the PRA Desk Officer may differ from agency to agency and this information is specific to GSA. They are responsible for entering information about PRA clearances into ROCIS, and can offer additional support throughout the process. , external,GSARegSec@gsa.gov

Process overview

Detailed, step-by-step instructions follow this table.

Phase Timeline Steps
Documentation Dependent on researcher Complete “Generic A-11 Information Collection Review (ICR)” template for your project and attach all instruments. All documentation must be complete before proceeding.
Pre-review Up to 7 days OMB CX Team offers pre-review of the completed Generic Information Collection (Gen IC) package to minimize rejection later: you can send the completed documentation to the OMB CX Team to receive feedback (cc’ing GSA PRA Desk for awareness).
Submission 1-2 business days Submit finalized documentation to GSA PRA Desk for review.
Review 1-2 business days OMB CX Team receives Gen IC package, reviews it, and notifies you of decision.
Using the PRA clearance n/a If approved, you are free to proceed with research. If denied, you must repeat the process.

Step-by-step instructions

Follow the steps outlined below to request Fast Track (A-11 Section 280) PRA clearance for your research:

1. Documentation

  • Download the , external,Generic A-11 Information Collection Review (ICR) template (PIV card login required) and complete it for your research project.
    • Detailed instructions on how to complete the form are included at the link above.
  • Attach all completed instruments (forms, surveys, etc.), instructions and scripts to this document to create the Gen IC package.
    • Google forms is an allowed platform for public participant recruiting screeners and UX/CX research in GSA.
      • It is recommended to send Word documents or screenshots for ease of use in providing feedback to submitted materials, as the OMB CX team cannot access Google links.
    • Apply the , external,GSA OMB control number found here (PIV card login required) to all instruments.
      • Use the “GSA Touchpoints” control number if using a Touchpoints form; otherwise use the generic GSA control number. Contact , external,GSARegSec@gsa.gov for support if necessary.
  • To avoid common mistakes, please consult the OMB CX Team’s , external,tips on how to finalize the template (PIV card login required).

2. Pre-review

  • If you would like the OMB CX Team to pre-review your Gen IC package (template and all instruments, instructions, and scripts), email it to the OMB CX Team for pre-review.
  • Make any necessary edits to finalize submission.
    • Double check with the OMB CX Team if necessary.

3. Submission

  • Email your finalized Gen IC package to GSA PRA Desk (cc’ing OMB CX Team).
  • GSA PRA Desk will upload your Gen IC package into ROCIS.
    • ROCIS is the electronic management system where IC data gets uploaded and filed. You will not have to interface with this system.

4. Review

  • OMB CX Team receives Gen IC package in ROCIS and reviews it.
    • OMB CX Team will enter the decision into ROCIS.
    • GSA PRA Desk is automatically notified of approval through ROCIS.
  • OMB CX PRA Team will notify you of the decision by email.
    • If denied, you must repeat the process.

5. Using the PRA clearance

  • If approved, you may proceed with research!

Making changes after receiving PRA clearance

  • You do not need to repeat the approval process if you are making de minimus changes.
    (, external,More information).
    • These are changes that affect only the look and feel (design improvements or minor plain language edits that do not change the nature or type of information collected and do not increase burden on the public). Examples include:
      • Color
      • Visual layout
      • Reordering instructions
      • Correcting grammar or framing questions in plain language
      • Fixing an address or phone number
      • Making a field or option more prominent
      • Updating an icon
  • “Non-substantive” changes should be submitted to OMB. (, external,More information).
    • Non-substantive changes are those that do not introduce new concepts or have new intended uses for the data being collected that go beyond what was described in the original approval). However, once you submit them, they generally get them approved within days.
  • If you need to amend the instrument or number of burden hours, you must repeat the above process to get approval for the changes.
    • If you need to make substantive changes, work with the OMB CX Team and GSA PRA Desk to do so.
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