CONVERSATIONS WITH AMERICA
Paperwork Reduction Act
The Paperwork Reduction Act (PRA) was signed by President Clinton in 1995, but the statutory antecedent of the PRA was first signed by President Roosevelt in 1942. The PRA requires that the Office of Management and Budget (OMB) approve each collection of information by a Federal agency before it can be implemented. The statute defines "collection of information" broadly. It covers any identical questions posed to 10 or more members of the public -- whether voluntary or mandatory, whether written, electronic, or oral.
Many "conversations with America" do not require PRA clearance -- employee conferences, complaint systems, suggestion systems, and town halls and other meetings with customers (driven by an agenda rather than "questions"). These conversations are either one-on-one, or structured so loosely that the questions are not "identical" within the meaning of the PRA. On the other hand, the PRA is a statute, and it applies to "conversations with America" just as it applies to other Federal information collections. Customer satisfaction questionnaires, focus groups, websites (seeking a response to more specific questions than just an invitation for open-ended comments) are covered by the PRA.
Given the importance of facilitating customer satisfaction surveys and other more structured "conversations," many agencies have obtained generic clearances for customer satisfaction surveys from OMB. A generic clearance is a master plan for conducting one or more customer surveys. Many agencies have a current generic clearance for customer satisfaction surveys. OMB review for these plans occurs in two stages -- a full review of the overall plan, plus a quick review of the actual details of each customer survey. Once an agency has a plan on which the public has had full opportunity to comment, the agency's PRA paperwork clearance officer is able to obtain OMB approval for each customer survey very quickly without having to repeat the Federal Register notices or public comment periods. If you think that you want to develop a customer satisfaction questionnaire to assist your efforts, you should consult with your agency's PRA contact early on. Others in your agency may have already developed ones that could serve as models. You should also ask the PRA paperwork clearance officer for a copy of OMB's Resource Manual for Customer Surveys.
Some have asked what the PRA requires. To obtain OMB approval, the agency PRA paperwork clearance officer assembles a clearance package including the draft questionnaire and its justification, and puts a notice in the Federal Register seeking public comment for 60 days. The PRA paperwork clearance officer then submits the clearance package to OMB for approval, and publishes a 30-day notice in the Federal Register notifying the public it can comment to OMB. OMB will then approve or disapprove the agency's clearance package. Given these public notices, the normal clearance process will total at least 100 days. When OMB approves an agency's survey, OMB provides the agency with an OMB approval number to place on the information collection instrument. Only at that point may the agency begin to distribute the questionnaire. We caution, however, that this is only a summary discussion. You need to contact your agency PRA paperwork clearance officer to learn the full scope of the PRA and your agency's procedures for obtaining OMB clearance.