The Paperwork Reduction Act requires that all federal websites request permission from the Office of Management and Budget (OMB) before collecting information from 10 or more members of the public. Therefore, Office of Energy Efficiency and Renewable Energy (EERE) surveys and user experience (UX) research projects may require OMB approval before proceeding.
Note that proposed survey projects must first be approved by the Web Governance Team before being submitted to OMB for approval.
What Does the Paperwork Reduction Act Require?
You must get approval from OMB if you conduct any activity that collects information from 10 or more respondents from the general public. This generally applies to surveys or UX research projects, but it can apply to any project that gathers user data.
You do not need approval if you're only collecting information from federal employees. However, OMB does not consider government contractors to be federal employees, so any survey that collects information from more than 10 contractors will need OMB approval.
If you don't know whether your survey requires OMB approval, contact the Web Governance Team Facilitator before you begin work on your survey.
Getting Approval from the Office of Management and Budget
You can get OMB approval through two different processes: the Fast Track system or standard OMB approval.
The Fast Track System
Some EERE surveys or UX projects qualify for OMB's "Fast Track" approval process. This is for products that collect data on stakeholder awareness, understanding, attitudes, preferences, or experiences about existing or future services, products, or communication materials. Your data collection activity may be eligible for the Fast Track process if it meets all of the below factors:
- The data collection is focused on improving existing or future services, products, or communication materials
- The data collection is voluntary
- Statistical rigor is not required
- The burden on participants is not high
- Public dissemination of results is not intended.
Before you submit your materials, you'll also need to calculate your product's burden. Use this formula:
Burden = The amount of time to complete the survey or UX test * The maximum number of survey respondents
For example, if you are sending the survey out over a mailing list, you would take the total number of newsletter subscribers, subtract all federal employees, and then multiply that number by the number of minutes it takes to complete the survey. If you planned to put the survey on a website for two weeks, you could use your website statistics from Google Analytics to estimate the number of visitors you get, on average, in two weeks.
The number of people can be estimated, but the total burden MUST be that number multiplied by the time. Do not factor in the fact that most of your visitors will not read your survey.
If your product has a high burden, OMB may reject your Fast Track approval request. In this case, you will need to go through the standard approval process instead.
Once you've calculated the burden of your task, you can submit it for review. Follow these steps:
- Contact the Web Governance Team Facilitator and ask for the Paperwork Reduction Act (PRA) Fast Track submission form.
- Write your draft questions for your survey or UX project.
- Attend a Web Governance Team meeting and present your questions and the completed PRA Fast Track submission form. Contact the Web Governance Team Facilitator to get on the Web Governance Team agenda.
- Submit the completed form and your survey or UX questions to the Web Governance Team Facilitator, who may recommend changes.
- Once the Web Governance Team Facilitator has approved your product, submit the forms and questions to the U.S. Department of Energy's liaison with OMB (the Policy and Performance Management Division of DOE's Chief Information Office) via a central mailbox for these requests.
- The DOE OMB liaison will review your product and suggest changes.
- Make these changes and send them back to the Web Governance Team Facilitator.
- The DOE OMB liaison will submit your product for a preliminary OMB review. OMB may provide preliminary suggestions and recommendations or may approve it. At this point, OMB will determine whether your product is appropriate for the Fast Track process. If OMB determines that your questions or your estimated burden will not work for the Fast Track process, follow the process outlined in the "standard Office of Management and Budget approval" section, below.
- Make the necessary changes. The Web Governance Team Facilitator will then send your materials back to the DOE OMB liaison, who will formally submit your final product to OMB. Then OMB has 5 business days to respond. If OMB reviewers have a question or require more information, they will contact you in this time.
- If OMB inquires within those 5 days, they have an additional 5 days to respond after you send them your response.
- If no response is received in 5 days, the survey is assumed approved on the 6th day and you may begin your survey or UX project.
The amount of time it takes to get approval varies widely, but often takes 1–3 months.
Standard Office of Management and Budget Approval
Follow the process above. OMB will determine whether your survey needs to go through the Fast Track process or the standard approval process in step #8. If you need to follow the standard approval process, follow these steps:
- Submit these files to the Web Governance Team Facilitator:
- The Web Governance Team Facilitator will coordinate with DOE's General Counsel's Office to obtain approval in writing.
- Fill out the 60-day Federal Register Notice. You will also need to get a signed certification letter from the technology office director or other senior leader on letterhead to certify the Federal Register notice is legitimate.
- Provide the following items to the Office of Federal Register:
- The original signed Federal Register notice in Word
- Three copies of the notice
- One copy of the General Counsel's concurrence
- The certification letter on letterhead in Word
- A disk or CD with the Federal Register notice saved in Word.
- Fill out the 30-day Federal Register Notice. Submit the same items you submitted in step #4 for the 30-day Federal Register notice. The 30-day notice will address any comments received after the 60-day notice publishes.
- Once both the 60- and 30-day notices have published, the Web Governance Team Facilitator will provide the following package to DOE's Policy and Performance Management Division of the Chief Information Office to upload for OMB approval:
- Form OMB 831
- Supporting Statement
- 30-day Federal Register notice
- 60-day Federal Register notice
- Survey questionnaire
- After this process is complete and OMB has given final approval, you may post your survey.
Synopsis of the Standard Approval Timeline
- The Office of Federal Register publishes the 60-day Federal Register notice after you provide the notice, certification letter, General Counsel's concurrence, and a disk with the notice saved in Word to the Office of Federal Register. You will get a copy.
- During those 60 days, the public has an opportunity to comment on the survey.
- You prepare the 30-day Federal Register notice, which will be published once the 60-day notice has run its course. You will address any comments in the 30-day notice that you received while the 60-day notice was in effect.
- You provide the 30-day notice, certification letter, General Counsel's concurrence, and a disk with the notice saved in Word, to the Office of Federal Register. Once the 30-day notice is published, you will get a copy.
- The published Federal Register notices, other forms, and survey questions are provided by the Usability Coordinator to the Policy and Performance Management team to upload into OMB's approval system.
- OMB reviews and provides comments and gives approval (or asks for changes).
- Once approval is received, you can conduct your survey and collect results.