PRA Implications

Resources

1. 2010 PRA Primer

On January 21, 2009, the President issued a memorandum calling for the establishment of “a system of transparency, public participation, and collaboration.” This Memorandum responds to that requirement by offering clarifying guidance with respect to the Paperwork Reduction Act of 1995 (PRA) in order to specify its central requirements and to increase transparency and openness.

2. 2014 Handy Chart of exceptions to PRA's definition of "information" that do not need to go through the PRA approval process.

Some of the most relevant exceptions as pertains to USFS are:

User Accounts: Items collected to create user accounts or profiles for agency websites. This category does not apply to information collected for programmatic purposes.

Voluntary Commercial Transactions: Information that is necessary for the selection, payment, or delivery of an item, or to identify the person ordering an item, if such information is used solely for the purpose of completing a commercial transaction.

Data Calculation: Items collected to allow users to obtain information from a table or formula, if the items are used solely to help the user obtain information and will not be used for other purposes.

3. 2016 White House Memo, outlining PRA "Flexibilities"

De minimis Changes

In September 2015 OIRA issued its Behavioral Science Insights and Federal Forms guidance, which clarified that de minimis changes of a cosmetic nature to approved information collections do not require further approval under the PRA. De minimis changes to a collection are changes that affect the look and feel of a collection, but do not change the nature or type of information collected. In addition, de minimis changes do not increase the burden of a collection, though they might reduce its burden.

"Non-Substantive Changes"

...a recent, active area of agency activity for many information collections is the development of interactive, web-based or similar applications* to help facilitate responses. Such tools can improve responsiveness and accuracy, and lower the burden, of any particular information collection.

*These types of applications are also sometimes referred to as online "wizards".

As long as the underlying, approved form is not altered and the interactive materials essentially collect the same information, then OIRA considers these applications a nonsubstantive change to an already approved collection, and would encourage their development.

4. OMB Federal Collection of Information Page

An aggregation of useful PRA links.