CDC Paperwork Reduction Act Compliance: Ensuring Quality and Reducing Public Information Collection Burdens

The Paperwork Reduction Act (PRA) is the law that requires Federal agencies (1) to seek public comment on proposed information collections and (2) to obtain approval from the Office of Management and Budget (OMB) before collecting information from the public. The PRA grants authority to the Office of Management and Budget (OMB) to review and approve federally conducted and sponsored data collections involving ten (10) or more respondents. Thus, the law and its implementing regulation (5 CFR 1320) were also designed to reduce the burden placed upon non-Federal entities (the public) and to prevent Federal agencies and their programs from collecting unnecessary information. However, the PRA significantly increased the paperwork burden on the Government in order to justify the collection of information.

Goals of the PRA are to:

1. Minimize the burden on the public when collecting information, especially by using technology
2. Maximize the practical use of the information collected
3. Ensure that an Information Collection does not duplicate already existing information, or duplicate effort
4. Maximize the cooperation amongst Federal program areas and agencies
5. Promote openness and accountability in the collection and use of information
6. Improve integrity, quality, security, and utility of information to all users within and outside the Federal Government
7. Improve Federal responsibility and accountability

Paperwork Reduction Act Clearance

The PRA states that "an agency shall not conduct or sponsor the collection of information unless... [OMB] has approved the proposed collection of information."¹ OMB approval is required prior to voluntary and mandatory collections, as well as collections required to obtain a Federal benefit (e.g., a job, a grant, a permit). Thus, agencies must submit a set of documents known as an Information Collection Request (ICR), sometimes called a "clearance package," to seek OMB approval of an information collection. The clearance package or ICR includes a description of the information collection (its need, planned use, collection method, and how much time, money, and effort it will cost the respondents and the government to collect the information). In essence, the clearance package provides the justification for collecting information. The package also includes copies of all data collection instruments, supporting documents such as consent forms, letters, and telephone scripts, as well as other information and supporting documents that demonstrates that the agency has met the requirements of the PRA.

Prior to submitting a clearance package for OMB review and approval, those outside of CDC must be given the opportunity to provide input on the planned data collections. To solicit this input, CDC publishes a 60-day Federal Register Notice (FRN) which informs the public of CDC’s intent to ask OMB for collection of information clearance and to solicit comments for a 60-day period. The public’s comments are considered and noted in the clearance package.

Following the conclusion of the 60-day public comment period and after Department of Health and Human Services approval, a second notice is published in the Federal Register. This second opportunity for comment, known as a 30-day FRN, notifies the public that the clearance request has been submitted to OMB and the public has an opportunity to comment on the final version of the clearance package.

During the OMB review, discussions or negotiations may occur between CDC and OMB concerning the proposed clearance package. OMB review considerations include underlying statutory, regulatory, budgetary, and policy issues and statistical design and methodology concerns. OMB pays particular attention to the practical utility of the data to the federal government.

Information collection activities may not begin before OMB approves the clearance package. When OMB approves an information collection, it assigns an OMB control number that must be displayed on the information collection instruments. Collections may be approved for a maximum of three years.

Any changes or revisions to the approved information collection package (e.g., to the data collection instruments, to the number or type of respondents, to the burden hours or methods) require further OMB approval before implementation of the changes or revisions.

HHS Information Collection/Paperwork Reduction Act Website