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Not every request or collection falls under the PRA’s scope, and you may not need clearance at all. Voluntary collections are not automatically exempt. When figuring out if PRA clearance is needed, consider the following:
What type of information are you collecting,
Who are you collecting it from,
How will you be collecting it, and
Why you are collecting this information.
Voluntary or Mandatory Collection
Voluntary collections are not automatically exempt.
Regardless whether your collection is voluntary (i.e., the public is not required by law to provide information) or mandatory, the Paperwork Reduction Act treats the collection the same.
Who are you collecting information from?
Members of the public: Generally, this means people or groups outside of the federal government. Some groups that are considered members of the public include:
Individual people (including federal contractors)
Businesses and associations
State, territorial, tribal, and local governments
Foreign governments, businesses, and individual people
In general, the PRA applies even when information is collected from non-US citizens, residences, or businesses as those entities are considered “persons” under the Act. If you’re only collecting information from federal employees or military personnel as part of their job, then you don’t need PRA clearance. If the information isn’t part of their work-related duties, you may need PRA clearance.
Ten or more people or groups
Over a 12-month period, if you are requesting the same information from ten or more people or entities, you need PRA clearance. If you’re requesting information from fewer than ten people or groups, but they represent the majority or all of an industry or sector, you may need PRA clearance.
Social networks, blogs, webinars, and other public meetings
Covered under the “public meetings” exclusion, these generally don’t need PRA approval, as long as the public is not surveyed or asked identical questions: Public conference calls, Webinars, Blogs, Discussion boards, Forums, Chat sessions, Social networks, Online communities.
Wikis and collaborative drafting platforms
Web-based collaboration tools that facilitate interactions between the agency and the public and essentially provide a technology-based equivalent to in-person collaboration generally don’t need PRA approval. If they are used to collect information that an agency would otherwise gather by asking for responses to identical questions, however, they would need PRA approval.
The Basics of the PRA continued...
Specific type of collection, usually associated with surveys, customer satisfaction surveys, focus group tests, and website usability surveys, that allows for conducting more than one information collection using very similar methods. Most generic clearances cover collections that are voluntary, low-burden, and uncontroversial.
Generic clearances still require the initial generic collection to go through the normal PRA process, but allows for quicker clearance of associated collections later on.
Generic clearance is best when you’ll have multiple collections which:
Common Form Clearance
A clearance used by two or more agencies, or government-wide, for the same purpose. One agency will host the collection to use itself, and additional agencies can request to use that collection.
After OMB approves the primary collection, any agency that wishes to collect the same information and use it for the same purpose can obtain expedited approval by providing its agency-specific information to OMB (e.g., burden estimates and number of respondents).
Because the hosting agency has already gone through the PRA approval process, an expedited, 3-day approval is used for other agencies using the common form.
Expedited / Emergency Clearance
A rare type of approval granted only when there is a time-sensitive need for the collection based on very specific criteria for reasons outside of the agency’s control.
Typically, a collection is only eligible for this type of approval if the standard PRA approval process would cause likely public harm (such as the delivery of resources after a natural disaster) or missing a court-ordered or statutory deadline.
OMB will work with a more streamlined review process that still fits the purposes of the PRA. OMB may decide to modify or waive the public comment requirements, but you still need to make every possible effort to get public input about your collection.
Emergency clearances can only be approved for a maximum of six months; after this, your agency needs to renew the collection using the normal PRA process.
US Forest Service Generic Clearance for Citizen Science Projects in 2017 (Not Completed or Approved)
The USGS Open Innovation (OI) Community welcomes anyone interested in using participatory science and innovation methods like Crowdsourcing, Citizen Science, and Prize Competitions to obtain ideas, data, services, and solutions from the public and organizations in an open way. Ignite Open Innovation (OI) Forum is a series of different talks and panels to inform the development of a USGS Open Innovation Strategy.