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Traditional Clearance Process for Information Collection

The Traditional Clearance process is one of the two processes for obtaining PRA clearance. Traditional Clearance Process requires a 60-day Federal Register notice.  If certain requirements are met, the particular collection instead may be able to fall under the Fast-Track Clearance.

Steps for Preparing and Submitting Requests

In general, there are four steps to preparing and submitting and information collection request for PRA approval.  Before running your test, survey or interview, the PRA generally requires Federal agencies to:

  1. Prepare and publish a notice in the Federal Register to provide a 60-day period for the public to comment on the reporting and record keeping requirements associated with the information collection.
  2. Prepare an information collection request (ICR) package. A complete package should contain the following items in the order listed:
  3. Supporting Statement:
    1. Copies of all the necessary attachments. These attachments can include data collection instruments (questionnaires, surveys, etc.), instructions, scripts, consent forms, IRB letters, and other reference materials related to the collection (e.g., OIG/GAO audits or studies substantiating the need for the collection, copies of documents published as a result of previous collection efforts, etc.)
    2. Publish the 30-Day Federal Register Notice and forward the submission to your OPDIV Reports Clearance Officer for review prior to forwarding it through the Department.
  4. Submit the proposed collection for review and approval by the Office of Management and Budget (OMB) concurrent with the 30-day Federal Register notice.  Note: The Departmental Reports Clearance Officer reviews the collection for quality and potential duplication across the Department prior to forwarding the collection to OMB.

How Long Does the Review and Approval Process Take?

The complete review and approval process can take anywhere from 6-9 months, depending on the number of requests currently in process and the data collection subject matter.   This estimate includes the 60-day and 30-day public comment periods and the 60 days OMB has to review and act upon each submission.

Example Process from the Department of Health and Human Services

For the Department of Health and Human Services (HHS), the Traditional Clearance process is as follows:

Milepost 1:  “Draft” ICR package

An example of the Traditional Clearance process at HHS is as follows:

  1. Develop "draft ICR"
  2. Submit 60-day Federal Register Notice
  3. Draft ICR is reviewed and approved by OpDiv PRA office
  4. Submit 30-day Federal Register Notice
  5. Draft ICR is reviewed and approved by HHS PRA office
  6. HHS PRA office sends the ICR to OMB
  7. OMB has 60 days to review the ICR (includes back-and-forth with OpDiv)
  8. OMB issues NOA (approval, disapproval, withdrawal)

When drafting the “draft” Information Collection Request (ICR) package, you will need to include the following:

  • Supporting Statement: narrative information explaining the purpose, scope, and benefit(s) of the collection
  • Citation of authorizing legislation
  • Citation of the initial 60-day Federal Register Notice
  • Question lists or prototype of instruments used for collection

Milepost 2:  Submit 60-day Federal Register Notice

A 60-day Federal Register Notice:

  • Notifies the public of the proposed information collection
  • Solicits comments from the public
  • Draft of ICR must be developed in case the public requests this during the 60-day review period.

Milepost 3:  Submit 30-day Federal Register Notice

The 30-day federal Register Notice should IDEALLY be concurrent with the OMB 60-day review.

  • This is after the package has been reviewed and approved by the OPDIV PRA Office.
  • Notifies public that the clearance request has been submitted to OMB.
  • Solicits comments from public (which goes to OMB)

References

  1. Frequently Asked Questions About PRA / Information Collection
  2. OMB-OIRA Federal Collection of Information