PRA approval process
Plan ahead for PRA
Most agencies estimate six to nine months for PRA clearance from agency development to OIRA’s decision. By law, this process in most cases includes at least three months of public comment.
However, you don’t need to extend your project timeline for PRA! You can start the 60-day comment period in the Federal Register and consider public comments while simultaneously developing the more detailed request for OMB review.
PRA approval does take time, but it doesn’t have to all be done at the very end. Please note that if you are dealing with a collection of information stemming from a proposed rule the process is slightly different.
Process overview for standard clearance
Develop the information collection request within your agency
If your collection needs PRA clearance, it’s time to put together the basics of the information collection request (ICR). This first request won’t be reviewed by OMB, but it will require a Federal Register Notice for the public to review and comment on.
The Notice should include details about:
- What information is being collected
- Who you’re collecting it from
- Why you’re collecting it
- What is the estimated burden cost, i.e., the time (in hours), financial considerations, and paperwork needed for the collection
- How will the information be used once you’ve collected it
This information helps the public understand your collection during the comment period. It will be important in writing a strong supporting statement when requesting approval from OMB.
Issue a 60-day request for comment in the Federal Register
Since you’ll be collecting information from the public, the PRA makes sure they have time to ask questions and offer comments or ideas. Your notice needs to have enough detail for the public to consider these questions:
- Do they feel collecting this information is necessary?
- Does the burden estimate seem accurate and justified, and could it be lower?
- How will you make sure the information collected is high quality, clear, and useful?
Consider the public comments on the notice
Reviewing comments from the public is an excellent way to understand how the people actually responding to your information collection feel about it. Review and consideration of public comments is essential and allows you to adjust and improve the request before submitting the collection to OMB for review. Part of the review involves a summary of public comments, and if you made any changes based on them.
Issue a 30-day notice to the Federal Register
The 30-day Federal Register notice lets the public know you’ve submitted the collection to OMB and that OMB is reviewing it. It includes all the information from the 60 day notice and any changes you have made from public comments. If the public has further comments, they’re sent to OMB directly instead of the agency.
Submit request to OMB for review
With your agency, you’ll submit an Information Clearance Request (ICR) package to OMB for review. ICR’s are submitted to OMB through a system called ROCIS. The ICR package submitted into ROCIS contains:
- Supporting Statement and other supporting documentation.
- The instruments of the collection (copies of the forms, surveys, recordkeeping requirements, etc.).
- A summary of any public comments, and the agency’s response(s).
- Details about the 60-day and 30-day Federal Register notices, including date, page, expected or actual publishing date, and the full text of the 30-day notice.
- A copy of the relevant statute and regulation mandating or authorizing the collection of information.
- Guides or instructions for interviewers.
- Explanatory material to be given to prospective respondents, and follow-up material to be given to members of the public who do not respond.
OMB review timeline and process
OMB typically reviews ICR packages within sixty days, from the date of submission or publication of the 30-day Federal Register notice (whichever is later), but can take longer in some circumstances.
During this time, your ICR package should be reviewed by an OIRA desk officer. The desk officer will look at how the collection’s supporting statement and documentation meet the standards of the PRA.