OMB Requires Agencies to Test Data Collection Forms

In an August 9th memorandum from the Office of Information and Regulatory Affairs (OIRA), a component of the Office of Management and Budget, the Obama administration instructed federal agencies to “engage in advance testing of information collections” – the forms we all fill out regularly for grant applications, taxes, etc. The purpose of this requirement is to help ensure that agencies are doing everything possible to minimize complexity and confusion for users in filling out government forms.

The memorandum instructs agencies to test forms “in order (1) to ensure that they are not unnecessarily complex, burdensome, or confusing, (2) to obtain the best available information about the likely burdens on members of the public (including small businesses), and (3) to identify ways to reduce burdens and to increase simplification and ease of comprehension.”

Agencies may use focus groups, observation, web-based experimentation, and randomized controlled experiments or other appropriate means to fulfill this obligation either before or during the public comment period associated with information collections based on the Paperwork Reduction Act.

The memorandum identifies various types of information collections where such testing may be particularly relevant including applications to obtain permits, licenses, benefits and grants. Could this eventually signal a re-evaluation of the 424/424RR grant application forms? Research administrators and principal investigators will have to wait and see.

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