Limitations of the Programmatic Clearance Process

In accordance with the Open Government Directive’s call for clarifying guidance, the availability and uses of “generic” Information Collection Requests (ICRs) was established to significantly streamline the process by which agencies may obtain OMB’s approval for particular information collections—usually voluntary, low-burden, and uncontroversial collections. The list below includes, but is not restricted to, some of the limitations of the NPS Programmatic Clearance Process.

  • Previously Approved Questions: Questions that were previously approved by OMB (for this or another agency), and are not within the scope or the Topic Areas approved under this Programmatic Clearance will not automatically be exempt from this review. Each question must be reviewed and approved within the context of the NPS Programmatic Clearance Process and the proposed survey. Some previously used questions may not be approved at the discretion of the NPS Information Collection Review Coordinator.
  • On-Site Intercept Surveys: All information collections in this category will be restricted to last no more than 15 minutes. There will be very few exceptions and those will be considered on a case by case basis. This burden must be verified by evidence of pretesting with subjects not familiar with the development of the study. On-site surveys should be implemented in a manner that is consistent with methods that will consider respondent fatigue. Previous survey results without an examination of respondent burden will not be considered as the sole justification for approval.
  • Non-Response Bias Testing: Each submission requesting programmatic approval must include a description of techniques used to minimize and offset bias. All methods will require non-response bias testing and a reporting of what the implications may have on the results of the study. At a minimum, agencies should plan to compare respondents and non-respondents on information available from the sampling frame. Sampling frames that include data on various attributes of the population unit are helpful in examining whether response rates vary on those attributes or whether the characteristics of respondents and non-respondents differ on these characteristics.
  • Pool of Known Questions: At least 80% of the questions in any information requests submitted through the Programmatic Clearance Process must come from the currently approved Pool of Known Questions. If the specific questions are not in the Pool of Known Questions a “variation” of a currently approved question will be considered. A “significant” variation of questions outside of the scope of the currently approved topic areas will not be considered for approval.
  • Socio-Economic Monitoring: The use of questions that employ stated preference or stated choice techniques to estimate consumer surplus values and non-market values associated with park visitation is outside the scope of this approval. The responses to the questions in TOPIC AREA 10 are not intended to be used or combined with any other survey responses outside the scope of the proposed survey request. Results should only be aggregated to the population of visitors to the specific park unit for which the approval is granted. There should be no attempt to disaggregate any values to generalize the results above or beyond the scope of the intended proposed and approved purpose.

Authorities and Guidance

The authorities and guidance that apply to the programmatic process are:

  • Paperwork Reduction Act of 1995 (P.L. 104-13 May 22, 1995)
  • 5 CFR Part 1320: Controlling Paperwork Burdens on the Public; Regulatory Changes Reflecting Recodification of the Paperwork Reduction Act
  • United States Code, Title 44, Chapter 25: Coordination of Federal Information Policy
  • OMB, The Paperwork Reduction Act of 1995: Implementing Guidance (draft, August 16, 1999)
  • NPS Director’s Order #78, Social Science, Section III (October 7, 2002)
  • NPS, Social Science Surveys and Interviews in the National Parks and for the National Park
  • OMB, Guidance on Agency Survey and Statistical Information Collections: Questions and Answers When Designing Surveys for Information Collections (January 2006)

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Last updated: July 7, 2020


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