Frequently Asked Questions

  1. Why is OMB approval necessary?
  2. What is OIRA?
  3. Do I need to submit an approval for a survey at a National Park?
  4. Will I be required to submit a 60 day Federal Register notice if I use the NPS Programmatic Review Process?
  5. What is the Federal Register?
  6. Is approval required for information collected in focus groups or field experiments?
  7. I am a graduate student conducting a study of national park visitors. I have an approved IRB from my university; will I need OMB approval for my study?
  8. How long does the Programmatic review process take?
  9. I intend to study visitor response to interpretive exhibits. I will observe visitors' behavior as they approach, read, and interact with the exhibits under different experimental conditions. Will I need approval?
  10. I will be surveying small groups of park visitors. Is approval required?
  11. Do I need approval if I am pre-testing a survey for later submission?
  12. I intend to offer respondents to my survey an incentive or small token of thanks from the park cooperating association. Is this acceptable?
  13. Are there any restrictions on the use of web surveys?
  14. How should I anticipate my expected response rate?
  15. Can I assure my participants that their identity (if known) will remain confidential?
  16. What does it mean for an agency to conduct or sponsor an information collection?
  17. How can I request approval for collections that are not eligible for the NPS Programmatic Review Process?
  18. Can I collect personally identifiable information (PII) under the Programmatic Review Process?
  19. What should I do if my submission for fast-track request is returned as improperly submitted or as outside scope of the generic clearance?
  20. How does the Privacy Act affect my collection?
  21. What is a respondent?
  22. What information collections to not require OMB approval?
  23. Does the PRA affect questions at public meetings?
  24. Is there any way to speed up the PRA clearance process?
  25. How can I view approved Information Collections?
  26. How can I view NPS Information Collection currently under OMB review?

1. Why is OMB approval necessary?
The Paperwork Reduction Act (PRA) requires Federal Agencies to submit proposed collections of information for review and approval by the Office of Management and Budget (OMB). Under the PRA, OMB's Office of Information and Regulatory Affairs (OIRA) reviews agency information collection requests for approval, modification, or disapproval. For more information on the PRA and how it applies to information collection activities see memo from the White House [pdf]

2. What is OIRA?
The Office of Information and Regulatory Affairs (OIRA, pronounced "oh-eye-ruh") administers the Paperwork Reduction Act of 1995, which calls for clearance and assessment of information collection requests by agencies. OIRA is part of the Office of Management and Budget (OMB), responsible for providing reviews that help ensure that the agency has adequately defined the problem that it intends to address;considered alternatives;assessed available information, risks, costs, and benefits (both qualitative and quantitative);consulted affected parties and promoted transparency and participation;and tailored the collection to focus on the problem in a simple and clear way that does not conflict with other rules or statutes. OIRA seeks to ensure, to the extent permitted by law, that the benefits of agency actions justify the costs and that the chosen approach maximizes net benefits to society.

3. Do I need to submit an approval for a survey at a National Park?
An Information Collection Request (ICR) must be completed and OMB approval must be granted for any situation where 10 or more respondents are involved in a collection of information sponsored, co-sponsored (or have the appearance of sponsorship) by the National Park Service. If the questions are standardized in nature and will be used to inform management or planning decisions, OMB approval must be obtained. This is general guidance on assessing if an ICR is required. One notable exemption is information collections of Federal Employees. If there are any questions it is best to consult the NPS Information Collection Review Coordinator.

4. Will I be required to submit a 60 day Federal Register notice if I use the NPS Programmatic Review Process?
The NPS Programmatic Review Process is limited in scope and not all NPS sponsored surveys will be eligible, to be submitted through this process. However, if a submission is eligible a Federal Register notice is not required because the collection will be managed in accordance to the provisions set forth in the approval of OMB Control Number 1024-0224 and not individually.

5. What is the Federal Register?
The Federal Register is the official daily publication for notices of Federal agencies and organizations, as well as for Executive Orders and other presidential documents. The Federal Register is published by the Office of the Federal Register within the National Archives and Records Administration (NARA). To learn more, visit the Federal Register website.

6. Is approval required for information collected in focus groups or field experiments?
There is no exemption for focus groups in the PRA. Information collected in focus groups or field experiments must be approved if the participation includes ten or more persons and they are asked identical questions. If a series of focus groups is conducted on the same topic using substantially similar questions and the total participants in all groups combined is more than ten, then approval is required. Although each focus group may not be asked the exact same questions in the same order, focus groups should be treated as information collections under the PRA if the same information is being sought from the groups.

7. I am a graduate student conducting a study of national park visitors. I have an approved IRB from my university;will I need OMB approval for my study?
NPS and OMB approval is required if the study is conducted, sponsored, or funded by the NPS. If you are receiving financial or in-kind support from the NPS, approval will be required. The submission should list your major professor or faculty advisor as the PI. Approval by university Institutional Review Boards (Human Subjects Committees) does not substitute for NPS and OMB approval. However, research occurring in national park units that is funded by external sources (e.g., independent grants) and is not assisted or reviewed by the NPS in any way does not require NPS and OMB approval.

8. How long does the Programmatic review process take?
The request for Programmatic review, and submission of a complete and accurate review package, must be made at least 60 calendar days prior to the first day the PI wishes to administer the survey in the field.

9. I intend to study visitor response to interpretive exhibits. I will observe visitors' behavior as they approach, read, and interact with the exhibits under different experimental conditions. Will I need approval?
Unobtrusive observations are exempt from the review and PRA approval process if no information is solicited from the public.


10. I will be surveying small groups of park visitors. Is approval required?
NPS and OMB approval is required if identical questions are asked of 10 or more persons.

11. Do I need approval if I am pre-testing a survey for later submission?
Pre-testing of survey instruments and methodology is encouraged. If pre-testing involves collecting the same information from ten or more members of the public, clearance for the pre-test is required. The request for approval of the pre-test can be submitted separately or with the final survey package, whichever is appropriate.

12. I intend to offer respondents to my survey an incentive or small token of thanks from the park cooperating association. Is this acceptable?
While incentives have been used in the private sector without much controversy, most Federal Government surveys do not provide incentives to respondents, and the use of incentives by Federal agencies has raised a variety of concerns about their cost, the use of taxpayer funds, impact on survey responses, and implications for the "social contract" between the Federal Government and citizens.The regulations implementing the Paperwork Reduction Act (PRA) of 1980 prohibited the use of incentives for respondents to Federal surveys unless agencies could demonstrate a substantial need. The regulations implementing the 1995 reauthorization of the PRA require agencies to justify any payments to respondents. Under certain circumstances, non-monetary incentives can be used when the agency provides a clearly justified need for the incentive and can demonstrate positive impacts on response and data quality by using an incentive. You should contact the NPS Information Collection Review Coordinator to discuss your proposed use of an incentive in your survey.

13. Are there any restrictions on the use of web surveys?
Use of web or on-line surveys as an option for respondents is acceptable. The Web should not be the only method of survey administration. There are restrictions on surveys of Web site users. If you intend to do a survey of this population, please contact the NPS Social Science Branch early in your planning process. Further, in terms of sample selection, the Web should not be the means by which a sample population is recruited, since this will bias the sample. An exception occurs when the population being surveyed consists of visitors to a Web site, such as www.nps.gov. Contact the Information Collection Review Coordinator if you are planning such a survey.

14. How should I anticipate my expected response rate?
Expected response rates should be based on previous studies in which the method of data collection and sample population were similar (please see OMB Standards and Guidelines for Statistical Surveys [pdf], Section 1.3, and American Association for Public Opinion Research response rate definitions). In reporting your expected response rate, please be sure to justify it with specific reference to these similar studies. If you are having difficulty with this, please contact the NPS Information Collection Review Coordinator for assistance.

15. Can I assure my participants that their identity (if known) will remain confidential?
Information collections approved under this program are subject to Freedom of Information Act requests. The Department of the Interior has no statutory authority to exempt studies from such requests. Therefore, confidentiality cannot be pledged. However, any information on surveys that identifies respondents can be removed or stored separately from survey databases so that the two are not linked. These steps should be disclosed to respondents.

16. What does it mean for an agency to conduct or sponsor an information collection?
An agency conducts or sponsors an information collection if the agency collects the information using its own staff and resources, or causes another agency or entity to collect the information, or enters into a contract or cooperative agreement with another person or contractor to obtain the information.If the agency requests the collection directly or indirectly through another entity or contractor or exercises control over those collecting the information, the agency is conducting or sponsoring the collection.

17. How can I request approval for collections that are not eligible for the NPS Programmatic Review Process?
If you would like to collect any information that is not covered by the NPS Programmatic Review Process you will have to draft the information collection instrument and then publish a Federal Register notice to solicit public comment (for 60 days) on the information collection. Concurrent with the 60-day Federal Register notice, the supporting statement (s) and information collection instrument(s) will be reviewed by the NPS. After the 60-day comment period has ended, the agency will consider any public comments submitted in reference to the 60 day Federal Register notice and make any revisions to the collection that the agency believes are necessary or desirable. The final submission will be reviewed by the Department of Interior (DOI) and upon the completion of that review the agency will be allowed to publish the 30-day notice and submit the proposed collection to OIRA. During its review, OIRA will either approve the collection as submitted, or approve the collection in part (and disapprove it in part), or disapprove the collection altogether. Only after OMB assigns an OMB control number may the agency proceed with the collection.

18. Can I collect personally identifiable information (PII) under the Programmatic Review Process?
Yes, but only in limited circumstances, such as when an agency collects contact information PII in order to have follow-up contact with a respondent (e.g., in order to provide a follow-up survey or phone call). And in those limited circumstances, the agency may collect PII only to the extent that its collection is a necessary element of the Information Collection Request. Moreover, in such circumstances, the agency must comply (as is also the case with other PII that the agency collects) with the applicable requirements, restrictions and prohibitions of the Privacy Act and other privacy and confidentiality laws that govern the agency's collection, retention, use, and/or disclosure of such PII.

19. What should I do if my submission for fast-track request is returned as improperly submitted or as outside scope of the generic clearance?
If your request is returned as improperly submitted, it means that you have not provided all the required information, you have not filled out the form correctly, or your submission is otherwise incomplete. If it is unclear why you improperly submitted, you should ask the NPS Information Collections Coordinator what needs to be done for resubmission. If OIRA returns a collection as outside the scope of the generic collection, the collection will not be approved. You should discuss with your clearance coordinator why it was outside the scope of the generic approval.

20. How does the Privacy Act affect my collection?
NPS Privacy Act Program: While compliance with the Privacy Act is managed separately within NPS, the Privacy Act Program is closely linked to the Paperwork Reduction Act since information collected might be Personally Identifiable Information (PII). The Privacy Act (5 U.S.C. 552a), enacted in 1974, established controls over what personal information the Federal government collects and how it uses or discloses that information. The Privacy Act has four basic objectives that NPS is committed to fulfilling to the greatest extent possible:
  1. To restrict disclosure of personally identifiable records maintained by agencies;
  2. To grant individuals increased rights of access to agency records maintained on them;
  3. To grant individuals the right to seek amendment of agency records maintained on themselves upon a showing that the records are not accurate, relevant, timely, or complete;and
  4. To establish a code of "fair information practices" that requires agencies to comply with statutory norms for collection, maintenance, and dissemination of records.
21. What is a respondent?
Under the PRA, a respondent is any member of “the public.” This includes but is not limited to: individual, partnerships, corporations, universities, nonprofit organizations, State, local, and tribal governments and agencies, and other associations and organizations, whether foreign or domestic. Federal agencies are not included in the definition of the public. OMB clearance is not required to collect information from other Federal agencies unless the information will be used for general statistical purposes. Under the PRA, OMB is responsible for identifying and managing the collection and use of statistical data throughout the Federal Government.

22. What information collections do not require OMB approval?
Agency collections from “agencies, instrumentalities, or employees of the United States” in their official capacities are generally not subject to the PRA, unless those collections are for “general statistical purposes.” It is worth emphasizing that agencies may ask for facts and opinions of Federal employees without triggering the PRA.

23. Does the PRA affect questions at public meetings?
Not usually. No clearance is needed if the attendees are just asked to comment or give suggestions on the program or subject in question. However, if the group is gathered for the purpose of having attendees respond to a specific set of formatted questions, then the PRA DOES apply.

24. Is there any way to speed up the PRA clearance request process?
There are provisions in the PRA for emergency processing of ICR packages. Such processing can be done very quickly. Approvals obtained this way are only good for a maximum of 6 months, allowing enough time to obtain approval through the normal process, if necessary. Emergency processing is only to be used to respond to circumstances that could not be foreseen and when the use of regular procedures would result in significant harm to the public or the program. Failure to plan, avoidance of embarrassment, etc., are not valid justifications. Requests for emergency processing must be approved in advance by the OMB Desk Officer.

25. How can I view approved Information Collections?
  1. Go to the OMB/GSA RegInfo.gov Information Collection Review web page;
  2. Near the top of the web page you will see a section called "Current Inventory";
  3. Click on the downward-pointing arrow in the "Select Agency" box below the "Current Inventory" heading;
  4. Select "National Park Service" from the list of agencies presented in the "Select Agency" box;
  5. Click the "Submit" button to the right of the "Select Agency" box;
  6. A list of NPS information collections currently approved by OMB will be displayed. Click on an OMB Control Number or ICR Reference Number to display detailed information about each collection.

26. How can I view NPS Information Collections Currently under OMB review?
  1. Go to the OMB/GSA RegInfo.gov Information Collection Review web page;
  2. Look for the section of the web page called "Currently Under Review";
  3. Click on the downward-pointing arrow in the "Select Agency" box below the "Currently Under Review" heading;
  4. Select "National Park Service" from the list of agencies presented in the "Select Agency" box;
  5. Click the "Submit" button to the right of the "Select Agency" box;
  6. A list of NPS information collection requests (ICRs) under OMB review will be displayed. Click on an ICR Reference Number to display detailed information about the ICR."

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