What is OMB Clearance Process
What the OMB Clearance Process Means for Market Research Teams
For any study that asks the U.S. public for information on behalf of a federal agency, the Paperwork Reduction Act requires OMB clearance. For market research leaders, this process is not red tape to endure. It is a framework that protects data quality, ensures you ask only what is necessary, and builds public trust by being transparent about burden and purpose. When planned well, you can align PRA milestones with your research roadmap and keep decisions moving.
- Scope: Applies to surveys, interviews, forms, focus groups, and record‑keeping requests sponsored by a federal agency, including collections conducted by contractors or partners.
- Outcome: If approved, OMB assigns a control number and expiration date that must be shown on the instrument and related instructions.
- Value: OMB review pressures teams to justify every question, document burden, and explain how findings will be used—raising the bar on methodology and stakeholder confidence.
- Alternatives and variants: Some efforts may use generic clearances for iterative, low‑burden studies, fast‑track approvals under an existing generic, or non‑substantive changes to modify an approved collection. True emergencies may pursue emergency clearance with shortened timelines. Exclusions exist for activities outside PRA scope.
Step‑by‑Step: From Idea to OMB Control Number
Here is how a standard clearance typically unfolds, and how research and compliance work together at each milestone.
- Plan the collection and build the ICR package. Define purpose, target population, sampling, instruments, burden estimates, incentives, privacy/SORN/PIA status, and data use. Assemble the Supporting Statement, instruments, recruitment and reminder materials, and any governing statute or rule.
- Publish a 60‑day Federal Register notice. Invite public comment on necessity, utility, methodology, clarity, and burden. Monitor comments and prepare responses. You can continue refining instruments during this window.
- Revise and ready the submission. Update materials based on comments. Document changes and rationales.
- Publish a 30‑day Federal Register notice and submit in ROCIS. Post the final notice and concurrently upload the full Information Collection Request in ROCIS for OIRA review, including the comment summary and final instruments.
- OIRA/OMB review and decision. An OIRA desk officer engages with questions. Agencies respond, adjust as needed, and receive a decision. If approved, OMB issues a control number and expiration date that must appear on the collection.
Timing guide: Most teams plan for 6–9 months end‑to‑end. Statute sets at least 90 days of public comment across the 60‑ and 30‑day notices. OMB typically aims to decide within about 60 days after submission or the 30‑day notice, whichever is later.
Practical Tips, Timelines, and Common Pitfalls
- Start PRA early. Kick off the 60‑day notice as soon as your research problem, audience, and initial instruments are sketched. Do not wait for final polish.
- Right‑size the pathway. If your organization holds a relevant generic clearance, use it for iterative concept tests or usability sessions. For tweaks to an approved collection, consider a non‑substantive change.
- Document burden with care. Show math for time per respondent, sample sizes, and total annual hours. Align incentives with burden and norms.
- Design for clarity. Use plain language. Pilot test where appropriate and summarize findings in the Supporting Statement.
- Track notices precisely. Record Federal Register citation details and ensure the 30‑day notice text matches the final package.
- Label everything. After approval, display the OMB control number and expiration date on every instrument and instruction. Include the required PRA statement.
- Coordinate privacy and records. Confirm any SORN/PIA status, confidentiality pledges, and data retention. Be explicit about use, sharing, and storage.
- Avoid common pitfalls. Underestimating burden, vague purpose statements, missing recruitment materials, or misaligned sample frames often trigger OIRA questions and delays.
Pro tip: Build a shared checklist covering the Supporting Statement, instruments, recruitment, scripts, burden table, Federal Register notices, ROCIS fields, and post‑approval labeling. Reuse it across projects to shorten cycle time.




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