Before planning interviews, surveys, or outreach, determine if your activity is a "collection of information" under 5 CFR 1320.3. The PRA triggers when an agency or its contractor asks identical questions or imposes identical reporting/recordkeeping on ten or more persons in a 12‑month period, whether voluntary or mandatory, and in any format (forms, questionnaires, interviews, web polls, emails, or digital tools). If triggered, you must publish notices, estimate burden, and secure an OMB Control Number before collecting responses. Collections must disclose the control number and inform respondents they are not required to respond without a valid number (5 CFR 1320.5).

• Key terms
  • Collection of information: identical questions or requirements posed to 10+ people, including surveys, interview guides, forms, or standardized emails.
  • Burden: total time, effort, and cost for respondents to understand, find, compile, complete, review, and transmit information (5 CFR 1320.3). Usual and customary activities may be excluded when demonstrably routine.
  • OMB approval window: approvals last up to three years; expiration dates appear on the collection.
• What changes for market research
  • Methodology is shaped to minimize burden hours and frequency.
  • Transparency on purpose, burden estimate, and expiration is required in notices and on instruments.
  • Scope control: sample sizes, question standardization, and recruitment approaches are adjusted to avoid unintended PRA triggers or to align with approval.
• Not everything is covered
  Some activities are outside PRA coverage (see 5 CFR 1320.4 and related guidance). However, do not assume that voluntary or anonymous outreach is exempt. The 10‑person threshold and identical questions are the practical tripwires.

A sound approach protects timelines and data quality while meeting PRA requirements. Use this sequence to keep projects on track:

1. Scope and triage
   • Map audiences and counts. If you may hit 10+ respondents with identical questions, plan for PRA early.
   • Decide whether to consolidate instruments or split by audience to control counts and burden.
2. Design for minimal burden
   • Ask only what you will use; remove nice‑to‑know items.
   • Prefer closed‑ended questions and reuse validated items.
   • Pilot with fewer than ten people to refine wording and timing without triggering PRA.
3. Quantify burden accurately
   • Time a realistic completion window, include recruitment and follow‑ups.
   • Convert minutes to annual burden hours and provide a clear calculation in the submission.
   • Highlight technology choices that reduce burden (e.g., skip logic, prefill, mobile‑ready forms).
4. Prepare notices and package
   • Draft the 60‑day and 30‑day Federal Register notices that explain purpose, use, methodology, and burden.
   • Assemble instruments, recruitment scripts, and privacy statements. Ensure each displays the OMB Control Number placeholder and PRA statement.
5. Run the clearance path
   • Submit under the correct pathway (e.g., standard clearance). Track OMB questions and adjust instruments quickly.
   • After approval, publish the control number and expiration on every instrument and landing page.
6. Operate compliantly
   • Train the team to use only approved instruments and scripts.
   • Monitor respondent counts to avoid exceeding approval.
   • Maintain records that support the burden estimate and any exclusions for usual and customary activities.

Teams tend to stumble on the same issues. Use this checklist to catch them early:

• "It's voluntary, so we're exempt." Voluntary collections still count toward PRA if identical questions go to 10+ people.
• "Interviews are not surveys." Structured interview guides with identical questions are covered as collections of information.
• "We asked nine people across three months, so we're fine." The threshold applies over a 12‑month period. Rolling outreach can add up.
• "We can start while approval is pending." You may not conduct or sponsor the collection until you have a valid OMB Control Number and display it on the instrument.
• "Burden is just the time to fill out the form." Burden includes time to read instructions, search data, coordinate internally, and transmit responses. Be honest and show your math.
• "Vendors can collect without PRA." If the agency directs, funds, or requires the collection, PRA likely applies even through contractors.

If you are close to the threshold, consider alternatives: qualitative sessions without identical scripts, observational research, or targeted expert consultations that avoid standardized questioning. When in doubt, consult your agency PRA officer and 5 CFR part 1320.