NWS Paperwork Reduction Act Overview PowerPoint Presentation

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The National Weather Service (NWS) is increasing its use of social science research methods such as surveys and focus groups across its workforce, with Core Partners and others within their County Warning Areas (CWA). Some of the those exercises are external and intended to gain more insight into NWS partners and stakeholder needs and better understand the way Core Partners use NWS products, information and services. Others are internal and intended to gain insight across the NWS workforce. Whether they are internal or external, there is a process for developing and implementing these types of inquiries.

There is a strong need to better coordinate across NWS given the potential for duplication, overlap, and fatigue. While the NWS Social Science Team is excited to see more applied social science research into the great work conducted by NWS, we want to ensure our workforce complies with OMB regulations and that our Core Partners are not overburdened by well-intended NWS efforts.

The Paperwork Reduction Act (PRA) is he law governing how federal agencies collect information from the American public.

It is overseen by the Office of Information and Regulatory Affairs (OIRA), under the Office of Management and Budget (OMB), which approves all information collection requests (ICR)

Why does PRA exist?

• Minimize unnecessary or duplicative requests for information: We want to be good stewards of the public’s time, and not overwhelm them with unnecessary or duplicative requests for information. The PRA clearance process involves calculating burden hours. It’s important to understand how long it will take members of the public to complete your request.
• Making decisions based on high-quality data: We want to make sure the data we collect are accurate, helpful, and a good fit for the proposed use. Part of the PRA process involves the Office of Information and Regulatory Affairs (OIRA) reviewing details about how the information you plan to collect fits with your goals.
• Protecting private information: To respect privacy, we avoid asking for personal information that is not relevant or necessary. OIRA asks for extra details if you’re collecting personally identifying information (PII).

When does PRA apply?

A Federal Agency "sponsors" an Information Collection Request that:

• Collects information from ten (10) or more people in a 12-month period,
• Is voluntary or mandatory,
• Is conducted under cooperative agreements or Federal contracts,
• Is conducted under grants if the collection is conducted at the request of the agency or part of terms and conditions of the grant,
• Collects info from Federal employees outside their duties

Sponsorship means that the NWS cannot perform any research action e.g. sending a survey directly to partners or using NWS social media accounts to share it

When does PRA not apply?

You do not need PRA approval every time you collect information from the public (*). Some of the more common exemptions to PRA include:

• Requesting information from 9 or fewer people in a 12-month period [Note, this can not be avoided by having 5 focus groups of 9 people. If you are asking the same question each time and it is over 9 people that will trigger the PRA]
• Open-ended requests for comments or feedback [Note, this means you can ask something like “please send comments on this proposal to this email.”],
• Only collecting information from federal employees as part of their work duties,
• Discussions and questions at a public hearing, workshop, meeting, or online equivalent [NOTE, poll questions within meetings and workshops (even meeting satisfaction/feedback style polls) are subject to PRA],
• Some information collections are generally not subject to the PRA, including: certain federal investigations and civil actions, antitrust actions, and intelligence activities.

What happens if I don’t comply with PRA?

The PRA is a law, and compliance is mandatory. Collecting information without clearance can open your work, including decisions made based on the data, to legal challenge. If uncleared collections or changes are discovered, OIRA may insist that the collections across all of NOAA are stopped. Further, OMB reports these violations to Congress and the President in the Information Collection Budget.

NOAA has two sets (quantitative and qualitative) of pre-approved questions under generic clearance. Questions that match the basic objectives of the pre-approved questions could fall under this generic clearance and be eligible for an accelerated approval through OMB. [NOTE - When the generic clearance expires, all approved packages under it also expire. You must renew individual collections of information when the generic clearance collection renews.]

It is important to note that even if someone wants to use the generic clearance questions word for word, collection requests must still go through the OMB approval process.

1. Sponsor should contact NWS PRA Liaison
2. In consultation with the NWS PRA Liaison, the Sponsor drafts email to the following contacts and prepares answers to the questions:
   1. Does NWS anticipate any future need to obtain similar data on weather events, such that scope of the collection could be expanded to include those events as well?
   2. Is it expected that this collection will be renewed after the initial 3-year period? 
   3. What type of questions will be asked?  Please provide a copy of questions for all proposed survey instruments, even if it is in draft form.  
   4. Could these surveys go under either the DOC or NOAA generic ICR?
   5. How will the collected information benefit NWS?
   6. If statistical analysis will be done on the results, has the sponsor consulted with the Chief Economist's Office as to methodology, sampling, etc.?
3. The Sponsor sends the email to the following contacts:
   1. NOAA’s Office of Performance, Risk and Social Science (PRSSO):  Contact Tadesse Wodajo  - If statistical analysis will be done on the results sponsor should consult with the Chief Economist's Office as to methodology, sampling, etc.
   2. NOAA’s PRA Officer (Adrienne Thomas)
   3. NWS PRA Liaison (Dr. Vankita Brown)

As noted above, the OMB OIRA plays a key role in enforcing the requirements of the PRA. The Standard ICR clearance process can take as long as six (6) to nine (9) months and includes the following steps:

1. Consultation with OMB to discuss the existing information gap and the need for data collection to obtain its consent to initiate the ICR process [NOTE, this step applies to new collections that have not been previously approved by OMB, but OMB may want to hold a consultation if a new survey is collecting economic or socioeconomic data, even if the survey will be added to an existing OMB control number.],
2. Publishing a 60-day notice in the Federal Register to allow the public to comment on the need, burden, and usefulness of the information that will be collected, [NOTE:  Routing for publication should go to NWS PRA Liaison],
3. Development of the Information Collection Request (ICR).  Review of public comments and make any necessary changes to the ICR,
4. Submission of the ICR to the NOAA Performance, Risk and Social Science Office (PRSSO) and specifically to the NOAA Chief Economist team for review.  [NOTE, This is not part of OMB’s’ standard process, but required by NOAA for requests that include statistical methods (*)] 
5. Publish a 30-day notice in the Federal Register to notify the public that the OMB review is underway, [NOTE:  Routing for publication should go to NWS PRA Liaison],
6. Submission of the ICR to OMB for review,
7. OMB reviews the ICR and either approves or disapproves the collection, [NOTE:  OMB engages with NWS to resolve questions and comments and then issues a decision to either approve or disapprove the ICR].

As noted above, the process of developing an ICR and receiving approval from OMB to proceed with the information can span several months. The process may take longer, depending on the amount of time required by the applicant to resolve issues identified by OMB, but OMB has developed a simplified method for lots of requests that are similar through the use of bundled ICRs, generic ICRs, and developed hybrid-generic ICRs. 

Decision Tree for OMB Approval

The first step is to determine if OMB approval will be required. Below is a decision tree to help in that process. Please contact the NWS PRA Liaison for assistance.

Internal (NWS & NOAA) Surveys

Internal to NOAA surveys are those that will be distributed internally only to federal employees. Example: An AFS Service Program would like to gather information from WFOs regarding their local criteria for a certain hazard.

External Surveys

Determining Whether NWS “Conducts” or “Sponsors” an Information Collection:  

Any 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.

Determining Whether Studies Involving Third Party or Investigator-Initiated Grants are Subject to PRA Review:  

Collections of information conducted through investigator-initiated grants (e.g., in response to a Request for Applications (RFA)) are generally not subject to OMB review under the PRA. However, information collections by a Federal grant recipient are subject to PRA review if

1. the grant recipient is conducting the collection at the specific request of the agency, or
2. the terms and conditions of the grant require specific approval by the agency for the collection or collection procedures.

If either of these conditions are met, the sponsoring agency needs to seek and obtain OMB approval, and the grantee needs to display the OMB control number on the collection instrument.

• Example:  A WFO is asked to send a survey to partners/customers/stakeholders using WFO email listserv or social media.  [NOTE:  If the WFO sends out the survey, it is seen as “sponsoring” the survey and triggers the OMB review process.]
• Example: A WFO would like to survey their local emergency managers to determine their preferred method of communication.
• Example: An AFS Service Program wants to send out a public survey to gather information on how people interpret probabilistic information. 
• Example: A WFO would like to conduct focus groups with a new set of partners to better understand their needs.
• Example: A WFO is hosting a partner workshop and would like to use polls to collect feedback and information from participants.

NOAA-Funded Social, Behavioral, and Economic Science (SBES) Research

• Must go through the OMB clearance process.  
• NOTE:  NOAA-Funded SBES directed to NWS employees, not including contractors, must relate to their scope of work

SBES Research Conducted with Cooperative Institutes

• While Cooperative Institutes (CIs) follow their own university institutional review board (IRB) policies, government partnerships with CIs may imply NWS is a sponsor (e.g., asking NWS offices to send out a CI survey to Core Partners using a NOAA email, survey link on NOAA website, etc.) and therefore require the OMB clearance process.
• The NWS sponsor and the CI must reach out to the NWS PRA Liaison through the NWS.PRA@noaa.gov email.

• NOAA PRA Officer: Adrienne Thomas
• NWS PRA Liaison: Valerie Were

The NWS PRA Liaison is the focal point for all NWS PRA-related questions and assists in the planning and coordination of the Information Collection Request (ICR) review timeline. The NWS PRA Liaison coordinates with the NOAA PRA Officer and with NWS sponsors on an ICR to obtain OMB approval. This coordinating role fills a critical gap between NWS and the NOAA PRA Officer and ensures compliance with the PRA rules governing information collection from the public.

To increase the efficiency and transparency of the ICR process, the NWS PRA Liaison will maintain an organized repository of OMB approved questions (coordinated alongside the NOAA PRA Officer). The repository shall include the list of approved NWS questions, their date of expiration, the Federal Information Security Management Act (FISMA) system where housed, the Federal Register Notice (FRN) information, and the NWS (or NOAA) sponsor.

For all questions relating to OMB PRA please email: NWS.PRA@noaa.gov.

1. Sponsors should email NWS PRA Liaison and fill out the NWS PRA Request Form
2. In consultation with the NWS PRA Liaison, the Sponsor drafts email to the following contacts and prepares answers to the questions:
   1. NOAA’s Office of Performance, Risk and Social Science (PRSSO): Email Tadesse Wodajo - If statistical analysis will be done on the results sponsor should consult with the Chief Economist's Office as to methodology, sampling, etc.
   2. Email NOAA’s PRA Officer (Adrienne Thomas)
   3. Questions to be addressed in email:  
      1. Does NWS anticipate any future need to obtain similar data on weather events, such that scope of the collection could be expanded to include those events as well?
      2. Is it expected that this collection will be renewed after the initial 3-year period? 
      3. What type of questions will be asked?  Please provide a copy of questions for all proposed survey instruments, even if it is in draft form.  
      4. Could these surveys go under either the DOC or NOAA generic IC?
      5. How will the collected information benefit NWS?
      6. If statistical analysis will be done on the results, has the sponsor consulted with the Chief Economist's Office as to methodology, sampling, etc.?
3. NOAA PRA Officer will hold a meeting with the Sponsor
   1. Following the meeting with the Sponsor, the NOAA PRA Officer will reach out to DOC/OMB to determine if the collection is able to move forward (Timeframe:  1-2 week response).
4. Once the new collection is approved to move forward by DOC/OMB, then the Sponsor (in consultation with the NWS PRA Liaison) will prepare the 60-day FRN to allow the public to comment on the need, burden, and usefulness of the information that will be collected,
5. Sponsor drafts and submits the following documents to the PRSSO (only when a Supporting Statement B is required):
   1. Supporting Statement A,
   2. Supporting Statement B.
   3. Finalized Survey Instrument
6. PRSSO works with Sponsor on any required edits to their OMB Package,
7. Once approved by PRSSO OR if PRSSO review is not required, Sponsor submits the following finalized documents to the NWS PRA Liaison:
   1. 30-FRN
   2. Supporting Statement A,
   3. Supporting Statement B.
   4. Finalized Survey Instrument
8. NWS PRA Liaison submits documents into the RISC/OIRA Consolidated Information System (ROCIS)  (i.e., the Regulatory Information Service Center (RISC) and Office of Information and Regulatory Affairs (OIRA)
9. Sponsor awaits OMB approval
    

1. Notify the NWS PRA Liaison, NOAA PRA Officer, and PRSSO of intent to renew,
2. The Sponsor (in consultation with the NWS PRA Liaison) will prepare the 60-day FRN to allow the public to comment on the need, burden, and usefulness of the information that will be collected,
3. Sponsor drafts and submits the following documents to the PRSSO (only when a Supporting Statement B is required):
   1. Supporting Statement A,
   2. Supporting Statement B.
   3. Finalized Survey Instrument
4. PRSSO works with Sponsor on any required edits to their OMB Package,
5. Once approved by PRSSO OR if PRSSO review is not required, Sponsor submits the following finalized documents to the NWS PRA Liaison:
   1. 30-FRN
   2. Supporting Statement A,
   3. Supporting Statement B.
   4. Finalized Survey Instrument
6. NWS PRA Liaison submits documents into the RISC/OIRA Consolidated Information System (ROCIS)  (i.e., the Regulatory Information Service Center (RISC) and Office of Information and Regulatory Affairs (OIRA)
7. Sponsor awaits OMB approval
    

• Supporting Statement PART A [docx] - (Questions and guidance for Responses)
• Supporting Statement PART B [docx] - (Questions and guidance for Responses)
• 30-day FRN Template [docx] - See highlighted sections
• 60-day FRN Template [docx] - See highlighted sections
• Example of a NWS submitted FRN [PDF] - See highlighted sections