Guidance for Completing an Information Collection Request (ICR)
Information Collection Request OverviewIn response to public complaints concerning the burden of federal paperwork, the requires the Office of Management and Budget (OMB) to clear any planned collection of information from the public.
To comply with the PRA and its implementing regulations, federal agencies must complete an Information Collection Request (ICR) which consists of a set of documents that describe what information is needed, why it is needed, how it will be collected, and how much collecting the information will cost the respondents and the government. The sponsor OPDIV for the collection of information from the public is responsible for completing the ICR.
The total ICR process takes approximately 6-9 months from beginning to end. More details are available in the Information Collection Request (ICR) Time Line.
Steps to Complete the ICR Process
I. Do you need to complete an ICR for PRA Clearance?
An ICR must be completed and OMB approval must be granted for any situation where 10 or more respondents are involved and the questions are standardized in nature. 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 your OPDIV Reports Clearance Officer (RCO).
II. If your collection needs clearance, first publish a 60-Day Federal Register Notice?
Working with your OPDIV PRA office, the first step in the process is to submit a 60-Day Federal Register Notice informing the public of your intent to ask for clearance for the collection of information and soliciting comments for a 60 day period. Consult with your OPDIV RCO for an example specific for your OPDIV.
At this time a “draft” Information Collection Request (ICR) must also be developed which includes the Supporting Statement and all supporting documents. This is important because documents should be ready for review by the public if requested during the 60-day public comment period.
III. Developing a Supporting Statement and Attachments
A Supporting Statement includes narrative information explaining the purpose, scope, and benefit(s) of the collection. Items generally included in the supporting statement include:
- Cite the authorizing legislation (public law, executive order, etc.) or the pertinent regulation if the collection is being carried out pursuant to a proposed rulemaking.
- The Supporting Statement must include an explicit reference to the operating unit’s information quality guidelines, as required by the Data Quality Act.
- Cite the initial 60-Day Federal Register notice (Step 2) notifying the public of the proposed information collection and soliciting comment.
- Attachments should include the data collection instrument form, questionnaire, survey, interview guide, telephone interview script or other instruments that will be used for the collection. Any instructions for completing information collection. Introductory and follow-up letters to respondents. If Institutional Review Board (IRB) approval is needed, include the IRB letter of approval for research involving human subjects. Include additional backup information necessary to explain the procedures describes in Part B of the supporting statement.
The Supporting Statement is divided into two parts; Part A (Justification) and Part B (Statistical Methodology). Part A is mandatory for all supporting statements; Part B is required for all supporting statements that involve statistical methods.
IV. Package Review by OPDIV and HHS PRA Offices
The draft ICR must be reviewed and approved by the OPDIV PRA office. Next the OPDIV submits the ICR to the HHS PRA Office for review. A 30-Day Federal Register Notice (FRN) is published. This second opportunity for public comment notifies the public that the clearance request has been submitted to OMB and they have an opportunity to comment on the final version of the ICR and their comments must go to OMB. Publication of the 30-Day FRNshould occur prior to the ICR submission to HHS.
V. OPDIV Submission to HHS Reports Clearance OfficerOnce the package has been review by the OPDIV PRA office and the 30-Day FRN has published, the OPDIV then submits the ICR and all related documentation to HHS viaThe HHS RCO reviews and finalizes the request for submission to OMB. At this point an ICR can be retracted back to the OPDIV if all documents cannot be certified by the HHS RCO.
VI. HHS Review and Submission to OMB
Once the ICR is finalized and approved by the HHS RCO, the ICR is submitted from HHS through ICRAS to OMB’s ROCIS system. The OPDIV PRA Office will receive an e-mail confirming receipt by OMB and an e-mail will be sent to the program staff as well. Once OMB has received the ICR, the 60-Day OMB review period begins.
VII. OMB and OPDIV Pass–Back Period
During the 60-Day OMB review period, discussions, or negotiations concerning the ICR may occur between the program OPDIV and OMB by either conference call or e-mail. Comments received from the public during this review period can also be discussed at this time. The HHS RCO may be involved if necessary during this period.
VIII. OMB Action
At the conclusion of the 60-Day OMB review, OMB issues a Notice of Action (NOA). The OMB Notice of Action contains one of three responses: Approval, Disapproval, with a process for appeal, or Withdrawal. Additionally terms of clearance can be attached to the ICR.