Do Federal agencies need OMB clearance to conduct usability testing?

Answer

You do not need OMB clearance for tests with nine or fewer users.

The NIH Generic OMB Clearance for Online Surveys states:

Does this generic clearance address focus group evaluations or usability task analyses? No, this clearance pertains only to online surveys. However, it is useful to know that OMB clearance for focus groups and usability studies is not required as long as you do not have more than nine participants and do not repeat the identical questions or script with other groups of nine.