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Guidance on the Paperwork Reduction Act “Collection of Information” or “Information Collection” for USGS Authors

By Office of Science Quality and Integrity

January 2023

The Paperwork Reduction Act (PRA) of 1995 is a law that provides the framework for collecting, using, and disseminating information by Federal Government employees. Federal agencies must comply with the PRA by seeking and obtaining approval from the Office of Management and Budget (OMB) prior to collecting or sponsoring the collection of information from 10 or more members of the public within a 12-month period by means of identical questions, whether the collection is mandatory or voluntary. The intent of the PRA is to be a good steward of the public’s time, not to inflict unnecessary burden on the public or make duplicative requests for information, and to maximize the potential use of the information collected. 

The first point of contact for all questions related to information collection from the public is the U.S. Geological Survey (USGS) Information Collection Clearance Officer (ICCO) at gs-info_collections@usgs.gov. The USGS ICCO coordinates the review and submission of all collections needing approval within the USGS and coordinates approvals with the ICCO in the Department of the Interior. Refer to SM 431.10 - Information Collection Requirements for additional guidance, including definitions of terms, responsibilities, and general procedures. 

This guidance is provided for USGS authors and approving officials of scientific information products as described in Survey Manual (SM) policy chapter SM 502.1 to ensure compliance with the PRA. Basic frequently asked questions (FAQs) and answers for the collection of information as it relates to the PRA and science publications are below: 

  1. What types of information collections may or may not require PRA clearance?

PRA clearance is required when information is collected using a standard set of questions (e.g., a survey) from 10 or more non-Federal members of the public by a Federal agency, on behalf of a Federal agency, by contractors hired by a Federal agency, or is initiated, developed, funded, or requested by a Federal agency. The USGS cannot request a non-Federal entity, such as a university, to conduct a survey on behalf of the USGS under the assumption that doing so would not require PRA clearance and OMB approval. Compliance with the PRA is required regardless of how the information is collected if done on behalf of a Federal agency. Examples of information collections can be found on the internal USGS Information Collection under the Paperwork Reduction Act web page, the Digital.gov Do I need clearance? web page and by contacting the USGS ICCO.

PRA clearance may not be required when information is collected from the public by non-Federal persons or entities for use by those entities as long as the information collection was not requested, approved, developed, or funded by any Federal person or entity.

PRA clearance may or may not be required when information is collected from the public through an interview, it depends on how the interview is formatted. A conversation with a respondent on one or multiple topic(s) using open-ended questions (qualitative interview) does not require PRA clearance. An interview containing ‘fixed’ questions that constrain the respondent to answer in a certain way (directed interview) may require clearance under the PRA. Contact the USGS ICCO for additional guidance.

  1. What PRA obligations do I have as a USGS author on a manuscript for which information will be collected from the public?



The USGS ICCO should be contacted before you or your non-USGS co-authors collect information or sponsor an information collection from the public. If your collection requires PRA clearance, it must be approved by the OMB before the information can be collected. Planning months in advance is important because OMB approval can take six to nine months or longer. Examples and more information can be found on the internal USGS Information Collection under the Paperwork Reduction Act web page, the Digital.gov Do I need clearance? web page and by contacting the USGS ICCO.

  1. What disclaimer statements related to PRA should be placed in the information product?

A disclaimer statement (most commonly placed in the Acknowledgments section) should appear in the information product whether the information collection activities required PRA clearance and OMB approval or not.

  • For publications that include information collections (e.g., a survey) that required and received PRA clearance and OMB approval, the following disclaimer statement should appear in the information product:
    • “Consistent with requirements of the Federal Paperwork Reduction Act, the information-collection activities for the survey described in this study were approved by the Office of Management and Budget [year, OMB control number].”
  • For publications that include information collections (e.g., a survey) not conducted by or on behalf of the USGS and do not require PRA clearance or OMB approval, the following disclaimer statement should appear in the information product:
    • “The survey described in this information product was organized and implemented by [name of responsible party] and was not conducted on behalf of the U.S. Geological Survey.”
  1. May I as a USGS author use information collected from the public by another Federal agency?

All information collected from the public by any Federal person or entity that requires PRA clearance must have an OMB control number. If the OMB control number is not provided, either on the information product or in response to a request from USGS to the other Federal agency, USGS authors may not use that collection of information.