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Framework

When federal research needs OMB approval: the four tests

The four phrases in 5 CFR 1320.3(c) that decide whether a study is a collection of information

Framework of the four Paperwork Reduction Act tests: by or for an agency, identical questions, ten or more persons, and mandatory, voluntary or for a benefit.
Ask the same question of ten people for an agency and you need OMB clearance first Source: Paperwork Reduction Act regulation, 5 CFR 1320.3(c)
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A framework of the four phrases in the Paperwork Reduction Act regulation that decide whether government customer research is a collection of information needing OMB approval. It covers who sponsors the work, whether questions are identical, the ten-person threshold over 12 months, and why voluntary surveys are still covered. Use it before writing a questionnaire for a federal agency. Koji studies keep a fixed, reviewable core of structured questions that a clearance package can describe.

Where this appears

What's in this framework

  1. By or for an agency: The duty follows the sponsor. A contractor or research platform running an agency's study is inside the regime.
  2. Identical questions: The trigger is standardization. A discussion guide that asks every participant the same thing is what gets regulated.
  3. Ten or more persons: People addressed within any 12 months, not responses. Inviting 100 and hearing from 9 still counts.
  4. Mandatory, voluntary or for a benefit: All three are covered. Making a survey voluntary does not exempt it.

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