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1 [1] (January 23, 2025)

handle is hein.crs/govesez0001 and id is 1 raw text is: Congre Won I Fesedrch Service I ~ or ning legi I live I ta ~ 'e 914 January 23, 2025 Customer Experience Research, Usability Testing, and the Paperwork Reduction Act Agencies may conduct customer research to help understand how people experience the delivery of federal services and to improve such delivery and experiences. The Paperwork Reduction Act (PRA, codified at 44 U.S.C. §§3501-3521) generally imposes procedural and approval requirements on agencies' efforts to collect information from the public, establishing procedures intended to minimize the burden associated with federal information collections, including from agency research. In 2024, the Government Accountability Office (GAO) reported that some viewed the PRA as a barrier to improving customer experience (sometimes abbreviated as CX), in part because it creates a months-long process for agencies to undertake before soliciting information from federal customers through surveys, questionnaires, feedback forms, and focus groups, among other methods. Issued in December 2021, Executive Order 14058, Transforming Federal Customer Experience to Rebuild Trust in Government, discussed the need for agencies to understand how people experience the delivery of federal government services, defining customer experience as the public's perceptions of and overall satisfaction with interactions with an agency, product, or service. Among its directives, the executive order instructed the Office of Management and Budget (OMB) to update and clarify its existing guidance to agencies on administrative flexibilities under the PRA to facilitate CX research. On November 21, 2024, the Office of Information and Regulatory Affairs (OIRA), the OMB component that reviews and approves proposed information collections (44 U.S.C. §3504(c)(1)), issued a memorandum to agencies to clarify when a category of CX research known as usability testing is subject to the PRA's information collection requirements (44 U.S.C. §3507). This In Focus puts into context OIRA's memorandum, discusses the PRA's information collection requirements, and concludes with some considerations for Congress. Usab ty Testin In its memorandum, OIRA defines usability testing as a type of user research that consists of asking users to navigate or perform tasks with a paper or digital form or a federal website while observing users in person or remotely, and engaging with them by asking semi- structured or open-ended questions. For example, users might be asked where on a website they would click to find or do something or be asked what was frustrating or confusing when trying to execute a web-based task. According to GAO, usability testing is often used in software development that uses agile practices, where an iterative and incremental approach emphasizes early and continuous software delivery, fast feedback cycles, rhythmic delivery cadence, the use of collaborative teams, and measuring progress in terms of working software. Agile development is often compared to waterfall methods, where software requirements are set at the beginning; software is designed, developed, and tested in linear and sequential phases; and work from a previous phase is generally not revisited or reconsidered, which may create uncertainty until testing. In this context of software development, usability is described as the effectiveness, efficiency, and overall satisfaction of a product or service to its end user. Legis at V Context Congress has taken steps to improve the usability of public- facing agency content, particularly in efforts to modernize the federal government's technology and internet use. The 21st Century Integrated Digital Experience Act (P.L. 115- 336) directed agencies to develop and design public-facing websites, web-based forms and applications, and digital services around users' needs and to continually test such products to ensure these needs are being addressed. In its implementation guidance (M-23-22), OMB advised agencies to employ usability testing and noted that well- designed digital forms can improve the accuracy and usability of information collected from the public, reduce business inefficiencies, enhance security, and reduce the costs and labor associated with using paper-based forms. For instance, research conducted by the General Services Administration (GSA) Office of Evaluation Sciences (OES) found that changing the placement of instructions on a form affected the likelihood that the form would be completed and submitted. Federa Information CoVecdons Generally, if an agency wants to collect the same information from 10 or more members of the public (e.g., asking 10 people the same question), including when that information might be provided voluntarily, then the collection is likely subject to the PRA. This means that the agency has to follow certain steps and obtain OIRA's approval before collecting the information. These steps- referred to as the clearance process-include internal agency review processes and publication of a Federal Register notice with a 60-day public comment period. The agency must then submit an information collection request (ICR) to OIRA, which is accompanied by a second notice in the Federal Register with a 30-day comment period. OIRA then has 60 days to approve or disapprove the agency's request. Thus, an agency is to spend no less than 90 days going through the clearance process in addition to the time spent internally.

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