Guidance Meant to Improve Usability Testing on Federal Forms, Websites

There’s no doubt about it. Federal forms and websites can be complicated, meaning some users can struggle to understand them, potentially denying them the ability to access government services.

With that in mind, usability testing is important to find out whether a form is easy to understand and fill out. It also helps agencies make changes and prevent service disruptions. 

However, many agencies have complained there is a gray area about whether testing actually complies with the Paperwork Reduction Act (PRA), which is intended to reduce the paperwork burdens the government imposes on individuals and companies.

To clear up misconceptions, the White House Office of Information and Regulatory Affairs (OIRA) released guidance to help agencies understand how to conduct usability testing in a timely and effective manner consistent with the PRA. The guidance was reportedly in the works for over a decade. 

“Usability testing is a key tool that helps agencies fulfill the PRA’s primary purpose,” wrote OIRA Administrator Richard Revesz in a blog post. “In today’s guidance, OIRA clarifies that usability testing can often be conducted without the need for PRA clearance. It is important for agencies to understand that, in many cases, they are free to engage in usability testing, with any number of participants, without OIRA clearance.”

The guidance emphasizes flexibilities that allow agencies to quickly receive approval to make changes to forms, after problems are identified in usability testing. 

The guidance also encourages agencies to be proactive when it comes to testing. For example, if an agency plans to conduct a test on an item subject to PRA clearance, it “should proactively discuss its plans during that process” as it would allow for “speedier deployment of improvements identified through usability testing.” 

“This will not only reduce paperwork burdens on the public, but also ensure that the public can more easily access the government resources to which they are entitled,” wrote Administrator Revesz. 

Paperwork Burden

Meanwhile the Information Collection Budget of the United States Government reported that paperwork burden hours in fiscal year (FY) 2023 alone totaled over 10 billion, slightly higher than the prior year. 

The Department of the Treasury is far and away the leader in paperwork, with over 6.6 billion hours in FY 2023. The second was the Department of Health and Human Services (HHS) at 1.6 billion hours. 

To put this into context, Forbes notes that the 10 billion hours figure is equivalent to nearly 15,000 human lifetimes.