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What Do You Think about OMB Soc Media and PRA Guidance?

What's Your Take on the new OMB Social Media Guidance re: PRA?

Tags: collaboration, collaboration government, gov20, government 2.0, open government, opengov

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Lots excluded from PRA including
-Suggestion boxes.
-Interactive meeting tools.
-Basic registration and account profiles excluded. Just can't ask age, sex, race, employment, citizenship
-Contests excluded

If you have ever gone through PRA clearance (I have), you know how painful of an experience it can be (and costly as often it is contractors writing up allt he docs). So this is a step in the right direction

This may be old news to some but it is on my front burner right now.  Has anything changed that would allow us to use polling or surveys with a group of grantees inside a closed wiki?


Hi Steve,

I'm afraid I disagree with you - this is fairly far from awesome. I'd actually label it fairly disappointing. Not only are both documents written to be as vague as possible (the PRA primer, for instance, spends most of its text simply repeating statute), this doesn't really get us where we need to be. Basic web usability questionnaires (or facebook surveys), or really, any structured interaction are still subject to the PRA because they ask the same set of questions to more than 10 users, many uses of wikis are not covered (although this is ambiguous enough guidance that most could probably argue their way out of it), but at least open-ended blog-based questions, user registrations and contest/idea generation approaches are free of PRA concerns.

More disappointing from my standpoint, it keeps in place the notion that citizen interaction with the government is essentially a "burden" and still codifies the position that significant interaction with the public should be minimized (this is clearly contrary to open government). Over time, this will continue to reduce innovation in participating with the citizens, as folks will still be caught up with the question of, "But if we do that, will we have to go through a laborious 6 month approval process?" It also still assumes that OMB is actually able to keep up with the massive shift in the use of information online. Their existing process is still in place. If there was ever a process in govt in need of re-engineering it’s the PRA process.

I do agree its a step in the right direction, but from my standpoint, this was "not the change I was looking for".
Noel -- Isn't there really SO much they can change given that the Paperwork Reduction Act still is the law.

To be honest, I just didn't have time yesterday to read through the guidance -- but I'm also going to have to go back and re-read the law itself

But it seems OMB can't just say, 'Oh that PRA thing -- just ignore it.' Congress has to eventually do that.

I understand that there is a lot o' frustration around PRA, but is this really a OMB issues, or should PRA just be thrown out by Congress in lieu of new and updated principles?

Again, I'll go back and read the law today, but I remember the discussion around PRA when it was passed -- and that was the discussion... that the paperwork that people had to fill out WAS a burden and we have to stop it. (Remember this law was enacted in 1980. )

Even the idea of a PAPERWORK Reduction Act seems outdated to me... and, in some ways, isn't OMB just trying to put lipstick on a pig? (or on the PRA?)
Hi Chris, just for context, I spent more a couple of months studying the PRA (based on need, and more specifically, looking for loopholes to get around it) and came out with a number of recommendations to OMB that I submitted in a number of ways to them. You can see my comments here if interested:

But in short, no, they cannot ignore the PRA. But they can change the process by which its implemented. This is what I was hoping for. When we get caught up by truly silly propositions - such as the idea that making a common usability survey on a website takes six months and lots of paperwork to implement, there is clearly something fundamentally wrong. Partially, the problem certainly exists in statute, but more specifically it exists in OMB's process for implementing the language.

If there was one line I'd change in Statute, it would be the reference to voluntary information collections, which is at Title 44, Chapter 35, Section 3506 (c)(1)(B)(iii)(IV), which in talking about the person receiving the collection of information states that, “whether responses to the collection of information are voluntary, required to obtain a benefit, or mandatory…”. If this were removed, most of the easier problems would go away. But this definitely requires an act of Congress.
Horrible. Truly horrible. You still can't have a simple web poll on your website. Any web poll would trigger an OMB request. Six month (or more) process, published in the Federal Register. Imagine asking, "Do you like our homepage redesign? Y/N" and having to get OMB approval for this?

Total White House fail. This wasn't the change I was expecting...
Interesting. Others take?

I like the feedback. So basically you see is they are taking an old framework and making it slightly better. Vs starting from scratch with fundamental shift evolving in terms of engagement.

I wonder if that is due to compromises in the evolution of the document.

What's the original reason for need for public notice before reaching out to citizen?

Just to be clear, there is a very wide chasm between making something slightly better and starting from scratch. The big objection from the Web Content Managers, for instance, was that we couldn't do a simple "What did you come here to find?" and "Did you find it?" question on the website without going through an insanely ridiculous process for a completely basic question. Just on this point, they could have come up with a number of ways to address this, such as saying "all website usability forms, as long as they fit within the following parameters, are automatically waived from the PRA process."

Just following that one point further, we're now are in a situation were Agencies will have a huge incentive to essentially ask unstructured questions in the hopes of getting the structured answers they need. The idea that because something is posed as a survey instead of an open ended question that one becomes a "Information collection" while the other one doesn't is just silly. OMB even tacitly acknowledges this point in the guidance by in essence saying it would be a bad idea for Agencies to make decisions based on unstructured data - all the while knowing full well that is exactly what is going to happen.
Steve, your question at the end gets it a little backward, speaking as a former regulator.

The idea isn't to stop us from reaching out for input. It's to stop gov't from putting overly burdensome reporting requirements on regulated businesses.

Imagine you're a small business owner and 10 federal agencies require you to fill out 200-page forms every year in order to operate. You wouldn't be happy, right? So OMB is charged with coordinating reporting requirements.

The problem is that this has been so minutely implemented that it covers silly stuff like posting a survey in a blog asking about readers' favorite ways to spend time outdoors.

As to voluntary submissions being "obviously" irrelevant, well, what if you gave special treatment to people who voluntarily did it?

A lot of what is now overdone and overinterpreted started out as good gov't efforts. And more of the problem comes from the review process. If it took a matter of minutes to get approved to ask that survey about outdoor recreation, and we could build it right into the survey posting process (press this button and wait 5 minutes), our collective complaints would be much quieter.
Nancy Scola's take on it at techPresident: Use Social Media Freely, White House Tells Agencies
That's kind of the idea I got from reading the document. Then again, I'm not familiar with all the intricacies of "memo speak". Happy to hear more about any limitations or obstacles that may still remain despite this memo.
The white paper from several of us on the Federal Web Managers Council about barriers and solutions still has quite a bit of relevant thinking, including on today's guidance.


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