https://reason.com/2025/04/16/the-paperwork-reduction-act-created-a-paperwork-explosion/
You might think that sharing stories about the positive, burden-reducing effects of user research would result in OIRA encouraging the practice. You might also think that demonstrating what's possible if burden reduction is really your goal—holistically considering and aligning all information collections, using wizards, thoughtfully reusing known information, ensuring systemwide address updates, and even better accounting for people's real names—would change how the PRA is implemented.
But it hasn't. A quiet attempt was made in 2014 to exempt "direct observation" from PRA authority, which changed no one's behavior. Ten years later, OIRA issued a memo, insisting it had been a fan of user research all along. But this memo is meaningless progress; you can see that agencies are still submitting user research plans for OIRA approval as of April 2025. This marks over a decade of internal battles for only one of the many improvements the PRA implementation desperately needs, with virtually no progress—and a great deal of harm—to show for it.
Changes from the inside didn't work. Chipping away at the margin didn't work. The PRA has to go.
Ultimately, Congress should repeal the PRA entirely. In the meantime, the current legislation includes pilot and delegated authority that would allow the OIRA administrator to declare that as long as agencies self-attest to testing their information collections with their end users, and streamlining information collection when possible—both of which the PRA's current implementation makes virtually impossible—then they are exempt from OIRA review.
There is tremendous danger right now that half the country views any activity in the current administration as something to fight against. This should not be one of them. The only proponent of the PRA is inertia.