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Posted by on Aug 10, 2012

OMB Tells Agencies to “Test” New Forms

Beginning in August, federal agencies will have to “test” new or revised forms to ensure that the forms and instructions are clear and easy for users to understand.

This requirement was issued by OMB’s Office of Information and Regulatory Affairs (OIRA) through an August 9 memo to the heads of all federal agencies. In the text of that memo, OIRA Administrator Cass Sunstein wrote:

“With respect to Federal forms, simplicity and ease of comprehension are exceedingly important. In recent years, agencies have made important efforts to simplify and streamline forms and, where appropriate, to eliminate them. Despite these efforts, it is a continuing challenge for agencies to minimize complexity and confusion. The purpose of this memorandum is to help agencies to meet that challenge by testing whether forms are sufficiently clear and comprehensible.”

Agencies will test forms either before issuing them for public comment or during the OIRA review. This testing should: ensure that the forms are not unnecessarily complex, burdensome, or confusing; help agencies obtain reliable information about the likely burdens on members of the public; and identify ways to reduce burdens and to increase ease of comprehension.

Advance testing might include focus groups, in-person observations of users’ perceptions of the forms and questions (cognitive testing), web-based experiments, and randomized controlled experiments.

A copy of the memo, which includes links to several guidance documents and resources for federal agencies, is available at

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