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NIH Generic OMB Clearance for Online Surveys
FAQ - Background on the OMB Clearance and its Relationship to Usability TestingPlease direct additional questions to Mangala Manivannan.
Why do we need an OMB clearance to evaluate our Web site? OMB regulations prevent us from asking the same questions of more than 9 members of the public (non-Federal employees) unless we have the appropriate clearance to do so. OMB encourages Federal agencies to use automated information technology to "reduce public burden" when gathering response data. If your online survey or Web poll can be accessed by the public, it must bear the OMB clearance number and expiration date signifying that the survey form has been reviewed by OMB and that it does not place "undue burden" on the public. If you think that a pool of respondents recruited from Federal employees could provide you with valuable feedback on your Web site, and you devise an online survey that is functionally unavailable to the general public, then OMB clearance is not required. What kind of statistical analysis can we perform on the survey responses? We are not cleared to employ formal statistical methods in the analysis of survey data. You can use descriptive and summary statistics to evaluate results. How long will it take for us to receive clearance on our survey instrument? It takes 4 to 6 weeks to receive clearance from the time you submit your survey instrument and form to OLIB. We submit your request package via e-mail to NIH/OD/OER/OPERA, they review it, print out three copies, and send it via courier to DHHS. From there, the package is sent to OMB. This process takes about two weeks. Once OMB has your submission in hand, they are obligated to review your request and provide a response within ten days. You will receive an e-mail from OLIB once your survey has been cleared. Does this generic clearance address focus group evaluations or usability task analyses? No, this clearance pertains only to online surveys. However, it is useful to know that OMB clearance for focus groups and usability studies is not required as long as you do not have more than nine participants and do not repeat the identical questions or script with other groups of nine. Can we use this clearance to evaluate user satisfaction with the content of our Web site as well as the navigation? Yes, with caution. NIH's request for a generic clearance was written in broad language to ensure that all aspects of a Web site could be evaluated using this mechanism: The purpose of the proposed research is to ensure that intended audiences find the information provided on the Internet sites easy to access, clear, informative, and useful. Specifically, the research will examine whether the information is presented in an appropriate technological format and whether it meets the needs of users of these Internet sites. The research will also provide a means by which to classify visitors to the NIH Internet sites, to better understand how to serve them. You can evaluate both content and navigation of your Web site under this generic clearance, however, you must be careful in how you word your survey questions. OLIB has created a repository of cleared surveys for your reference, and we are happy to work with you to develop OMB-compliant survey questions that will capture the data you need. Note that this clearance cannot be used for off-line surveys, or Web-based surveys of off-line content. For example, under this clearance you can use an online survey to help evaluate a Flash multimedia product that is presented on your Web site, but you cannot use an online survey to evaluate user satisfaction with the same product distributed on CDROM or DVD. Can we gather new program data under this clearance? No. The generic OMB clearance was designed to help you evaluate your Web site as a communications tool, measuring you constituents' satisfaction with site navigation and content in terms of quality, clarity, and relevance. The clearance is not a license to gather new program data simply because it's done via the Web. For example, if your Web site provides information on the health risks associated with poor eating habits, and you want to determine whether it's conveying the information effectively, you can evaluate this under the generic OMB clearance. You may not, in this example, use the clearance to survey your site visitors about their eating habits and disease conditions in order to come to scientific conclusions about the sample population. A study of this nature would require a separate clearance request. Can we use this clearance to help us design a new Web page, application, product, or service offering? Yes, with caution. The official title of NIH's generic OMB clearance is "Evaluation of User Satisfaction with NIH Internet Sites," which offers an important clue to understanding the kind of questions that you can ask. A survey of this kind measures site visitors' attitudes toward existing products, tools, and services on existing Web pages. You may not ask users how they would feel "if" you made changes, for example, "Would this page be more user-friendly if there were more graphics on it?" or "Would you prefer to view this multimedia presentation in a version compatible with RealPlayer?" This crosses the line into "market research," and the Federal government has strict policies against conducting marketing-related activities. However, you may build a prototype Web offering (for the examples above, a live graphic-rich page or a RealPlayer version) and then ask users to respond to a survey rating their satisfaction with the proof of concept. Certain kinds of planning information can be gathered without building a prototype, using carefully constructed questions in a "Request for Comment." This mechanism does not require OMB Clearance. Contact Mangala Manivannan for more information on this approach. Can we perform off-line surveys, distributed in hard-copy, under this clearance? No. Our approved clearance request states that "survey instruments will be conducted over the Internet" in order to "reduce the burden on the public." If you wish to use print media in conjunction with your online survey, we suggest that you use it to alert potential respondents to the existence of your online survey by offering a URL that points them to the appropriate Web page. How can we ask all the questions we need to ask and still stay within the 5-minute limit on response time?
We recommend that you test your survey functionality with a few users to see how long it takes them to complete it. As long as the average response time is 5 minutes, as stated in the burden disclosure language on your survey, you're within OMB guidelines. For an in-depth look at designing user-friendly Web forms, consult the Usability.gov guidelines at http://usability.gov/pdfs/chapter13.pdf. Can we find out who is visiting our Web site under this clearance? Yes. You may use a reasonable number of demographic questions to get an idea of who is visiting your Web site. There is no actual limit on the number of questions you can ask, but each must be shown to contribute to an evaluation of Web site content or navigation, and not to provide new program data. You will be called upon to justify your use of demographic questions when submitting your survey form for OMB review. No. You may not use cookies to record information about respondents - with or without their knowledge. If your Web site relies on cookies for its function, we ask that you provide a link on your survey form to a privacy statement that informs the public about the use of cookies on your site. You may not use any information resulting from your Web site's cookies to correlate to survey response data. NOTE: You may be aware that in FY2003, an NIH Institute applied to DHHS for permission to employ cookies so that site visitors weren't presented with a pop-up more than once. Please note that while this Institute did receive permission to use the cookie, two subsequent requests to use cookies have not been approved by DHHS. Can we collect e-mail addresses under this clearance? No. You may not specifically ask for respondent e-mail addresses. If, in the process of filling out your survey, a user volunteers an e-mail address and asks you to respond to a request for information, you may store the e-mail address for as long as it takes you to respond. This approach is part of our "assurance of confidentiality," as set forth in our clearance justification: Demographic information will be used for analytical purposes only. Names will not be recorded on the questionnaires, nor will personal identifying data be maintained in the database. While respondents may be given the option of providing their e-mail addresses for the purpose of receiving a response to a particular inquiry, these addresses will not be used for purposes of linking particular respondents to particular survey responses. The addresses will not be retained after the reply is sent to the respondent. Can we collect social security numbers and other sensitive information under this clearance? No. We are not allowed to ask for "sensitive information" under this clearance. Sensitive information includes respondents' social security numbers, household income, and other information that is usually considered "personal." Can we ask respondents to report their race and ethnicity under this clearance? Yes, with justification. You can ask for respondents' race and ethnicity if you need it in order to understand response data. You will be asked to justify the need for this data, along with any other demographic data you ask for, on the submission form. You must structure your question in the following way: How many responses can I reasonably expect from an online survey? The number of responses you'll receive depends on how you publicize the survey. The Submission form offers you multiple notification methods to choose from. Choose as many as you think will offer you the number of responses you need.
As part of this clearance activity, the Online Information Branch is required to track the "total burden placed on respondents." The target number of respondents you supply is used to calculate this burden figure. We add the burden for your survey to the burdens of all other NIH online surveys under the clearance, and report the total to OMB upon request. It is important that you track the number of responses your survey receives once it is launched from your Web site, so that you do not exceed your target number. Incomplete responses count. If you decide to remove your survey before you reach your target, please send e-mail to Mangala Manivannan with the actual number of responses recorded. Can I offer respondents a payment or gift as an incentive to complete the survey? No. We do not have clearance to offer any type of remuneration to respondents. This page was last reviewed on
July 10, 2007
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