EXPERT ENGAGEMENT GUIDE: Writing Effective Public Comments on Information Collection Requests (ICRs

Purpose of This Resource

Information Collection Requests (ICRs) are the legal mechanism through which federal agencies impose data collection on the public. Every federal form, survey, application, and reporting requirement that collects information from ten or more persons passes through the Paperwork Reduction Act (PRA, 44 U.S.C. §§ 3501–3521) and is reviewed and approved by the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget. ICRs receive two public comment periods, are catalogued at reginfo.gov, and are renewed at least every three years. They are one of the highest-leverage and most underused points of influence in federal data policy.

ICR comments are where federal information collection burden, methodology, instrument design, and data quality are shaped. They are also where the Data Foundation’s evidence-based efficiency, open data, AI and data quality, and modern privacy framework priorities are most directly operationalized. A well-constructed ICR comment can shift burden estimates by orders of magnitude, redirect a collection toward existing administrative or statistical data, and require structured machine-readable formats and open metadata for the resulting dataset.

This is one of the Data Foundation’s Expert Engagement Guides, produced by the Center for Evidence Capacity. It is designed to be read alongside the companion guide on notices of proposed rulemaking (NPRMs), which addresses substantive rulemaking under the Administrative Procedure Act. A forthcoming guide will address System of Records Notices (SORNs) under the Privacy Act.

Download: EXPERT ENGAGEMENT GUIDE: Writing Effective Public Comments on Information Collection Requests (ICRs)