Converting forms to digital: unfortunate copy

[cjforms]

Your page:
https://pra.digital.gov/do-i-need-clearance/form-updates-and-conversions/

says:
"As long as the approved form fields and questions are not changed and the digital materials collects the same information, OIRA would likely consider conversion to an electronic format a non-substantive change to an already approved collection, and it wouldn’t need additional public comment."

Unfortunately, this can easily be interpreted to mean that it is better NOT to change form fields or form questions when you move a form to digital.

This is deeply saddening as most paper forms have either never had any design attention, or if they have had any work done on improving their design then this is likely to have been many years ago.

If you move a badly-designed paper form to become a digital form without working on improving the design, then you will achieve a badly-designed digital form. Digital forms are typically much harder to improve, and a valuable opportunity to reduce paperwork and burden will both be lost right now, and made harder to achieve in future.

Please can you re-work this page to make it clear that unthinkingly reproducing a paper form as a digital form is not within the spirit of the Paperwork Reduction Act.