PAPERWORK 

REDUCTION ACT 

Burden Reduction May 

Require a New Approach 

Statement of Linda D. Koontz 

Director, Information Management 

United States Government Accountability Office

GAO Testimony

Before the Subcommittee on Regulatory 

Affairs, Committee on Government 

Reform, House of Representatives 

For Release on Delivery 

Expected at 2 p.m. EDT 

Tuesday, June 14, 2005 

GAO-05-778T 
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What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-778T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at 

(202) 512-6240 or koontzl@gao.gov. 

Highlights of GAO-05-778T, a testimony 

before the Subcommittee on Regulatory 

Affairs, Committee on Government 

Reform, House of Representatives 

June 14, 2005

PAPERWORK REDUCTION ACT

Reducing Burden May Require a New 

Approach 

The total paperwork burden imposed by federal information collections 

shrank slightly in fiscal year 2004, according to estimates provided in OMB’s 

annual PRA report to Congress. The estimated total burden was 7.971 billion 

hours—a decrease of 1.6 percent (128 million burden hours) from the 

previous year’s total of about 8.099 billion hours. Different types of changes 

contributed to the overall change in these estimates, according to OMB. For 

example, adjustments to the estimates (from such factors as changes in 

estimation methods and estimated number of respondents) accounted for a 

decrease of about 156 million hours (1.9 percent), and agency burden 

reduction efforts led to a decrease of about 97 million hours (1.2 percent). 

These decreases were partially offset by increases in other categories, 

primarily an increase of 119 million hours (1.5 percent) arising from new 

statutes. However, because of limitations in the accuracy of burden 

estimates, the significance of small changes in these estimates is unclear. 

Nonetheless, as the best indicators of paperwork burden available, these 

estimates can be useful as long as the limitations are clearly understood. 

Among the PRA provisions aimed at helping to achieve the goals of 

minimizing burden while maximizing utility is the requirement for CIO 

review and certification of information collections. GAO’s review of 12 case 

studies showed that CIOs provided these certifications despite often missing 

or inadequate support from the program offices sponsoring the collections. 

Further, although the law requires CIOs to provide support for certifications, 

agency files contained little evidence that CIO reviewers had made efforts to 

improve the support offered by program offices. Numerous factors have 

contributed to these problems, including a lack of management support and 

weaknesses in OMB guidance. Because these reviews were not rigorous, 

OMB, the agency, and the public had reduced assurance that the standards 

in the act—such as minimizing burden—were consistently met. 

In contrast, the Internal Revenue Service (IRS) and the Environmental 

Protection Agency (EPA) have set up processes outside the CIO review 

process that are specifically focused on reducing burden. These agencies, 

whose missions involve numerous information collections, have devoted 

significant resources to targeted burden reduction efforts that involve 

extensive outreach to stakeholders. According to the two agencies, these 

efforts led to significant reductions in burden on the public. In contrast, for 

the 12 case studies, the CIO review process did not reduce burden. 

In its report, GAO recommended that OMB and the agencies take steps to 

improve review processes and compliance with the act. GAO also suggested 

that the Congress may wish to consider mandating pilot projects to target 

some collections for rigorous analysis along the lines of the IRS and EPA 

approaches. OMB and the agencies agreed with most of the 

recommendations, but disagreed with aspects of GAO’s characterization of 

agencies’ compliance with the act’s requirements. 

Americans spend billions of hours 

each year providing information to 

federal agencies by filling out 

information collections (forms, 

surveys, or questionnaires). A 

major aim of the Paperwork 

Reduction Act (PRA) is to minimize 

the burden that these collections 

impose on the public, while 

maximizing their public benefit. 

Under the act, the Office of 

Management and Budget (OMB) is 

to approve all such collections and 

to report annually on the agencies’ 

estimates of the associated burden. 

In addition, agency Chief 

Information Officers (CIO) are to 

review information collections 

before they are submitted to OMB 

for approval and certify that the 

collections meet certain standards 

set forth in the act. 

For its testimony, GAO was asked 

to comment on OMB’s burden 

report for 2004 and to discuss its 

recent study of PRA 

implementation (GAO-05-424), 

concentrating on CIO review and 

certification processes and 

describing alternative processes 

that two agencies have used to 

minimize burden. For its study, 

GAO reviewed a governmentwide 

sample of collections, reviewed 

processes and collections at four 

agencies that account for a large 

proportion of burden, and 

performed case studies of 12 

approved collections. 
Page 1 GAO-05-778T

Madam Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the implementation of the 

Paperwork Reduction Act (PRA).1

 As you know, the primary goals of 

the act are to minimize the government paperwork burden on the 

public while maximizing the public benefit and utility of the 

information collections that the government undertakes. To achieve 

these goals, the PRA includes a range of provisions that establish 

standards and procedures for effective implementation and 

oversight. Among these provisions is the requirement for the Office 

of Management and Budget (OMB) to report annually to the 

Congress on the estimated burden imposed on the public by 

government information collections (forms, surveys, and 

questionnaires). Another requirement is that agencies not establish 

information collections without having them approved by OMB, and 

that before submitting them for approval, agencies’ Chief 

Information Officers (CIO) certify that the collection meets 10 

specified standards (for example, that it avoids unnecessary 

duplication and minimizes burden). 

As you requested, I will begin by commenting briefly today on the 

estimates of government paperwork burden provided in the annual 

PRA report (known as the Information Collection Budget) that OMB 

recently released, which presents federal agencies’ estimates of 

federal paperwork burden as of the end of fiscal year 2004. I will 

then discuss results from a report that we prepared on PRA 

processes and compliance, which is being released today.2 I will 

concentrate on our findings regarding agencies’ processes to certify 

that information collections meet PRA standards and on alternative 

processes that two agencies have used to minimize burden. 

 1

 The Paperwork Reduction Act was originally enacted into law in 1980 (Pub. L. 96-511, 

Dec. 11, 1980). It was reauthorized with minor amendments in 1986 (Pub. L. 99-591, Oct. 30, 

1986) and was reauthorized a second time with more significant amendments in 1995 (Pub. 

L. 104-13, May 22, 1995). 

2

 GAO, Paperwork Reduction Act: New Approach May Be Need to Reduce Government 

Burden on Public, GAO-05-424 (Washington, D.C.: May 20, 2005). 
Page 2 GAO-05-778T

In preparing this testimony, we reviewed our testimonies on 

previous annual PRA reports as well as examining the most recent 

one. For our discussion of the certification process, we drew on our 

report, for which we performed detailed reviews of paperwork 

clearance processes and collections at four agencies: the 

Department of Veterans Affairs (VA), the Department of Housing 

and Urban Development (HUD), the Department of Labor, and the 

Internal Revenue Service (IRS). Together, these four agencies 

represent a broad range of paperwork burdens, and in 2003, they 

accounted for about 83 percent of the 8.1 billion hours of estimated 

paperwork burden for all federal agencies. Of this total, IRS alone 

accounted for about 80 percent.3

 We also selected 12 approved 

collections as case studies (three at each of the four agencies) to 

determine how effective agency processes were. In addition, we 

analyzed a random sample (343) of all OMB-approved collections 

governmentwide as of May 2004 (8,211 collections at 68 agencies) to 

determine compliance with the act’s requirements regarding agency 

certification of the 10 standards and consultation with the public. 

We designed the random sample so that we could determine 

compliance levels at the four agencies and governmentwide. Finally, 

although the Environmental Protection Agency (EPA) was not one 

of the agencies whose processes we reviewed, we analyzed 

documents and interviewed officials concerning the agency’s efforts 

to reduce the burden of its information collections. Further details 

on our scope and methodology are provided in our report. 

The work on which this testimony is based was conducted from May 

2004 to May 2005, in accordance with generally accepted 

government auditing standards. 

 3

Although IRS accounted for about 80 percent of burden, it did not account for 80 percent 

of collections: it accounted for 808 out of the total 8,211 collections governmentwide as of 

May 2004. 
Page 3 GAO-05-778T

Results in Brief 

The total paperwork burden imposed by federal information 

collections shrank slightly in fiscal year 2004, according to estimates 

provided in OMB’s May 2005 annual PRA report to Congress. The 

estimated total burden was 7.971 billion hours, which is a decrease 

of 1.6 percent (128 million burden hours) from the previous year’s 

total of about 8.099 billion hours. Different types of changes 

contributed to the overall change in the total burden estimates, 

according to OMB. For example, adjustments to the estimates (from 

such factors as changes in estimation methods and the population of 

respondents4) accounted for a decrease of about 156 million hours 

(1.9 percent), and agency burden reduction efforts led to a decrease 

of about 97 million hours (1.2 percent). These decreases were 

partially offset by increases in other categories, primarily an 

increase of 119 million hours (1.5 percent) arising from new 

statutes. However, because of limitations in the ability to develop 

accurate burden estimates, the degree to which agency burden-hour 

estimates reflect real burden is unclear, and so the significance of 

small changes in these estimates is also uncertain. Nonetheless, 

these estimates are the best indicators of paperwork burden 

available, and they can be useful as long as the limitations are 

clearly understood. 

Among the PRA provisions intended to help achieve the goals of 

minimizing burden while maximizing utility is the requirement for 

CIO review and certification of information collections. 

Governmentwide, agency CIOs generally reviewed information 

collections before they were submitted to OMB and certified that 

the required standards in the act were met. However, our review of 

12 case studies showed that CIOs provided these certifications 

despite often missing or inadequate support from the program 

offices sponsoring the collections. Further, although the law 

requires CIOs to provide support for certifications, agency files 

 4

 That is, an agency may change its method for estimating the burden associated with a 

collection of information, or new information or circumstances may lead to a changed 

estimate of the number of respondents (the people or entities that can or must respond to 

an information collection). 
Page 4 GAO-05-778T

contained little evidence that CIO reviewers had made efforts to 

improve the support offered by program offices. Numerous factors 

have contributed to these problems, including a lack of management 

support and weaknesses in OMB guidance. Because these reviews 

were not rigorous, OMB, the agency, and the public have reduced 

assurance that the standards in the act—such as avoiding 

duplication and minimizing burden—were consistently met. 

In contrast, IRS and EPA have used additional evaluative processes 

that focus specifically on reducing burden. These processes are 

targeted, resource-intensive efforts that involved extensive outreach 

to stakeholders. According to these agencies, their processes led to 

significant reductions in burden on the public while maximizing the 

utility of the information collections. 

In our report, we recommended that OMB and the agencies take 

steps to improve review processes and compliance with the act. We 

also suggested that the Congress may wish to consider mandating 

pilot projects to target some collections for rigorous analysis along 

the lines of the IRS and EPA approaches. OMB and the agencies 

agreed with most of the recommendations, but disagreed with 

aspects of GAO’s characterization of agencies’ compliance with the 

act’s requirements.5

Background 

Collecting information is one way that federal agencies carry out 

their missions. For example, IRS needs to collect information from 

taxpayers and their employers to know the correct amount of taxes 

owed. The U.S. Census Bureau collects information used to 

apportion congressional representation and for many other 

 5

 For example, OMB, the Treasury, Labor, and HUD disagreed with our position that the 

PRA requires agencies both to publish a Federal Register notice and to otherwise consult 

with public. Our position, however, is that the PRA’s language is unambiguous: agencies 

shall “provide 60-day notice in the Federal Register, and otherwise consult with members 

of the public and affected agencies concerning each proposed collection...” Pub. L. 104-13, 

109 Stat. 173, 44 U.S.C. 3506(c)(2). 
Page 5 GAO-05-778T

purposes. When new circumstances or needs arise, agencies may 

need to collect new information. We recognize, therefore, that a 

large portion of federal paperwork is necessary and often serves a 

useful purpose. 

Nonetheless, besides ensuring that information collections have 

public benefit and utility, federal agencies are required by the PRA 

to minimize the paperwork burden that they impose. Among the 

act’s provisions aimed at this purpose are detailed requirements, 

included in the 1995 amendments to the PRA, spelling out how 

agencies are to review information collections before submitting 

them to OMB for approval. According to these amendments, an 

agency official independent of those responsible for the information 

collections (that is, the program offices) is to evaluate whether 

information collections should be approved. This official is the 

agency’s CIO,6

 who is to review each collection of information to 

certify that the collection meets 10 standards (see table 1) and to 

provide support for these certifications. 

 6

The 1995 amendments used the 1980 act’s reference to the agency “senior official” 

responsible for implementation of the act. A year later, Congress gave that official the title 

of agency Chief Information Officer (the Information Technology Management Reform Act, 

Pub. L. 104-106, Feb. 10, 1996, which was subsequently renamed the Clinger-Cohen Act, 

Pub. L. 104-208, Sept. 30, 1996). 
Page 6 GAO-05-778T

Table 1: Standards for Information Collections Set by the Paperwork Reduction Act 

Standards 

The collection is necessary for the proper performance of agency functions. 

The collection avoids unnecessary duplication. 

The collection reduces burden on the public, including small entities, to the extent 

practicable and appropriate. 

The collection uses plain, coherent, and unambiguous language that is understandable 

to respondents. 

The collection will be consistent and compatible with respondents’ current reporting and 

recordkeeping practices to the maximum extent practicable. 

The collection indicates the retention period for any recordkeeping requirements for 

respondents. 

The collection informs respondents of the information they need to exercise scrutiny of 

agency collections information (the reasons the information is collected; the way it is 

used; an estimate of the burden; whether responses are voluntary, required to obtain a 

benefit, or mandatory; and a statement that no person is required to respond unless a 

valid OMB control number is displayed).

The collection was developed by an office that has planned and allocated resources for 

the efficient and effective management and use of the information to be collected. 

The collection uses effective and efficient statistical survey methodology (if applicable). 

The collection uses information technology to the maximum extent practicable to reduce 

burden and improve data quality, agency efficiency and responsiveness to the public. 

Source: Paperwork Reduction Act, Pub. L. 104-13, 109 Stat. 173-4, sec. 3506(c)(3). 

 

In addition, the original PRA of 1980 (section 3514(a)) requires OMB 

to keep Congress “fully and currently informed” of the major 

activities under the act and to submit a report to Congress at least 

annually on those activities. Under the 1995 amendments, this report 

must include, among other things, a list of any increases in burden. 

To satisfy this requirement, OMB prepares the annual PRA report, 

which reports on agency actions during the previous fiscal year, 

including changes in agencies’ burden-hour estimates. 

In addition, the 1995 PRA amendments required OMB to set specific 

goals for reducing burden from the level it had reached in 1995: at 

least a 10 percent reduction in the governmentwide burden-hour 

estimate for each of fiscal years 1996 and 1997, a 5 percent 

governmentwide burden reduction goal in each of the next 4 fiscal 

years, and annual agency goals that reduce burden to the “maximum 

practicable opportunity.” At the end of fiscal year 1995, federal 

agencies estimated that their information collections imposed about 

7 billion burden hours on the public. Thus, for these reduction goals 
Page 7 GAO-05-778T

to be met, the burden-hour estimate would have had to decrease by 

about 35 percent, to about 4.6 billion hours, by September 30, 2001. 

In fact, on that date, the federal paperwork estimate had increased 

by about 9 percent, to 7.6 billion burden hours. 

For the most recent PRA report, the OMB Director sent a bulletin in 

September 2004 to the heads of executive departments and agencies 

requesting information to be used in preparing its report on actions 

during fiscal year 2004. In May 2005, OMB published this report, 

which shows changes in agencies’ burden-hour estimates during 

fiscal year 2004.

Reported Paperwork Burden Decreased Slightly in 2004 

According to OMB’s most recent PRA report to Congress, the 

estimated total burden hours imposed by government information 

collections in fiscal year 2004 was 7.971 billion hours; this is a 

decrease of 128 million burden hours (1.6 percent) from the 

previous year’s total of about 8.099 billion hours. It is also about a 

billion hours larger than in 1995 and 3.4 billion larger than the PRA 

target for the end of fiscal year 2001 (4.6 billion burden hours). 

The reduction for fiscal year 2004 was a result of several types of 

changes, which OMB assigns to various categories. OMB classifies 

all changes—either increases or decreases—in agencies’ burdenhour estimates as either “program changes” or “adjustments.” 

● Program changes are the result of deliberate federal government 

action (e.g., the addition or deletion of questions on a form) and can 

occur as a result of new statutory requirements, agency-initiated 

actions, or the expiration or reinstatement of OMB-approved 

collections.7

 7

 When an agency allows OMB approval of a collection to lapse but continues to collect the 

information, this is a violation of the PRA. However, the expired collection is accounted for 

as a decrease in burden. When the approval is reinstated, the reinstatement is accounted 

for as an increase in burden in OMB’s accounting system. The lapse and reinstatement thus 

generally cancel each other out, unless the reinstatement involves changed burden 

estimates based on new analysis. 
Page 8 GAO-05-778T

● Adjustments do not result from federal burden-reduction activities 

but rather are caused by factors such as changes in the population 

responding to a requirement or agency reestimates of the burden 

associated with a collection of information. For example, if the 

economy declines and more people complete applications for food 

stamps, the resulting increase in the Department of Agriculture’s 

paperwork estimate is considered an adjustment because it is not 

the result of deliberate federal action. 

Table 2 shows the changes in reported burden totals since the fiscal 

year 2003 PRA report. 

Table 2: Changes in Governmentwide Reported Burden Totals by Category 

In millions 

Change from fiscal year 2003 PRA report 

total (hours and percentage)

Category of change 

Baseline: Fiscal year 2003 total 8,098.79 

Fiscal year 2004 program changes: 

Changes due to agency action –96.84 (–1.2%) 

Changes due to new statutes 119.00 (1.5%) 

Changes due to lapses in OMB approval 6.39 (0.1%) 

Total program changes 28.54 (0.4%) 

Fiscal year 2004 adjustments –156.15 (–1.9%) 

Fiscal year 2004 total 7971.18 (–1.6%)

Source: OMB annual PRA reports. 

As table 2 shows, the change in the “adjustments” category was the 

largest factor in the decrease for fiscal year 2004. These results are 

similar to those for fiscal year 2003, in which adjustments of 181.7 

million hours led to an overall decrease of 116.3 million hours (1.4 

percent) in total burden estimated. The slight decreases that 

occurred in fiscal years 2004 and 2003 followed several years of 

increases, as shown in table 3. As table 3 also shows, if adjustments 

are disregarded, the federal government paperwork burden would 

have increased by about 28.5 million burden hours in fiscal year 

2004 (“total program changes” in table 2). 
Page 9 GAO-05-778T

Table 3: Increases in Burden Hours Due to Program Changes Between Fiscal Years 

1998 and 2004 

In millions 

Fiscal year 

Total governmentwide 

burden-hour estimate 

Net increase in burden hours 

due to program changes 

2004 7,971.2 28.5

2003 8,105.4 72.1 

2002 8,223.2 294.1 

2001 7,651.4 158.7 

2000 7,361.0 188.0 

1999 7,183.9 189.0 

1998 6,951.1 41.1 

Source: OMB. 

The largest percentage of governmentwide burden can be attributed 

to the IRS. In fiscal year 2004, IRS accounted for about 78 percent of 

governmentwide burden: about 6210 million hours. No other 

agency’s estimate approaches this level: As of September 30, 2004, 

only five agencies had burden-hour estimates of 100 million hours or 

more (the Departments of Health and Human Services, Labor, and 

Transportation; EPA; and the Securities and Exchange 

Commission). Thus, as we have previously reported, changes in 

paperwork burden experienced by the federal government have 

been largely attributable to changes associated with IRS.8

However, in interpreting these figures, it is important to keep in 

mind their limitations. First, as estimates, they are not precise; 

changes from year to year, particularly small ones, may not be 

meaningful. Second, burden-hour estimates are not a simple matter. 

The “burden hour” has been the principal unit of paperwork burden 

for more than 50 years and has been accepted by agencies and the 

public because it is a clear, easy-to-understand concept. However, it 

is challenging to estimate the amount of time it will take for a 

respondent to collect and provide the information or how many 

 8

 GAO, Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates Due to Federal 

Actions Continue to Increase, GAO-04-676T (Washington, D.C.: Apr. 20, 2004). 
Page 10 GAO-05-778T

individuals an information collection will affect.9 Therefore, the 

degree to which agency burden-hour estimates reflect real burden is 

unclear. (IRS is sufficiently concerned about the methodology it 

uses to develop burden estimates that it is in the process of 

developing and testing alternative means of measuring paperwork 

burden.) Because of these limitations, the degree to which agency 

burden-hour estimates reflect real burden is unclear, and so the 

significance of small changes in these estimates is also uncertain. 

Nonetheless, these estimates are the best indicators of paperwork 

burden available, and they can be useful as long as the limitations 

are clearly understood.

Agency Review Processes Were Not Rigorous 

Among the PRA provisions intended to help achieve the goals of 

minimizing burden while maximizing utility are the requirements for 

CIO review and certification of information collections. The 1995 

amendments required agencies to establish centralized processes 

for reviewing proposed information collections within the CIO’s 

office. Among other things, the CIO’s office is to certify, for each 

collection, that the 10 standards in the act have been met, and the 

CIO is to provide a record supporting these certifications. 

The four agencies in our review all had written directives that 

implemented the review requirements in the act, including the 

requirement for CIOs to certify that the 10 standards in the act were 

met. The estimated certification rate ranged from 100 percent at IRS 

and HUD to 92 percent at VA. Governmentwide, agencies certified 

that the act’s 10 standards had been met on an estimated 98 percent 

of the 8,211 collections. 

However, in the 12 case studies that we reviewed, this CIO 

certification occurred despite a lack of rigorous support that all 

standards were met. Specifically, the support for certification was 

 9

 See GAO, EPA Paperwork: Burden Estimate Increasing Despite Reduction Claims, 

GAO/GGD-00-59 (Washington, D.C.: Mar. 16, 2000), for how one agency estimates 

paperwork burden. 
Page 11 GAO-05-778T

missing or partial on 65 percent (66 of 101) of the certifications.10

Table 4 shows the result of our analysis of the case studies. 

Table 4: Support Provided by Agencies for Paperwork Reduction Act Standards in 12 Case Studies 

 Support provided

Standards Totala Yes Partial No

The collection is necessary for the proper performance of agency functions. 12 6 6 0

The collection avoids unnecessary duplication. 11 2 2 7

The collection reduces burden on the public, including small entities, to the extent practicable and 

appropriate. 12 5 7 0

The collection uses plain, coherent, and unambiguous language that is understandable to 

respondents. 12 1 0 11

The collection will be consistent and compatible with respondents’ current reporting and 

recordkeeping practices to the maximum extent practicable. 12 3 0 9

The collection indicates the retention period for any recordkeeping requirements for respondents.b 6 3 3 0

The collection informs respondents of the information they need to exercise scrutiny of agency 

collections (i.e., the reasons the information is collected; the way it is used; an estimate of the 

burden; whether responses are voluntary, required to obtain a benefit, or mandatory; and a 

statement that no person is required to respond unless a valid OMB control number is displayed).b

 12 4 8 0

The collection was developed by an office that has planned and allocated resources for the 

efficient and effective management and use of the information to be collected. 11 2 0 9

The collection uses effective and efficient statistical survey methodology (if applicable). 1 1 0 0

The collection uses information technology to the maximum extent practicable to reduce burden 

and improve data quality, agency efficiency, and responsiveness to the public. 12 8 4 0

Totals 101 35 30 36

Sources: Paperwork Reduction Act, GAO. 

a

The total number of certifications is not always 12 because not all certifications applied to all 

collections. 

b

For these two standards, the presence on the forms of the information indicated was categorized as 

support, the absence of some elements was categorized as partial support, and the absence of all 

elements was categorized as no support. 

For example, under the act, CIOs are required to certify that each 

information collection is not unnecessarily duplicative. According to 

OMB instructions, agencies are to (1) describe efforts to identify 

duplication and (2) show specifically why any similar information 

already available cannot be used or modified for the purpose 

described. 

 10The total number of certifications does not total 120 (12 cases times 10 standards) 

because some standards did not apply to some cases. 
Page 12 GAO-05-778T

In 2 of 11 cases, agencies provided the description requested; for 

example: 

Program reviews were conducted to identify potential areas of duplication; however, none 

were found to exist. There is no known Department or Agency which maintains the 

necessary information, nor is it available from other sources within our Department. 

In an additional 2 cases, partial support was provided. An example is 

the following, provided by Labor: 

[The Employer Assistance Referral Network (EARN)] is a new, nationwide service that 

does not duplicate any single existing service that attempts to match employers with 

providers who refer job candidates with disabilities. While similar job-referral services 

exist at the state level, and some nation-wide disability organizations offer similar services 

to people with certain disabilities, we are not aware of any existing survey that would 

duplicate the scope or content of the proposed data collection. Furthermore, because this 

information collection involves only providers and employers interested in participating in 

the EARN service, and because this is a new service, a duplicate data set does not exist. 

While this example shows that the agency attempted to identify 

duplicative sources, it does not discuss why information from state 

and other disability organizations could not be aggregated and used, 

at least in part, to satisfy the needs of this collection. 

In 7 cases, moreover, support for these certifications was missing. 

An example is the following statement, used on all three IRS 

collections: 

We have attempted to eliminate duplication within the agency wherever possible. 

This assertion provides no information on what efforts were made 

to identify duplication or perspective on why similar information, if 

any, could not be used. Further, the files contained no evidence that 

the CIO reviewers challenged the adequacy of this support or 

provided support of their own to justify their certification. 

A second example is provided by the standard requiring each 

information collection to reduce burden on the public, including 
Page 13 GAO-05-778T

small entities, 11 to the extent practicable and appropriate. OMB 

guidance emphasizes that agencies are to demonstrate that they 

have taken every reasonable step to ensure that the collection of 

information is the least burdensome necessary for the proper 

performance of agency functions. In addition, OMB instructions and 

guidance direct agencies to provide specific information and 

justifications: (1) estimates of the hour and cost burden of the 

collections and (2) justifications for any collection that requires 

respondents to report more often than quarterly, respond in fewer 

than 30 days, or provide more than an original and two copies of 

documentation. 

With regard to small entities, OMB guidance states that the standard 

emphasizes such entities because these often have limited resources 

to comply with information collections.12 The act cites various 

techniques for reducing burden on these small entities,13 and the 

guidance includes techniques that might be used to simplify 

requirements for small entities, such as asking fewer questions, 

taking smaller samples than for larger entities, and requiring small 

entities to provide information less frequently. 

Our review of the case examples found that for the first part of the 

certification, which focuses on reducing burden on the public, the 

files generally contained the specific information and justifications 

called for in the guidance. However, none of the case examples 

 11OMB’s instructions to agencies state that a small entity may be (1) a small business, which 

is deemed to be one that is independently owned and operated and that is not dominant in 

its field of operation; (2) a small organization, which is any not-for-profit enterprise that is 

independently owned and operated and is not dominant in its field; or (3) a small 

government jurisdiction, which is a government of a city, county, town, township, school 

district, or special district with a population of less than 50,000. 

12“Particularly for small businesses, paperwork burdens can force the redirection of 

resources away from business activities that might otherwise lead to new and better 

products and services, and to more and better jobs. Accordingly, the Federal Government 

owes the public an ongoing commitment to scrutinize its information requirements to 

ensure the imposition of only those necessary for the proper performance of an agency’s 

functions.” H. Report 104-37 (Feb. 15, 1995) p. 23. 

13These include (a) establishing different compliance or reporting requirements or 

timetables for respondents with fewer available resources; (b) clarifying, consolidating, or 

simplifying compliance and reporting requirements; and (c) exempting certain respondents 

from coverage of all or part of the collection. 
Page 14 GAO-05-778T

contained support that addressed how the agency ensured that the 

collection was the least burdensome necessary. According to agency 

CIO officials, the primary cause for this absence of support is that 

OMB instructions and guidance do not direct agencies to provide 

this information explicitly as part of the approval package. 

For the part of the certification that focuses on small businesses, 

our governmentwide sample included examples of various agency 

activities that are consistent with this standard. For instance, Labor 

officials exempted 6 million small businesses from filing an annual 

report; telephoned small businesses and other small entities to 

assist them in completing a questionnaire; reduced the number of 

small businesses surveyed; and scheduled fewer compliance 

evaluations on small contractors. 

For four of our case studies, however, complete information that 

would support certification of this part of the standard was not 

available. Seven of the 12 case studies involved collections that were 

reported to impact businesses or other for-profit entities, but for 4 

of the 7, the files did not explain either 

● why small businesses were not affected or 

● even though such businesses were affected, that burden could or 

could not be reduced. 

Referring to methods used to minimize burden on small business, 

the files included statements such as “not applicable.” These 

statements do not inform the reviewer whether there was an effort 

made to reduce burden on small entities or not. When we asked 

agencies about these four cases, they indicated that the collections 

did, in fact, affect small business. 

OMB’s instructions to agencies on this part of the certification 

require agencies to describe any methods used to reduce burden 

only if the collection of information has a “significant economic 

impact on a substantial number of small entities.” This does not 

appropriately reflect the act’s requirements concerning small 

business: the act requires that the CIO certify that the information 

collection reduces burden on small entities in general, to the extent 

practical and appropriate, and provides no thresholds for the level 
Page 15 GAO-05-778T

of economic impact or the number of small entities affected. OMB 

officials acknowledged that their instruction is an “artifact” from a 

previous form and more properly focuses on rulemaking rather than 

the information collection process. 

The lack of support for these certifications appears to be influenced 

by a variety of factors. In some cases, as described above, OMB 

guidance and instructions are not comprehensive or entirely 

accurate. In the case of the duplication standard specifically, IRS 

officials said that the agency does not need to further justify that its 

collections are not duplicative because (1) tax data are not collected 

by other agencies so there is no need for the agency to contact them 

about proposed collections and (2) IRS has an effective internal 

process for coordinating proposed forms among the agency’s 

various organizations that may have similar information. 

Nonetheless, the law and instructions require support for these 

assertions, which was not provided. 

In addition, agency reviewers told us that management assigns a 

relatively low priority and few resources to reviewing information 

collections. Further, program offices have little knowledge of and 

appreciation for the requirements of the PRA. As a result of these 

conditions and a lack of detailed program knowledge, reviewers 

often have insufficient leverage with program offices to encourage 

them to improve their justifications. 

When support for the PRA certifications is missing or inadequate, 

OMB, the agency, and the public have reduced assurance that the 

standards in the act, such as those on avoiding duplication and 

minimizing burden, have been consistently met. 

Two Agencies Have Developed Processes to Reduce Burden 

Associated with Information Collections 

IRS and EPA have supplemented the standard PRA review process 

with additional processes aimed at reducing burden while 

maximizing utility. These agencies’ missions require them both to 
Page 16 GAO-05-778T

deal extensively with information collections, and their management 

has made reduction of burden a priority.14 

In January 2002, the IRS Commissioner established an Office of 

Taxpayer Burden Reduction, which includes both permanently 

assigned staff and staff temporarily detailed from program offices 

that are responsible for particular information collections. This 

office chooses a few forms each year that are judged to have the 

greatest potential for burden reduction (these forms have already 

been reviewed and approved through the CIO process). The office 

evaluates and prioritizes burden reduction initiatives by 

● determining the number of taxpayers impacted; 

● quantifying the total time and out-of-pocket savings for taxpayers; 

● evaluating any adverse impact on IRS’s voluntary compliance 

efforts; 

● assessing the feasibility of the initiative, given IRS resource 

limitations; and 

● tying the initiative into IRS objectives. 

Once the forms are chosen, the office performs highly detailed, indepth analyses, including extensive outreach to the public affected, 

the users of the information within and outside the agency, and 

other stakeholders. This analysis includes an examination of the 

need for each data element requested. In addition, the office 

thoroughly reviews form design.15 

The office’s Director16 heads a Taxpayer Burden Reduction Council, 

which serves as a forum for achieving taxpayer burden reduction 

 14“IRS is committed to reducing taxpayer burden and established the Office of Taxpayer 

Burden Reduction (OTBR) in January 2002 to lead its efforts.” Congressional testimony by 

the IRS Commissioner, April 20, 2004, before the Subcommittee on Energy Policy, Natural 

Resources, and Regulatory Affairs, House Committee on Government Reform. 

15In congressional testimony, the IRS Commissioner stated that OMB had referred another 

agency to IRS’s Office of Taxpayer Burden Reduction as an example of a “best practice” in 

burden reduction in government. 

16 The Director reports to the IRS Commissioner for the Small Business and Self-Employed 

Division. 
Page 17 GAO-05-778T

throughout IRS. IRS reports that as many as 100 staff across IRS and 

other agencies can be involved in burden reduction initiatives, 

including other federal agencies, state agencies, tax practitioner 

groups, taxpayer advocacy panels, and groups representing the 

small business community. 

The council directs its efforts in five major areas: 

● simplifying forms and publications; 

● streamlining internal policies, processes, and procedures; 

● promoting consideration of burden reductions in rulings, 

regulations, and laws; 

● assisting in the development of burden reduction measurement 

methodology; and 

● partnering with internal and external stakeholders to identify areas 

of potential burden reduction. 

IRS reports that this targeted, resource-intensive process has 

achieved significant reductions in burden: over 200 million burden 

hours since 2002. For example, it reports that about 95 million hours 

of taxpayer burden were reduced through increases in the incomereporting threshold on various IRS schedules.17 Another burden 

reduction initiative includes a review of the forms that 15 million 

taxpayers use to request an extension to the date for filing their tax 

returns.18 

Similarly, EPA officials stated that they have established processes 

for reviewing information collections that supplement the standard 

PRA review process. These processes are highly detailed and 

 17In addition, the office reports that IRS staff positions could be freed up through its efforts 

to raise the reporting threshold on various tax forms and schedules. Fewer IRS positions 

are needed when there are fewer tax forms and schedules to be reviewed. 

18 We did not verify the accuracy of IRS’s reported burden-hour savings. We have previously 

reported that the estimation model that IRS uses for compliance burden ignores important 

components of burden and has limited capabilities for analyzing the determinants of 

burden. See GAO, Tax Administration: IRS Is Working to Improve Its Estimates of 

Compliance Burden, GAO/GGD-00-11 (Washington, D.C.: May 22, 2000). Moreover, IRS has 

an effort under way to revise the methodology used to compute burden. That new 

methodology, when completed, may result in different estimates of reduced burden hours. 
Page 18 GAO-05-778T

evaluative, with a focus on burden reduction, avoiding duplication, 

and ensuring compliance with PRA. According to EPA officials, the 

impetus for establishing these processes was the high visibility of 

the agency’s information collections and the recognition, among 

other things, that the success of EPA’s enforcement mission 

depended on information collections being properly justified and 

approved: in the words of one official, information collections are 

the “life blood” of the agency. 

According to these officials, the CIO staff are not generally closely 

involved in burden reduction initiatives, because they do not have 

sufficient technical program expertise and cannot devote the 

extensive time required.19 Instead, these officials said that the CIO 

staff’s focus is on fostering high awareness within the agency of the 

requirements associated with information collections, educating and 

training the program office staff on the need to minimize burden and 

the impact on respondents, providing an agencywide perspective on 

information collections to help avoid duplication, managing the 

clearance process for agency information collections, and acting as 

liaison between program offices and OMB during the clearance 

process. To help program offices consider PRA requirements such 

as burden reduction and avoiding duplication as they are developing 

new information collections or working on reauthorizing existing 

collections, the CIO staff also developed a handbook20 to help 

program staff understand what they need to do to comply with PRA 

and gain OMB approval. 

In addition, program offices at EPA have taken on burden reduction 

initiatives that are highly detailed and lengthy (sometimes lasting 

years) and that involve extensive consultation with stakeholders 

(including entities that supply the information, citizens groups, 

information users and technical experts in the agency and 

elsewhere, and state and local governments). For example, EPA 

 19These officials added that in exceptional circumstances the CIO office has had staff 

available to perform such projects, but generally in collaboration with program offices. 

20EPA Office of Environmental Information, Collection Strategies Division, ICR Handbook: 

EPA’s Guide to Writing Information Collection Requests Under the Paperwork Reduction 

Act of 1995, draft (revised March 2005).
Page 19 GAO-05-778T

reports that it amended its regulations to reduce the paperwork 

burden imposed under the Resource Conservation and Recovery 

Act. One burden reduction method EPA used was to establish higher 

thresholds for small businesses to report information required under 

the act. EPA estimates that the initiative will reduce burden by 

350,000 hours and save $22 million annually. Another EPA program 

office reports that it is proposing a significant reduction in burden 

for its Toxic Release Inventory program.21 

Overall, EPA and IRS reported that they produced significant 

reductions in burden by making a commitment to this goal and 

dedicating resources to it. In contrast, for the 12 information 

collections we examined, the CIO review process resulted in no 

reduction in burden. Further, the Department of Labor reported that 

its PRA reviews of 175 proposed collections over nearly 2 years did 

not reduce burden.22 Similarly, both IRS and EPA addressed 

information collections that had undergone CIO review and received 

OMB approval and nonetheless found significant opportunities to 

reduce burden. 

In summary, government agencies often need to collect information 

to perform their missions. The PRA puts in place mechanisms to 

focus agency attention on the need to minimize the burden that 

these information collections impose—while maximizing the public 

benefit and utility of government information collections—but these 

mechanisms have not succeeded in achieving the ambitious 

reduction goals set forth in the 1995 amendments. Achieving real 

reductions in the paperwork burden is an elusive goal, as years of 

PRA reports attest. 

Among the mechanisms to fulfill the PRA’s goals is the CIO review 

required by the act. However, as this process is currently 

implemented, it has limited effect on the quality of support provided 

 21We did not verify the accuracy of EPA’s burden reduction estimates. 

22These reviews did result in a 1.3 percent reduction in calculated burden by correcting 

mathematical errors in program offices’ submissions. 
Page 20 GAO-05-778T

for information collections. CIO reviews appear to be lacking the 

rigor that the Congress envisioned. Many factors have contributed 

to these conditions, including lack of management support, 

weaknesses in OMB guidance, and the CIO staff’s lack of specific 

program expertise. As a result, OMB, federal agencies, and the 

public have reduced assurance that government information 

collections are necessary and that they appropriately balance the 

resulting burden with the benefits of using the information 

collected. 

The targeted approaches to burden reduction used by IRS and EPA 

suggest promising alternatives to the current process outlined in the 

PRA. However, the agencies’ experience also suggests that to make 

such an approach successful requires top-level executive 

commitment, extensive involvement of program office staff with 

appropriate expertise, and aggressive outreach to stakeholders. 

Indications are that such an approach would also be more resourceintensive than the current process. Moreover, such an approach may 

not be warranted at all agencies that do not have the level of 

paperwork issues that face IRS and similar agencies. Consequently, 

it is critical that any efforts to expand the use of the IRS and EPA 

models consider these factors. 

In our report, we suggested options that the Congress may want to 

consider in its deliberations on reauthorizing the act, including 

mandating pilot projects to test and review alternative approaches 

to achieving PRA goals. We also made recommendations to the 

Director of OMB, including that the office alter its current guidance 

to clarify and emphasize issues raised in our review, and to the 

heads of the four agencies to improve agency compliance with the 

act’s provisions. 

Madam Chairman, this completes my prepared statement. I would 

be pleased to answer any questions. 
Page 21 GAO-05-778T

Contacts and Acknowledgments 

For future information regarding this testimony, please contact 

Linda Koontz, Director, Information Management, at (202) 512-6420, 

or koontzl@gao.gov. Other individuals who made key contributions 

to this testimony were Barbara Collier, Alan Stapleton, Warren 

Smith, and Elizabeth Zhao. 

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