United States Government Accountability Office

GAO Testimony

Before the Subcommittee on Regulatory 

Affairs, Committee on Government 

Reform, House of Representatives 

PAPERWORK 

REDUCTION ACT 

For Release on Delivery 

Expected at 2:00 p.m. EST

Wednesday, March 8, 2006

New Approaches Can 

Strengthen Information 

Collection and Reduce 

Burden 

Statement of Linda D. Koontz, Director 

Information Management 

GAO-06-477T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 8, 2006

PAPERWORK REDUCTION ACT

New Approaches Can Strengthen 

Information Collection and Reduce 

Burden 

Highlights of GAO-06-477T, a report to the 

Subcommittee on Regulatory Affairs, 

Committee on Government Reform, 

House of Representatives

Americans spend billions of hours 

each year providing information to

federal agencies by filling out 

forms, surveys, or questionnaires. 

A major aim of the Paperwork

Reduction Act (PRA) is to minimize 

the burden that these information 

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. In

addition, agency Chief Information

Officers (CIO) are to review 

information collections before they

are submitted to OMB for approval

and certify that these meet certain 

standards set forth in the act. 

GAO was asked to testify on the

implementation of the act’s

provisions regarding the review

and approval of information 

collections. For its testimony, GAO

reviewed previous work in this 

area, including the results of an 

expert forum on information 

resources management and the 

PRA, which was held in February

2005 under the auspices of the 

National Research Council. GAO

also drew on its earlier study of 

CIO review processes (GAO-05-

424) and alternative processes that 

two agencies have used to

minimize burden. For this 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. 

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 that support be provided for 

certifications, agency files contained little evidence that CIO reviewers had 

made efforts to get program offices to improve the support they offered. 

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. To address the issues raised by its review, GAO made 

recommendations to the agencies and OMB aimed at strengthening the CIO 

review process and clarifying guidance. OMB and the agencies report 

making plans and taking steps to address GAO’s recommendations. 

Beyond the collection review process, the Internal Revenue Service (IRS) 

and the Environmental Protection Agency (EPA) have set up processes 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 public 

outreach. According to the two agencies, these efforts led to significant 

reductions in burden. For example, each year, IRS subjects a few forms to 

highly detailed, in-depth analyses, reviewing all data requested, redesigning 

forms, and involving stakeholders (both the information users and the public 

affected). IRS reports that this process—performed on forms that have 

undergone CIO review and received OMB approval—has reduced burden by 

over 200 million hours since 2002. In contrast, for the 12 case studies, the 

CIO review process did not reduce burden. 

When it considers PRA reauthorization, the Congress has the opportunity to 

promote new approaches, including alternatives suggested by the expert 

forum and by GAO. Forum participants made a range of suggestions on 

information collections and their review. For example, they suggested that 

OMB’s focus should be on broad oversight rather than on reviewing each 

individual collection and observed that the current clearance process

appeared to be “pro forma.” They also observed that it seemed excessive to 

require notices of collections to be published twice in the Federal Register, 

as they are now. GAO similarly observed that publishing two notices in the 

Federal Register did not seem to be effective, and suggested eliminating one

of these notices. GAO also suggested that the Congress mandate pilot 

projects to target some collections for rigorous analysis along the lines of 

the IRS and EPA approaches. Such projects would permit agencies to build 

on the lessons learned by the IRS and EPA and potentially contribute to true 

burden reduction. 

www.gao.gov/cgi-bin/getrpt?GAO-06-477T.

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. 
Madam Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the Paperwork Reduction 

Act (PRA) and federal information collections.1

 As you know, one of 

the goals of the PRA is to help ensure that when the government 

asks the public for information, the burden of providing this 

information is as small as possible and the information itself is used 

effectively. In other words, the goal is to minimize the paperwork 

burden while maximizing the public benefit and utility of the 

information collected. To achieve this goal, the PRA includes 

provisions that establish standards and procedures for effective 

implementation and oversight of information collections.2

 Among 

these provisions is the requirement that agencies not establish 

information collections without having them approved by the Office 

of Management and Budget (OMB), and that before submitting them 

for approval, agencies’ Chief Information Officers (CIO) certify that 

collections meet 10 specified standards—including that they avoid 

unnecessary duplication and reduce burden as much as possible. 

As you requested, I will discuss results from a May 2005 report that 

we issued on PRA processes and compliance.3

 In that work, we 

reviewed agencies’ processes to certify that information collections 

meet PRA standards, and we described alternative processes that 

two agencies have used to minimize burden. I will also discuss 

various suggestions for alternative approaches to burden reduction 

that the Congress may wish to consider. 

In preparing this testimony, we reviewed our previous work on PRA 

issues, including the results of an expert forum on information 

 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

 Such collections may have a range of purposes: applications for government benefits, 

program evaluation, general purpose statistics, audit, program planning or management, 

research and regulatory or compliance all of which may occur in a variety of forms, 

including questionnaires and telephone surveys.

3

 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 1 GAO-06-477T
resources management and the PRA, which was held in February 

2005. To convene this forum, we contracted with the National 

Academies’ National Research Council, which recruited panelists 

with expertise in the PRA and related areas. The 11⁄2 day legislative 

forum was attended by observers from our agency, OMB, the 

Congressional Research Service, and staff of the House Government 

Reform Committee. (Attachment 1 lists the participants.) 

In reviewing our previous work, we focused particularly on our May 

2005 report and a subsequent June testimony.4

 For this report and 

testimony, 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.5

 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. 

 4

 GAO, Paperwork Reduction Act: Burden Reduction May Require a New Approach, 

GAO-05-778T (Washington, D.C.: June 14, 2005). 

5

 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 2 GAO-06-477T
All work on which this testimony is based was conducted in 

accordance with generally accepted government auditing standards. 

Results in Brief 

Among the PRA provisions aimed at the goal 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 contained little evidence that 

CIO reviewers had made efforts to get program offices to improve 

the support that they offered. Numerous factors 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 light of these 

findings, we recommended (among other things) that agencies 

strengthen the support provided for CIO certifications and that OMB 

update its guidance to clarify and emphasize this requirement. OMB 

and the agencies report making plans and taking steps to address 

GAO’s recommendations. 

In relation to information collections, IRS and EPA have developed 

and 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 contrast, for the 12 case studies, the CIO review 

process did not reduce burden. 

Page 3 GAO-06-477T
When it considers PRA reauthorization, the Congress should 

consider some new approaches, including alternatives suggested by 

the expert forum and by our findings. Forum participants developed 

several suggestions regarding the review of information collections. 

For example, they suggested that OMB should focus on broad 

oversight rather than on reviews of each individual collection; they 

described this approach as a “retail” process that appeared to have 

become “pro forma.” They also observed that it seemed excessive to 

require notices of collections to be published twice in the Federal 

Register, as they are now. We too observed that publishing two 

notices in the Federal Register seemed to be ineffective, as they 

elicited very little public comment; we suggested eliminating one of 

them. In addition, we suggested that the Congress mandate pilot 

projects to target some collections for rigorous analysis along the 

lines of the IRS and EPA approaches. Such projects would permit 

agencies to build on the lessons learned by the IRS and EPA and 

potentially contribute to true burden reduction. 

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 

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 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 

provisions of the act aimed at this purpose are requirements for the 

review of information collections by OMB and by agency CIOs. 

Under PRA, federal agencies may not conduct or sponsor the 

collection of information unless approved by OMB. OMB is required 

Page 4 GAO-06-477T
to determine that the agency collection of information is necessary 

for the proper performance of the functions of the agency, including 

whether the information will have practical utility.6

 Consistent with 

the act’s requirements, OMB has established a process to review all 

proposals by executive branch agencies (including independent 

regulatory agencies) to collect information from 10 or more persons, 

whether the collections are voluntary or mandatory. 

In addition, the act as amended in 1995 requires every agency to 

establish a process under the official responsible for the act’s 

implementation (now the agency’s CIO7

) to review program offices’ 

proposed collections. This official is to be sufficiently independent 

of program responsibility to evaluate fairly whether information 

collections should be approved. Under the law, the CIO is to review 

each collection of information before submission to OMB, including 

reviewing the program office’s evaluation of the need for the 

collection and its plan for the efficient and effective management 

and use of the information to be collected, including necessary 

resources.8

 As part of that review, the agency CIO must ensure that 

each information collection instrument (form, survey, or 

questionnaire) complies with the act. The CIO is also to certify that 

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

support for these certifications. 

 6

 44 U.S.C. 3508. 

7

 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). 

8

 44 U.S.C. 3506(c)(1)(A). 

Page 5 GAO-06-477T
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 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 the fact 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). 

The paperwork clearance process currently takes place in two 

stages. The first stage is CIO review. During this review, the agency 

is to publish a notice of the collection in the Federal Register. The 

public must be given a 60-day period in which to submit comments, 

and the agency is to otherwise consult with interested or affected 

parties about the proposed collection. At the conclusion of the 

agency review, the CIO submits the proposal to OMB for review. 

The agency submissions to OMB typically include a copy of the data 

collection instrument (e.g., a form or survey) and an OMB 

submission form providing information (with supporting 

documentation) about the proposed information collection, 

including why the collection is necessary, whether it is new or an 

extension of a currently approved collection, whether it is voluntary 

or mandatory, and the estimated burden hours. Included in the 

submission is the certification by the CIO or the CIO’s designee that 

the collection satisfies the 10 standards. 

The OMB review is the second stage in the clearance process. This 

review may involve consultation between OMB and agency staff. 

Page 6 GAO-06-477T
During the review, a second notice is published in the Federal 

Register, this time with a 30-day period for soliciting public 

comment. At the end of this period, OMB makes its decision and 

informs the agency. OMB maintains on its Web site a list of all 

approved collections and their currently valid control numbers, 

including the form numbers approved under each collection. 

The 1995 PRA amendments also require 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 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. As of March 2006, OMB’s 

estimate for governmentwide burden is about 10.5 billion hours9

—

about 2.5 billion hours more than the estimate of 7.971 billion hours 

at the end of fiscal year 2004.10 

Over the years, we have reported on the implementation of PRA 

many times.

11 In a succession of reports and testimonies, we noted 

that federal paperwork burden estimates generally continued to 

increase, rather than decrease as envisioned by the burden 

reduction goals in PRA. Further, we reported that some burden 

reduction claims were overstated. For example, although some 

 9

 Some of this increase may have arisen because IRS adopted a new technique for 

estimating burden. As the IRS accounts for about 80 percent of burden, as mentioned

earlier, any change in IRS estimates has a major impact on governmentwide totals. The IRS 

previously changed its formula for calculating burden hours in 1989. At that time, the

change resulted in major increases: the agency’s paperwork burden estimate increased by

3.4 billion hours, and the governmentwide burden-hour estimate nearly tripled. 

10 The 7.971 billion hours as of the end of fiscal year 2004 was a slight decrease (1.6

percent) from the previous year-end estimate of about 8.099 billion.

11We have included a list of related GAO products at the end of this statement. 

Page 7 GAO-06-477T
reported paperwork reductions reflected substantive program 

changes, others were revisions to agencies’ previous burden 

estimates and, therefore, would have no effect on the paperwork 

burden felt by the public. In our previous work, we also repeatedly 

pointed out ways that OMB and agencies could do more to ensure 

compliance with PRA. In particular, we have often recommended 

that OMB and agencies take actions to improve the paperwork 

clearance process. 

Agency Processes for Reviewing Information Collections Were Not 

Effective 

Governmentwide, agency CIOs generally reviewed information 

collections before they were submitted to OMB and certified that 

the 10 standards in the act were met. However, in our 12 case 

studies, CIOs provided these certifications despite often missing or

partial 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 get program offices to improve the 

support that they offered. Numerous factors have contributed to 

these conditions, including a lack of management support and 

weaknesses in OMB guidance. Without appropriate support and 

public consultation, agencies have reduced assurance that 

collections satisfy the standards in the act. 

Support for Certifications Was Often Missing or Partial, Despite CIO Reviews 

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 

Page 8 GAO-06-477T
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 

missing or partial on 65 percent (66 of 101) of the certifications.12

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

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

because some standards did not apply to some cases. 

Page 9 GAO-06-477T
Table 2: Support Provided by Agencies for Paperwork Reduction Act Standards in 12 Case Studies 

Support provided

Standards Total

a

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.b6 3 3 0

The collection informs respondents of 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 the fact 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. 

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. 

Page 10 GAO-06-477T
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 

small entities,13 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 

 13 OMB’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. 

Page 11 GAO-06-477T
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.14 The act cites various 

techniques for reducing burden on these small entities,15 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 

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 

 14 “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. 

15 These 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 12 GAO-06-477T
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 

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 

Page 13 GAO-06-477T
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 

certifications, 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 

deal extensively with information collections, and their management 

has made reduction of burden a priority.16

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 

 16 “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. 

Page 14 GAO-06-477T
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.17

The office’s Director18 heads a Taxpayer Burden Reduction Council, 

which serves as a forum for achieving taxpayer burden reduction 

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; 

 17 In 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. 

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

Division. 

Page 15 GAO-06-477T
● 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.19 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.20

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 

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. 

 19 In 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.

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

reported that the estimation model that IRS has used for compliance burden ignored

important components of burden and had 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). IRS

has recently begun to introduce a revised methodology for computing burden that may 

result in different estimates of burden-hour savings. 

Page 16 GAO-06-477T
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.21 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 handbook22 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 

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 

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

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

22 EPA 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 17 GAO-06-477T
office reports that it is proposing a significant reduction in burden 

for its Toxic Release Inventory program.23

Both the EPA and IRS programs involve extensive outreach to 

stakeholders, including the public. This outreach is particularly 

significant in view of the relatively low levels of public consultation

that occur under the standard review process. As we reported in 

May 2005, public consultation on information collections is often 

limited to publication of notices in the Federal Register.

24 As a 

means of public consultation, however, these notices are not 

effective, as they elicit few responses. An estimated 7 percent of the 

60-day notices of collections in the Federal Register received one or 

more comments. According to our sample of all collections at the 

four agencies reviewed, the number of notices receiving at least one 

comment ranged from an estimated 15 percent at Labor to an 

estimated 6 percent at IRS. In contrast, according to EPA and IRS, 

their efforts at public consultation are key to their burden reduction 

efforts and an important factor in their success. 

Overall, EPA and IRS reported that their targeted processes 

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 

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

24 In our May 2005 report, we reported that agencies were only publishing notices and 

performing no further consultation, and we took the position that the PRA requires 

agencies both to publish a Federal Register notice and to otherwise consult with the

public. We recommended that OMB clarify its guidance on this point and that agencies 

increase public consultation. OMB, the Treasury, Labor, and HUD disagreed with our 

position on the grounds that it was not a good use of agency resources to consult on every

collection; in their view, additional consultation should occur only on those collections that

are particularly important. We consider, however, 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). We believe that agencies should comply with 

current law. However, we are also concerned that public consultation be efficient and

effective; accordingly, we suggested that pilot projects be developed to test and review 

alternative approaches to achieving the PRA’s goals. 

Page 18 GAO-06-477T
over nearly 2 years did not reduce burden.25 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. 

Agencies Could Strengthen CIO Review 

In our 2005 report, we concluded that the CIO review process was 

not working as Congress intended: It did not result in a rigorous 

examination of the burden imposed by information collections, and 

it did not lead to reductions in burden. In light of these findings, we 

recommended (among other things) that agencies strengthen the 

support provided for CIO certifications and that OMB update its 

guidance to clarify and emphasize this requirement. 

Since our report was issued, the four agencies have reported taking 

steps to strengthen their support for CIO certifications: 

● According to the HUD CIO, the department established a seniorlevel PRA compliance officer in each major program office, and it 

has revised its certification process to require that before 

collections are submitted for review, they be approved at a higher 

management level within program offices. 

● The Treasury CIO established an Information Management SubCouncil under the Treasury CIO Council and added resources to the 

review process. 

● According to the VA’s 2007 budget submission, the department 

obtained additional resources to help review and analyze its 

information collection requests. 

● According to the Office of the CIO at the Department of Labor, the 

department intends to provide guidance to components regarding 

the need to provide strong support for clearance requests and has 

met with component staff to discuss these issues. 

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

mathematical errors in program offices’ submissions. 

Page 19 GAO-06-477T
OMB reported that its guidance to agencies will be updated through 

a planned automated system,26 which is expected to be operational 

by the end of this year. According to the acting head of OMB’s Office 

of Information and Regulatory Affairs, the new system will permit 

agencies to submit clearance requests electronically, and the 

instructions will provide clear guidance on the requirements for 

these submissions, including the support required. This official 

stated that OMB has worked with agency representatives with direct 

knowledge of the PRA clearance process in order to ensure that the 

system and its instructions clearly reflect the requirements of the 

process. If this system is implemented as described and OMB 

withholds clearance from submissions that lack adequate support, it 

could lead agencies to strengthen the support provided for their 

certifications. 

According to PRA Experts, the Current Approach to Paperwork 

Reduction Could Be Improved 

In considering PRA reauthorization, the Congress has the 

opportunity to take into account ideas that were developed by the

various experts at the PRA forum that we organized in 2005. These 

experts noted, as we have here, that the burden reduction goals in 

the act have not been met, and that in fact burden has been going 

up. They suggested first that the goal of reducing burden by 5 

percent is not realistic, and also that such numerical goals do not 

appropriately recognize that some burden is necessary. The 

important point, in their view, is to reduce unnecessary burden 

while still ensuring maximum utility. 

Forum participants also questioned the level of attention that OMB 

devotes to the process of clearing collections on what they called a 

“retail” basis, focusing on individual collections rather than looking 

across numerous collections. In their view, some of this attention 

 26 The new system, ROCIS (the RISC/OIRA Consolidated Information System), is operated 

for OMB’s Office of Information and Regulatory Affairs (OIRA) by the Regulatory 

Information Service Center (RISC) of the General Services Administration. 

Page 20 GAO-06-477T
would be better devoted to broader oversight questions. In their 

discussion, participants mentioned that the clearance process 

informs OMB with respect to its other information resource 

management functions, but that this had not led to high-level 

integration and coordination. It was suggested that the volume of 

collections to be individually reviewed could impede such 

integration. 

Participants made a number of suggestions regarding ways to 

reduce the volume of collections that OMB reviews, with the goal of 

freeing OMB resources so that it could address more substantive, 

wide-ranging paperwork issues. Options that they suggested 

including limiting OMB review to significant and selected 

collections, rather than all collections. This would entail shifting 

more responsibility for review to the agencies, which they stated 

was one of the avowed purposes of the 1995 amendments: to 

increase agencies’ attention to properly clearing information 

collection requests. One way to shift this responsibility, the forum 

suggested, would be for OMB to be more creative in its use of the 

delegation authority that the act provides. (Under the act, OMB has 

the authority to delegate to agencies the authority to approve 

collections in various circumstances.) Also, participants mentioned 

the possibility of modifying the clearance process by, for example, 

extending beyond 3 years the length of time that OMB approvals are 

valid, particularly for the routine types of collections. This 

suggestion was paired with the idea that the review process itself 

should be more rigorous; as the panel put it, “now it’s a rather pro 

forma process.” They also observed that two Federal Register

notices seemed excessive in most cases. 

To reduce the number of collections that require OMB review, 

another possibility suggested was to revise the PRA’s definition of 

an information collection. For example, the current definition 

includes all collections that contact 10 or more persons; the panel 

suggested that this threshold could be raised, pointing out that this 

low threshold makes it hard for agencies to perform targeted 

outreach to the public regarding burden and other issues (such as 

through customer satisfaction questionnaires or focus groups). 

However, they had no specific recommendation on what the number 

should be. Alternatively, they suggested that OMB could be given 

Page 21 GAO-06-477T
authority to categorize types of information collections that did not 

require clearance (for example, OMB could exempt collections for 

which the response is purely voluntary). 

Finally, the forum questioned giving agency CIOs the responsibility 

for reviewing information collections. According to the forum, CIOs 

have tended to be more associated with information technology 

issues than with high level information policy.

Our previous work has not addressed every topic raised by the 

forum, so we cannot argue for or against all these suggestions. 

However, the work in our May 2005 report is consistent with the 

forum’s observations in some areas, including the lack of rigor in the 

review process and the questionable need for two Federal Register

notices. I would like to turn here, Madam Chairman, to the matters 

for congressional consideration that we included in that report. 

Our Work Suggests Ways to Explore New Approaches 

We observed that to achieve burden reduction, the targeted 

approaches used by IRS and EPA were a promising alternative. 

However, the agencies’ experiences also suggest that to make such 

approaches 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 resource-intensive than 

the current process. Moreover, such an approach may not be 

warranted at all agencies, since not al agencies have the level of 

paperwork issues that face IRS and similar agencies. 

On the basis of the conclusions in our May 2005 report, we 

suggested that the Congress consider mandating the development of 

pilot projects to test and review the value of approaches to burden 

reduction similar to those used by IRS and EPA. OMB would issue 

guidance to agencies on implementing such pilots, including criteria 

for assessing collections along the lines of the process currently 

employed by IRS. According to our suggestion, agencies 

participating in such pilots would submit to OMB and publish on 

their Web sites (or through other means) an annual plan on the 

Page 22 GAO-06-477T
collections targeted for review, specific burden reduction goals for 

those collections, and a report on reductions achieved to date. We 

also suggested that in view of the limited effectiveness of the 60-day 

notice in the Federal Register in eliciting public comment, this 

requirement could be eliminated. 

Under a pilot project approach, an agency would develop a process 

to examine its information collections for opportunities to reduce 

burden. The experiences at IRS and EPA show that targeted burden 

reduction efforts depend on tapping the expertise of program staff, 

who are generally closely involved in the effort. That is, finding 

opportunities to reduce burden requires strong familiarity with the 

programs involved. 

Pilot projects would be expected to build on the lessons learned at 

IRS and EPA. For example, these agencies have used a variety of 

approaches to reducing burden, such as 

● sharing information—for example, by facilitating cross-agency 

information exchanges; 

● standardizing data for multiple uses (“collect once—use multiple 

times”); 

● integrating data to avoid duplication; and 

● re-engineering work flows. 

Pilot projects would be most appropriate for agencies for which 

information collections are a significant aspect of the mission. As 

the results and lessons from the pilots become available, OMB may 

choose to apply them at other agencies by approving further pilots.27

Lessons learned from the mandated pilots could thus be applied 

more broadly. 

 27 OMB currently has this authority under PRA. As mentioned earlier, OMB also has the 

authority to delegate to agencies the authority to approve collections in various 

circumstances. It may choose to delegate such authority at agencies whose pilot projects 

demonstrate success in reducing burden through information management improvements 

of the types mentioned. 

Page 23 GAO-06-477T
In developing processes to involve program offices in burden 

reduction, agencies would not have to impose a particular 

organizational structure for the burden reduction effort. For 

instance, the burden reduction effort might not necessarily be 

performed by the CIO. For example, at IRS, the Office of Burden 

Reduction is not connected to the CIO, whereas at EPA, CIO staff 

are involved in promoting burden reduction through staff education 

and outreach. However, the EPA CIO depends on program offices to 

undertake specific initiatives. Under a mandate for pilot projects, 

agencies would be encouraged to determine the approach that 

works best in their own situations. 

Finally, both IRS and EPA engaged in extensive outreach to the 

public and stakeholders. In many cases, this outreach involves 

contacts with professional and industry organizations, which are 

particularly valuable because they allow the agencies to get 

feedback without the need to design an information collection for 

the purpose (which would entail its own review process, burden 

estimate, and so on). According to agency officials, the need to 

obtain OMB approval for an information collection if they contact 

more than nine people often inhibits agencies’ use of questionnaires 

and similar types of active outreach to the public.28 Agencies are 

free, however, to collect comments on information posted on Web 

sites. OMB could also choose to delegate to pilot project agencies 

the authority to approve collections that are undertaken as part of 

public outreach for burden reduction projects. 

The work we reported in May and June 2005 strongly suggested that 

despite the importance of public consultation to burden reduction, 

the current approach is often ineffective. Federal Register notices 

elicit such low response that we questioned the need for two such 

notices (the 60-day notice during the agency review and the 30-day 

notice during the OMB review). Eliminating the first notice, in our 

 28 In certain instances, agencies may be able to get “generic clearances” if they routinely 

conduct information collections using very similar methods. For example, an agency may 

want to develop a generic customer satisfaction survey that can be customized for use with 

different groups. See Memorandum to the President’s Management Council from the 

Administrator, Office of Information and Regulatory Affairs, OMB, “Guidance on Agency

Survey and Statistical Information Collections” (Washington, D.C.: Jan. 20, 2006). 

Page 24 GAO-06-477T
view, is thus not likely to decrease public consultation in any 

significant way. Instead, our intent was for agencies, through pilot 

projects, to explore ways to perform outreach to information 

collection stakeholders, including the public, that will be more 

effective in eliciting useful comments and achieving real reductions 

in burden. 

In summary, Madam Chairman, the information collection review 

process appeared to have little effect on paperwork burden. As our

review showed, the CIO review process, as currently implemented, 

tended to lack rigor, allowing agencies to focus on clearing an 

administrative hurdle rather than on performing substantive 

analysis. Going further, the expert forum characterized the whole 

clearance process as “pro forma.” The forum also made various 

suggestions for improving the clearance process; many of these 

were aimed at finding ways to reduce its absorption of OMB 

resources, such as by changing the definition of an information 

collection. Both we and the forum suggested removing one of the 

current administrative hurdles (the 60-day Federal Register notice). 

Although these suggestions refer to specific process improvements, 

the main point is not just to tweak the process. Instead, the intent is

to remove administrative impediments, with the ultimate aim of 

refocusing agency and OMB attention away from the current 

concentration on administrative procedures and toward the goals of 

the act—minimizing burden while maximizing utility. To that end, 

we suggested that the Congress mandate pilot projects that are 

specifically targeted at reducing burden. Such projects could help to 

move toward the outcomes that the Congress intended in enacting 

PRA. 

Madam Chairman, this completes my prepared statement. I would 

be pleased to answer any questions. 

Page 25 GAO-06-477T
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 Timothy Bober, Barbara Collier, David 

Plocher, Elizabeth Powell, J. Michael Resser, and Alan Stapleton. 

Page 26 GAO-06-477T
Attachment 1. Forum: The Legislative 

Framework for Information Resources 

Management 

Forum Participants 

Prudence S. Adler Associate Executive Director Association 

of Research Libraries 

William Barron Princeton University; formerly National 

Opinion Research Center 

Gary Bass Founder and Executive Director, OMB 

Watch 

Maya Bernstein Administrative Law & Information Policy; 

formerly OMB and IRS Privacy Officer 

Daniel Chenok Vice President, SRA International; 

formerly OMB 

Sharon S. Dawes Director, Center for Technology in 

Government, University at Albany, State 

University of New York 

James Flyzik Partner, Guerra, Kiviat, Flyzik and 

Associates; formerly Department of 

Treasury and Secret Service 

Robert M. Gellman Privacy & Information Policy Consultant; 

formerly counsel to the House of 

Representatives’ Subcommittee on

Information, Justice, Transportation and 

Agriculture 

Page 27 GAO-06-477T
Harry A. Hammitt Editor of Access Reports, FOIA Journal 

Jefferson Hill Independent Consultant; formerly OMB 

Sally Katzen Professor and Independent Consultant; 

formerly OMB 

Andrew Langer Manager, Regulatory Policy National 

Federation of Independent Business 

David LeDuc Director, Public Policy, Software & 

Information Industry Association

Herb Lin Senior Scientist, Computer Science and 

Telecommunications Board, The National 

Academies 

Jeffrey Lubbers Fellow in Law and Government, American 

University, Washington College of Law; 

formerly Administrative Conference of the 

U.S. 

Charles McClure Francis Epps Professor and Director, 

Information Use Management & Policy 

Institute, Florida State University 

David L. McClure Research Director Gartner; formerly 

Council for Excellence in Government and 

GAO 

Bruce McConnell President and Founder, McConnell 

International; formerly OMB 

Patrice McDermott Deputy Director, Office of Government 

Relations, American Library association 

Michael McGill McGill Associates and Internet2 

Lynn McNulty Consultant, McConnell International, LLC; 

formerly NIST 

Page 28 GAO-06-477T
Doug Robinson Executive Director, National Association 

of State Chief Information Officers 

J. Timothy Sprehe President, Sprehe Information 

Management Associates 

Ari Schwartz Associate Director, Center for Democracy 

and Technology 

Miron Straf Deputy Director, Division of Behavioral 

and Social Sciences and Education, The 

National Academies 

Jeanne Young Independent Consultant; formerly Federal 

Reserve Board of Governors Records 

Officer and NAGARA officer 

Others in Attendance 

At the forum, others attending included GAO staff and a number of 

other observers: 

Donald Arbuckle Deputy Administrator, Office of 

Information and Regulatory Affairs 

Michelle Ash Minority Senior Legislative Counsel, 

House Committee on Government Reform 

Krista Boyd Minority Counsel, House Committee on 

Government Reform 

Curtis Copeland Congressional Research Service 

Dan Costello Policy Analyst, Office of Information and 

Regulatory Affairs 

Michael Formica Director of Energy and Environment, U.S. 

Chamber of Commerce 

Page 29 GAO-06-477T
Eva Kleederman Senior Policy Analyst, Office of 

Management and Budget 

Kristy Lalonde Policy Analyst, Office of Management and 

Budget 

David McMillen Minority Professional Staff Member, 

House Committee on Government Reform 

Jim Moore Counsel, House Committee on 

Government Reform 

Kim Nelson Policy Analyst, Office of Management and 

Budget 

Lew Oleinick Office of Information and Regulatory 

Affairs 

Kenneth Peskin U.S. Chamber of Commerce 

Victoria Proctor Senior Professional Staff Member, House 

Committee on Government Reform 

Edward Schrock House Committee on Government Reform 

Katherine Wallman Branch Chief, Statistics Branch, Office of 

Information and Regulatory Affairs 

In addition, staff of the National Academies’ National Research 

Council, Computer Science and Telecommunications Board, helped 

to develop and facilitate the forum: Charles Brownstein, Director; 

Kristen Batch, Research Associate; and Margaret Huynh, Senior 

Program Assistant. 

Page 30 GAO-06-477T
Related GAO Products 

Paperwork Reduction Act: Subcommittee Questions Concerning 

the Act’s Information Collection Provisions. GAO-05-909R. 

Washington, D.C.: July 19, 2005. 

Paperwork Reduction Act: Burden Reduction May Require a New 

Approach. GAO-05-778T. Washington, D.C.: June 14, 2005. 

Paperwork Reduction Act: New Approach May Be Needed to 

Reduce Government Burden on Public. GAO-05-424. Washington, 

D.C.: May 20, 2005. 

Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates 

Due to Federal Actions Continue to Increase. GAO-04-676T. 

Washington, D.C.: April 20, 2004.

Paperwork Reduction Act: Record Increase in Agencies’ Burden 

Estimates. GAO-03-619T. Washington, D.C.: April 11, 2003. 

Paperwork Reduction Act: Changes Needed to Annual Report.

GAO-02-651R. Washington, D.C.: April 29, 2002. 

Paperwork Reduction Act: Burden Increases and Violations 

Persist. GAO-02-598T. Washington, D.C.: April 11, 2002.

Information Resources Management: Comprehensive Strategic 

Plan Needed to Address Mounting Challenges. GAO-02-292. 

Washington, D.C.: February 22, 2002. 

Paperwork Reduction Act: Burden Estimates Continue to Increase.

GAO-01-648T. Washington, D.C.: April 24, 2001. 

Electronic Government: Government Paperwork Elimination Act 

Presents Challenges for Agencies. GAO/AIMD-00-282. Washington, 

D.C.: September 15, 2000. 

Tax Administration: IRS Is Working to Improve Its Estimates of

Compliance Burden. GAO/GGD-00-11. Washington, D.C.: May 22, 

2000. 

Page 31 GAO-06-477T
Paperwork Reduction Act: Burden Increases at IRS and Other 

Agencies. GAO/T-GGD-00-114. Washington, D.C.: April 12, 2000.

EPA Paperwork: Burden Estimate Increasing Despite Reduction 

Claims. GAO/GGD-00-59. Washington, D.C.: March 16, 2000. 

Federal Paperwork: General Purpose Statistics and Research 

Surveys of Businesses. GAO/GGD-99-169. Washington, D.C.: 

September 20, 1999. 

Paperwork Reduction Act: Burden Increases and Unauthorized 

Information Collections. GAO/T-GGD-99-78. Washington, D.C.: April 

15, 1999. 

Paperwork Reduction Act: Implementation at IRS. GAO/GGD-99-4. 

Washington, D.C.: November 16, 1998. 

Regulatory Management: Implementation of Selected OMB 

Responsibilities Under the Paperwork Reduction Act. GAO/GGD98-120. Washington, D.C.: July 9, 1998. 

Paperwork Reduction: Information on OMB’s and Agencies’ 

Actions. GAO/GGD-97-143R. Washington, D.C.: June 25, 1997. 

Paperwork Reduction: Governmentwide Goals Unlikely to Be Met.

GAO/T-GGD-97-114. Washington, D.C.: June 4, 1997. 

Paperwork Reduction: Burden Reduction Goal Unlikely to Be Met.

GAO/T-GGD/RCED-96-186. Washington, D.C.: June 5, 1996. 

Environmental Protection: Assessing EPA’s Progress in

Paperwork Reduction. GAO/T-RCED-96-107. Washington, D.C.: 

March 21, 1996. 

Paperwork Reduction: Burden Hour Increases Reflect New 

Estimates, Not Actual Changes. GAO/PEMD-94-3. Washington, D.C.: 

December 6, 1993. 

 (310753) Page 32 GAO-06-477T
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