United States Government Accountability Office

GAO Report to Congressional Requesters

FEDERAL 

INFORMATION 

COLLECTION 

A Reexamination of 

the Portfolio of Major 

Federal Household 

Surveys Is Needed 

November 2006 

 

GAO-07-62 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-07-62.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Bernice 

Steinhardt at (202) 512-6543 or 

steinhardtb@gao.gov. 

Highlights of GAO-07-62, a report to 

congressional requesters 

November 2006

FEDERAL INFORMATION COLLECTION

A Reexamination of the Portfolio of Major 

Federal Household Surveys Is Needed 

At the time of GAO’s review, the Office of Management and Budget (OMB) 

had approved 584 ongoing federal statistical or research surveys, of which 40 

percent were administered to individuals and households. Under the 

Paperwork Reduction Act, agencies are to certify to OMB that each 

information collection does not unnecessarily duplicate existing 

information, and OMB is responsible for reviewing the content of agencies’ 

submissions. OMB provides guidance that agencies can use to comply with 

the approval process and avoid unnecessary duplication, which OMB defines 

as information similar to or corresponding to information that could serve 

the agency’s purpose and is already accessible to the agency. 

Based on this definition, the seven surveys GAO reviewed could be 

considered to contain necessary duplication. GAO identified three subject 

areas, people without health insurance, people with disabilities, and housing, 

covered in multiple major surveys that could potentially involve unnecessary 

duplication. Although they have similarities, most of these surveys originated 

over several decades, and differ in their purposes, methodologies, 

definitions, and measurement techniques. These differences can produce 

widely varying estimates on similar subjects. For example, the estimate for 

people who were uninsured for a full year from one survey is over 50 percent 

higher than another survey’s estimate for the same year. While agencies have 

undertaken efforts to standardize definitions and explain some of the 

differences among estimates, these issues continue to present challenges. In 

some cases, agencies have reexamined their existing surveys to reprioritize, 

redesign, combine, and eliminate some of them. Agencies have also used 

administrative data in conjunction with their surveys to enhance the quality 

of information and limit respondent burden. These actions have been 

limited in scope, however. In addition, two major changes to the portfolio of 

major federal household surveys are underway. The American Community 

Survey is intended to replace the long-form decennial census starting in 

2010. This is considered to be the cornerstone of the government’s efforts to 

provide data on population and housing characteristics and will be used to 

distribute billions of dollars in federal funding. Officials are also redesigning 

the Survey of Income and Program Participation which is used in estimating 

future costs of certain government benefit programs. 

In light of these upcoming changes, OMB recognizes that the federal 

government can build upon agencies’ practices of reexamining individual 

surveys. To ensure that surveys initiated under conditions, priorities, and 

approaches that existed decades ago are able to cost-effectively meet 

current and emerging information needs, there is a need to undertake a 

comprehensive reexamination of the long standing portfolio of major federal 

household surveys. The Interagency Council on Statistical Policy (ICSP), 

which is chaired by OMB and made up of the heads of the major statistical 

agencies, is responsible for coordinating statistical work and has the 

leadership authority to undertake this effort.

Federal statistical information is 

used to make appropriate decisions 

about budgets, employment, and 

investments. GAO was asked to 

(1) describe selected 

characteristics of federally funded 

statistical or research surveys, 

(2) describe agencies’ and OMB’s 

roles in identifying and preventing 

unnecessary duplication, (3) 

examine selected surveys to assess 

whether unnecessary duplication 

exists in areas with similar subject 

matter, and (4) describe selected 

agencies’ efforts to improve the 

efficiency and relevance of surveys. 

GAO reviewed agency documents 

and interviewed officials. Using 

this information and prior GAO 

work, GAO identified surveys with 

potential unnecessary duplication. 

What GAO Recommends

Upcoming changes provide an 

opportunity to go beyond 

individual agency efforts and 

examine the portfolio of major 

federal household surveys. 

Therefore, GAO recommends that 

the Director of OMB work with the 

ICSP to plan for a comprehensive 

reexamination to redesign or 

reprioritize the major federal 

household surveys. OMB and the 

Department of Housing and Urban 

Development agreed with GAO’s 

recommendation. The Department 

of Health and Human Services 

stated that a reexamination was 

not warranted without evidence of 

unnecessary duplication, but GAO's 

recommendation is based on other 

factors, including the upcoming 

changes. 
Contents 

Letter 1

Results in Brief 5

Background 7

More Than 500 Statistical or Research Surveys Have Been 

Approved 10

Agencies and OMB Have Procedures Intended to Identify and

Prevent Unnecessary Duplication 17 

Duplicative Content in Selected Surveys Exists, but Survey 

Purposes and Scope Differ 20 

Agencies Have Undertaken Efforts to Improve the Efficiency and 

Relevance of Surveys 30 

Conclusions 33

Recommendation for Executive Action 34 

Agency Comments 35 

Appendix I Scope and Methodology 37 

Appendix II Comments from the Department of Housing and 

Urban Development 41 

Appendix III Comments from the Department of Health & 

Human Services 43 

Appendix IV GAO Contact and Staff Acknowledgments 46 

Tables 

Table 1: Selected Surveys That Cover Similar Content in Three 

Subject Areas 4 

Table 2: Characteristics of Selected Research and Statistical 

Surveys 14

Table 3: Uninsured Estimates from Selected Surveys 23 

Table 4: Estimated Population of Persons with Disabilities, by Data 

Source and Different Categories of Disability 26 

Page i GAO-07-62 Federal Information Collection
Figures 

Figure 1: Primary Purpose of OMB-approved Information 

Collections 11

Figure 2: Respondents to OMB-approved Statistical and Research 

Surveys 12

Figure 3: Burden Hour Ranges of the 584 Research and General 

Purpose Statistics Surveys 13 

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Page ii GAO-07-62 Federal Information Collection
United States Government Accountability Office

Washington, DC 20548 

November 15, 2006 

The Honorable Tom Davis 

Chairman, Committee on Government Reform 

House of Representatives 

The Honorable Michael R. Turner 

Chairman, Subcommittee on Federalism and the Census 

Committee on Government Reform 

House of Representatives 

Governments, businesses, and citizens depend on relevant and timely 

statistical information from federal statistics to make appropriate 

decisions about budgets, employment, investments, and many other 

essential topics. Given the importance of federally funded surveys to the 

quality of statistical information, and the ever-increasing demand for more 

and better information within limited resources, it is essential to maximize

their utility. To this end, officials implementing federally funded surveys 

must avoid unnecessary duplication with existing information sources, as 

mandated by the Paperwork Reduction Act of 1980 (PRA), as amended, 

and work to ensure efficiency in areas where subject matter is similar.1

 As 

highlighted in our 21st Century Challenges report, the federal government 

must address and adapt to a range of major trends and challenges in the 

nation and the world—including, among other things, a long-term 

structural fiscal imbalance and a transformation to a knowledge-based 

economy.2

 Statistical programs are likely to continue to face constrained 

resources in the future, and the changing information needs of our society

and economy raise important questions regarding the portfolio of major 

federal household surveys—a portfolio that has been developing for more 

than six decades in response to conditions and information needs that 

have changed over time.

In light of the importance of minimizing unnecessary duplication between 

statistical and research surveys, at your request this report (1) identifies 

 1

 The PRA was enacted in 1980 and has been amended several times. 44 U. S. C. §§ 3501 - 

3521. 

2

 GAO, 21st Century Challenges: Reexamining the Base of the Federal Government, 

GAO-05-325SP (Washington, D.C.: February 2005). 

Page 1 GAO-07-62 Federal Information Collection
the number and selected characteristics of Office of Management and 

Budget (OMB)-approved federally funded statistical or research surveys, 

(2) describes agencies’ and OMB’s roles in identifying and preventing 

unnecessary duplication, (3) examines selected surveys to assess whether 

unnecessary duplication exists in areas with similar subject matter, and 

(4) describes selected efforts agencies have used to improve the efficiency

and relevance of surveys. OMB defines the term unnecessary duplication 

as information similar to or corresponding to information that could serve 

the agency’s purpose and is already accessible to the agency. Therefore, as 

agreed, our review focused on several surveys that we identified as having

the potential for being unnecessarily duplicative because they contain

similar information. 

To address the first objective to identify the number and characteristics of 

OMB-approved federally funded surveys, we reviewed the information 

collections that OMB approved under the PRA. We used information from

the database of OMB-approved federally funded information collections.3

In 2005 we conducted a reliability assessment of the database of OMBapproved information collections and concluded that the data were 

accurate and complete for the purposes of that report.4

 Because this 

assessment was recent, we decided that we would not repeat this 

assessment. As OMB’s approval can be in effect for a maximum of 3 years,

and may be for a shorter period, our review reflects a snapshot in time of 

all those collections that OMB had approved for use as of August 7, 2006. 

We focused on two categories of information collections: general purpose 

statistics, which are surveys whose results are to be used for statistical 

compilations of general public interest, and research surveys.5

For the second objective to describe agencies’ and OMB’s roles in 

identifying and preventing unnecessary duplication, we reviewed the PRA 

requirements for both agencies and OMB. We interviewed clearance 

officers from the Departments of Commerce, Labor, and Health and

 3

 The database of OMB-approved federally funded information collections is administered 

by the General Service Administration, which works closely with OMB. 

4

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

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

5

 OMB Form 83-I provides seven categories for agencies’ use in designating the purpose for 

the proposed information collection: application for benefits, program evaluation, general 

purpose statistics, audit, program planning or management, research, regulatory, and 

compliance. 

Page 2 GAO-07-62 Federal Information Collection
Human Services to learn about their processes for submitting the 

information collection packages to OMB. These agencies were the top 

three agencies in terms of funding for statistical activities in fiscal year 

2006. We also interviewed OMB officials regarding their role in approving 

information collections.

For the third objective to examine selected surveys to assess whether 

unnecessary duplication exists in areas with similar subject matter, we 

reviewed our reports and literature and interviewed agency officials to 

identify areas of similar content covered in multiple surveys. We

subsequently identified three subject areas with potentially unnecessary 

duplication based on similar content in the surveys: (1) people without 

health insurance, (2) those with disabilities, and (3) housing. Once we had 

identified these three subject areas, we analyzed information from 

literature and interviews we conducted to identify the current federally 

funded surveys that were cited as the major surveys on people without 

health insurance (Current Population Survey (CPS), National Health 

Interview Survey (NHIS), Medical Expenditure Panel Survey (MEPS), and 

Survey of Income and Program Participation (SIPP)) and disability (NHIS, 

National Health and Nutrition Examination Survey (NHANES), MEPS, 

SIPP, and the American Community Survey (ACS)) as shown in table 1. 

For the third area, housing, we relied on our earlier report that identified

the potential unnecessary duplication between the ACS and American 

Housing Survey (AHS).6

 One of the surveys we included, the Census 

Bureau’s SIPP, will be reengineered. However, the content of the 

redesigned SIPP has not been determined, and as a result, it may continue 

to include questions on disability and people without health insurance, so 

we have included information relative to this long-standing survey in this

report. 

 6

 GAO, The American Community Survey: Accuracy and Timeliness Issues, GAO-02-956R 

(Washington D.C.: Sept. 30, 2002). 

Page 3 GAO-07-62 Federal Information Collection
Table 1: Selected Surveys That Cover Similar Content in Three Subject Areas 

Survey Purpose

People

without 

health

insurance Disability Housing 

American 

Community Survey 

(ACS) 

Will replace the decennial 

census long-form, and 

monitors changes in 

communities. 

X X

American Housing 

Survey (AHS) 

Collects data on the nation’s 

housing, including income, 

neighborhood quality, costs, 

equipment and fuels, and 

movement. 

X

Current Population 

Survey (CPS) and 

the Annual Social 

and Economic 

Supplement 

(ASEC) 

Obtains information on labor 

force characteristics for the 

U.S. population. (The ASEC 

in addition covers income, 

noncash benefits, and 

migration). 

X

Medical

Expenditure Panel 

Survey (MEPS) 

Provides extensive 

information on health care 

use and costs. 

X X

National Health and 

Nutrition 

Examination 

Survey (NHANES) 

Assesses the health and 

nutritional status of adults 

and children. 

X

National Health 

Interview Survey 

(NHIS) 

Monitors health of U.S. 

population on a variety of 

health topics. 

X X

Survey of Income 

and Program 

Participation (SIPP)

Collects source and amount 

of income, labor force 

information, program 

participation and eligibility 

data, and general 

demographic characteristics 

to measure the effectiveness 

of existing federal, state, and 

local programs and to 

estimate future costs and 

coverage for government 

programs. 

X X

Source: GAO analysis of selected surveys. 

To learn more about the potentially duplicative content between these 

surveys, we reviewed relevant literature and agency documents. We also 

interviewed officials from OMB, Census Bureau at the Department of 

Commerce (DOC), the Bureau of Labor Statistics (BLS) at the Department 

Page 4 GAO-07-62 Federal Information Collection
of Labor (DOL), the National Center for Health Statistics (NCHS) and the 

Agency for Healthcare Research and Quality (AHRQ) at the Department of 

Health and Human Services (HHS), and the Division of Housing and 

Demographic Analysis at the Department of Housing and Urban 

Development (HUD). We also interviewed experts from organizations that 

focus on federal statistics, such as the Council of Professional 

Associations on Statistics and the Committee on National Statistics, 

National Academies of Science. 

For the fourth objective, to describe selected agency efforts to improve the 

efficiency and relevance of surveys, we analyzed information from agency 

and OMB interviews, expert interviews as discussed above, and literature. 

We conducted our work in accordance with generally accepted 

government auditing standards from April 2005 through June 2006. 

Appendix I provides a more complete description of our scope and 

methodology. 

At the time of our review, OMB had approved 584 new and ongoing federal 

statistical or research surveys7

 of which 40 percent were administered to 

individuals and households. About 35 percent of the approved statistical 

and research surveys each required 1,000 or less annual estimated burden 

hours (i.e., the amount of time for an average respondent to complete a 

survey, multiplied by the total number of respondents). 

Results in Brief 

Under the PRA, agencies are responsible for certifying to OMB that each

information collection does not unnecessarily duplicate existing 

information. OMB defines unnecessary duplication as information that is 

similar to or corresponding to information that could serve the agency’s 

purpose and is already accessible to the agency. In prior work, we found 

that some of these certifications were made without complete supporting 

information.8

 When approving a survey, OMB is required to review the 

content of the agency’s submission to ensure that each information 

collection is not unnecessarily duplicative. OMB also provides guidance 

that agencies can use to comply with the approval process, including 

guidance on when it is acceptable to duplicate questions in other surveys. 

 7

 The data are current as of August 7, 2006. OMB’s approvals may be in effect for up to 3 

years and include new and ongoing information collections. 

8

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

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

Page 5 GAO-07-62 Federal Information Collection
An agency may consult with OMB before it submits an information 

collection for approval, and officials told us that early consultation can

help identify and prevent unnecessary duplication. 

Based on OMB’s definition of unnecessary duplication, the surveys we 

reviewed could be considered to contain necessary duplication. The seven

surveys we reviewed have duplicative content and in some cases ask the 

same or similar questions in three subject areas: (1) people without health

insurance (CPS, NHIS, MEPS, and SIPP), (2) people with disabilities 

(NHIS, NHANES, MEPS, SIPP, and ACS), and (3) housing (AHS and ACS). 

However, the agencies and OMB judged that this was not unnecessary 

duplication given the differences among the surveys. The surveys 

originated at various times over several decades, and some differ in their 

purposes and methodologies (such as the sampling methodologies) as well 

as in their definitions and measurement techniques (such as the time 

frames used). In some instances, the ability to link this information with 

other questions in the same survey can yield richer data that allow for a 

fuller description or understanding of specific topics. However, the 

resulting estimates of similar characteristics can be very different, which 

can be confusing. For example, the 2004 CPS estimate for people who 

were uninsured for a full year is over 50 percent higher than the NHIS 

estimate of the number of uninsured for that year. Interagency groups 

have undertaken efforts to explain or reconcile inconsistencies among 

surveys that address the same subject area, such as explaining the 

differences between estimates of the number of uninsured persons. 

In some cases, agencies have taken steps to enhance the relevance and 

efficiency of their surveys. For example, the Census Bureau undertook a 

review of its portfolio of manufacturing surveys and decided to eliminate 

several in order to undertake new surveys on the industrial sectors that 

were of growing importance to the economy. Agencies have also used 

administrative data in conjunction with their surveys, which has enhanced

the quality of the information and limited respondent burden. 

At the same time, there are two major changes upcoming to the portfolio 

of major federal household surveys. The ACS, which is intended to replace 

the long-form decennial census in 2010, is considered to be the 

cornerstone of the government’s efforts to provide data on population and

housing characteristics and will be used to distribute billions of dollars in 

federal funding. Efforts are also underway to redesign the SIPP, which is 

used in estimating future costs of certain government benefit programs. In 

light of these upcoming changes, OMB recognizes that the federal 

government should build upon agencies’ practice of reexamining 

Page 6 GAO-07-62 Federal Information Collection
individual surveys. Providing greater coherence among surveys, 

particularly in definitions and time frames, could help reduce costs to the 

federal government and associated burden hours. The Interagency Council 

on Statistical Policy, which is chaired by OMB and made up of the heads of 

the major statistical agencies, is responsible for coordinating statistical 

work and has the leadership authority to undertake a comprehensive 

reexamination of the portfolio of major federal household surveys. 

The rollout of the ACS and the reengineering of the SIPP provide an

opportunity to go beyond these individual efforts to examine the 

effectiveness and efficiency of the portfolio of major household surveys 

that have developed over six decades. Therefore, we are recommending 

that the Director of OMB work with the Interagency Council on Statistical 

Policy to plan for a comprehensive reexamination to identify opportunities 

for redesigning or reprioritizing the portfolio of major federal household 

surveys. Such a reexamination would identify opportunities to ensure that

major federal household surveys initiated under conditions, priorities, and 

approaches that existed decades ago are able to cost-effectively meet 

current and emerging information needs. 

OMB and HUD agreed with our recommendation but OMB officials 

expressed concerns about the range of participants and the universe of 

surveys that might be involved in such a reexamination. In response, we 

revised the recommendation to clarify that OMB should work with the 

ICSP and focused the recommendation on seven surveys that are 

considered to be major federal household surveys. HHS stated that a 

reexamination was not warranted without evidence of unnecessary 

duplication, but our recommendation is based on other factors, including a 

need to provide greater coherence among the surveys and to take 

advantage of changes in the statistical system to reprioritize information 

needs and possibly help reduce costs to the federal government and 

associated burden hours. HHS also provided additional information that 

we incorporated as appropriate in the report. In addition, we obtained 

written comments from the DOC and informal electronic comments from 

the DOL, which we incorporated as appropriate in the report.

The purpose of the PRA is to (1) minimize the federal paperwork burden 

for individuals, small businesses, state and local governments, and other 

persons; (2) minimize the cost to the federal government of collecting,

maintaining, using, and disseminating information; and (3) maximize the 

usefulness of information collected by the federal government. The PRA 

also aims to provide for timely and equitable dissemination of federal 

Background 

Page 7 GAO-07-62 Federal Information Collection
information; improve the quality and use of information to increase 

government accountability at a minimized cost; and manage information 

technology to improve performance and reduce burden, while improving 

the responsibility and accountability of OMB and the federal agencies to 

Congress and the public.

To achieve these purposes, the PRA prohibits federal agencies from 

conducting or sponsoring an information collection unless they have prior 

approval from OMB. The PRA requires that information collections be 

approved by OMB when facts or opinions are solicited from 10 or more 

people. Under the law, OMB is required to determine that an agency

information collection is necessary for the proper performance of the 

functions of the agency, including whether the information will have 

practical utility. 

The PRA requires every agency to establish a process for its chief 

information officer (CIO) to review program offices’ proposed information 

collections, such as certifying that each proposed collection complies with 

the PRA, including ensuring that it is not unnecessarily duplicative. The 

agency is to provide two public notice periods—an initial 60-day notice 

period and a 30-day notice period after the information collection is 

submitted to OMB for approval.9

 Agencies are responsible for consulting 

with members of the public and other affected agencies to solicit 

comments on, among other things, ways to minimize the burden on 

respondents, including through the use of automated collection techniques 

or other forms of information technology. According to an OMB official, 

this could include asking for comments on a proposal to use 

administrative data instead of survey data. 

Following satisfaction of these requirements, an agency is to submit its 

proposed information collection for OMB review, whether for new 

information collections or re-approval of existing information collections. 

Before an agency submits a proposed information collection for approval, 

an agency may invest substantial resources to prepare to conduct an 

information collection. An agency may undertake, among other things, 

designing the information collection, testing, and consulting with users. 

For example, over the last 8 years, BLS has led an interagency effort 

 9

 We have suggested that Congress eliminate the 60-day Federal Register notice from the 

agency clearance process, since these notices elicit few comments. GAO, Paperwork 

Reduction Act: New Approach May Be Needed to Reduce Government Burden on Public,

GAO-05-424 (Washington, D.C.: May 20, 2005). 

Page 8 GAO-07-62 Federal Information Collection
designed to develop a measure of the employment rate of adults with 

disabilities pursuant to Executive Order 13078 signed by President Clinton 

in 1998. This effort has entailed planning, developing, and testing disability 

questions to add to the CPS. OMB is responsible for determining whether 

each information collection is necessary for the proper performance of the 

agency’s functions. According to the Statistical Programs of the United 

States Government: Fiscal Year 2006, an estimated $5.4 billion in fiscal 

year 2006 was requested for statistical activities.10

The PRA also requires the establishment of the Interagency Council on 

Statistical Policy (ICSP). According to the Statistical Programs of the 

United States Government: Fiscal Year 2006, the ICSP is a vehicle for 

coordinating statistical work, particularly when activities and issues cut 

across agencies; for exchanging information about agency programs and 

activities; and for providing advice and counsel to OMB on statistical 

matters. 

The PRA also requires OMB to annually report on the paperwork burden 

imposed on the public by the federal government and efforts to reduce this

burden, which is reported in Managing Information Collection: 

Information Collection Budget of the United States Government. For 

example, the 2006 Information Collection Budget reported on agency 

initiatives to reduce paperwork, such as HHS’s assessment of its 

information collections with a large number of burden hours, which 

resulted in reducing the department’s overall burden hours by over 

36 million in fiscal year 2005. 

OMB produces the annual Statistical Programs of the United States 

Government report to fulfill its responsibility under the PRA to prepare an 

annual report on statistical program funding. This document outlines the 

effects of congressional actions and the funding for statistics proposed in 

the President’s current fiscal year budget, and highlights proposed 

program changes for federal statistical activities. It also describes a 

number of long-range planning initiatives to improve federal statistical 

 10 According to the Statistical Programs of the United States Government: Fiscal Year

2006, approximately 40 percent of the funding for statistical programs provides resources

for 10 agencies that have statistical activities as their principal mission. The remaining 

funding is spread among almost 70 other agencies that carry out statistical activities in 

conjunction with other program missions, such as providing services or enforcing 

regulations. 

Page 9 GAO-07-62 Federal Information Collection
programs, including making better use of existing data collections while 

protecting the confidentiality of statistical information. 

At the time of our review, OMB had approved 584 new and ongoing 

statistical and research surveys as recorded in the database of OMBapproved information collections. OMB uses the database for tracking 

purposes, as it provides the only centralized information available on the 

characteristics of the surveys that OMB has approved. The database 

contains information on some, but not all, of the characteristics of the 

information collections. The information that agencies provide in the 

packages they submit to OMB for approval includes additional data, such

as the estimated cost. 

More Than 500 

Statistical or 

Research Surveys 

Have Been Approved 

Statistical and research surveys represent about 7 percent of the total 

universe of 8,463 OMB-approved information collections, the majority of 

which, as shown in figure 1, are for regulatory or compliance and 

application for benefits purposes. Although there are certain surveys 

funded through grants and contracts that are not approved by OMB under 

the PRA, OMB stated that there is no comprehensive list of these surveys.

11

 11 As referenced in OMB’s draft guidance on agency information collections, surveys 

conducted by recipients of federal funding generally do not require OMB approval. 

However, there are circumstances where the survey may require OMB approval. See

appendix I for explanation. 

Page 10 GAO-07-62 Federal Information Collection
Figure 1: Primary Purpose of OMB-approved Information Collections

Forty percent of OMB-approved statistical and research surveys were 

administered to individuals and households, as shown in figure 2. 

Page 11 GAO-07-62 Federal Information Collection
Figure 2: Respondents to OMB-approved Statistical and Research Surveys 

Annual estimated burden hours are defined as the amount of time for the 

average respondent to fill out a survey times the number of respondents.12

Figure 3 shows the range of burden hours, for general purpose research 

and statistics information collections, with about 35 percent of the surveys 

each accounting for 1,000 or fewer total burden hours. 

 12 We have reported that it is important to recognize that burden-hour estimates have 

limitations. Estimating the amount of time it will take for an individual to collect and 

provide information or how many individuals an information collection will affect is not a

simple matter. Therefore, the degree to which agency burden-hour estimates reflect real 

burden is unclear. Nevertheless, these are the best indicators of paperwork burden 

available, and we believe they can be useful as long as their limitations are kept in mind. 

GAO, The Paperwork Reduction Act: Burden Increases and Violations Persist

GAO-02-598T (Washington, D.C.: Apr. 11, 2002). 

Page 12 GAO-07-62 Federal Information Collection
Figure 3: Burden Hour Ranges of the 584 Research and General Purpose Statistics 

Surveys 

According to an OMB official, the electronic system, Regulatory 

Information Service Center Office of Information and Regulatory Affairs 

Consolidated Information System, has automated the agency submission 

and OMB review process. This new system, which was implemented in 

July of 2006, is intended to allow OMB and agency officials to search 

information collection titles and abstracts for major survey topics and key

words. 

Table 2 provides information from agency officials and documents for the 

selected surveys that we reviewed in more depth. For these seven surveys,

the sample sizes ranged from 5,000 individuals for the NHANES to 55,000 

housing units for the AHS. The NHANES has a much smaller sample size 

and greater cost (as compared to the other surveys with similar burden 

hours) because it includes both an interview and a physical examination in 

a mobile exam center. The physical examination can include body 

measurements and tests and procedures, such as a blood sample and 

dental screening, to assess various aspects of respondents’ health. Other 

Page 13 GAO-07-62 Federal Information Collection
differences among the surveys we reviewed included their specific 

purposes (e.g., to obtain health information or demographics data); the 

time period considered (some of the surveys provide data as of a certain

point in time while others are longitudinal and follow the same 

respondents over a period of time); and the frequency with which the 

surveys were conducted.

In addition, many of these surveys have been in existence for decades. Of

the seven surveys we reviewed, five are defined by the Statistical 

Programs of the United States Government Fiscal Year 2006 as major 

household surveys (ACS, AHS, CPS, NHIS, and SIPP), and in addition 

MEPS’s household sample is a sub-set of NHIS’s sample. The ACS, unlike 

the other surveys, is mandatory and will replace the decennial census 

long-form. In addition to the surveys that we reviewed, two other surveys, 

the Consumer Expenditure Surveys and the National Crime Victimization 

Survey, are also defined by the Statistical Programs of the United States 

Government of 2006 as major household surveys. 

Table 2: Characteristics of Selected Research and Statistical Surveys

Survey 

Sponsoring 

agency Purpose

Sample 

size 

Produces 

statelevel 

estimates

Survey 

frequency Longitudinal

2006 Cost 

(dollars in 

millions) 

Date 

originated

Annual 

burden 

hours

ACS Census 

Bureau, 

DOC 

Will replace the 

decennial 

Census longform, and 

monitors 

changes in 

communities 

3,122,900 

householdsa

X Monthly $169 Fully

Implemented 

January 

2005 

1,917,410

AHS HUD Collect data on

the nation’s 

housing, 

including 

income, 

neighborhood 

quality, costs, 

equipment and

fuels, and 

movement 

55,000 

(average) 

housing 

units for 

national 

component 

and about 

4,100 

housing 

units for 

each of the 

47 

metropolitan 

areas 

 Odd years 

for national 

sample 

Every 6 

years for 47 

metropolitan 

areas 

X $16 1973 30,517

Page 14 GAO-07-62 Federal Information Collection
Survey 

Sponsoring 

agency Purpose

Sample 

size 

Produces 

statelevel 

estimates

Survey 

frequency Longitudinal

2006 Cost 

(dollars in 

millions) 

Date 

originated

Annual 

burden 

hours

CPS and 

the 

Annual 

Social 

and 

Economic 

Supplement 

(ASEC) 

CPS: BLS, 

DOL and 

Census 

Bureau, 

DOC 

ASEC: 

Census 

Bureau, 

DOC 

Obtain 

information on 

labor force 

characteristics 

for the U.S. 

population (The

ASEC is the 

primary source

of detailed 

information on 

income and 

work experience

in the United 

States.) 

60,000 

households 

monthly for 

CPS; 

76,000 

annually for 

ASEC 

X Monthly for

CPS; 

February, 

March and 

April for 

ASEC 

 $62.7 for 

CPS; $2 

for ASCE 

1948 for 

the CPS 

34,980

MEPS AHRQ, HHS Provides

extensive 

information on 

health care use 

and costs. 

12,860 

householdsb

Annual X $55.3 1977 203,414

NHANES NCHS, HHS Assesses the 

health and 

nutritional status

of adults and 

children. 

5,000 

individuals 

Continuous $40.4 1960 62,974

NHIS NCHS, HHS Monitors health 

of U.S. 

population on a 

broad range of 

health topics. 

35,000 

households 

For larger 

statesc

Continuous $26 1957 39,837

Page 15 GAO-07-62 Federal Information Collection
Survey 

Sponsoring 

agency Purpose

Sample 

size 

Produces 

statelevel 

estimates

Survey 

frequency Longitudinal

2006 Cost 

(dollars in 

millions) 

Date 

originated

Annual 

burden 

hours

SIPP Census

Bureau, 

DOC 

Collects source

and amount of 

income, labor 

force 

information, 

program 

participation and 

eligibility data, 

and general 

demographic 

characteristics 

to measure the

effectiveness of

federal, state, 

and local 

programs, to 

estimate future 

costs, and 

coverage for 

government 

programs. 

26,000 

households 

Continuing 

with monthly 

interviews 

X $46.2 1983 148,028

Source: GAO analysis.

Note: The costs data were rounded to the nearest tenth of a million. 

a

Although the ACS’ annual sample size is 3,122,900, starting in 2006, data will be available annually

for all areas with populations of 65,000 or more. For smaller areas, it will take 3 to 5 years to

accumulate a large enough sample to produce annual data. For example, areas of 20,000 to 65,000 

can receive data averaged over 3 years. For rural areas, small urban neighborhoods or population 

groups of less than 20,000, it will take five years to accumulate a sample size comparable to the 

decennial census. These averages will be updated every succeeding year. 

b

In addition to the MEPS survey to households, MEPS also includes surveys to public and private 

employers to collect data on the number and types of private health insurance offered, benefits 

associated with those plans, premiums, contributions by employers and employees, eligibility 

requirements, and employer characteristics. 

c

According to a HHS official, depending on the year and the population being estimated, NHIS can 

produce state-level estimates for most states, with the exception of approximately 8 to10 smaller 

states. For example, using the 2004 NHIS data to estimate the number of people who do not have 

health insurance by state, HHS produced state-level data for all states except District of Columbia, 

Delaware, Iowa, North Dakota, New Hampshire, Rhode Island, South Dakota, and Wyoming. 

Page 16 GAO-07-62 Federal Information Collection
Agencies and OMB have procedures intended to identify and prevent 

unnecessary duplication in information collections. Agencies are 

responsible for certifying that an information collection is not 

unnecessarily duplicative of existing information as part of complying with 

OMB’s approval process for information collections. OMB has developed 

guidance that agencies can use in complying with the approval process. 

Once an agency submits a proposed information collection to OMB, OMB 

is required to review the agency’s paperwork, which includes the agency’s 

formal certification that the proposed information collection is not 

unnecessarily duplicative. 

Under the PRA, agencies are responsible for certifying that a proposed 

information collection does not unnecessarily duplicate an available 

information source. According to OMB’s draft Implementing Guidance for 

OMB Review of Agency Information Collection, the term unnecessary 

duplication is defined as information similar to or corresponding to 

information that could serve the agency’s purpose and need and is already

accessible to the agency. OMB guidance states the following:

Agencies and OMB 

Have Procedures 

Intended to Identify 

and Prevent 

Unnecessary 

Duplication 

Agencies are Responsible 

for Identifying and 

Preventing Unnecessary 

Duplication 

“For example, unnecessary duplication exists if the need for the proposed collection can be

served by information already collected for another purpose - such as administrative 

records, other federal agencies and programs, or other public and private sources. If 

specific information is needed for identification, classification, or categorization of

respondents; or analysis in conjunction with other data elements provided by the 

respondent, and is not otherwise available in the detail necessary to satisfy the purpose and 

need for which the collection is undertaken; and if the information is considered essential 

to the purpose and need of the collection, and/or to the collection methodology or analysis

of results, then the information is generally deemed to be necessary, and therefore not

duplicative within the meaning of the PRA and OMB regulation.” 13

When an agency is ready to submit a proposed information collection to 

OMB, the agency’s CIO is responsible for certifying that the information 

collection satisfies the PRA standards, including a certification that the 

information collection is not unnecessarily duplicative of existing 

 13 Office of Management and Budget, The Paperwork Reduction Act of 1995:

Implementing Guidance for OMB Review of Agency Information Collection, draft (Aug. 

16, 1999). 

Page 17 GAO-07-62 Federal Information Collection
information sources.14 We have previously reported that agency CIOs 

across the government generally reviewed information collections and 

certified that they met the standards in the act. However, our analysis of 

12 case studies at the Internal Revenue Service (IRS) and the Department 

of Veterans Affairs, HUD, and DOL, showed that the CIOs certified 

collections even though support was often missing or incomplete. For 

example, seven of the cases had no information and two included only 

partial information on whether the information collection avoided 

unnecessary duplication. Further, although the PRA requires that agencies 

publish public notices in the Federal Register and otherwise consult with 

the public, agencies governmentwide generally limited consultation to the 

publication of the notices, which generated little public comment. Without 

appropriate support and public consultation, agencies have reduced 

assurance that collections satisfy the standards in the act. We 

recommended that the Director of OMB alter OMB’s current guidance to

clarify the kinds of support that it asks agency CIOs to provide for 

certifications and to direct agencies to consult with potential respondents 

beyond the publication of Federal Register notices.15 OMB has not 

implemented these recommendations. 

OMB Is Responsible for 

Reviewing Agencies’ 

Efforts to Identify and 

Prevent Unnecessary 

Duplication 

OMB has three different guidance publications that agencies can consult 

in the process of developing information collection submissions, 

according to OMB officials. The three guidance publications address 

unnecessary duplication to varying degrees. The draft, Implementing 

Guidance for OMB Review of Agency Information Collection, provides, 

among other things, instructions to agencies about how to identify 

unnecessary duplication of proposed information collections with existing 

available information sources. 

OMB’s Questions and Answers When Designing Surveys for Information 

Collections discusses when it is acceptable to duplicate questions used in 

other surveys. The publication also encourages agencies to consult with 

OMB when they are proposing new surveys, major revisions, or large-scale 

 14 There are 10 information collection standards required by the PRA. The packages 

agencies submit to OMB typically include a copy of the survey instrument and a Paperwork 

Reduction Act Submission (Standard Form 83-I). The 83-I requires agencies to answer 

questions, and provide supporting documentation, about why the collection is necessary, 

whether it is new or an extension of a currently approved survey, whether it is voluntary or 

mandatory, and the estimated burden hours.

15 GAO-05-424. 

Page 18 GAO-07-62 Federal Information Collection
experiments or tests, before an information collection is submitted. For 

example, when BLS was developing its disability questions for the CPS, 

BLS officials stated that they consulted OMB on numerous occasions. 

OMB officials also said that when they are involved early in the process, it

is easier to modify an agency’s plan for an information collection. 

OMB officials told us that an agency consultation with OMB before an 

information collection is developed can provide opportunities to identify 

and prevent unnecessary duplication. For example, according to an OMB 

official, while OMB was working with the Federal Emergency Management 

Agency (FEMA) to meet the need for information on the impact of 

Hurricane Katrina, OMB identified a survey partially funded by the 

National Institute of Mental Health (NIMH) that was in the final stages of

design and would be conducted by Harvard University—the Hurricane 

Katrina Advisory Group Initiative. OMB learned that this survey, which 

was funded through a grant (and was not subject to review and approval 

under the PRA), planned to collect data on many of the topics that FEMA 

was interested in. OMB facilitated collaboration between FEMA and HHS 

and ultimately, FEMA was able to avoid launching a new survey by 

enhancing the Harvard study. 

OMB’s draft of the Proposed Standards and Guidelines for Statistical 

Surveys, which focuses on statistical surveys and their design and 

methodology, did not require that agencies assess potential duplication 

with other available sources of information as part of survey planning. We

suggested that OMB require that when agencies are initiating new surveys 

or major revisions of existing surveys they include in their written plans 

the steps they take to ensure that a survey is not unnecessary duplicative 

with available information sources. OMB has incorporated this suggestion. 

Under the PRA, OMB is responsible for reviewing proposed information 

collections to determine whether a proposed information collection meets 

the PRA criteria, which include a requirement that it not unnecessarily 

duplicate available information. According to an OMB official responsible 

for reviewing information collections, OMB’s review process consists of 

several steps. She said that once an agency has submitted the proposed 

information collection package to OMB, the package is sent to the 

appropriate OMB official for review. When there is a need for clarification 

or questions exist, this OMB official told us that OMB communicates with 

the agency either through telephone conferences or via e-mail. After 

approval, OMB is required to assign a number to each approved 

information collection, which the agencies are then to include on their 

information collection (e.g., survey) forms. 

Page 19 GAO-07-62 Federal Information Collection
In addition to its responsibilities for reviewing proposed information 

collections, OMB also contributes to or leads a wide range of interagency

efforts that address federal statistics. For example, OMB chairs the ICSP. 

The ICSP is a vehicle for coordinating statistical work, exchanging 

information about agency programs and activities, and providing advice 

and counsel to OMB on statistical matters. The council consists of the 

heads of the principal statistical agencies,16 plus the heads of the statistical 

units in the Environmental Protection Agency, IRS, National Science 

Foundation, and Social Security Administration (SSA). According to an 

OMB official, the ICSP can expand its membership for working groups to 

address specific topics. For example, the ICSP established an 

employment-related health benefits subcommittee and included non-ICSP

agencies, such as HHS’s AHRQ (which co-chaired the subcommittee). The 

ICSP member agencies exchange experiences and solutions with respect 

to numerous topics of mutual interest and concern. For example, in the 

past year, the council discussed topics such as 

• the revision of core standards for statistical surveys 

• opportunities for interagency collaboration on information technology 

development and investment and 

• sample redesign for the major household surveys with the advent of the 

ACS. 

On the basis of OMB’s definition of unnecessary duplication, the surveys 

we reviewed could be considered to contain necessary duplication. To 

examine selected surveys to assess the extent of unnecessary duplication 

in areas with similar subject matter, we looked at surveys that addressed 

three areas: (1) people without health insurance (CPS, NHIS, MEPS, and 

SIPP), (2) people with disabilities (NHIS, NHANES, MEPS, SIPP, and 

ACS), and (3) the housing questions on the AHS and ACS. We found that 

the selected surveys had duplicative content and asked similar questions 

in some cases. However, the agencies and OMB judged that this was not 

unnecessary duplication given the differences among the surveys. In some 

instances, the duplication among these surveys yielded richer data, 

allowing fuller descriptions of specific topics and providing additional 

Duplicative Content 

in Selected Surveys 

Exists, but Survey 

Purposes and Scope 

Differ 

 16 The principal statistical agencies are the Bureau of the Census, Bureau of Economic 

Analysis, Bureau of Justice Statistics, Bureau of Labor Statistics, Bureau of Transportation

Statistics, Economic Research Service, Energy Information Administration, National 

Agricultural Statistics Service, National Center for Education Statistics, and National 

Center for Health Statistics. 

Page 20 GAO-07-62 Federal Information Collection
perspectives on a topic, such as by focusing on the different sources and 

effects of disabilities. The seven surveys we reviewed originated at 

different times and differ in many aspects, including the samples drawn, 

the time periods measured, the types of information collected, and level of

detail requested. These factors can affect costs and burden hours 

associated with the surveys. In addition, the differences can create 

confusion in some cases because they produce differing estimates and use 

different definitions. 

Although the CPS, NHIS, MEPS, and SIPP all measure people who do not 

have health insurance, the surveys originated at different times and differ 

in several ways, including the combinations of information collected that

relate to health insurance, questions used to determine health insurance 

status, and time frames. Health insurance status is not the primary 

purpose of any of these surveys, but rather one of the subject areas in each

survey. In addition, because each survey has a different purpose, each

survey produces a different combination of information related to people’s 

health insurance. 

Surveys That Measure 

People without Health 

Insurance Produce 

Differing Estimates 

• The CPS originated in 1948 and provides data on the population’s 

employment status. Estimates from the CPS include employment, 

unemployment, earnings, hours of work, and other indicators. 

Supplements also provide information on a variety of subjects, including 

information about employer-provided benefits like health insurance. CPS 

also provides information on health insurance coverage rates for 

sociodemographic subgroups of the population. The time frame within 

which data is released varies; for example, CPS employment estimates are 

released 2-3 weeks after collection while supplement estimates are 

released in 2-9 months after collection. 

• The NHIS originated in 1957 and collects information on reasons for lack 

of health insurance, type of coverage, and health care utilization. The 

NHIS also collects data on illnesses, injuries, activity limitations, chronic 

conditions, health behaviors, and other health topics, which can be linked 

to health insurance status. HHS stated that although health insurance data

are covered on other surveys, NHIS’s data on health insurance is key to 

conducting analysis of the impact of health insurance coverage on access 

to care, which is generally not collected on other surveys. 

• The MEPS originated in 1977 and provides data on health insurance 

dynamics, including changes in coverage and periods without coverage. 

The MEPS augments the NHIS by selecting a sample of NHIS respondents 

and collecting additional information on the respondents. The MEPS also 

links data on health services spending and health insurance status to other 

demographic characteristics of survey respondents. The MEPS data can 

Page 21 GAO-07-62 Federal Information Collection
also be used to analyze the relationship between insurance status and a 

variety of individual and household characteristics, including use of and 

expenditures for health care services. 

• The SIPP originated in 1983 in order to provide data on income, labor 

force, and government program participation. The information collected in

the SIPP, such as the utilization of health care services, child well-being, 

and disability, can be linked to health insurance status. The SIPP also 

measures the duration of periods without health insurance. 

Because the surveys use different methods to determine health insurance 

status, they can elicit different kinds of responses and consequently 

differing estimates within the same population. To determine if a person is

uninsured, surveys use one of two methods: they ask respondents directly 

if they lack insurance coverage or they classify individuals as uninsured if 

they do not affirmatively indicate that they have coverage. The CPS and 

the NHIS directly ask respondents whether they lack insurance coverage.

While the difference between these approaches may seem subtle, using a 

verification question prompts some people who did not indicate any 

insurance coverage to rethink their status and indicate coverage that they

had previously forgotten to mention. 

The surveys also differ both in the time period respondents are asked to 

recall and in the time periods measured when respondents did not have 

health insurance. Hence, the surveys produce estimates that do not rely 

upon standardized time or recall periods and as a result are not directly 

comparable. The ASEC to the CPS is conducted in February, March, and 

April and asks questions about the prior calendar year. An interviewer 

asks the respondent to remember back for the previous calendar year 

which can be as long as 16 months in the April interview. The other three 

surveys, in contrast, asked about coverage at the time of the interview. 

Because a respondent’s ability to recall information generally degrades 

over time, most survey methodologists believe that the longer the recall 

period, the less accurate the answers will be to questions about the past, 

such as exactly when health insurance coverage started or stopped, or 

when it changed because of job changes. Another difference is the time 

period used to frame the question. The CPS asked whether the respondent 

was uninsured for an entire year, while NHIS, MEPS, and SIPP asked 

whether the individual was ever insured, or was uninsured at the time of 

the interview, for the entire last year, and at any time during the year. 

Table 3 illustrates the differing estimates obtained using data from the four 

selected surveys. While these differences can be explained, the wide 

differences in the estimates are of concern and have created some 

Page 22 GAO-07-62 Federal Information Collection
confusion. For example, the 2004 CPS estimate for people who were 

uninsured for a full year is over 50 percent higher than the NHIS estimate 

for that year. HHS has sponsored several interagency meetings on health 

insurance data, which involved various agencies within HHS and the 

Census Bureau. The meetings focused on improving estimates of health 

insurance coverage and included, among other things, examining how 

income data are used, exploring potential collaboration between HHS and 

the Census Bureau on whether the CPS undercounts Medicaid recipients, 

examining health insurance coverage rates, and discussing a potential 

project to provide administrative data for use in the CPS. As a result, HHS 

created a Web site with reports and data on relevant surveys and HHS’s 

office of the Assistant Secretary for Planning and Evaluation (ASPE) 

produced the report Understanding Estimates of the Uninsured: Putting

the Differences in Context with input from the Census Bureau in an effort

to explain the differing estimates.17

Table 3: Uninsured Estimates from Selected Surveys 

Survey 

Most recent 

year 

Uninsured for full 

year 

Point in time 

estimate 

Ever uninsured

during the year 

CPS 2004 45.8 million N/A N/A

NHIS 2004 29.2 million 42.1 million 51.6 million 

MEPS 2003 33.7 million 48.1 million 62.9 million 

SIPP 2001 18.9 million 38.7 million 66.5 million 

Source: GAO extract of ASPE issue brief: Understanding Estimates Of the Uninsured: Putting the Differences in Context (September, 

2005). 

Similarly, although the NHIS, NHANES, MEPS, SIPP, and ACS all estimate 

the percentage of the population with disabilities, the surveys define 

disability differently and have different purposes and methodologies. In 

addition to these five surveys, which measure aspects of disability, BLS is 

also currently developing questions to measure the employment levels of 

the disabled population. HHS also stated that disability is included on 

multiple surveys so that disability status can be analyzed in conjunction 

with other information that an agency needs. For example, disability 

information is used by health departments to describe the health of the 

population, by departments of transportation to assess access to 

Surveys that Measure 

Disability Status Differ in 

Definitions, Purposes, and 

Methodologies Used 

 17 Department of Health and Human Services, ASPE Issue Brief: Understanding Estimates 

of the Uninsured: Putting the Differences in Context (September, 2005).

Page 23 GAO-07-62 Federal Information Collection
transportation systems, and departments of education in the education 

attainment of people with disabilities. The lack of consistent definitions is 

not unique to surveys; there are over 20 different federal agencies that 

administer almost 200 different disability programs for purposes of 

entitlement to public support programs, medical care, and government 

services. 

Although each of the surveys asks about people’s impairments or 

functionality in order to gauge a respondent’s disability status, there are 

some differences in how disability is characterized. For example, the NHIS 

asks respondents if they are limited in their ability to perform agedependent life and other activities. The NHIS also asks about the 

respondent needing assistance with performing activities of daily living 

and instrumental activities of daily living.18 The NHANES measures the 

prevalence of physical and functional disability for a wide range of 

activities in children and adults. Extensive interview information on selfreported physical abilities and limitations is collected to assess the 

capacity of the individual to do various activities without the use of aids, 

and the level of difficulty in performing the task. The MEPS provides 

information on days of work or school missed due to disability. The SIPP 

queries whether the respondent has limitations of sensory, physical, or 

mental functioning and limitations on activities due to health conditions or 

impairments. The ACS asks about vision or hearing impairment, difficulty 

with physical and cognitive tasks, and difficulty with self-care and 

independent living. 

Because surveys produce different types of information on disability, they 

can provide additional perspectives on the sources and effects of 

disabilities, but they can also cause confusion because of the differences 

in the way disability is being measured. The NHIS contains a broad set of 

data on disability-related topics, including the limitation of functional 

activities, mental health questions used to measure psychological distress, 

limitations in sensory ability, and limitations in work ability. Moreover, the 

NHIS provides data, for those persons who indicated a limitation 

performing a functional activity, about the source or condition of their 

functional limitation. The NHANES links medical examination information 

 18 Activities of daily living include getting around inside the home, getting in or out of bed 

or a chair, bathing, dressing, eating, and toileting. Instrumental activities of daily living 

include going outside the home, keeping track of money and bills, preparing meals, doing 

light housework, taking prescription medicines in the right amount at the right time, and

using the telephone. 

Page 24 GAO-07-62 Federal Information Collection
to disability. The MEPS measures how much individuals spend on medical 

care for a person with disabilities and can illustrate changes in health 

status and health care expenses. The SIPP provides information on the use 

of assistive devices, such as wheelchairs and canes. Finally, the ACS 

provides information on many social and economic characteristics, such 

as school enrollment for people with disabilities as well as the poverty and 

employment status of people with different types of disabilities. 

However, the estimates of disability in the population that these surveys 

produce can vary widely. A Cornell University study compared disability 

estimates among the NHIS, SIPP, and ACS. A number of categories of 

disability were very similar, such as the nondisabled population, while 

others, such as the disabled population or people with sensory disabilities,

had widely varying estimates, as shown in table 4.19 For example, 

according to data presented in a Cornell University study that used survey

questions to define and subsequently compare different disability 

measures across surveys, the SIPP 2002 estimate of people with sensory 

disabilities for ages 18-24 was more than six times the NHIS estimate for 

that year for ages 18-24. In commenting on this report, the DOC and HHS 

acknowledged that comparing the NHIS and SIPP with respect to sensory 

disabilities is problematic. HHS officials noted that the confusion caused 

by these different estimates derives mostly from the lack of a single 

definition of disability, which leads to data collections that use different 

questions and combinations of information to define disability status. 

 19 Benjamin H. Harris, Gerry Hendershot, and David C. Stapleton, A Guide to Disability 

Statistics From the National Health Interview Survey (New York: Cornell University 

Employment and Disability Institute, October 2005).

Page 25 GAO-07-62 Federal Information Collection
Table 4: Estimated Population of Persons with Disabilities, by Data Source and Different Categories of Disability 

Surveys No disability Disability

Work 

limitation

Instrumental 

activities of

daily living

Activities 

of daily

living Mental Physical Sensory

Ages 

18-24

NHIS 

(2002) 

25,225,000 2,126,000 927,000 228,000 147,000 786,000 859,000 78,000

SIPP

(2002) 

24,820,000 2,426,337 1,209,000 366,000 146,000 1,076,000 982,000 533,000

ACS

(2003) 

24,194,401 1,667,355 714,229 399,423 187,904 953,448 535,666 356,820

Ages 

25-61

NHIS 

(2002) 

115,934,000 23,192,000 13,725,000 3,169,000 1,350,000 4,627,000 14,545,000 2,730,000

SIPP

(2002) 

115,900,000 26,620,000 14,420,000 4,931,000 3,362,000 4,394,000 18,790,000 6,490,000

ACS

(2003) 

126,649,510 17,146,845 9,854,223 4,227,427 2,925,715 5,745,569 10,819,521 3,944,388

Source: GAO extract of Cornell University’s Employment and Disability Institute report A Guide to Disability Statistics from the National

Health Interview Survey (2005). 

Note: Instrumental activities of dally living (IADL) include a broader set of participation restrictions

than the ‘“go-outside-home” definition in the ACS. It also includes participation restrictions that affect 

the ability to: manage money and keep track of bills, prepare meals, and do work around the house.

Because the concept of disability varies, with no clear consensus on 

terminology or definition, and there are differing estimates, several federal 

and international groups are examining how the associated measures of 

disability could be improved. HHS’s Disability Workgroup, which includes 

officials from HHS and the Department of Education, examines how 

disability is measured and used across surveys. The task of another federal 

group, the Subcommittee on Disability Statistics of the Interagency

Committee on Disability Research, is to define and standardize the 

disability definition. The Washington Group on Disability Statistics 

(WGDS), an international workgroup sponsored by the United Nations in 

which OMB and NCHS participate, is working to facilitate the comparison 

of data on disability internationally. The WGDS aims to guide the 

development of a short set or sets of disability measures that are suitable 

for use in censuses, sample-based national surveys, or other statistical 

formats, for the primary purpose of informing policy on equalization of 

opportunities. The WGDS is also working to develop one or more 

extended sets of survey items to measure disability, or guidelines for their 

design, to be used as components of population surveys or as supplements 

to specialty surveys. HHS added that the interest in standardizing the 

measurement of disability status is also driven by the desire to add a 

Page 26 GAO-07-62 Federal Information Collection
standard question set to a range of studies so that the status of persons 

with disabilities can be described across studies.

The AHS and ACS Ask 

Some Similar Questions on 

Housing, but Their 

Purposes and Scope Differ 

In 2002, we reported that the AHS and ACS both covered the subject of 

housing.20 Of the 66 questions on the 2003 ACS, 25 were in the section on 

housing characteristics, and all but one of these questions were the same 

as or similar to the questions on the AHS. For example, both the AHS and

the ACS ask how many bedrooms a housing unit has. However, the two 

surveys differ in purposes and scope.

The purpose of the AHS is to collect detailed housing information on the 

size, composition, and state of housing in the United States, and to track 

changes in the housing stock over time, according to a HUD official. To

that end, the AHS includes about 1,000 variables, according to a HUD 

official, such as the size of housing unit, housing costs, different building 

types, plumbing and electrical issues, housing and neighborhood quality, 

mortgage financing, and household characteristics. The AHS produces 

estimates at the national level, metropolitan level for certain areas, and 

homogenous zones of households with fewer than 100,000 households. 

The AHS is conducted every 2 years nationally and every 6 years in major 

metropolitan areas, except for six areas, which are surveyed every 4 years. 

In contrast, the level of housing data in the ACS is much less extensive. 

The ACS is designed to replace the decennial Census 2010 long-form and 

covers a wide range of subjects, such as income, commute time to work, 

and home values. The ACS provides national and county data and, in the 

future, will provide data down to the Census tract level, according to a 

Census Bureau official. The ACS is designed to provide communities with 

information on how they are changing, with housing being one of the main

topic areas along with a broad range of household demographic and 

economic characteristics. 

The AHS and ACS also have different historical and trend data and data 

collection methods. The AHS returns to the same housing units year after 

year to gather data; therefore, it produces data on trends that illustrate the 

flow of households through the housing stock, according to a HUD official, 

while the ACS samples new households every month. Historical data are 

 20 GAO-02-956R. 

Page 27 GAO-07-62 Federal Information Collection
also available from the AHS from the 1970s onward, according to a HUD 

official. 

Analysts can use AHS data to monitor the interaction among housing 

needs, demand, and supply, as well as changes in housing conditions and

costs. In addition, analysts can also use AHS data to support the 

development of housing policies and the design of housing programs 

appropriate for different groups. HUD uses the AHS data, for example, to 

analyze changes affecting housing conditions of particular subgroups, 

such as the elderly. The AHS also plays an important role in HUD’s 

monitoring of the lending activities of the government-sponsored 

enterprises, Fannie Mae and Freddie Mac, in meeting their numeric goals 

for mortgage purchases serving minorities, low-income households, and 

underserved areas. AHS’s characteristic of returning to the same housing 

units year after year provides the basis for HUD’s Components of 

Inventory Change (CINCH) and Rental Dynamics analyses. The CINCH 

reports examine changes in housing stock over time by comparing the 

status and characteristics of housing units in successive surveys. The 

Rental Dynamics program, which is a specialized form of CINCH, looks at 

rental housing stock changes, with an emphasis on changes in

affordability. Another use of AHS data has been for calculating certain fair 

market rents (FMR), which HUD uses to determine the amount of rental 

assistance subsidies for major metropolitan areas between the decennial 

censuses. However, HUD plans to begin using ACS data for fiscal year 

2006 FMRs. As we previously reported, this could improve the accuracy of

FMRs because the ACS provides more recent data that closely matches the 

boundaries of HUD’s FMR areas than the AHS.21

In our 2002 report, which was published before the ACS was fully 

implemented, we also identified substantial overlap for questions on place 

of birth and citizenship, education, labor force characteristics, 

transportation to work, income, and, in particular, housing characteristics. 

We recommended that the Census Bureau review proposed ACS questions 

for possible elimination that were asked on the AHS to more completely 

address the possibility of reducing the reporting burden in existing 

surveys.22 The Census Bureau responded that they are always looking for 

opportunities to streamline, clarify, and reduce respondent burden, but 

 21 GAO, Rental Housing: HUD Can Improve Its Process for Estimating Fair Market 

Rents, GAO-05-342 (Washington, D.C.: Mar. 31, 2005). 

22 GAO-02-956R. 

Page 28 GAO-07-62 Federal Information Collection
that substantial testing would be required before changes can be made in

surveys that provide key national social indicators. 

The Advent of the ACS and 

the Proposed 

Reengineering of the SIPP 

Are Changes to the 

Portfolio of Major 

Household Surveys 

In addition to efforts underway to try to reconcile inconsistencies among 

surveys that address the same subject areas, a number of major changes 

have occurred or are planned to occur that will affect the overall portfolio 

of major household surveys. As previously discussed, the ACS was fully 

implemented in 2005 and provides considerable information that is also 

provided in many other major household surveys. The ACS is the 

cornerstone of the government’s effort to keep pace with the nation’s 

changing population and ever-increasing demands for timely and relevant

data about population and housing characteristics. The new survey will 

provide current demographic, socioeconomic, and housing information 

about America’s communities every year, information that until now was 

only available once a decade. Starting in 2010, the ACS will replace the 

long-form census. As with the long-form, information from the ACS will be 

used to administer federal and state programs and distribute more than 

$200 billion a year. Detailed data from national household surveys can be

combined with data from the ACS to create reliable estimates for small 

geographic areas using area estimation models. 

Partly in response to potential reductions in funding for fiscal year 2007,

the Census Bureau is planning to reengineer the SIPP with the intent of 

ultimately providing better information at lower cost. SIPP has been used 

to estimate future costs of certain government programs. For example, 

HUD used SIPP’s longitudinal capacity to follow families over time to 

determine that households with high-rent burdens in one year move in and 

out of high-rent burden status over subsequent years. Therefore, although 

the overall size of the population with worst-case housing needs is fairly 

stable, the households comprising this population change with 

considerable frequency—an issue that HUD told us is potentially 

important in the design of housing assistance programs. 

Although the SIPP has had problems with sample attrition and releasing 

data in a timely manner, which the reengineering is intended to ameliorate, 

there has been disagreement about this proposal among some users of 

SIPP data. Census Bureau officials said they are meeting with internal and 

external stakeholders and are considering using administrative records. 

Census Bureau officials told us that they could develop a greater quality 

survey for less money, with a final survey to be implemented in 2009. They

also said that they may consider using the ACS or CPS sampling frame. 

Page 29 GAO-07-62 Federal Information Collection
In addition to the seven surveys discussed previously, we also identified 

examples of how, over the years, agencies have undertaken efforts to 

enhance their surveys’ relevance and efficiency through steps such as 

using administrative data in conjunction with survey data, reexamining 

and combining or eliminating surveys, and redesigning existing surveys. 

The Census Bureau and BLS have used administrative data collected for 

the administration of various government programs in conjunction with 

survey data. The Census Bureau and BLS have used the administrative 

data to target specific populations to survey and to obtain information 

without burdening survey respondents. 

Agencies Have 

Undertaken Efforts to 

Improve the 

Efficiency and 

Relevance of Surveys 

Agencies Have Used 

Administrative Data in 

Conjunction with Surveys 

The Census Bureau uses administrative data in combination with survey 

data to produce its Economic Census business statistics, which, every 

5 years, profile the U.S. economy from the national to the local level. The 

Economic Census relies on the centralized Business Register, which is 

compiled from administrative records from IRS, SSA, and BLS, along with 

lists of multi-establishment businesses that the Census Bureau maintains. 

The Business Register contains basic economic information for over 

8 million employer businesses and over 21 million self-employed 

businesses. The Economic Census uses the Business Register as the 

sampling frame to identify sets of businesses with specific characteristics, 

such as size, location, and industry sector. 

BLS also uses a combination of administrative and survey data to produce 

its quarterly series of statistics on gross job gains and losses. BLS uses 

administrative data provided by state workforce agencies that compile and

forward quarterly state unemployment insurance (UI) records to BLS. 

These state agencies also submit employment and wage data to BLS. The 

data states provide to BLS include establishments subject to state UI laws 

and federal agencies subject to the Unemployment Compensation for 

Federal Employees program, covering approximately 98 percent of U.S. 

jobs. These administrative data enable BLS to obtain information on many 

businesses without having to impose a burden on respondents. BLS 

augments the administrative data with two BLS-funded surveys conducted 

by the states. The Annual Refiling Survey updates businesses’ industry 

codes and contact information, and the Multiple Worksite Report survey 

provides information on multiple work sites for a single business, data that 

are not provided by the UI records, enabling BLS to report on business 

statistics by geographic location. Combining the data from these surveys 

Page 30 GAO-07-62 Federal Information Collection
with administrative data helps BLS increase accuracy, update information, 

and include additional details on establishment openings and closings. 

However, because of restrictions on information sharing, BLS is not able 

to access most of the information that the Census Bureau uses for its 

business statistics because much of this information is commingled with 

IRS data. The Confidential Information Protection and Statistical 

Efficiency Act of 2002 (CIPSEA, 44 U.S.C. § 3501 note) authorized 

identifiable business records to be shared among the Bureau Economic 

Analysis (BEA), BLS, and the Census Bureau for statistical purposes. 

CIPSEA, however, did not change the provisions of the Internal Revenue

Code that preclude these agencies from sharing tax return information for 

statistical purposes. OMB officials stated that there is continued interest in

examining appropriate CIPSEA companion legislation on granting greater 

access for the Census Bureau, BLS, and BEA to IRS data. 

Reexamination Has Led to 

Modification or 

Elimination of Surveys 

Several agencies have reexamined some of their surveys, which has led to 

their elimination or modification. The Census Bureau, for example, 

reviewed its portfolio of Current Industrial Reports (CIR) program surveys 

of manufacturing establishments, which resulted in the elimination and 

modification of some surveys. Census Bureau officials said they decided to

undertake this reexamination in response to requests for additional data 

that could not be addressed within existing budgets without eliminating 

current surveys. They were also concerned that the character of 

manufacturing, including many of the industries surveyed by the CIR 

program, had changed since the last reexamination of the CIR programs, 

which had been over 10 years earlier. Using criteria developed with key 

data users, Census Bureau officials developed criteria and used them to 

rank 54 CIR program surveys. The criteria included 11 elements, such as 

whether the survey results were important to federal agencies or other 

users, and the extent to which the subject matter represented a growing 

economic activity in the United States. The recommendations the Census 

Bureau developed from this review were then published in the Federal 

Register and after considering public comments, the Census Bureau 

eliminated 11 surveys, including ones on knit fabric production and 

industrial gases.23 The Census Bureau also redesigned 7 surveys, scaling 

back the information required to some extent and updating specific 

 23 Knit fabric is fabric made on a knitting machine, and industrial gases are manufactured 

industrial organic and inorganic gases in compressed, liquid, or solid forms. 

Page 31 GAO-07-62 Federal Information Collection
product lists. As a result of this reexamination, the Census Bureau was 

able to add a new survey on “analytical and biomedical instrumentation,” 

and it is considering whether another new CIR program survey is needed

to keep pace with manufacturing industry developments. Census Bureau 

officials told us that they plan on periodically reexamining the CIR surveys 

in the future. 

HHS has also reexamined surveys to identify improvements, in part by 

integrating a Department of Agriculture (USDA) survey which covered

similar content into HHS’s NHANES. For about three decades, HHS and 

USDA conducted surveys that each contained questions on food intake 

and health status (NHANES and the Continuing Survey of Food Intakes by

Individuals, respectively). HHS officials stated that HHS and USDA 

officials considered how the two surveys could be merged for several 

years before taking action. According to HHS officials, several factors led 

to the merger of the two surveys, including USDA funding constraints, the 

direct involvement of senior-level leadership on both sides to work 

through the issues, and HHS officials’ realization that the merger would 

enable them to add an extra day of information gathering to the NHANES. 

Integrating the two surveys into the NHANES made it more 

comprehensive by adding a follow-up health assessment. According to 

HHS officials, adding this component to the original in-person assessment 

allows agency officials to better link dietary and nutrition information with 

health status. 

Another mechanism HHS has established is a Data Council, which, in 

addition to other activities, assesses proposed information collections. The 

Data Council oversees the entire department’s data collections to ensure 

that the department relies, where possible, on existing core statistical 

systems for new data collections rather than on the creation of new 

systems. The Data Council implements this strategy through

communicating and sharing plans, conducting annual reviews of proposed 

data collections, and reviewing major survey modifications and any new 

survey proposals. According to HHS officials, in several instances, 

proposals for new surveys and statistical systems have been redirected 

and coordinated with current systems. For example, HHS officials stated 

that when the Centers for Disease Control and Prevention (CDC) 

proposed a new survey on youth tobacco use, the Data Council directed it

to the Substance Abuse and Mental Health Services Administration’s 

National Survey of Drug Use and Health. The Data Council stated that by

adding questions on brand names, CDC was able to avoid creating a new 

survey to measure youths’ tobacco use. 

Page 32 GAO-07-62 Federal Information Collection
OMB recognizes that the federal government should build upon agencies’ 

practice of reexamining individual surveys to conduct a comprehensive 

reexamination of the portfolio of major federal household surveys, in light

of the advent of the ACS. OMB officials acknowledged that this effort 

would be difficult and complex and would take time. According to OMB, 

integrating or redesigning the portfolio of major household surveys could 

be enhanced if, in the future, there is some flexibility to modify the ACS 

design and methods.24 For example, an OMB official stated that using 

supplements or flexible modules periodically within the ACS might enable

agencies to integrate or modify portions of other major household surveys. 

OMB officials indicated that such an effort would likely not happen until 

after the 2010 decennial census, a critical stage for ACS when ACS data 

can be compared to 2010 Census data. OMB officials said and their longrange plans have already indicated their expectation that there will be 

improved integration of the portfolio of related major household surveys 

with the advent of the ACS. For example, the Statistical Programs of the 

United States Government: Fiscal Year 2006 describes plans for 

redesigning the samples for demographic surveys, scheduled for initial 

implementation after 2010, when the ACS may become the primary data 

source. 

In light of continuing budgetary constraints, as well as major changes 

planned and underway within the U.S. statistical system, the portfolio of 

major federal household surveys could benefit from a holistic 

reexamination. Many of the surveys have been in place for several 

decades, and their content and design may not have kept pace with 

changing information needs. The duplication in content in some surveys, 

while considered necessary, may be a reflection of incremental attempts 

over time to address information gaps as needs changed. OMB and the 

statistical agencies have attempted to address some of the more 

troublesome aspects of this duplication by providing explanations of the 

differences in health insurance estimates and with efforts to develop more 

consistent definitions of disability. These efforts, however, while helpful,

address symptoms of the duplication without tackling the larger issues of 

need and purpose. In many cases, the government is still trying to do 

business in ways that are based on conditions, priorities, and approaches 

Conclusions 

 24 At least 2 years before the decennial census is implemented, census-proposed questions

must be submitted to the committees of Congress having legislative jurisdiction over the 

Census. 13 U.S.C. § 141(f). 

Page 33 GAO-07-62 Federal Information Collection
that existed decades ago and are not well suited to addressing today’s 

challenges. Thus, while the duplicative content of the surveys can be

explained, there may be opportunities to modify long-standing household 

surveys, both to take advantage of changes in the statistical system, as 

well as to meet new information needs in the face of ever-growing 

constraints on budgetary resources. 

Some agencies have begun to take steps to reevaluate their surveys in 

response to budget constraints and changing information needs. Agencies

have reexamined their surveys and used administrative data in 

conjunction with survey data to enhance their data collection efforts. 

These actions, however, focused on individual agency and user 

perspectives. By building upon these approaches and taking a more 

comprehensive focus, a governmentwide reexamination could help reduce 

costs in an environment of constrained resources and help prioritize 

information needs in light of current and emerging demands. 

Given the upcoming changes in the statistical system, OMB should lead the 

development of a new vision of how the major federal household surveys 

can best fit together. OMB officials told us they are beginning to think 

about a broader effort to better integrate the portfolio of major household 

surveys once the ACS has been successfully implemented. Providing 

greater coherence among the surveys, particularly in definitions and time 

frames, could help reduce costs to the federal government and associated

burden hours. The Interagency Council on Statistical Policy (ICSP) could 

be used to bring together relevant federal agencies, including those that 

are not currently part of the ICSP. The ICSP has the leadership authority,

and in light of the comprehensive scope of a reexamination initiative, 

could draw on leaders from the agencies that collect or are major users of 

federal household survey data. While OMB officials have stated that the 

ACS may not have demonstrated its success until after 2010, the 

complexity and time needed to reexamine the portfolio of major federal 

household surveys means that it is important to start planning for that 

reexamination. 

To deal with the longer term considerations crucial in making federally 

funded surveys more effective and efficient, GAO recommends that the 

Director of OMB work with the Interagency Council on Statistical Policy 

to plan for a comprehensive reexamination to identify opportunities for 

redesigning or reprioritizing the portfolio of major federal household 

surveys. 

Recommendation for 

Executive Action 

Page 34 GAO-07-62 Federal Information Collection
We requested comments on a draft of this report from the Director of OMB 

and the Secretaries of Commerce, HHS, HUD, and Labor or their 

designees. We obtained oral and technical comments on a draft of this 

report from the Chief Statistician of the United States and her staff at 

OMB, as well as written comments from the Acting Deputy Under 

Secretary for Economic Affairs at Commerce; the Assistant Secretary for 

Legislation at HHS; and the Assistant Secretary for Policy Development 

and Research at HUD; and technical comments from the Acting 

Commissioner of BLS at Labor, which we incorporated in the report as 

appropriate. In commenting on a draft of the report, OMB officials stated 

that the draft report presented an interesting study that addresses an issue 

worth looking at. OMB officials generally agreed with our 

recommendation, although they expressed concerns about the range of 

participants that might be involved in such a reexamination. We revised 

the recommendation to provide clarification that OMB should work with 

the Interagency Council on Statistical Policy rather than with all relevant 

stakeholders and decision makers. OMB officials also expressed concerns 

about moving from examining selected surveys in three subject areas to 

the conclusion that the entire portfolio of household surveys should be 

reexamined. In response we clarified that we were recommending a 

comprehensive reexamination of the seven surveys that comprise the 

portfolio of major federal household surveys, most of which were included 

in our review. OMB officials also provided clarification on how we 

characterized their statements on reexamining the portfolio of major 

household surveys, which we incorporated into the report. 

Agency Comments 

Each of the four departments provided technical clarifications that we 

incorporated into the report, as appropriate. In addition, HHS and HUD 

officials offered written comments on our findings and recommendation, 

which are reprinted in appendix II. HHS stated that a reexamination was 

not warranted without evidence of unnecessary duplication and also 

highlighted a number of examples of agency efforts to try to clarify varying

estimates. However we did not rely on evidence of duplication, but rather 

based our recommendation on other factors, including a need to provide 

greater coherence among the surveys and to take advantage of changes in 

the statistical system to reprioritize information needs and possibly help 

reduce costs to the federal government and associated burden hours. 

Further, in light of the major upcoming changes involving the ACS and 

SIPP, and in conjunction with constrained resources and changing 

information needs, we believe that the major household surveys should be 

considered from a broader perspective, not simply in terms of unnecessary

duplication.

Page 35 GAO-07-62 Federal Information Collection
HHS also provided a number of general comments. We incorporated 

additional information to reflect HHS’s comments on the different uses of 

disability information, a standard set of disability questions, NHIS’s 

coverage of access to care, and the fact that MEP’s sample is a subset of 

the NHIS sample. HHS’s comments on differences in estimates and the 

lack of a single definition of disability were already addressed in the 

report. HHS also stated that NCHS works through various mechanisms to 

ensure that surveys are efficient. We support efforts to enhance efficiency 

and believe that our recommendation builds upon such efforts. 

HUD officials were very supportive of our recommendation, stating that 

such a reexamination is especially important as the ACS approaches fullscale data availability. In response to HUD’s comments suggesting adding 

more information on SIPP and AHS, we expanded the report’s discussion 

of the longitudinal dimension of SIPP and AHS. 

As agreed with your office, unless you publicly announce the contents of

the report earlier, we plan no further distribution of it until 30 days from 

the date of the report. We will then send copies of this report to the 

appropriate congressional committees and to the Director of OMB, and the 

Secretaries of Commerce, HHS, HUD, and Labor, as well as to other 

appropriate officials in these agencies. We will also make copies available 

to others upon request. In addition, the report will be available at no 

charge on the GAO Web site at http:/www.gao.gov. 

If you or your staff have any questions regarding this report, please 

contact me at (202) 512-6543 or steinhardtb@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found on

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix II. 

Bernice Steinhardt 

Director, Strategic Issues 

Page 36 GAO-07-62 Federal Information Collection
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To answer our first objective of identifying the number and characteristics

of Office of Management and Budget (OMB)-approved federally funded 

statistical and research surveys, we obtained the database of information 

collections that had been approved by OMB as of August 7, 2006. The 

information in the database is obtained from Form 83-I which is part of an 

agency’s submission for OMB approval of an information collection. As the 

approval is in effect for up to 3 years, this database reflects all those 

collections with OMB approval for their use as of that date, and is thus a 

snapshot in time. 

Although OMB Form 83-I requires agencies to identify various types of 

information about an information collection, including whether the 

information collection will involve statistical methods, the form does not 

require agencies to identify which information collections involve surveys

consequently the database of OMB-approved information collections does 

not identify which information collections are surveys. Furthermore, the 

definition of information collections contained in the Paperwork 

Reduction Act (PRA) of 1980 is written in general terms and contains very 

few limits in scope or coverage. On the form, agencies can select from 

seven categories when designating the purpose of an information 

collection, which are (1) application for benefits, (2) program evaluation, 

(3) general purpose statistics, (4) audit, (5) program planning or 

management, (6) research, and (7) regulatory or compliance. When 

completing the form, agencies are asked to mark all categories that apply, 

denoting the primary purpose with a “P” and all others that apply with an 

“X.” Since OMB does not further define these categories, the agency

submitting the request determines which categories best describe the 

purpose(s) of the proposed collection. The choices made may reflect 

differing understandings of these purposes from agency to agency or 

among individuals in the same agency. 

The list of surveys contained in this report was derived from the database 

of OMB-approved information collections and therefore contains all 

information collections that an agency designated as either “general 

purpose statistics” or “research” in the primary purpose category that we 

used as a proxy for the universe of surveys. The directions to agencies 

completing the forms call for agencies to mark “general purpose statistics” 

when the data are collected chiefly for use by the public or for general 

government use without primary reference to the policy or program 

operations of the agency collecting the data. Agencies are directed to mark 

“research” when the purpose is to further the course of research, rather

than for a specific program purpose. We did not determine how accurately

or reliably agencies designated the purpose(s) of their information 

Page 37 GAO-07-62 Federal Information Collection
Appendix I: Scope and Methodology 

collections. It is also possible that the database may contain other 

federally funded surveys that the agency did not identify under the primary 

purpose we used to “identify” surveys, and these would not be included in

our list of surveys. 

We have taken several steps to ensure that the database of OMB-approved 

information collections correctly recorded agency-submitted data and

contained records of all Forms 83-I submitted to OMB. Our report, entitled 

Paperwork Reduction Act: New Approach May Be Needed to Reduce 

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

examined the reliability of the database of OMB-approved information 

collections and concluded that the data were accurate and complete for 

the purposes of that report. Because this assessment was recent, we 

decided that we would not repeat this assessment. We did, however, 

compare a sample of the surveys from the Inventory of Approved 

Information Collection on OMB’s Web site to our copy of the database of 

OMB-approved collections. We found that all of the surveys in the 

Inventory of Approved Information Collection were contained in the 

database. 

Not all information collections require OMB approval under the PRA. 

OMB’s draft Implementing Guidance for OMB Review of Agency 

Information Collection explains that in general, collections of information 

conducted by recipients of federal grants do not require OMB approval 

unless the collection meets one or both of the following two conditions: 

(1) the grant recipient is collecting information at the specific request of 

the sponsoring agency or (2) the terms and conditions of the grant require 

that the sponsoring agency specifically approve the information collection 

or collection procedures. As also stated in the OMB draft, information 

collections that are federally funded by contracts do not require OMB 

approval unless the information collection meets one or both of the 

following two conditions: (1) if the agency reviews and comments upon 

the text of the privately developed survey to the extent that it exercises 

control over and tacitly approves it or (2) if there is the appearance of 

sponsorship, for example, public endorsement by an agency, the use of an 

agency seal in the survey, or statements in the instructions of the survey 

indicating that the survey is being conducted to meet the needs of a 

federal agency. Although there are additional surveys funded through 

grants and contracts that are not approved by OMB under the PRA, OMB 

stated that there is no comprehensive list. In addition, the draft guidance

states that the PRA does not apply to current employees of the federal

government, military personnel, military reservists, and members of the 

National Guard with respect to all inquiries within the scope of their 

Page 38 GAO-07-62 Federal Information Collection
Appendix I: Scope and Methodology 

employment and for purposes of obtaining information about their duty 

status. 

For the second objective describing current agency and OMB roles in 

identifying and preventing unnecessary duplication, we took several 

different steps. We reviewed the PRA requirements for agencies and OMB. 

We also interviewed agency clearance officers at the Departments of 

Commerce, Health and Human Services, and Labor about their processes 

for submitting information collection packages to OMB. These agencies 

are the top three agencies in terms of funding for statistical activities in 

fiscal year 2006. We also interviewed OMB officials about their role in 

approving proposed information collections. 

For the third objective, through reviewing our reports and literature and 

by interviewing agency officials, we identified surveys with duplicative

content. We identified duplication by looking for areas of potential 

duplication when several surveys contained questions on the same 

subject. This duplication was strictly based on similar content in the 

surveys on the same subject, specifically people without health insurance 

and those with disabilities. We also looked at the duplication in the subject 

area of housing between the American Community Survey and American 

Housing Survey, which had been identified by our previous work. We also

looked at environmental surveys, but determined that there was not 

duplicative content with our major surveys. Once we had identified the 

three subject areas, we used literature and interviews to identify the 

current federally funded surveys that were cited as the major surveys in 

each theme. We did not focus on any particular type of survey, but rather 

chose the surveys that were cited as the major surveys in each theme. To 

learn more about the duplicative content between surveys related to these 

three themes, we reviewed relevant literature and agency documents. We 

also interviewed officials from OMB, and the Departments of Commerce, 

Labor, Health and Human Services, and Housing and Urban Development.

In addition, we interviewed experts from organizations that focus on 

federal statistics, such as at the Council of Professional Associations on 

Statistics and the Committee on National Statistics, National Academies of 

Science. 

Although we have included the Census Bureau’s Survey of Income and 

Program Participants as part of our assessment of potential duplication, 

the fiscal year 2007 President’s budget proposed to cut Census Bureau 

funding by $9.2 million, to which the Census Bureau responded by stating 

that it would reengineer the SIPP. Therefore, the fate of the SIPP is 

uncertain, and reengineering has not been completed. 

Page 39 GAO-07-62 Federal Information Collection
Appendix I: Scope and Methodology 

For the fourth objective, we also interviewed OMB officials, agency

officials, and organizations that focus on federal statistics. Through the 

combination of agency and OMB interviews, expert interviews, and 

research, we identified selected agency efforts to improve the efficiency

and relevance of surveys. 

Page 40 GAO-07-62 Federal Information Collection
Appendix II: Comments from the Department Appendix II: Comments from the Department of Housing and Urban Development 

of Housing and Urban Development 

Report incorporates

additional information on 

pages 28 and 29. 

Page 41 GAO-07-62 Federal Information Collection
Appendix II: Comments from the Department 

of Housing and Urban Development 

Page 42 GAO-07-62 Federal Information Collection
Appendix III: Comments from the Department Appendix III: Comments from the of Health & Human Services 

Department of Health & Human Services 

Page 43 GAO-07-62 Federal Information Collection
Appendix III: Comments from the Department 

of Health & Human Services 

Report addresses on

pages 21-29. 

Report incorporates

additional information on 

pages 23, 24, 26, and 27. 

Report incorporates

additional information on 

page 21. 

Page 44 GAO-07-62 Federal Information Collection
Appendix III: Comments from the Department 

of Health & Human Services 

Report addresses on

pages 23-26. 

Report incorporated

additional information on 

page 14. 

Report addresses on

page 36. 

Report addresses on

page 35. 

Page 45 GAO-07-62 Federal Information Collection
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 46 GAO-07-62 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

Bernice Steinhardt, (202) 512-6543 or steinhardtb@gao.gov

In addition to the contact named above, key contributors to this report 

were Susan Ragland, Assistant Director; Maya Chakko; Kisha Clark; Ellen 

Grady; Elizabeth M. Hosler; Andrea Levine; Jean McSween; Elizabeth 

Powell; and Greg Wilmoth. 

Federal Information Collection

GAO Contact 

Staff 

Acknowledgments 

(450414) 
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