United States Government Accountability Office

GAO Testimony

Before the Subcommittee on Regulatory 

Affairs, Committee on Government 

Reform, House of Representatives 

PAPERWORK 

REDUCTION ACT 

For Release on Delivery 

2:00 p.m. EDT Tuesday, July 18, 2006

Increase in Estimated 

Burden Hours Highlights 

Need for New Approach 

Statement of Linda D. Koontz, Director 

Information Management 

GAO-06-974T 
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What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

July 18, 2006

PAPERWORK REDUCTION ACT

Increase in Estimated Burden Hours 

Highlights of GAO-06-974T, a testimony Highlights Need for New Approach 

before the Subcommittee on Regulatory 

Affairs, Committee on Government

Reform, House of Representatives

Americans spend billions of hours 

each year providing information to

federal agencies by filling out 

information collections (forms, 

surveys, or questionnaires). A 

major aim of the Paperwork

Reduction Act (PRA) is to minimize 

the burden that responding to these 

collections imposes on the public, 

while maximizing their public 

benefit. Under the act, the Office of

Management and Budget (OMB) is

to approve all such collections and

to report annually on the agencies’ 

estimates of the associated burden. 

In addition, agency chief 

information officers (CIO) are to 

review information collections 

before submitting them to OMB for 

approval and certify that the 

collections meet certain standards 

set forth in the act. 

GAO was asked to testify on OMB’s 

burden report for 2005 and on a 

previous study of PRA 

implementation (GAO-05-424), 

which focused on the CIO review

and certification processes and 

described alternative processes 

that two agencies have used to

minimize paperwork burden. To

prepare this testimony, GAO 

reviewed the current burden report 

and its past work in this area. For 

its 2005 study, GAO reviewed a 

governmentwide sample of

collections, reviewed processes 

and collections at four agencies

that account for a large proportion

of burden, and performed case

studies of 12 approved collections

at the four agencies. 

After 2 years of slight declines, OMB reports that paperwork burden grew in 

fiscal year 2005 and is expected to increase further in fiscal year 2006.

Estimates in OMB’s annual report to Congress show that the total paperwork 

burden imposed by federal information collections increased last year to 

about 8.4 billion hours—an increase of 5.5 percent from the previous year’s 

total of about 8.0 billion hours. Nearly all this increase resulted from the 

implementation of new laws (for example, about 224 million hours were due 

to the implementation of voluntary prescription drug coverage under 

Medicare). The rest of the increase came mostly from adjustments to the 

estimates due to such factors as changes in estimation methods and in the 

numbers of respondents. Looking ahead to fiscal year 2006, OMB expects an

increase of about 250 million hours because of a new model for estimating 

burden being implemented by the Internal Revenue Service (IRS). According 

to OMB, this expected rise does not reflect any real change in the burden on 

taxpayers, but only in how IRS estimates it. 

The PRA requires that CIOs review information collections and certify that 

they meet standards to minimize burden and maximize utility; however, 

these reviews were not always rigorous, reducing assurance that these 

standards were met. In 12 case studies at four agencies, GAO determined 

that CIOs certified collections proposed by program offices despite missing 

or inadequate support. Providing support for certifications is a CIO 

responsibility under the PRA, but agency files contained little evidence that 

CIO reviewers had made efforts to improve the support offered by program 

offices. Numerous factors contributed to these problems, including a lack of 

management attention and weaknesses in OMB guidance. Based on its 

review, GAO recommended (among other things) that agencies strengthen 

the support provided for certifications and that OMB update its guidance to 

clarify and emphasize this requirement. Since GAO’s study was issued, the 

four agencies have reported taking steps to strengthen their support for CIO 

certifications, such as providing additional resources and guidance for the 

process, and OMB has updated parts of its guidance. 

In contrast to the CIO review process, which did not lead to reduced 

paperwork burden in GAO’s 12 case studies, IRS and the Environmental 

Protection Agency (EPA) have set up alternative processes specifically

focused on reducing burden. These agencies, whose missions involve 

numerous information collections, have devoted significant resources to 

targeted burden reduction efforts that involve extensive outreach to 

stakeholders. According to the two agencies, these efforts have led to 

significant reductions in paperwork burden on the public. In light of these 

promising results, the weaknesses in the current CIO review process, and 

the persistent increases in burden, a new approach to burden reduction 

appears warranted. GAO suggested that Congress should consider 

mandating pilot projects to target some collections for rigorous analysis

along the lines of the IRS and EPA approaches. 

www.gao.gov/cgi-bin/getrpt?GAO-06-974T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Linda Koontz at

(202) 512-6240 or koontzl@gao.gov. 
Madam Chairman and Members of the Subcommittee: 

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

Paperwork Reduction Act (PRA).1

 As you know, one of the goals of 

the PRA is to help ensure that when the government asks the public 

for information, the burden of providing this information is as small 

as possible and the information itself is used effectively. In other 

words, the goal is to minimize the paperwork burden while 

maximizing the public benefit and utility of the information 

collected. To achieve this goal, the PRA includes provisions that 

establish standards and procedures for effective implementation 

and oversight of information collections. Among these provisions is 

the requirement that agencies not establish information collections 

without having them approved by the Office of Management and 

Budget (OMB), and that before submitting them for approval, 

agencies’ Chief Information Officers (CIO) certify that the collection 

meets 10 specified standards—including that they avoid 

unnecessary duplication and reduce the paperwork burden as much 

as possible. 

As you requested, I will begin by discussing the estimates of 

government paperwork burden provided in the annual PRA report 

(known as the Information Collection Budget) that OMB recently 

released, which presents federal agencies’ estimates of federal 

paperwork burden as of the end of fiscal year 2005. I will also 

discuss results from a May 2005 report2

 that we issued on PRA 

processes and compliance, concentrating on our findings regarding 

agencies’ processes to certify that information collections meet PRA 

standards and on alternative processes that two agencies have used 

to minimize the paperwork burden. 

 1

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

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

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

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

2

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

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

Page 1 GAO-06-974T
In preparing this testimony, we reviewed prior work and analyzed 

OMB and other documents. For our discussion of the Information 

Collection Budget, we examined the current OMB report as well as 

our reviews of previous annual PRA reports.3

 For our discussion of 

the certification process, we drew on our May 2005 report, for which 

we performed detailed reviews of paperwork clearance processes 

and collections at four agencies: the Departments of Veterans 

Affairs (VA), Housing and Urban Development (HUD), and Labor 

and the Internal Revenue Service (IRS). Together, these four 

agencies represent a broad range of paperwork burden, and in 2004, 

they accounted for about 82 percent of the almost 8 billion hours of 

estimated paperwork burden for all federal agencies. Of this total, 

IRS alone accounted for about 80 percent.4

 We also selected 12 

approved collections as case studies (three at each of the four 

agencies) to determine how effective agency processes were. In 

addition, we analyzed a random sample (343) of all OMB-approved 

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

agencies) to determine compliance with the act’s requirements 

regarding agency certification of the 10 standards and consultation 

with the public. We designed the random sample so that we could 

determine compliance levels at the four agencies and 

governmentwide. Finally, although the Environmental Protection 

Agency (EPA) was not one of the agencies whose processes we 

reviewed, we analyzed documents and interviewed officials 

concerning the agency’s efforts to reduce the paperwork burden of 

its information collections. Further details on our scope and 

methodology are provided in the report. All work on which this 

testimony is based was performed in accordance with generally 

accepted government auditing standards. 

 3

For our most recent testimony on this subject, see GAO, Paperwork Reduction Act: New 

Approaches Can Strengthen Information Collection and Reduce Burden, GAO-06-477T

(Washington, D.C.: Mar. 8, 2006). 

4

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

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

governmentwide as of May 2004. 

Page 2 GAO-06-974T
Results in Brief 

After 2 years of slight declines, the total paperwork burden imposed 

by federal information collections increased in fiscal year 2005 and 

is projected to increase again in fiscal year 2006, according to 

estimates provided in OMB’s July 2006 annual PRA report to 

Congress. The estimated total burden for fiscal year 2005 was 8.4 

billion hours, which is an increase of 5.5 percent (441 million burden 

hours) from the previous year’s total of 8.0 billion hours. Nearly all 

this increase is the result of the implementation of new statutes. For 

example, there was an increase of about 224 million hours from the 

implementation of voluntary prescription drug coverage under 

Medicare. In addition, adjustments to the estimates (from such 

factors as changes in estimation methods and the population of 

respondents) accounted for a net increase in the burden of about 19 

million hours, and agency discretionary program changes led to a 

net increase of 180,000 hours. With regard to PRA violations 

(information collections that did not have OMB approval or for 

which that approval had expired), OMB reports that fewer occurred 

in fiscal year 2005 than previously, for a total of 97 violations. OMB 

also stated in this year’s report that IRS began using a new statistical 

model in fiscal year 2006 that will improve the accuracy and 

transparency of future taxpayer burden estimates. Using this new 

model is expected to result in an increase of 250 million hours in the 

burden estimate that IRS will report for next year. However, 

according to OMB, this expected rise does not reflect any real 

change in the burden on taxpayers, but only in how IRS estimates 

the paperwork burden.

The PRA requires that CIOs review information collections and 

certify that they meet standards to minimize burden and maximize 

utility; however, these reviews were not always rigorous. As we 

reported in 2005, agency CIOs generally reviewed information 

collections before they were submitted to OMB and certified that 

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

12 case studies showed that CIOs provided these certifications 

despite missing or inadequate support from the program offices 

sponsoring the collections. Further, although the law requires CIOs 

to provide support for certifications, agency files contained little 

Page 3 GAO-06-974T
evidence that CIO reviewers had made efforts to improve the 

support offered by program offices. Numerous factors have 

contributed to these problems, including a lack of management 

support and weaknesses in OMB guidance. Because these reviews 

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

assurance that the standards in the act—such as avoiding 

duplication and minimizing burden—were consistently met. 

In contrast, our May 2005 report discussed how IRS and EPA have 

used additional evaluative processes that focus specifically on 

reducing burden. These processes are targeted, resource-intensive 

efforts that involve extensive outreach to stakeholders. According to 

these agencies, their processes led to significant reductions in 

burden on the public while maximizing the utility of the information

collections. For example, in this year’s PRA report, OMB cites a 

decrease of about 19 million hours from streamlining IRS’s Form 

1041 to make it easier and faster to understand and file. 

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

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

suggested that Congress should consider mandating pilot projects to 

target some collections for rigorous analysis along the lines of the 

approaches used by IRS and EPA. OMB and the agencies agreed 

with most of the recommendations. Since our study was issued, the 

four agencies have reported taking steps to strengthen their support 

for CIO certifications, such as providing additional resources and 

guidance for the process, and OMB has updated parts of its 

guidance to agencies. However, the updated guidance is not aimed 

at all information collections, but rather at conducting surveys that 

are used for general-purpose statistics or as part of program 

evaluations or research studies. 5 In addition, it does not provide 

clear guidance on one of the topics mentioned in our 

recommendation: determining whether small entities are affected by 

a collection and reducing reporting burden on these entities. 

 5

 The updated guidance is focused on surveys and statistical information collections, but it 

includes some general PRA requirements applicable to any information collection, namely, 

general information on submissions to OMB and the scope of the definition of 

information collection (explaining, for example, that focus groups are included). 

Page 4 GAO-06-974T
Background 

Collecting information is one way that federal agencies carry out 

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

taxpayers and their employers to know the correct amount of taxes 

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

apportion congressional representation and for many other 

purposes. When new circumstances or needs arise, agencies may 

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

large portion of federal paperwork is necessary and often serves a 

useful purpose. 

Nonetheless, besides ensuring that information collections have 

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

to minimize the paperwork burden that the collection of information 

imposes. Among the provisions of the act aimed at this purpose are 

requirements for the review of information collections by OMB and 

by agency CIOs. 

Under PRA, federal agencies may not conduct or sponsor the 

collection of information unless approved by OMB; information 

collections for which OMB approval is expired or missing are 

considered violations of the PRA. Before approving collections, 

OMB is required to determine that the agency’s collection of 

information is necessary for the proper performance of the 

functions of the agency, including whether the information will have

practical utility.6

 Consistent with the act’s requirements, OMB has 

established a process to review all proposals by executive branch 

agencies (including independent regulatory agencies) to collect 

information from 10 or more persons, whether the collections are 

voluntary or mandatory. 

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

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

 6

44 U.S.C. 3508. 

Page 5 GAO-06-974T
implementation (now the agency’s CIO7

) to review program offices’ 

proposed collections. This official is to be sufficiently independent 

of program responsibility to evaluate fairly whether information 

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

each collection of information before submission to OMB, including 

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

collection and its plan for the efficient and effective management 

and use of the information to be collected, including necessary 

resources.8

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

each information collection instrument (form, survey, or 

questionnaire) complies with the act, certify that the collection 

meets 10 standards (see table 1), and provide support for these 

certifications. 

 7

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

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

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

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

Pub. L. 104-208, Sept. 30, 1996). 

8

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

Page 6 GAO-06-974T
Table 1: Standards for Information Collections Set by the Paperwork Reduction Act 

Standards 

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

The collection avoids unnecessary duplication. 

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

practicable and appropriate. 

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

respondents. 

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

recordkeeping practices to the maximum extent practicable. 

The collection indicates the retention period for any recordkeeping requirements for 

respondents. 

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

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

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

or mandatory; and a statement that no person is required to respond unless a valid OMB

control number is displayed). 

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

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

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

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

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

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

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

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

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

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

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

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

which reports on agency actions during the previous fiscal year, 

including changes in agencies’ burden-hour estimates as well as 

violations of the PRA. 

The 1995 PRA amendments also required OMB to set specific goals 

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

10 percent reduction in the governmentwide burden-hour estimate 

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

burden reduction goal in each of the next 4 fiscal years, and annual 

agency goals that reduce burden to the “maximum practicable 

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

estimated that their information collections imposed about 7 billion 

burden hours on the public. Thus, for these reduction goals to be 

Page 7 GAO-06-974T
met, the burden-hour estimate would have had to decrease by about 

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

on that date, the federal paperwork estimate had increased by about 

9 percent, to 7.6 billion burden hours. 

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

many times.

9

 In a succession of reports and testimonies, we noted 

that federal paperwork burden estimates generally continued to 

increase, rather than decrease as envisioned by the burden 

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

reduction claims were overstated. For example, although some 

reported paperwork reductions reflected substantive program 

changes, others were revisions to agencies’ previous burden 

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

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

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

compliance with PRA. In particular, we have often recommended 

that OMB and agencies take actions to improve the paperwork 

clearance process. 

Estimated Paperwork Burden Increased in 2005 

After 2 years of slight declines, OMB reports that burden hours 

increased in fiscal year 2005 and are expected to increase again in 

fiscal year 2006. According to OMB’s most recent PRA report to 

Congress, the estimated total burden hours imposed by government 

information collections in fiscal year 2005 was 8.4 billion hours; this 

is an increase of 441 million burden hours (5.5 percent) from the 

previous year’s total of 8.0 billion hours. It is also almost a billion 

and a half hours larger than it was in 1995 and 3.8 billion larger than 

the PRA target for the end of fiscal year 2001 (4.6 billion burden 

hours). OMB’s report also states that burden will increase in fiscal 

year 2006 by an estimated 303 million hours to about 8.7 billion 

hours; however, according to OMB, most of this projected increase 

(250 million hours or 83 percent) is attributable to a new method of 

 9

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

Page 8 GAO-06-974T
estimating burden that is being implemented by IRS, rather than to 

any increase in the actual burden. Finally, according to OMB, fewer 

violations of the act were reported than in previous years. 

Changes in Paperwork Burden Estimates Can Be Attributed to Various Causes 

Changes in paperwork burden estimates result from several causes, 

which OMB assigns to two main categories. OMB classifies all 

changes—either increases or decreases—in agencies’ burden-hour 

estimates as either program changes or adjustments. 

● Program changes are the result of deliberate federal government

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

can occur as a result of 

● new statutes, 

● agency-initiated actions, or 

● the expiration or reinstatement of OMB-approved collections.10

● Adjustments do not result from federal activities but from external 

factors. For example: 

● an agency may reestimate the burden associated with a 

collection of information, or 

● the population responding to a requirement may change—such as 

if the economy declines and more people complete applications 

for food stamps; the resulting increase in the Department of 

Agriculture’s paperwork estimate is considered an adjustment 

because it is not the result of deliberate federal action.

As shown above, within the category of program changes, OMB 

distinguishes between changes due to new statutes and changes due 

to agency action, which it also refers to as agency discretionary 

actions. However, this term should not imply that agencies have no 

discretion in how they implement new statutes. A major goal of the 

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

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

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

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

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

estimates based on new analysis. 

Page 9 GAO-06-974T
PRA is to ensure that agencies consider how to make the burden of 

information collections, whether old or newly established, as small 

as possible. In the second part of my statement, I will address one of 

the ways set forth in the PRA to help achieve this goal. 

Table 2 shows the changes in reported burden totals from fiscal year 

2004 to fiscal year 2005. 

Table 2: Changes in Governmentwide Reported Burden Totals by Category 

In millions

Change from fiscal year 2004 PRA report 

Category of change Hours Percent

Baseline: fiscal year 2004 total 7971.18

Fiscal year 2005 program changes: 0

Changes due to agency action 0.18 0 0.00

Changes due to new statutes 418.89 0 +5.26

Changes due to lapses in OMB approval 2.80 0 +0.04

Total program changes 422.00 +5.29

Fiscal year 2005 adjustments 19.14 +0.24

Fiscal year 2005 total 8412.27 +5.53

Source: OMB annual PRA report. 

Note: Numbers do not add exactly because of rounding. 

As the table shows, the change due to new statutes was by far the 

largest factor in the increase for fiscal year 2005. OMB reports that 

the statute having the largest impact on burden was the statute 

establishing voluntary prescription drug coverage under Medicare;11

implementing the program mandated by this statute required the 

collection of significant amounts of information, leading to an 

increase in burden of 224 million hours.12 An additional significant 

increase—about 116 million hours—resulted from the 

implementation by the Federal Communications Commission (FCC) 

of the CAN-SPAM Act, which requires disclosure of certain 

information contained in unsolicited commercial e-mails. 

 11 The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (Pub. L.

108-173). 

12 The prescription drug program, which began on January 1, 2006, is also projected to

result in an increase of about 5 million hours in fiscal year 2006. 

Page 10 GAO-06-974T
In contrast to changes due to new statutes, changes due to agency 

action did not contribute significantly to the overall change in 

burden this year, adding 180,000 hours out of the total rise of 441 

million. Although the overall result was a slight increase, agencies 

did take many actions that decreased burden; without these actions, 

the governmentwide increase would have been greater. The annual 

report does not list all these actions, but it does highlight actions 

that led to significant paperwork reductions and increases. (These 

include increases and decreases in burden from statutory 

requirements and miscellaneous agency actions, as well as burden 

reductions from changing regulations, cutting redundancy, changing 

forms, and using information technology.) From both an individual 

agency perspective and a governmentwide perspective, the 

relatively small increase due to agency action is the result of large 

increases and decreases that mostly offset each other: 

● From an individual agency perspective, the net change in an 

agency’s burden estimate is generally the result of disparate actions, 

some of which reduce burden and some of which increase it. An 

example is the IRS, which as an agency was responsible for a net 

decrease of about 3 million hours. Among the burden reductions 

that the annual report highlights are two IRS actions to change 

forms, both of which reduced burden by simplification and 

streamlining, for a reduction of about 19 million hours.13 The ICB 

also reports that in January 2006 IRS completed an initiative to 

simplify the process of applying for an extension to file an income 

tax return, which is associated with a burden reduction of 8 million

hours. Elsewhere, on the other hand, five IRS actions are highlighted 

that together resulted in an increase of about 24 million hours.14

Examples of reasons IRS took these actions included increasing 

accuracy and improving the agency’s ability to monitor compliance

with the law. 

 13 The two forms are Form 1041, U.S. Income Tax Return for Estates and Trusts and Form 

8879, IRS e-file Signature Authorization. 

14 These actions were associated with Form 1120, U.S. Corporation Income Tax Return; 

Form 1023, Application for Recognition of Exemption; Form 4070, Employee’s Report of

Tips to Employer; Form 941, Employer’s Quarterly Federal Tax Return; and Form 8858,

Information Return of U.S. Persons With Respect to Foreign Disregarded Entities. 

Page 11 GAO-06-974T
● Similarly, from a governmentwide perspective, the overall change is 

the result of some agencies whose actions produced a net decrease 

and others whose produced a net decrease. In fiscal year 2005, 

agencies with net decreases produced a reduction of about 14.02 

million hours. This reduction was offset, however, by agencies with 

net increases, which totaled about 14.20 million hours. 

Compared to program changes as a whole, adjustments to the 

estimates were a relatively small factor (as table 2 also shows), 

accounting for a net increase in the burden of about 19 million 

hours. In previous years, adjustments have had a much greater 

impact and have tended to decrease overall burden estimates, thus 

masking the effect of increases from program changes. In fiscal 

years 2003 and 2004, the impact of adjustments was large enough to 

lead to overall burden estimates that were lower than for the year 

before. In fiscal year 2004, OMB reported a decrease of about 156 

million hours in adjustments versus an increase of about 29 million

hours in program changes; the result was a lower overall burden 

estimate than for the previous year. Similarly, overall burden in 

fiscal year 2003 was slightly less than in fiscal year 2002, also as a 

result of a decrease in adjustments (about 182 million hours) that 

more than offset an increase in program changes (about 72 million

hours). 

Besides these large decreases due to adjustments, another reason 

for the slight decrease in total burden in fiscal years 2004 and 2003 

was that increases due to program changes were relatively small, as 

shown in table 3. This year, both program changes and adjustments 

went up, so adjustments did not have the effect of masking 

increases in program changes. As the table also shows, fiscal year 

2005 saw the largest net increase from program changes since 1998. 

Page 12 GAO-06-974T
Table 3: Increases in Burden Hours Due to Program Changes between Fiscal Years

1998 and 2005 

In millions

Fiscal year 

Total governmentwide burdenhour estimateNet increase in burden hours due

to program changes

2005 8,412.3 422.0

2004 7,971.2 28.5

2003 8,105.4 72.1

2002 8,223.2 294.1

2001 7,651.4 158.7

2000 7,361.0 188.0

1999 7,183.9 189.0

1998 6,951.1 41.1

Source: OMB. 

IRS Continues to Account for Largest Portion of Estimated Governmentwide Burden 

In fiscal year 2005, IRS accounted for about 76 percent of the 

governmentwide paperwork burden: about 6.4 billion hours. As 

shown in figure 1, no other agency’s estimate approaches this level. 

Six agencies had burden-hour estimates of 100 million hours or 

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

Transportation; EPA; FCC; and the Securities and Exchange 

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

paperwork burden experienced by the federal government have 

been largely attributable to changes associated with IRS.

15

 15GAO, Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates Due to Federal

Actions Continue to Increase, GAO-04-76T (Washington, D.C.: Apr. 20, 2004).

Page 13 GAO-06-974T
Figure 1: Distribution of Paperwork Burden among Agencies, Fiscal Year 2005 

OMB reports that starting in fiscal year 2006, IRS began using a new 

methodology based on a statistical model—the Individual Taxpayer 

Burden Model—to estimate the reporting burden imposed on 

individual taxpayers. Among other things, this new model, which 

was developed to improve the accuracy and transparency of 

taxpayer burden estimates, reflects the major changes over the past 

two decades in the way that taxpayers prepare and file their returns, 

including the use of electronic preparation methods. According to 

OMB, rather than estimating burden on a form-by-form basis, the 

new methodology takes into account broader and more 

comprehensive taxpayer characteristics and activities, considering 

how the taxpayer prepares the return (e.g., with or without software 

or a paid preparer) as well as the taxpayer’s activities, such as 

gathering tax materials, completing forms, recordkeeping, and tax 

planning. In contrast, the previous methodology primarily focused 

on the length and complexity of each tax form. OMB states that this

new model will make it possible to estimate the burden implications 

of new legislative and administrative tax proposals. 

OMB projects that these changes will create a one-time increase of 

about 250 million hours in the estimate of IRS burden levels in fiscal 

Page 14 GAO-06-974T
year 2006. This increase represents most (83 percent) of the total 

projected governmentwide increase for fiscal year 2006 of 303 

million hours. However, according to OMB, this increase does not 

reflect any change in the actual burden experienced by taxpayers, 

but rather a change in the way the burden is measured. 

In the past, we reported that IRS’s previous estimation model 

ignored important components of burden and had limited 

capabilities for analyzing the determinants of burden.16 The new 

model is the result of work that IRS has performed over the past 

several years to improve its model and address these and other 

limitations. At this time, we have not analyzed IRS’s new model to 

determine the extent to which it improves the accuracy of burden 

estimates, and we have not assessed the accuracy of the new 

model’s estimates. However, IRS’s efforts to increase the accuracy 

of its model appear to be an important step towards addressing the 

previous model’s shortcomings. 

These changes in IRS’s estimation methodology highlight the 

importance, when trying to interpret the annual burden estimates, of 

bearing in mind their limitations. For more than 50 years, the 

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

has been accepted by agencies and the public because it is a clear, 

easy-to-understand concept. But as IRS’s efforts show, burden-hour 

estimates are not a simple matter. The degree to which agency 

burden-hour estimates reflect real burden is unclear. It is 

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

respondent to collect and provide information or to estimate how 

many individuals an information collection will affect.17 In addition, 

like all estimates, paperwork burden estimates are not precise; 

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

meaningful. However, as long as the limitations are clearly 

 16GAO, Tax Administration: IRS Is Working to Improve Its Estimates of Compliance 

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

11See GAO, EPA Paperwork: Burden Estimate Increasing Despite Reduction Claims, 

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

paperwork burden. 

Page 15 GAO-06-974T
understood, these estimates can be useful as the best indicators of 

paperwork burden available. 

Fewer Violations Reported in Fiscal Year 2005 

OMB reports reductions in PRA violations for fiscal year 2005 

compared to previous years. The PRA prohibits an agency from 

conducting or sponsoring the collection of information unless 

(1) the agency has submitted the proposed collection to OMB, 

(2) OMB has approved the proposed collection, and (3) the agency 

displays an OMB control number on the collection. According to 

OMB’s annual report, agencies have made great progress in recent 

years in reducing the number of violations of these conditions and in 

resolving them more promptly. OMB attributed this reduction to 

several initiatives it had taken, including meeting with agency 

officials to discuss ways to reduce violations and adding reporting 

requirements. 

According to OMB, during fiscal year 2005, agencies reported a total 

of 97 violations: 60 information collections that expired during the 

year, and another 37 that had expired before October 1, 2004, and 

were not reinstated until fiscal year 2005. Of the 27 agencies 

included in the annual report, the three agencies with the greatest 

number of violations were the Departments of the Treasury and 

Homeland Security and the Small Business Administration. In 

addition, OMB reported no unresolved violations at the end of fiscal 

year 2005 and only 6 violations during the first 8 months of fiscal 

year 2006. The 97 violations reported in fiscal year 2005 is much less 

than the 164 violations in fiscal year 2004 and the 223 violations in 

fiscal year 2003. 

Although the reduction in violations is a positive trend, we should 

note that the violations reported may not be comprehensive; they 

include only those that agencies identified and reported to OMB. As 

a result, the statistics would omit violations of which agencies were 

unaware. In our May 2005 review, we examined forms posted on 

Web sites for four agencies (VA, HUD, Labor, and IRS). We found 

examples of violations among these forms of which the agencies 

Page 16 GAO-06-974T
were generally unaware.18 Based on our examination, we projected 

that the four agencies overall had an estimated 69 violations: 61 

collections in use without OMB approval and 8 expired collections. 

For example, we estimated 16 violations at VA; at that time, OMB’s 

report reflected VA’s belief that it had no violations. Based on these 

results, we recommended that the four agencies periodically review 

their Web sites to ensure that all forms comply with PRA 

requirements; we also recommended that OMB alter its guidance so 

that all federal agencies would be required to periodically review 

Web sites in this way. Since then, VA has reported to us that it 

removed forms from its Web site that were in violation of PRA.

However, OMB has not yet issued governmentwide guidance 

directing these types of reviews, so it is possible that some PRA 

violations remain undetected. 

Agency Processes for Reviewing Information Collections Were Not 

Effective 

Among the PRA provisions intended to help achieve the goals of 

minimizing burden while maximizing utility are the requirements for 

CIO review and certification of information collections. The 1995 

amendments required agencies to establish centralized processes 

for reviewing proposed information collections within the CIO’s 

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

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

CIO is to provide a record supporting these certifications. 

The four agencies that we reviewed for our May 2005 report all had 

written directives that implemented the review requirements in the 

act, including the requirement for CIOs to certify that the 10 

 18We examined all the forms that we could locate on the VA and Labor Web sites and 

examined a stratified random probability sample of forms on the IRS and HUD Web sites.

We randomly selected 119 forms from the 492 on the IRS Web site and selected a stratified 

random sample of 253 forms from the 423 on the HUD Web site. With these probability 

samples, each form in the population had a known and nonzero probability of being

selected. Each sampled form was subsequently weighted in the analysis to account

statistically for all the members of the population, including those that were not selected. 

Page 17 GAO-06-974T
standards in the act were met. However, in the 12 case studies that 

we reviewed, this CIO certification occurred despite a lack of 

rigorous support that all standards were met. Specifically, the 

support for certification was missing or partial on 65 percent (66 of 

101) of the certifications.19 Table 4 shows the result of our analysis 

of the case studies. 

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

Support provided

Standards Total

a

Yes Partial No

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

The collection avoids unnecessary duplication. 11 2 2 7

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

appropriate. 

12 5 7 0

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

respondents. 

12 1 0 11

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

recordkeeping practices to the maximum extent practicable. 

12 3 0 9

The collection indicates the retention period for any recordkeeping requirements for respondents.b6 3 3 0

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

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

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

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

12 4 8 0

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

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

11 2 0 9

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

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

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

12 8 4 0

Totals 101 35 30 36

Sources: Paperwork Reduction Act. GAO. 

a

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

collections. 

b

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

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

elements was categorized as no support. 

Under one of the standards mandated by the act, CIOs are required 

to certify that each information collection is not unnecessarily 

duplicative. According to OMB instructions, agencies are to 

 19The total number of certifications does not total 120 (12 cases times 10 standards) 

because some standards did not apply to some cases. 

Page 18 GAO-06-974T
(1) describe efforts to identify duplication and (2) show specifically 

why any similar information already available cannot be used or 

modified for the purpose described. In 2 of 11 cases, agencies 

provided the description requested, and in an additional 2 cases, 

partial support was provided.20 In 7 cases, support for these 

certifications was missing. An example of missing support is the 

following statement, used on all three IRS collections: 

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

This assertion provides no information on what efforts were made 

to identify duplication or perspective on why similar information, if 

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

the CIO reviewers challenged the adequacy of this support or 

provided support of their own to justify their certification. 

A second standard mandated by the act is that each information 

collection should reduce burden on the public, including small 

entities,

21 to the extent practicable and appropriate. OMB guidance 

emphasizes that agencies are to demonstrate that they have taken 

every reasonable step to ensure that a given collection of 

information is the least burdensome necessary for the proper 

performance of agency functions. In addition, OMB instructions and 

guidance direct agencies to provide specific information and 

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

collections and (2) justifications for any collection that requires 

respondents to report more often than quarterly, respond in fewer 

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

documentation. 

 20 The following is an example of support that we judged to be partial: for one collection,

the agency described how it attempted to identify duplicative sources, but it did not discuss 

why information from other sources could not be used, at least in part, to satisfy the needs

of the collection. 

21OMB’s instructions to agencies state that a small entity may be (1) a small business, which 

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

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

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

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

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

Page 19 GAO-06-974T
With regard to small entities, OMB guidance states that the standard 

emphasizes such entities because these often have limited resources 

to comply with information collections.22 The act and OMB guidance 

give various techniques for reducing burden on these small entities.23 

Our review of the case examples found that for the certification on 

reducing burden on the public, the files generally contained the 

specific information and justifications called for in the guidance. 

However, none of the case examples contained support that 

addressed how the agency ensured that the collection was the least 

burdensome necessary. According to agency CIO officials, the 

primary cause for this absence of support is that OMB instructions 

and guidance do not direct agencies to provide this information 

explicitly as part of the approval package. 

In addition, four of our case studies did not provide complete 

information that would support certification that the collection 

specifically addressed reducing burden for small entities.24

Specifically, 7 of the 12 case studies involved collections that were 

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

files for 4 of these 7 did not explain either 

● why small businesses were not affected, or 

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

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

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

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

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

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

23Techniques give in the act include (a) establishing different compliance or reporting

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

consolidating, or simplifying compliance and reporting requirements; and (c) exempting 

certain respondents from coverage of all or part of the collection. OMB guidance gives 

techniques that might be used to simplify requirements for small entities, such as asking

fewer questions, taking smaller samples than for larger entities, and requiring small entities 

to provide information less frequently. 

24In our governmentwide sample, some agencies did cite activities that are consistent with 

this standard, such as exempting certain small businesses and providing assistance to small 

businesses and other small entities. 

Page 20 GAO-06-974T
● even though such businesses were affected, that burden could or 

could not be reduced. 

Instead, the files included statements such as “not applicable,” 

which do not inform the reviewer whether or not there was an effort 

made to reduce burden on small entities. When we asked agencies 

about these four cases, they indicated that the collections did, in 

fact, affect small business. 

OMB’s instructions to agencies on minimizing burden on small 

entities require agencies to describe any methods used to reduce 

burden only if the collection of information has a “significant 

economic impact on a substantial number of small entities.” This 

does not appropriately reflect the act’s requirements concerning 

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

information collection reduces burden on small entities in general, 

to the extent practical and appropriate, and provides no thresholds 

for the level of economic impact or the number of small entities 

affected. OMB officials acknowledged that their instruction is an 

“artifact” from a previous form and more properly focuses on 

rulemaking rather than on the information collection process. 

The lack of support for the 10 certifications required by the act 

appeared to be influenced by a variety of factors. In some cases, as 

described above, OMB guidance and instructions were not 

comprehensive or entirely accurate. In the case of the duplication 

standard specifically, IRS officials said that the agency did not need 

to further justify that its collections are not duplicative because 

(1) tax data are not collected by other agencies, so there is no need 

for the agency to contact them about proposed collections, and 

(2) IRS has an effective internal process for coordinating proposed 

forms among the agency’s various organizations that may have 

similar information. Nonetheless, the law and instructions require 

support for these assertions, which was not provided. 

Further, agency reviewers told us that management assigns a 

relatively low priority and few resources to reviewing information 

collections. Further, program offices have little knowledge of and 

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

conditions and a lack of detailed program knowledge, reviewers 

Page 21 GAO-06-974T
often have insufficient leverage with program offices to encourage 

them to improve their justifications. 

When support for the PRA certifications is missing or inadequate, 

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

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

minimizing burden, have been consistently met. 

Two Agencies Have Developed Processes to Reduce Burden Associated with 

Information Collections 

IRS and EPA have supplemented the standard PRA review process 

with additional processes aimed at reducing the burden while 

maximizing the public benefit and utility of the information 

collected. These agencies’ missions require them both to deal 

extensively with information collections, and their management has 

made reduction of burden a priority.25

In January 2002, the IRS Commissioner established an Office of 

Taxpayer Burden Reduction, which includes both permanently 

assigned staff and staff temporarily detailed from program offices 

that are responsible for particular information collections. This 

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

greatest potential for burden reduction (these forms have already 

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

evaluates and prioritizes burden reduction initiatives by 

● determining the number of taxpayers impacted; 

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

● evaluating any adverse impact on IRS’s voluntary compliance 

efforts; 

● assessing the feasibility of the initiative, given IRS resource 

limitations; and 

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

Burden Reduction in January 2002 to lead its efforts.” Congressional testimony by the IRS

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

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

Page 22 GAO-06-974T
● tying the initiative into IRS objectives. 

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

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

stakeholders. This analysis includes an examination of the need for 

each data element requested. In addition, the office thoroughly 

reviews form design.26

The office’s director27 heads a Taxpayer Burden Reduction Council, 

which serves as a forum for achieving taxpayer burden reduction 

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

other agencies can be involved in burden reduction initiatives, 

including other federal agencies, state agencies, tax practitioner 

groups, taxpayer advocacy panels, and groups representing the 

small business community. 

The council directs its efforts in five major areas: 

● simplifying forms and publications; 

● streamlining internal policies, processes, and procedures; 

● promoting consideration of burden reductions in rulings, 

regulations, and laws; 

● assisting in the development of burden reduction measurement 

methodology; and 

● partnering with internal and external stakeholders to identify areas 

of potential burden reduction. 

According to IRS, this targeted, resource-intensive process has 

achieved significant reductions in burden. For example, it reported 

that about 95 million hours of taxpayer burden were reduced 

through increases in the income reporting threshold on various IRS 

 26In congressional testimony, the IRS Commissioner stated that OMB had referred another

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

burden reduction in government. 

27The director reports to the IRS Commissioner for the Small Business and Self-Employed 

Division. 

Page 23 GAO-06-974T
schedules.28 Another example, mentioned earlier, was given in 

OMB’s latest annual PRA report: in January 2006 IRS completed an 

initiative to simplify the process of applying for an extension to file 

an income tax return, which is associated with a burden reduction 

of 8 million hours.29 Another example from the annual PRA report is 

a reduction of about 19 million hours from a redesign of IRS form 

1041 to streamline the requirements and make it easier to read and 

file. 

Similarly, EPA officials stated that they have established processes 

for reviewing information collections that supplement the standard 

PRA review process. These processes are highly detailed and 

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

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

impetus for establishing these processes was the high visibility of 

the agency’s information collections and the recognition, among 

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

depended on information collections being properly justified and 

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

the “life blood” of the agency. 

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

involved in burden reduction initiatives, because they do not have 

sufficient technical program expertise and cannot devote the 

extensive time required.30 Instead, these officials said that the CIO 

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

requirements associated with information collections, educating and 

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

the impact on respondents, providing an agencywide perspective on

information collections to help avoid duplication, managing the 

 28In addition, the office reports that IRS staff positions could be freed up through its efforts 

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

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

29We did not verify the accuracy of IRS’s reported burden-hour savings. As discussed 

earlier, IRS’s revision to the methodology that it uses to compute burden is expected to 

result in different estimates of burden hours and burden-hour savings. 

30These officials added that in exceptional circumstances the CIO office has had staff 

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

Page 24 GAO-06-974T
clearance process for agency information collections, and acting as 

liaison between program offices and OMB during the clearance 

process. To help program offices consider PRA requirements such

as burden reduction and avoiding duplication as they are developing 

new information collections or working on reauthorizing existing 

collections, the CIO staff also developed a handbook31 to help 

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

and gain OMB approval. 

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

initiatives that are highly detailed and lengthy (sometimes lasting 

years) and that involve extensive consultation with stakeholders 

(including entities that supply the information, citizens groups, 

information users and technical experts in the agency and 

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

reported that it amended its regulations to reduce the paperwork 

burden imposed under the Resource Conservation and Recovery 

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

thresholds for small businesses to report information required under 

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

350,000 hours and save $22 million annually. Another example is an

ongoing EPA initiative reported in this year’s PRA report, the 

Central Data Exchange; this is an e-government initiative that is 

designed to enable fast, efficient, and more accurate environmental 

data submissions and exchange from state and local governments, 

industry, and tribes through the use of electronic reporting 

procedures. The estimated reduction for this initiative, which is 

expected to be complete in 2008, is 166,000 hours. 

Overall, EPA and IRS reported that they have produced significant 

reductions in paperwork burden by making a commitment to this 

goal and dedicating resources to it. In contrast, for the 12 

information collections we examined, the CIO review process 

resulted in no reduction in burden. Further, the Department of 

Labor reported that its PRA reviews of 175 proposed collections 

 31EPA Office of Environmental Information, Collection Strategies Division, ICR Handbook: 

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

Act of 1995, draft (revised March 2005). 

Page 25 GAO-06-974T
over nearly 2 years did not reduce burden.32 Similarly, both IRS and 

EPA addressed information collections that had undergone CIO 

review and received OMB approval and nonetheless found 

significant opportunities to reduce the paperwork burden. 

Agencies Could Strengthen PRA Review and Try Alternative Approaches to Reducing 

Burden 

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

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

examination of the burden imposed by information collections, and 

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

suggested options that Congress might want to consider when it 

next reauthorizes the act, including mandating pilot projects to test 

and review alternative approaches to achieving PRA goals. Such 

pilot projects could build on the lessons learned at IRS and EPA, 

which have used a variety of approaches to reducing burden, 

sharing information (for example, by facilitating cross-agency 

information exchanges), standardizing data for multiple uses, and 

integrating data to avoid duplication; and re-engineering work flows. 

Pilot projects would be most appropriate for agencies for which 

information collections are a significant aspect of the mission. 

In addition, we recommended (among other things) that agencies 

strengthen the support provided for CIO certifications and that OMB 

update its guidance to clarify and emphasize this requirement 

(including that agencies provide support showing that they have 

taken steps to reduce burden, determined whether small entities are 

affected and reduced reporting burden on them, and established a 

plan to manage and use the information to be collected, including 

the identification of necessary resources). OMB and the agencies 

agreed with most of the recommendations, although they disagreed 

 32These reviews did result in a 1.3 percent reduction in calculated burden by correcting

mathematical errors in program offices’ submissions. 

Page 26 GAO-06-974T
with aspects of GAO’s characterization of agencies’ compliance with 

the act’s requirements.33

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

steps to strengthen their support for CIO certifications: 

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

revised its certification process to require that before collections are 

submitted for review, they be approved at a higher management 

level within program offices. 

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

review process. 

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

obtained additional resources to help review and analyze its 

information collection requests. 

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

department intends to provide guidance to components regarding 

the need to provide strong support for clearance requests and has 

met with component staff to discuss these issues. 

OMB has updated parts of its guidance and plans to incorporate 

other guidance into an automated system to be used by agencies 

submitting information collections for clearance. In January 2006, 

OMB revised its guidance to agencies on surveys and statistical 

information collections. 34 This guidance, among other things, is 

aimed at strengthening the support that agencies must provide for 

certifying collections, as we recommended. For example, the 

guidance requires agencies submitting requests for approval to 

include context and detail that will allow OMB to evaluate the 

practical utility of the information to be collected. However, this 

 33For example, OMB, the Treasury, and HUD disagreed with our finding that certain forms

have been improperly treated as certifications and elections that are not subject to the 

PRA. Our view was and is that the forms in question did not properly fall into this category, 

because they entailed significant burden. 

34 OMB, Guidance to Agencies on Surveys and Statistical Information Collections, 

(Washington, D.C.: Jan. 20, 2006). 

Page 27 GAO-06-974T
guidance does not apply to all information collections. Rather, it 

applies only to surveys that are used for general-purpose statistics 

or as part of program evaluations or research studies. In addition, it 

does not provide clear guidance on one of the topics mentioned in 

our recommendation: determining whether small entities are 

affected by the collection and reducing reporting burden on these 

entities. 

OMB also reported that its guidance to agencies will be updated 

through a planned automated system that is to begin operating this

month.35 According to the former acting head of OMB’s Office of 

Information and Regulatory Affairs, the new system will permit 

agencies to submit clearance requests electronically, and the 

instructions will provide clear guidance on the requirements for 

these submissions, including the support required. This official 

stated that OMB has worked with agency representatives with direct 

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

system and its instructions clearly reflect the requirements of the 

process. If this system is implemented as described and OMB 

withholds clearance from submissions that lack adequate support, it 

could lead agencies to strengthen the support provided for their 

certifications. 

In conclusion, Madam Chairman, the PRA puts in place mechanisms 

to focus agency attention on the need to minimize the burden that 

information collections impose—while maximizing the public 

benefit and utility of government information collections—but these 

mechanisms have not succeeded in achieving the ambitious 

reduction goals set forth in the 1995 amendments. Achieving real 

reductions in the paperwork burden is an elusive goal, as attested by 

years of OMB’s annual PRA reports, including the latest. That report 

shows the largest rise in estimated burden for the last several years,

mostly due to new statutory requirements and how they have been 

 35The new system, ROCIS (the RISC/OIRA Consolidated Information System), is operated

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

Service Center of the General Services Administration. 

Page 28 GAO-06-974T
implemented. As we have seen, the tendency is for burden to rise 

unless agencies take active steps to reduce it. Agencies have taken 

such actions—by cutting redundancy, changing forms, and using 

information technology, among other things—but these have not 

been enough to make up for the increases. 

Besides demonstrating once again how challenging it is for the 

government to achieve true burden reduction, this year’s results 

highlight the need to look for new ways to achieve this and the other 

goals of the PRA. Among the mechanisms already in place is the CIO 

review and certification process. However, as it was implemented at 

the time of our review, this process had limited effect on the quality 

of support provided for information collections, and it appeared to 

have no appreciable impact on burden. 

The targeted approaches to burden reduction used by IRS and EPA 

appear promising, but the experience of these agencies suggests 

that success requires top-level executive commitment, extensive 

involvement of program office staff with appropriate expertise, and 

aggressive outreach to stakeholders. However, such an approach 

would probably also be more resource-intensive than the CIO 

certification process, and thus it may not be warranted at agencies 

where paperwork issues do not rise to the level of those at IRS and 

similar agencies. Consequently, it is critical that efforts to expand 

the use of the IRS and EPA models take these factors into 

consideration. 

Madam Chairman, this completes my prepared statement. I would 

be pleased to answer any questions. 

Contacts and Acknowledgments 

For future information regarding this testimony, please contact 

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

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

to this testimony were Barbara Collier, Nancy Glover, and Alan 

Stapleton. 

Page 29 GAO-06-974T
Attachment 1. Related GAO Products 

Paperwork Reduction Act: New Approaches Can Strengthen 

Information Collection and Reduce Burden. GAO-06-477T. 

Washington, D.C.: March 8, 2006. 

Paperwork Reduction Act: Subcommittee Questions Concerning 

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

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

Paperwork Reduction Act: Burden Reduction May Require a New 

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

Paperwork Reduction Act: New Approach May Be Needed to 

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

D.C.: May 20, 2005. 

Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates 

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

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

Paperwork Reduction Act: Record Increase in Agencies’ Burden 

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

Paperwork Reduction Act: Changes Needed to Annual Report. GAO02-651R. Washington, D.C.: April 29, 2002. 

Paperwork Reduction Act: Burden Increases and Violations 

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

Information Resources Management: Comprehensive Strategic 

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

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

Paperwork Reduction Act: Burden Estimates Continue to Increase. 

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

Electronic Government: Government Paperwork Elimination Act 

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

D.C.: September 15, 2000. 

Page 30 GAO-06-974T
Tax Administration: IRS Is Working to Improve Its Estimates of

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

2000. 

Paperwork Reduction Act: Burden Increases at IRS and Other 

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

EPA Paperwork: Burden Estimate Increasing Despite Reduction 

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

Federal Paperwork: General Purpose Statistics and Research 

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

September 20, 1999. 

Paperwork Reduction Act: Burden Increases and Unauthorized 

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

15, 1999. 

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

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

Regulatory Management: Implementation of Selected OMB 

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

Paperwork Reduction: Information on OMB’s and Agencies’ 

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

Paperwork Reduction: Governmentwide Goals Unlikely to Be Met. 

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

Paperwork Reduction: Burden Reduction Goal Unlikely to Be Met. 

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

Environmental Protection: Assessing EPA’s Progress in

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

March 21, 1996. 

Paperwork Reduction: Burden Hour Increases Reflect New 

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

December 6, 1993. 

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