FEDERAL

PAPERWORK

General Purpose

Statistics and

Research Surveys of

Businesses

United States General Accounting Office

GAO Report to the Honorable Sue W. Kelly

Chairwoman, Regulatory Reform and

Paperwork Subcommittee, House

Committee on Small Business

September 1999

GAO/GGD-99-169

United States

General Accounting Office

Washington, D.C. 20548

General Government Division

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Page 1 GAO/GGD-99-169 Federal Paperwork

GAO

September 20, 1999

The Honorable Sue W. Kelly

Chairwoman, Regulatory Reform and

Paperwork Reduction Subcommittee

Committee on Small Business

House of Representatives

Dear Madam Chairwoman:

The information collected by federal agencies is an integral tool for

accomplishing their missions. Agencies collect information for a variety of

purposes, including to verify regulatory and tax compliance, determine

eligibility for benefits, evaluate the effectiveness of federal programs,

develop economic statistics, and conduct research. However, these

information collections also impose a burden on those individuals,

businesses, and others asked or required to provide the information.

Federal paperwork is commonly measured in terms of “burden hours,” and

federal agencies estimated that they imposed nearly 7 billion burden hours

of paperwork in fiscal year 1998.1

 Previous studies have indicated that,

among businesses, small businesses can be disproportionately burdened

by federal regulatory requirements.2

Some small businesses have expressed concerns about the number of

surveys federal agencies ask them to complete, the amount of time it takes

them to complete the surveys, and the compulsory nature of some of the

surveys. To help address these concerns, you asked us to describe (1) the

paperwork burden associated with federal agencies’ general purpose

statistics and research (GPS/R) surveys that are directed towards

businesses; (2) the nature, use, and burden of selected GPS/R surveys; and

(3) the agencies’ efforts to reduce the burden associated with the selected

surveys.

GPS/R surveys account for an extremely small proportion (0.3 percent) of

the estimated paperwork burden that federal agencies impose on

businesses. Nevertheless, federal agencies estimated that businesses spent

12.6 million hours responding to 180 of these surveys in fiscal year 1998.

 

1

The burden-hour figures used in this report are, unless otherwise indicated, for information collections

approved by the Office of Management and Budget (OMB) at end of fiscal year 1998 (September 30,

1998). We refer to those collections in this report as burden imposed in fiscal year 1998.

2

Thomas D. Hopkins, A Survey of Regulatory Burdens, June 1995 report to the Small Business

Administration.

Results in Brief
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We estimate that all businesses’ financial costs to complete these 180

surveys were between about $219 million and $305 million. However, the

costs imposed on an individual business to complete even several of these

surveys may be quite small. Businesses are frequently required to respond

to the surveys and may face possible criminal or civil sanctions for failure

to do so. Two federal agencies—the Census Bureau in the Department of

Commerce and the Bureau of Labor Statistics (BLS) in the Department of

Labor (DOL)—accounted for more than half of the estimated

governmentwide GPS/R burden-hour total. Within these 2 agencies, 14

large surveys, each with at least 100,000 estimated burden hours,

accounted for nearly two-thirds of the governmentwide GPS/R burdenhour estimate.

The characteristics of the 14 large Census and BLS GPS/R surveys directed

at businesses varied widely. Six of these surveys were part of the

Economic Census, which is taken every 5 years, covers virtually all

businesses, and serves to update many other business statistics. Other

large GPS/R surveys were more frequent, more limited in the number of

businesses surveyed, covered only certain types of businesses, or

addressed more specialized topics. Survey topics ranged from changes in

the selling prices of goods and services to the characteristics of businesses

owned by minorities and women. The agencies’ estimates of the time

needed to complete each survey varied from a few minutes to 6 hours. The

estimated number of respondents ranged from about 27,000 for one survey

to more than 2 million in others. The statutes requiring or authorizing the

surveys generally provide the agencies with a substantial degree of

discretion to determine the scope, substance, and, in some cases,

frequency of the surveys. All of the surveys provide economic information

that is widely used by federal, state, and local governments; businesses;

and the general public. Although the agencies indicated that responses to 5

of the 14 surveys were voluntary, some of these “voluntary” surveys are

mandatory in certain states under the laws of those states. Census and BLS

estimated that these 14 surveys imposed $179 million in financial costs on

businesses in fiscal year 1998.

Both BLS and Census have taken steps to minimize or reduce the burden

associated with these 14 GPS/R surveys, including (1) designing and

administering the survey instruments to minimize burden on the survey

respondents, (2) using information technology to enable businesses to

respond to surveys electronically, and (3) using administrative records in

other agencies as a substitute for or a supplement to surveying the

businesses directly. However, both agencies said that statutory

confidentiality restrictions are an obstacle to greater burden reduction
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through data sharing. The executive branch has proposed and Congress

has introduced legislation to address this issue.

The Paperwork Reduction Act of 1995 (PRA) requires federal agencies to

minimize the paperwork burden that they impose on individuals, small

businesses, and others through their collections of information. At the

same time, the PRA recognizes that information is a critical resource

enabling the federal government to perform its most basic functions. The

original PRA in 1980 established the Office of Information and Regulatory

Affairs (OIRA) within OMB to provide central agency leadership and

oversight of governmentwide efforts to reduce unnecessary paperwork

and improve the management of information resources. The 1995 PRA

gave OIRA and executive branch agencies significant new responsibilities,3

but continued the requirement that agencies obtain OIRA approval before

collecting information from the public. It also required OIRA to set annual

burden-reduction goals totaling at least 25 percent for the 3-year period

ending on September 30, 1998.

As part of its review process, OIRA requires that agencies submit a

completed OMB Form 83-I along with other materials to justify a proposed

information collection. The Form 83-I provides the agency’s estimate of the

number of burden hours for the collection, which is based on (1) the

estimated amount of time needed by each respondent to provide the

requested information, (2) the number of respondents for the collection,

and (3) the frequency of the collection. The Form 83-I also indicates the

primary purpose of the collection (e.g., general purpose statistics,

research, or regulatory or compliance monitoring); the primary target of

the collection (e.g., businesses, individuals, or state and local

governments); and whether responding to the survey is voluntary or

mandatory. When OIRA completes its review, information from the Form

83-I is to be entered into a database maintained by the Regulatory

Information Service Center (RISC).4

 OIRA uses the RISC database and

other information to develop its annual Information Collection Budget,

which contains governmentwide data on the number of approved

information collections each year and the agencies’ burden-hour estimates

as of September 30 of each year.

 

3

For a discussion of some of those responsibilities, see Regulatory Management: Implementation of

Selected OMB Responsibilities Under the Paperwork Reduction Act (GAO/GGD-98-120, July 9, 1998).

4

RISC is part of the General Services Administration but works closely with OMB to provide the

President, Congress, and the public with information on federal regulations. RISC maintains a database

that includes information on all regulatory actions and all information collection review actions by

OIRA.

Background
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The PRA also makes OIRA responsible for governmentwide statistical

policy and coordination of the federal statistical system. The PRA requires

OIRA to ensure the efficiency and effectiveness of the system and the

integrity, objectivity, impartiality, utility, and confidentiality of data

collected for statistical purposes. The PRA also requires OIRA to develop

and oversee the implementation of governmentwide guidance concerning

statistical collection procedures and methods. Additionally, the PRA

mandated the establishment of an Interagency Council on Statistical

Policy, composed of the heads of major statistical programs and

representatives of other statistical agencies, to advise and assist OIRA on

statistical issues.

We have issued several reports and testimonies on the implementation of

the PRA, noting that the burden reduction goals envisioned in it were not

being met.5 Agencies frequently pointed to new and existing statutory

requirements for information collection as impediments to achieving the

goals. We also noted a variety of problems with the “burden-hour”

measures that are used as indicators of the paperwork burden and said

that it is important to recognize the difference between the government’s

“measured” paperwork burden that is reflected by the number of burden

hours an agency reports and the “real” burden that is felt by the public.

Users of paperwork burden-hour estimates need to proceed with great

caution because it is often unclear exactly what the burden estimates

represent and what factors can cause changes in the totals. Nevertheless,

these measures are the best indicators of paperwork burden available, and

they can be useful as long as their limitations are considered.

Although one of the key purposes of the PRA is to reduce paperwork and

minimize burden on the public and businesses, the PRA also requires

agencies to balance burden reduction goals against agencies’ needs for

information critical to performing their missions. For the federal statistical

system, after years of retrenchment, there has been renewed national

recognition in the 1990’s of the importance of federal statistics and a

commitment to improve the quality of the system. We have issued several

reports and testimonies on major initiatives to improve the quality of

federal economic statistics.6

 In 1990 and 1991, the Council of Economic

 

5

Paperwork Reduction: Burden Reduction Goal Unlikely To Be Met (GAO/T-GGD/RCED-96-186, June 5,

1996); Paperwork Reduction: Governmentwide Goals Unlikely To Be Met (GAO/T-GGD-97-114, June 4,

1997); and Paperwork Reduction Act: Implementation at IRS (GAO/GGD-99-4, Nov. 16, 1998).

6

For example, Economic Statistics: Status Report on the Initiative to Improve Economic Statistics

(GAO/GGD-95-98, July 7, 1995); Federal Statistics: Principal Statistical Agencies’ Missions and Funding

(GAO/GGD-96-107, July 1, 1996); Statistical Agencies: Statutory Requirements Affecting Government

Policies and Programs (GAO/GGD-96-106, July 17, 1996); Statistical Agencies: Consolidation and

Previous Reports and

Testimonies
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Advisors, chaired by Michael Boskin, reviewed national economic

statistics and announced a group of recommendations to improve the

quality of economic statistics. The recommendations from the two “Boskin

reports,” formally known as the Economics Statistics Initiative, have

subsequently been a key part of the federal government’s long range

statistical plan described in the Statistical Programs of the United States

Government: Fiscal Year 1999 that is produced annually by OMB.

Recommended improvements in those reports would require more

frequent collection of some data, revised measures of key economic

indicators, and the development of new measures for emerging industries

and services. However, collecting more information to improve these

economic statistics may conflict with agencies’ efforts to reduce

paperwork burden.

The Boskin reports and OMB also recommended increased data sharing

among statistical agencies to reduce burden. OMB developed a legislative

proposal to permit greater data sharing while preserving the confidentiality

protections in existing law. Relatedly, data-sharing legislation has been

introduced in each recent session of Congress. We have supported these

proposals to revise existing law to permit greater data sharing in our prior

reports and testimonies.

We used RISC data to describe the paperwork burden associated with

federal agencies’ GPS/R surveys that were directed toward businesses as

of September 30, 1998 (the end of fiscal year date that OMB uses in its

annual Information Collection Budget). RISC provided data on agencies’

burden-hour estimates for all information collections, those directed

primarily at businesses, and business surveys whose primary purpose was

to develop general purpose statistics or conduct research. Of the GPS/R

surveys on business, RISC provided data by agency, by whether responses

were voluntary or mandatory, and by individual collection within certain

agencies with large burden-hour totals. Using Census and BLS estimates of

wage rates from 14 large information collections, we developed estimates

of the annual governmentwide costs to businesses of responding to all

GPS/R surveys.

To describe the characteristics of the 14 large GPS/R surveys within

Census and BLS, we obtained information that agencies submitted on the

Form 83-I and in supplementary information that described the need for

the surveys, how the data would be used, the agencies’ burden-hour

 Quality Issues (GAO/T-GGD-97-78, April 9, 1997); and Statistical Agencies: Proposed Consolidation and

Data Sharing Legislation (GAO/T-GGD-98-91, March 26, 1998).

Scope and

Methodology
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estimates, and the agencies’ efforts to reduce paperwork burden,

particularly on small businesses. We also reviewed the relevant federal

statutory provisions for the 14 surveys to determine the extent to which

the agencies had discretion in administering these surveys. We discussed

each of the 14 surveys with responsible agency officials at BLS and Census

(e.g., to determine whether these surveys were mandatory or voluntary

within certain states), and discussed related issues (e.g., how national

economic statistics are used) with OIRA’s chief statistician and staff from

the statistics branch.

We obtained information on agencies’ efforts to reduce the burden

associated with the 14 GPS/R surveys of businesses through discussions

with BLS, Census, and OIRA officials, and by reviewing documentary

evidence. We also asked these officials about barriers to agencies sharing

the data collected through these information collections and initiatives to

eliminate these barriers to data sharing.

Our review focused on GPS/R information collections in effect at the end

of fiscal year 1998. Because the burden associated with the economic

censuses is primarily imposed only once every 5 years (which included

fiscal year 1998), the burden-hour estimates for the information collections

would be less in other years. Also, it is important to keep in mind that the

agencies’ burden-hour estimates are estimates; it is unclear how accurately

they reflect the real burden felt by the targets of the information

collections. Some of the information in this report is drawn from the RISC

database. We did not verify the accuracy of this database, but we did

obtain updated and corrected information for certain elements from BLS,

Census, and other agencies.

We did not evaluate the effectiveness of the agencies’ burden reduction

efforts or assess whether other reductions could have been made. Neither

did we independently determine how the information collected through

the GPS/R surveys is used. We conducted this review between November

1998 and August 1999 in the Washington, D.C., headquarters offices of

Census, BLS, and OIRA in accordance with generally accepted government

auditing standards.

We provided a draft of this report to officials responsible for GPS/R

surveys policy and administration in Census, BLS, and OMB for comment.

Their responses are presented in the Agency Comments and Our

Evaluation section at the end of this report.
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The estimated paperwork burden on businesses from GPS/R surveys in

fiscal year 1998 was a very small portion of the estimated burden on

businesses from all types of collections. Nevertheless, the 180 GPS/R

surveys approved by OIRA represented a substantial aggregate burden on

those businesses that had to complete the surveys—an estimated 12.6

million burden hours, or between $219 million and $305 million in

business’ compliance costs. Fourteen surveys administered by Census and

BLS accounted for nearly two-thirds of the governmentwide GPS/R

burden-hour estimate on businesses.

As of September 30, 1998, OIRA had authorized federal agencies to collect

information from businesses, individuals, and others through a total of

6,755 information collections. The agencies estimated that the paperwork

burden associated with all of these information collections was nearly 7

billion burden hours. As figure 1 shows, roughly two-thirds (4.6 billion) of

these burden hours were from information collections that were primarily

directed toward businesses.

Source: RISC database.

As figure 2 shows, most of the 4.6 billion burden hours on businesses were

associated with information collections primarily intended for regulatory

or compliance reporting. About three-tenths of 1 percent of the 4.6 billion

Most GPS/R Survey

Burden on Businesses

Was Imposed by

Census and BLS

GPS/R Surveys Are Small

Portion of Businesses’

Paperwork Burden

Figure 1: Burden Hours by Type of

Respondent
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burden hours on businesses (12.6 million burden hours) was from 180

information collections whose primary purpose was to develop general

purpose statistics or research.

Source: RISC database.

For more than three-quarters (9.8 million) of the 12.6 million burden hours

associated with GPS/R surveys primarily directed toward businesses, the

businesses were required to respond to the surveys. Although failure to

respond to the surveys could result in possible federal criminal or civil

sanctions, officials at OIRA, BLS, and Census told us that they were

unaware of any such sanctions being imposed for failure to respond to a

mandatory survey. In nearly all of the remaining surveys (about 3 million

burden hours), the respondents were under no federal obligation to

respond.7

 However, as will be discussed later in this report, some of these

“voluntary” surveys were made mandatory under the laws of certain states.

 

7

Surveys accounting for less than one-half of 1 percent of the governmentwide GPS/R burden-hour

estimate were coded in the RISC database as voluntary but required for benefits.

Figure 2: Burden Hours on Businesses

by Type of Information Collection

Most GPS/R Burden Hours Are

From Surveys With Mandatory

Responses
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As shown in table 1, more than 80 percent of the burden associated with

GPS/R surveys on businesses was from collections administered by two

departments—the Department of Commerce (about 66 percent) and DOL

(about 15 percent). Within the Department of Commerce, 7.8 million of the

8.3 million GPS/R burden hours were associated with surveys administered

by Census. Similarly, BLS accounted for almost all of DOL’s 1.9 million

GPS/R burden hours and surveys on businesses.

Department/Agency

Burden hours

(millions)

Percent of total

burden hours

Number of

surveys

Commerce 8.3 66% 61

 Bureau of the Census (7.8) (62) (41)

Labor 1.9 15 15

 Bureau of Labor Statistics (1.9) (15) (14)

Treasury 0.6 5 24

Health and Human Services 0.5 4 18

Energy 0.5 4 12

Other departments and agencies 0.8 6 50

Total 12.6 100 180

Source: RISC database.

Within Census and BLS, the paperwork burden is similarly concentrated in

a few surveys. Eight Census surveys and six BLS surveys account for about

85 percent of each bureau’s GPS/R survey burden on businesses. Together,

these 14 surveys accounted for nearly two-thirds (8.4 million hours) of the

governmentwide GPS/R burden-hour estimate.

Although paperwork burden has traditionally been reported in terms of

burden hours, federal agencies’ information collection requirements

impose real financial costs on individuals and organizations providing the

information. For businesses, those costs include the (1) financial resources

expended to cover capital, operating, and maintenance costs for

equipment, supplies, and nonlabor services (e.g., information technology

systems and monitoring equipment) and (2) wages of employees

responding to the collection. BLS and Census officials indicated that

employee wage costs account for virtually all of GPS/R survey

respondents’ financial costs.

In recent years, OMB has required agencies to convert burden hours into

dollar costs and report these estimates in their submissions to OMB. To do

so, agencies must estimate a wage rate that would be applicable to the

burden hours associated with the collection, including overhead and fringe

benefit costs related to the employee’s time (e.g., health insurance and

Census and BLS Imposed

Most GPS/R Survey Burden

on Businesses

Table 1: Number of Total Burden Hours

by Agency

GPS/R Surveys Impose

Substantial Aggregate Labor

Costs on Businesses
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contributions to a retirement plan).8 As will be discussed in detail later in

this report (see table 6), Census and BLS estimated respondents’ wage

rates for the 14 large GPS/R surveys range from $9.59 per hour to $30.00

per hour. Using these agency estimates, we calculated that businesses’

cost for completing all 14 of these surveys would be about $179 million.

The estimated wage rates in these 14 surveys can serve as a rough guide

for estimating the costs to businesses of responding to all GPS/R surveys.

As table 2 shows, if the wage rates associated with the other 166 GPS/R

surveys of businesses (4.2 million burden hours) were as low as $9.59 per

hour, the cost associated with completing those surveys would be about

$40 million. However, if the wage rates were as high as $30 per burden

hour, the businesses’ cost for the surveys would be about $126 million. By

adding these figures to the $179 million costs of the 14 largest surveys, we

estimated that businesses’ cost associated with all 180 GPS/R surveys was

between $219 million and $305 million.

Estimated range of labor

costs (millions)

Source

Number of

surveys

Burden

hours

(millions) Lower bound Upper bound

Large BLS and Census surveys 14 8.4 $179 $179

Other surveys 166 4.2 $40a $126b

Total 180 12.6 $219 $305

a

This estimate assumes labor costs of $9.59 per hour.

b

This estimate assumes labor costs of $30.00 per hour.

Source: The number of surveys and burden hours are from the RISC database. Cost estimates for the

l4 large BLS and Census surveys are from the agencies’ Form 83-I packages. (See table 6.) Upperand lower-bound labor cost estimates are based on wage rate ranges from BLS and Census surveys.

The characteristics of the 14 large Census and BLS GPS/R surveys varied

widely. Some of the surveys applied to all businesses, but others were

limited to certain sectors or types of businesses. The statutes requiring or

authorizing the surveys generally provide the agencies with a substantial

degree of discretion to determine the scope, substance, and in some cases,

frequency of the surveys. Survey topics ranged from changes in the selling

prices of goods and services to the characteristics of businesses owned by

minorities and women. The agencies’ estimates of the time needed to

complete each survey varied from a few minutes to 3.5 hours. Also, the

frequency of data collection differs across the surveys. Some of the

surveys are conducted monthly, but others are administered only once

 8

In the fiscal year 1999 Information Collection Budget, OIRA said “the proper accounting of such

overhead and fringe benefits has been an area of inconsistency and weakness in the present system of

burden estimation.”

Table 2: Estimated Labor Costs of

GPS/R Surveys of Businesses

Census and BLS GPS/R

Surveys Vary but

Collectively Impose

Substantial Burden on

Businesses
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every 5 years. The number of respondents ranges from about 27,000 for

one survey to more than 2 million in others.

All of the surveys provide economic information that is widely used by

federal, state, and local governments; businesses; and the general public.

Although the agencies indicated that responses to 5 of the 14 surveys were

voluntary, some of these surveys are mandatory in certain states. Together,

Census and BLS estimate that these GPS/R surveys of businesses account

for about two-thirds of the governmentwide burden-hour estimate for

those surveys, or $179 million in aggregate costs.

As tables 3 and 4 show, the scope and subject matter of the 14 Census and

BLS surveys of businesses that constitute the bulk of the agencies’ GPS/R

burden-hour estimates varied substantially. Some of the surveys collected

information about all businesses (e.g., the Producer Price Index), while

others focused on particular sectors (e.g., the various economic censuses)

or ownership groups (e.g., the Surveys of Minority- and Women-Owned

Business Enterprises). The topics covered by these surveys were equally

diverse, ranging from changes in businesses’ selling prices to

comprehensive information on establishments’ employment, payroll, and

geographic location.

Surveys’ Subject Matter and

Scope Differ
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Survey title Description

1. Economic Census of the Wholesale Trade Sector Every 5 years, this survey is to be conducted on the universe of businesses

in the wholesale trade industry. It is to collect facts about the structure and

functioning of the economy and features unique to this industry, such as

sales by commodity line and class of customer, the number of

establishments, sales, payroll, employment, and geographic location.

2. Economic Census of Manufactures Every 5 years, this survey is to be conducted on the universe of businesses

in the manufacturing industry. It is to collect facts about the structure and

functioning of the economy and features unique to this industry, such as

materials consumed, inventories held, the number of establishments,

payroll, employment, and geographic location.

3. Economic Census of Utilities; Transportation;

Information; Finance and Insurance; and Real Estate,

Rental, and Leasing Sectors

Every 5 years, this survey is to be conducted on the universe of businesses

in all of the listed sectors. It is to collect facts about the structure and

functioning of the economy and features unique to these industries, such

as amounts and sources of revenues/receipts, insurance benefits paid to

policyholders, purchased transportation, the number of establishments,

payroll, employment, and geographic location.

4. Economic Census of Retail Trade and Food Services Every 5 years, this survey is to be conducted on the universe of businesses

in the retail trade and food services industry. It is to collect facts about the

structure and functioning of the economy and features unique to this

industry, such as sales by merchandise line and customer class, the

number of establishments, receipts/revenues, payroll, employment, and

geographic location.

5. Economic Census of Professional, Scientific, and

Technical Services; Management, Support, Waste

Management, and Remediation Services; Educational

Services; Health and Social Assistance; Arts,

Entertainment, and Recreation; and Other Services,

except Public Administration Sectors

Every 5 years, this survey is to be conducted on the universe of businesses

in all of the listed industries. It is to collect facts about the structure and

functioning of the economy and features unique to these industries, such

as the number of establishments, receipts/revenues, payroll, employment,

and geographic locations.

6. Economic Census of Transportation/Commodity Flow

Survey

Every 5 years, this survey is to be conducted on a sample of businesses in

the commodity flow industry. It is to collect facts about the structure and

functioning of the economy and features unique to this industry, such as

the value of shipments, commodities shipped, modes of transportation

used, number of establishments, receipts/revenues, payroll, employment,

and geographic location.

7. Survey of Minority-Owned Business Enterprises

(SMOBE) and Survey of Women-Owned Business

Enterprises (SWOBE)

Every 5 years, this joint survey is to be conducted as part of the economic

census program. Unlike the other economic censuses, it surveys only a

sample of the businesses to obtain information on businesses owned by

minorities and women.

8. Shipper’s Export Declaration (SED) Program This survey is to collect information on individual shipments exported from

the United States. Shippers are to complete a survey form for almost every

shipment, and this information forms the basis for the official export

statistics compiled by Census.a The form itself serves as the export control

document used by Customs, the Bureau of Export Administration, and the

State Department.

a As discussed later in this report, exports between the United States and Canada do not require a

SED form to be completed. The United States and Canada have an agreement that the United States

will rely on Canadian import data for its export statistics.

Source: Supplementary documentation to the Form 83-I for each survey.

Table 3: Eight Surveys Accounted for Most of Census’ GPS/R Burden-Hour Estimate in Fiscal Year 1998
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Survey title Description

1. Current Employment Survey This survey is to collect data each month on employment, hours, and earnings

from a sample of nonfarm establishments (including governments). This is a

joint effort between BLS and the State Employment Security Agencies (SESA).

2. Occupational Employment Statistics This annual survey is to collect occupational employment data on workers in a

sample of businesses by industry. It is a joint effort between BLS, DOL’s

Employment and Training Administration, and the SESAs, which collect the

data.

3. Multiple Worksite Report This quarterly survey is to collect employment and wage data from the

universe of establishments of employers who operate more than one

establishment. This is a joint effort between BLS and the SESAs.

4. Survey of Occupational Injuries and Illnesses This annual survey is to collect information from a sample of businesses on the

characteristics of the most serious of nonfatal cases (i.e., those involving lost

work time) and the traits of workers sustaining such injuries and illnesses.

Participating state agencies collect and process the data from the employers

and provide it to BLS. (In other states, BLS collects the data directly from

employers.)

5. Producer Price Index This monthly survey, formerly known as the Wholesale Price Index, of a

sample of businesses is to measure average changes in selling prices

received by domestic producers for their goods and services.

6. Annual Refiling Survey This annual survey, formerly known as the Standard Industrial Classification

(SIC) form, is to collect and update information on a sample of employer’s

worksites, products, or services covering one-third of the businesses each

year. It is a joint effort between BLS and the SESAs.

Source: BLS Handbook of Methods (April 1997) and supplementary documentation to the Form 83-I

for each survey.

All 14 BLS and Census GPS/R surveys were based on statutory provisions

that either require or authorize the agencies to collect and/or report certain

information. However, all of the underlying statutes give the agencies at

least some discretion regarding how the surveys can be designed and

administered. For example, the agency may be able to decide whether to

collect information from all covered businesses or a sample of those

businesses, or determine the number and subject matter of questions

asked in the surveys. BLS’ annual Occupational Injuries and Illnesses

Survey is based, in part, on provisions in the Occupational Safety and

Health Act of 1970 (29 U.S.C. 673). The act requires the Secretary of Labor

to “develop and maintain an effective program of collection, compilation,

and analysis of occupational safety and health statistics,” and to “compile

accurate statistics on work injuries and illnesses.” However, the act does

not specify the frequency with which the survey should be conducted, the

number of businesses to be contacted, or the particular data elements in

the survey. The Occupational Injuries and Illnesses Survey is also based on

the general requirements in 29 U.S.C. 2, which says that BLS “shall collect,

collate, and report at least once each year, or oftener if necessary, full and

complete statistics on the conditions of labor and the products and

Table 4: Six Surveys Accounted for Most of BLS’ GPS/R Burden-Hour Estimate in Fiscal Year 1998

Underlying Statutes Give

BLS and Census Survey

Design Discretion
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distribution of the products of the same.” Therefore, although BLS must

collect the information on workplace injuries and illnesses (and other

“conditions of labor”) at least once each year, it could do so more

frequently if it determined that more frequent collection was necessary.

However, BLS has not done so.

Other statutes underlying the surveys are somewhat more specific, but still

provide broad discretion in survey design and administration. For

example, the Census Bureau’s SED Survey is based on 13 U.S.C. 301, which

requires the Secretary of Commerce to submit statistics on exports from

the United States by country and product to certain congressional

committees on quarterly and cumulative bases, and to report monthly and

cumulative international trade balances for the United States. The statute

authorizes the Secretary to collect information from all persons exporting

from the United States, and says the Secretary “shall compile and publish

such information pertaining to exports . . . as he deems necessary or

appropriate.” Therefore, although required to report the export

information by country quarterly, the Secretary has substantial discretion

regarding the specific content of the survey.

Also, 13 U.S.C. 131 says that the Secretary of Commerce “shall take,

compile, and publish censuses of manufactures, of mineral industries, and

of other businesses, including the distributive trades, service

establishments, and transportation . . .” The statute also requires that the

censuses be taken every fifth year after 1968, and that the data “relate to

the year immediately preceding the taking thereof.” Therefore, the Census

Bureau has no discretion regarding the frequency of the economic

censuses, the sectors on which information is to be collected, or the year

for which the data applies. On the other hand, the agency has broad

discretion regarding what specific information to collect, and whether to

contact all businesses or a sample of businesses within each specified

sector.

According to information provided by BLS, Census, and OMB, the data

collected in the 14 large GPS/R surveys are used for many different

purposes by both the public and private sectors. For example, the

Department of Transportation, the Federal Emergency Management

Agency, the Army Corps of Engineers, and other agencies use data from

the Census Bureau’s Commodity Flow Survey to plan transportation

infrastructure. Many localities also used the data from this survey in

responding to requirements in the Intermodal Surface Transportation

Efficiency Act of 1991. Similarly, the data collected in BLS’ monthly

Producer Price Index is used by the Federal Reserve Board’s Open Market

GPS/R Survey Data Are

Used for Many Purposes
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Committee in making decisions on monetary policy and in developing and

evaluating monetary and fiscal measures for evaluating the general

business environment. These survey data are also used in the private

sector to evaluate escalating contract costs, inventory accounting

processes, and the condition of markets. In addition, industry, academia,

legal professionals, the news media, and the general public use the data to

evaluate businesses, markets, and characteristics of firms; prepare

business plans; make economic decisions; and conduct economic

research. Other examples of how GPS/R survey data are used include the

following.

• The Small Business Administration and the Minority Business

Development Agency use data from the SMOBE/SWOBE Surveys when

allocating resources for their business assistance programs. Others use

data from these surveys to evaluate the concentration of minority-owned

businesses in particular industries or geographic areas.

• DOL’s Occupational Safety and Health Administration (OSHA) and its

state-level counterparts use the data from the Occupational Injuries and

Illnesses Survey to evaluate the effectiveness of federal and state programs

to improve workplace safety and to prioritize federal and state funds.

• BLS uses the data collected in the Multiple Worksite Report to develop the

Business Establishment List, which is used as the sampling frame for

establishment surveys, such as the Producer Price Index.

• Various private enterprises, government agencies, and organized labor use

data from the Current Employment Survey to calculate such indexes as the

Composite Index of Leading Economic Indicators.

• Information from the Annual Refiling Survey is used in developing BLS’

Business Establishment List to help ensure that the correct SIC code,

name, and physical location are assigned to the employers’ worksites for

unemployment insurance records and labor market information purposes

in a particular state. State and local officials also use these data for

industrial coding classification. In addition, state employment security

agencies use the data to administer their unemployment insurance

programs.

• The SED Survey serves as the official record of export transactions for the

United States. In addition, Customs and the Bureau of Export

Administration use the data to enforce export regulations.

The Census Bureau indicated that survey recipients were required to

respond to all eight of its large GPS/R surveys because the underlying

statutes require Census to collect and/or report the information. In

addition, Census officials said that they tend to get higher response rates

Response to Most Large

GPS/R Surveys Was

Mandatory
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on surveys with mandatory response requirements than on surveys with

voluntary responses.

Census officials said that the mandatory response requirement to their

surveys is traceable to 13 U.S.C. 224, which says

[w]hoever, being the owner, official, agent, person in charge, or assistant to the person in

charge, of any company, business, institution, establishment, religious body, or

organization of any nature whatsoever, neglects or refuses, when requested by the

Secretary or other authorized officer or employee of the Department of Commerce or

bureau or agency thereof, to answer completely and correctly to the best of his knowledge

all questions relating to his company, business, institution, establishment, religious body, or

other organization, or to records or statistics in his official custody, contained on any

census or other schedule or questionnaire prepared and submitted to him under the

authority of this title, shall be fined not more than $500; and if he willfully gives a false

answer to any such question, he shall be fined not more than $10,000.

The survey recipients’ obligation to respond to these mandatory Census

GPS/R surveys was communicated on the survey forms themselves and, in

some cases, in cover letters sent to the recipients. For example, the

Economic Census of Retail Trade and Food Services noted in bolded

capital letters that “your response is required by law.” At the bottom of the

form, also in bolded capital letters were the words “penalty for failure to

report.” The SED form required shippers to certify that they understand

“civil and criminal penalties, including forfeiture and sale, may be imposed

for making false or fraudulent statements herein, failing to provide the

requested information or for violation of U. S. laws on exportation.”

Although the statute allows for the imposition of criminal penalties for

failure to respond to a survey, Census officials told us that they have never

pursued any prosecutions.

In contrast to the Census surveys, response to five of the six BLS GPS/R

surveys of businesses was voluntary at the federal level. BLS officials said

that they prefer to use voluntary surveys, and that response rates are

generally higher when a survey is voluntary. They said one of their surveys,

the Occupational Injuries and Illnesses Survey, is mandatory because of a

specific federal statutory provision.

Although the RISC database indicated that responses to five of the six

large BLS GPS/R surveys were voluntary at the federal level, BLS officials

said that some states and territories made four of these surveys mandatory

during fiscal year 1998.

Some “voluntary” surveys were

mandatory in certain states
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• Response to the Multiple Worksite Report Survey was mandatory in 21

states, Puerto Rico, and the Virgin Islands.

• Response to the Annual Refiling Survey was mandatory in 19 states, Puerto

Rico, and the Virgin Islands.

• Response to the Current Employment Survey was mandatory in four states

and Puerto Rico.

• Response to the Occupational Employment Survey was mandatory in

North Carolina.

The officials said that survey recipients’ obligation to respond varied

between levels of government because BLS and the states and territories

jointly administered these surveys, and states can add requirements and

make the respondents’ obligation mandatory under state law. Although the

BLS survey instruments usually indicated that responses were voluntary,9

at least some of the cover letters that the states include with the surveys

inform the recipients of their mandatory nature. For example, on the first

page of the Multiple Worksite Report Survey, BLS stated that “[y]our

voluntary cooperation is needed to make the results of this survey

comprehensive, accurate, and timely.” However, the cover letter added by

the State of California stated that “completion of this form is required by

section 320 and 320.5 of the California Unemployment Insurance (UI)

Code.”

As noted earlier in this report, agencies’ annual burden-hour estimates for

an information collection are a function of three elements: (1) the time

needed to complete the information collection (including reviewing the

instructions, searching existing data sources, and gathering and

maintaining the needed data); (2) the number of respondents to the

collection; and (3) the frequency with which the information is collected

from the respondents within the specified year. Table 5 shows that,

although the agencies estimated that each of the 14 large GPS/R surveys

directed at businesses would require more than 100,000 burden hours of

paperwork, the surveys varied substantially in terms of these three

components. For example, the agencies estimated that some of the surveys

would take only a few minutes to complete (e.g., the Annual Refiling

Survey and the Current Employment Survey), but others were expected to

take hours (e.g., the Economic Census of Manufactures). Most of the

surveys were conducted only once during fiscal year 1998, but others were

administered quarterly (such as the Multiple Worksite Report) or monthly

(such as the Current Employment Survey and the Producer Price Index).

Several of the surveys that were administered during 1998 are not

 

9

BLS indicated in the Current Employment Survey that responses were mandatory in four states.

Large GPS/R Surveys

Impose Substantial

Aggregate Paperwork

Burden On Businesses
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scheduled to be repeated for 5 years. The number of survey respondents

varied from as few as 27,000 (the Producer Price Index) to more than 2

million (the Annual Refiling Survey and the SMOBE/SWOBE Survey). In

most cases, the surveys that the agencies expected to take the longest to

complete were administered less frequently and to fewer respondents than

surveys expected to take only a few minutes to complete.

Survey

Est. survey

completion time

(minutes) Survey frequency

Est. number of

respondents

(thousands)

Est. annual

burden hours

(thousands)

Bureau of Labor Statistics

Occupational Injuries and Illnesses Survey 54 Annually 230 207

Multiple Worksite Report 10 to 60 Quarterly 113 167

Current Employment Survey 2 to 15 Monthly 437 596

Annual Refiling Survey 5 to 15 Annually 2,086 203

Occupational Employment Survey 45 Annually 337 251

Producer Price Index

 Initial Visit

 Monthly Repricing

120

5 to 30

Once

Monthly

(6)

27

(13)

378

Total 3,230 1,802

Bureau of the Census

SED 3 to 11 Each shipment 159 1,316

Economic Census of Manufactures 120 to 360 Once every 5 years 210 762

Economic Census of Wholesale Trade Sector 70 Once every 5 years 540 634

Economic Census of Transportation/

Commodity Flow Survey 120

Quarterly during a 1-year

period every 5 years 100 805

Economic Census of Retail Trade 46 Once every 5 years 1,291 993

Economic Census of Professionals 37 Once every 5 years 1,443 900

Economic Census of Utilities 74 Once every 5 years 625 766

SMOBE/SWOBE 10 Once every 5 years 2,500 417

Total 6,868 6,593

Total for BLS and Census 10,098 8,395

Note 1. The estimated annual burden hour totals reported by the agencies do not always equal the

product of the estimated completion time, frequency, and number of respondents. Average

completion time is reported as a range for some surveys and anticipated response rate may affect the

estimated number of respondents.

Note 2. The Annual Refiling Survey is required at 3-year intervals. BLS annually surveys a different

third of the universe so that at the end of the 3-year period, it has administered this survey to the

universe. Unlike all the other surveys we reviewed, SED surveys are completed by the shippers at the

time of the export transaction and sent to Census. All of the other surveys are administered to the

businesses by the agencies on a monthly, quarterly, or annual basis. The economic censuses are

required every 5 years, which happened to fall during the time frame of our review. The Economic

Census of Transportation/Commodity Flow Survey is required during each quarter in the year that the

survey is taken.

Source: BLS and Census.

Table 5: Burden-Hour Estimates for Selected BLS and Census GPS/R Surveys of Businesses in Fiscal Year 1998
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Federal paperwork can also be measured in terms of financial costs

imposed on respondents. For businesses, those costs can be roughly

divided into the cost of the employees’ time to respond to the survey and

other costs, including capital and operating expenses (e.g., the purchase of

new hardware or software systems to produce the required information).

Both BLS and Census indicated that the 14 GPS/R surveys imposed no

such “other” costs.

BLS and Census estimated the cost of employees’ time to respond to an

information collection by multiplying the number of burden hours

associated with an information collection by the wage rate(s) of the types

of employees needed to produce the information. According to OMB,

agencies’ estimates of the wage rates for respondents should include

overhead and fringe benefit costs associated with the employee’s time

(e.g., health insurance and contributions to a retirement plan). As shown in

table 6, BLS’ estimates of the respondents’ hourly rates for its six largest

GPS/R surveys ranged from $9.59 to $19.91. Census estimated the

respondents’ hourly wage rates for its eight largest GPS/R surveys at

between $12.73 and $30.00. Multiplying the agencies’ estimates of the

respondents’ wage rates times their burden-hour estimates for the 14

GPS/R surveys of businesses yields a total cost to businesses of about $179

million in fiscal year 1998.

Agencies Indicate Surveys

Impose Substantial

Aggregate Costs
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Survey title

Respondents’

wage rate per

hour

Annual burden

hours

(thousands)

Total costs to

businesses

(millions)

Bureau of Labor Statistics

Occupational Injuries and Illnesses $12.50 207 $ 3

Multiple Worksite Report 13.72 167 2

Current Employment Survey 9.59 596 6

Annual Refiling Survey 13.04 203 3

Occupational Employment Survey 19.03 251 5

Producer Price Index 19.91 391 8

Total for BLS 1,815 $ 27

Bureau of the Census

SED a 1,316 $ 14

Economic Census of Manufactures 12.93 762 10

Economic Census of Wholesale

Trade Sector 30.00 634 19

Economic Census of

Transportation/Commodity Flow

Survey 30.00 805 24

Economic Census of Retail Trade 30.00 993 30

Economic Census of Professionals 30.00 900 27

Economic Census of Utilities 30.00 766 23

SMOBE/SWOBE 12.73 417 5

Total for Census 6,593 $152

Total (BLS and Census) 8,408 $179

a

The estimated cost per hour to complete a SED Survey ranges from $10 for a paper submission to

$15 for an electronic submission. Of the 1.3 million burden hours, Census estimated that about 1.1

million burden hours were for paper responses and about 0.2 million hours were for electronic

responses. Therefore, the burden-hour cost for the paper responses would be $10.7 million and for

the electronic responses $3.7 million.

Source: BLS and Census data.

It is important to remember that these are aggregate burden-hour and cost

estimates for all businesses in fiscal year 1998. The cost borne by each

business that receives one of these surveys is significantly less. For

example, recipients of the Occupational Injuries and Illnesses Survey take

an estimated 54 minutes (.9 hour) each year filling out the form, with an

associated wage rate of $12.50 per hour. Therefore, the estimated cost to

each recipient of the survey is $11.25 per year. Although a single business

may receive more than one of these surveys each year, its aggregate

burden may still not be substantial. For example, even if a single business

received all six of the BLS GPS/R surveys and the Census Bureau’s

SMOBE/SWOBE Survey in 1 year, the estimated labor cost to complete all

of the surveys would be less than $134.

Table 6: Estimated Costs Associated

with Responding to Surveys in Fiscal

Year 1998
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Both BLS and Census have taken a number of steps to minimize or reduce

the burden associated with the 14 large GPS/R surveys primarily directed

toward businesses. These steps include (1) designing and administering

the survey instruments to minimize burden on the survey respondents, (2)

using various types of information technology to enable businesses to

respond to surveys electronically, and (3) using information found in

administrative records in other agencies as a substitute or a supplement to

surveying the businesses directly. However, both agencies said that

statutory confidentiality restrictions are an obstacle to greater data

sharing, which could result in further burden reduction.

Census and BLS have attempted to design and administer their largest

GPS/R surveys to minimize the burden they impose on businesses,

particularly small businesses. For example, both agencies have developed

versions of some of their surveys for small businesses with fewer or less

complicated questions than versions directed to larger businesses. In the

Economic Census of Wholesale Trade, Census sends establishments with

fewer than four paid employees a simplified version of the survey form

that requests less data than the standard form that is sent to larger

employers. Similarly, businesses with only one owner receive shorter

SMOBE and SWOBE Surveys than businesses with more than one owner.

BLS and Census have also used sampling techniques to limit the number of

businesses to whom surveys are directed. The agencies also use special

sampling procedures in some surveys that reduce the chances of a smaller

business being selected compared to larger businesses, or of the same

businesses repeatedly being selected to respond to the survey. For

example, in its Occupational Injuries and Illnesses Survey, BLS employs a

stratified random sampling approach in selecting survey recipients.10 As a

result of using this approach, less than 4 percent of all businesses actually

receive a survey. Also, small employers (10 or fewer employees) are

prenotified in the Occupational Injuries and Illnesses Survey that they have

been selected for the survey and will need to maintain records. In the

Annual Refiling Survey, BLS annually surveys one-third of the universe of

the eligible businesses. As a result, an individual business can only be

selected for the survey once every 3 years. Similarly, to ensure that small

businesses are not unduly burdened by the Producer Price Index Survey,

BLS changes the sample of companies surveyed every 4 to 7 years.

 

10In stratified random sampling, the researcher ensures that appropriate numbers of elements are

drawn from homogeneous subsets of the population.

Census and BLS Have

Attempted to Minimize

Burden of GPS/R

Surveys on Businesses

Survey Design and

Administration
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The agencies have also attempted to minimize the surveys’ burden on

business by making it as easy as possible for the business to respond to the

surveys. For example, BLS’ Occupational Injuries and Illnesses Survey is

designed to allow employers who have no worker injuries or illnesses

(many of whom are small employers) to simply check a “no

injuries/illnesses” box on the survey, provide the number of employees and

hours worked, and return the survey in a postage paid envelope. Similarly,

the Census Bureau incorporated several changes into its Economic Census

of Transportation/Commodity Flow Survey to reduce burden on

businesses. For example, Census reduced the number of establishments

that were surveyed by 50 percent; reduced the shipping period covered by

the questionnaire from 2 weeks to 1 week; reduced the number of

shipments per questionnaire that respondents had to report on by 20

percent (from 50 to 40 shipments); and allowed respondents to use

estimates rather than actual numbers, particularly when generating the

actual numbers would require the respondent to incur additional expenses.

Changing the frequency of administering the surveys is another approach

that could be used to reduce burden on business. However, in some cases

the agencies are already administering the survey as infrequently as the

underlying statutes allow. Also, BLS and Census officials indicated that

administering their large GPS/R surveys any less frequently could have a

negative effect on the primary purposes of the data collections. For

example, BLS officials indicated that federal policymakers and economic

advisors use the monthly Producer Price Index in forming and evaluating

monetary and fiscal policy and helping to evaluate the general business

environment. They indicated that if this information were collected less

frequently it would take longer to recognize and adapt to changes in the

economy. Similarly, BLS officials said that collecting the quarterly Multiple

Worksite Report data less frequently (such as annually or semiannually)

would not provide the data necessary for certain users to produce

important economic indicators or to administer various programs at the

local, state, or national levels.

In addition, Census officials stated that conducting economic censuses

less frequently than every 5 years would diminish the time lines and

usefulness of the statistics produced and diminish the usefulness of the

economic census as a source of comprehensive information for economic

policymaking, planning, and program administration. Likewise, Census

officials said it is very important to collect export data through SED on an

ongoing basis. They said that if SED data were collected less frequently,

the government would not be able to produce monthly statistics on the

trade balance. They indicated that this information is a valuable
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component of the merchandise trade balance, which is one of the most

sensitive and closely watched economic indicators produced by the federal

government. Slight movements in the deficit could affect public policy,

financial decisions, or congressional actions.

Census and BLS are also using information technology in some of their

surveys to minimize the burden imposed on businesses through their

GPS/R surveys, to increase survey response rates, and to obtain more

accurate and up-to-date information. One common use of technology for

these surveys was some type of electronic filing of survey responses. For

example, BLS collects more than 80 percent of the responses to its Current

Employment Survey electronically. Census collects nearly half of the SED

responses in this manner. Electronic submission of the SED form cut the

estimated time needed to complete the survey from about 11 minutes to 3

minutes. The format of those electronic responses sometimes includes a

range of techniques for a single survey, including the use of computers,

telephones, and facsimiles. For example, BLS collects responses to the

Current Employment Survey via touch-tone data entry, computer-assisted

telephone interviews, electronic data interchange, facsimile collection, and

submission of tapes and diskettes.

The agencies are continuing to develop their uses of technology in virtually

all of these large GPS/R surveys, and have begun to provide technical

assistance to businesses in their use. For example, in 1987, Census

established a National Clearinghouse for Exporter Data Processing

Services to encourage exporters to use technology when filing their SED

reports. The Clearinghouse provides technological support to exporters,

freight forwarders, and carriers who want to file electronically but do not

have the capability to do so. Census officials said that they are replacing an

antiquated electronic exports reporting system with a new state-of-the-art

system that includes the filing of export documentation over the Internet.

When this is completed, there is to be one automated export tracking

system that would allow exporters to enter information into a single

common system that is used by Census, the Customs Service, and other

agencies.

BLS identified several specific ways it is changing its data collection

procedures to allow businesses to make better use of information

technology. For example, employers with worksites in more than one state

must currently submit their Multiple Worksite Reports to the relevant state

agencies in each state. BLS is encouraging the use of a program to permit

these employers to electronically submit the reports to a single data

collection center that would then distribute the report to all of the relevant

Use of Technology
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state agencies. BLS is also working with several private organizations that

prepare businesses’ payroll and reports commercially to enable them to

offer their clients the additional service of electronically submitting the

Multiple Worksite Reports directly to BLS. Finally, BLS officials said the

agency is developing a technology-based system for administering the

Producer Price Index that could benefit both businesses and BLS. Under

this system, BLS would be able to send businesses the price quotation

forms via the computer and allow the businesses to respond by facsimile.

For several of the 14 large GPS/R surveys, Census and BLS obtained at

least some of the needed data from administrative records kept by other

federal agencies, by state and local agencies, or by other organizations

rather than asking the respondents to provide the same information. In at

least some of these surveys, the use of administrative records resulted in

less paperwork burden on small businesses. For example, the Economic

Censuses on Manufactures, Professionals, and Utilities exclude most small

establishments from the mail surveys, relying instead on information from

administrative files kept by the Internal Revenue Service and the Social

Security Administration. The Census Bureau obtains more than 40 percent

of the responses to the Economic Census of Manufactures through

administrative records and more than one-quarter of the responses to the

Professionals and Utilities Censuses in this manner.

In the SED program, the United States and Canada entered into an

agreement in 1990 to share data on imports and exports, thereby reducing

the paperwork burden on shippers. In this agreement, the Census Bureau

uses Canadian data on imports from the United States as its measure of

American exports to Canada. Similarly, Canada uses U.S. data on Canadian

imports to replace the same data it had collected from its exporters. This

data-exchange agreement has resulted in the elimination of the

requirement for business exporting products from the United States to

Canada to file SEDs for each shipment, thereby saving American exporters

from preparing an estimated 3.5 to 4.0 million SEDs annually.

BLS also uses administrative data to reduce the paperwork burden

associated with some of its GPS/R surveys. For example, businesses

typically report workplace injuries and illnesses to both BLS through its

Occupational Injuries and Illnesses Survey and to state governments

through their workers’ compensation programs. However, version “W” of

the Occupational Injuries and Illnesses Survey enables businesses in six

participating states to provide less detail on their survey response if they

have already reported the detailed information to their states’ workers’

Use of Data From

Administrative Records
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compensation programs. BLS obtains this information from the worker

compensation agencies in those states.

In the Information Collection Budget for fiscal year 1999, OMB identified

seven categories of initiatives that agencies were undertaking to reduce

paperwork burden. Census and BLS have begun or completed initiatives in

most of these categories. However, Census and BLS are statutorily

prohibited from fully utilizing one of the seven categories—data sharing.

The Census Bureau’s restrictions on data sharing are in 13 U.S.C. 9, which

states that no officer or employee of the Department of Commerce or

bureau or agency thereof, may

“(1) use the information furnished under the provisions of this title for any purpose other

than the statistical purposes for which it is supplied; or (2) make any publication whereby

the data furnished by any particular establishment or individual under this title can be

identified; or (3) permit anyone other than the sworn officers and employees of the

Department or bureau or agency thereof to examine the individual reports.”

This and other statutory prohibitions on data sharing were put in place to

protect the confidentiality of survey respondents. The original PRA in 1980

gave the director of OMB the authority to direct a statistical agency to

share information it had collected with another statistical agency.

However, this authority did not apply to information covered by laws

prohibiting such disclosures. In the early 1980s, the statistical agencies,

under OMB’s leadership, proposed legislation that would have extended

their ability to share data, but legislation was not enacted.

For the past 2 decades, we and others have urged legislative changes that

would allow greater sharing of data and information on data sources

among agencies. In 1979, we recommended that existing law be amended

to allow the Bureau of the Census to share information on business

establishments with other government agencies.11 More recently, in March

1998, we said that the inability of statistical agencies to share data is one of

the most significant issues facing the statistical system and one of the

major factors affecting the quality of data, the efficiency of the system, and

the amount of burden placed on those who provide information to the

agencies.12

 

11After Six Years, Legal Obstacles Continue to Restrict Government Use of the Standard Statistical

Establishment List (GAO/GGD-79-17, May 25, 1979).

12Statistical Agencies: Proposed Consolidation and Data Sharing Legislation (GAO/T-GGD-98-91, Mar.

26, 1998).

Statutory Restrictions on

Data Sharing Prevent

Further Burden Reduction
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Data sharing is still an issue of concern in both the executive and

legislative branches. One of the Clinton administration’s key initiatives

identified in the Statistical Programs of the United States Government:

Fiscal Year 1999 addresses needed changes in statistical confidentiality

and data-sharing statutes and practices. Also, legislation has been

introduced in the 106th Congress (S. 205), which would, among other

things, permit limited sharing of records among designated agencies for

statistical purposes under strong safeguards.

Both Census and BLS support administration proposals to revise the

confidentiality statutes to allow data sharing among statistical agencies.

Officials in both agencies said that proposed changes permitting greater

data sharing offered a major way to reduce burden on businesses without

compromising the confidentiality or the quality of the information

collected. However, neither BLS nor Census is able to estimate how many

burden hours might be reduced in general or for specific surveys if datasharing legislation were enacted. A Census official told us that the extent

of burden reduction would depend on the specific provisions of the

legislation and on how data sharing was implemented. Among the 14

surveys that we examined, the official identified instances where Census

and BLS have duplication or overlap between collections and could

potentially reduce burden by sharing. However, he said the greater

potential for reducing burden would come from the agencies jointly

reengineering survey programs to increase standardization and reduce

duplication.

GPS/R surveys directed at businesses are extremely useful to federal

agencies, state and local governments, and to the businesses themselves.

For example, the Producer Price Index is used to make decisions on

monetary policy and to evaluate the condition of markets. Information

from the Occupational Injuries and Illnesses Survey is used to determine

the effectiveness of federal and state safety programs. The SED data are

the official record of export transactions from the United States. These

surveys also contribute data to national economic indicators that have

been developed and refined over the years to meet the needs of economic

policymakers and others for timely, accurate, and consistent information

on the state of our national economy.

Although GPS/R surveys of businesses account for a very small portion of

federal agencies’ total paperwork burden, the 12.6 million hours that

agencies estimated it took all businesses to complete GPS/R surveys in

fiscal year 1998 is a substantial paperwork burden. We estimated that

businesses’ aggregate labor costs to complete these surveys ranged from

Conclusions
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Page 27 GAO/GGD-99-169 Federal Paperwork

roughly $219 million to about $305 million. However, the burden imposed

on any one business may be quite small. Census and BLS, which account

for the bulk of the burden hours associated with GPS/R surveys, have

taken and continue to take steps to minimize or reduce the burden

associated with these information collections.

However, Census, BLS, and other statistical agencies are unable to

minimize or reduce paperwork burden as much as possible because of

statutory restrictions on sharing data collected for statistical purposes

between the agencies. We, OMB, and the statistical agencies have

supported revising those restrictions. Doing so could reduce information

collection costs to both respondents and the agencies collecting the data.

We provided a draft of this report to officials responsible for GPS/R survey

policy and administration in Census, BLS, and OMB for their review and

comment. We received oral comments from Census and BLS on August 20,

1999, and from OMB on August 30, 1999. Each agency agreed with our

overall characterization of GPS/R surveys of businesses and our

conclusions and each suggested technical and editorial changes, which we

incorporated into the final report as appropriate.

We are sending copies of this report to Representative William J. Pascrell,

Jr., Ranking Minority Member, House Committee on Small Business’

Subcommittee on Regulatory Reform and Paperwork Reduction; the

Honorable Jacob J. Lew, Director of OMB; the Honorable Alexis M.

Herman, Secretary of Labor; and the Honorable William M. Daley,

Secretary of Commerce. We will make copies available to others on

request.

Agency Comments and

Our Evaluation
B-281700

Page 28 GAO/GGD-99-169 Federal Paperwork

If you have any questions regarding this report, please contact me on (202)

512-8676. Key contributors to this assignment were Curtis Copeland,

Elizabeth Powell, and Ellen Wineholt.

Sincerely yours,

L. Nye Stevens

Director, Federal Management and

 Workforce Issues
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