FEDERAL 

STATISTICAL 

SYSTEM

Agencies Can Make 

Greater Use of 

Existing Data, but 

Continued Progress Is 

Needed on Access and 

Quality Issues

Report to the Chairman, Subcommittee on 

Federal Financial Management, Government 

Information, Federal Services, and International 

Security, Committee on Homeland Security and 

Governmental Affairs, U.S. Senate

February 2012

GAO-12-54

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-54, a report to the 

Chairman, Subcommittee on Federal Financial 

Management, Government Information, 

Federal Services, and International Security, 

Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

February 2012 

FEDERAL STATISTICAL SYSTEM 

Agencies Can Make Greater Use of Existing Data, 

but Continued Progress Is Needed on Access and 

Quality Issues

Why GAO Did This Study

As demand for more and better 

information increases, rising costs and 

other challenges require that the 

federal statistical system identify 

efficiencies. To explore opportunities to 

improve cost-effectiveness, GAO was 

asked to (1) review how the Office of 

Management and Budget (OMB) and 

agencies improve information 

collections, (2) evaluate opportunities 

and constraints for agencies to use 

administrative data (information 

collected as part of the administration 

of a program or held by private 

companies) with surveys, and (3) 

assess the benefits and constraints of 

surveys making greater use of the 

Census Bureau’s American 

Community Survey (ACS) data and 

resources. GAO focused on collections 

administered to households and 

individuals, analyzed statutory and 

agency documents, did five case 

studies of surveys, reviewed 

documentation of representative 

samples of active surveys, and 

interviewed agency officials and 

experts.

What GAO Recommends

GAO recommends that OMB take 

several actions to improve the broader 

efficiency of the federal statistical 

system, including implementing

additional quality-control procedures 

for selected website data, enhancing

awareness of ways to meet information 

collection requirements, better 

disseminating information on 

interagency committees, and 

developing comprehensive guidance 

for agencies to use when considering 

data sharing. OMB generally agreed 

with all of GAO’s recommendations. 

What GAO Found 

The Office of Management and Budget (OMB), agencies, and interagency 

statistical committees have distinct roles in identifying opportunities to improve 

federal information collection efforts. OMB exercises several authorities that 

promote the system’s efficiency, including overseeing and approving agency 

information collections. The website Reginfo.gov provides the public with 

information, such as cost and burden, on collections that OMB reviews, though 

GAO’s review identified some discrepancies in selected items. OMB periodically 

issues guidance to agencies on complying with federal requirements for 

information collections, but this guidance generally does not prescribe specific

actions to take. GAO’s analysis of agencies’ documentation of active surveys 

indicated that 77 percent included detailed descriptions of efforts to identify 

duplication, while those that did not tended to be for collections that are unlikely 

to duplicate existing information; and 75 percent reported actions beyond those 

required by statute to solicit external input. OMB, through enhanced guidance, 

could promote additional awareness of options agencies can take to identify 

duplication and solicit input. Interagency committees, which primarily draw 

members from the 13 agencies that have statistics as their primary focus, are 

particularly important in helping ensure collaboration. The committees have 

numerous projects underway aimed at addressing key challenges facing the 

statistical system. However, mechanisms for disseminating information about 

their work are not comprehensive or up-to-date. Though member agencies are 

the most-likely customers of the committees’ products, making information about 

committee work and priorities more accessible could benefit other agencies, 

academics, and the general public. It could also benefit committee members by 

providing a central repository for information. 

Administrative data have greater potential to supplement rather than replace 

survey data. Agencies currently combine the two data sources in four key ways 

to cost-effectively increase efficiency and quality. Specifically, agencies use 

administrative data to: (1) link to survey data to create new data products; (2) 

supplement surveys’ sample frames; (3) compare to survey data to improve 

accuracy and design of surveys; and (4) combine with survey data to create, or 

model, estimates. However, expanding the use of administrative data faces key 

constraints related to the access and quality of the data. While agencies and 

committees are taking steps to address these constraints and facilitate the 

process through which agencies work together to share data, individual tools 

may not be sufficient. A more-comprehensive framework for use by all agencies 

involved in data-sharing decisions that includes key questions to consider when 

evaluating potential use of administrative data could make the decision process 

more consistent and transparent.

ACS, an ongoing monthly survey that provides information about the nation’s

communities, offers agencies important opportunities to increase the efficiency 

and reduce the costs of their surveys, but its current design limits the extent to 

which agencies can utilize some of these opportunities. Uses that do not affect 

ACS design or the survey’s respondents, such as using ACS estimates to inform 

survey design or evaluate other surveys’ results, have widespread potential. 

However, more-intensive uses, such as adding content or supplemental surveys 

to the ACS, currently have limited potential.

View GAO-12-54. For more information, 

contact Robert Goldenkoff at (202) 512-2757 

or goldenkoffr@gao.gov or Ronald S. Fecso at 

(202) 512-7791 or fecsor@gao.gov. 
Page i GAO-12-54 Federal Statistical System

Letter 1 

Background 4

OMB and Agencies Take a Number of Steps to Ensure Efficient 

Information Collections, Though Opportunities Exist for 

Refinements 8

Administrative Data Could Help Improve Federal Surveys, but 

Continued Progress Is Needed on Access and Quality Issues 19

Prospects for Enhanced Use of the ACS with Other Surveys Are 

Mixed 28

Conclusions 34

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 36

Appendix I Scope and Methodology 39

Appendix II Description of Case-Study Surveys 45

Appendix III Selected Statutes Related to Information Collection 51

Appendix IV Printable Interactive Graphic 53

Appendix V Comments from the Department of Commerce 54

Appendix VI GAO Contacts and Staff Acknowledgments 56

Tables

Table 1: Overview of Interagency Statistical Committees 17

Table 2: Key Characteristics of the ACS 29

Table 3: Number of Collections, by Stratum 42

Table 4: Actions Taken to Address Constraints That Hamper 

Greater Use of Administrative Data 53

Contents
Page ii GAO-12-54 Federal Statistical System

Figures

Figure 1: The Thirteen Principal Statistical Agencies and Their 

Parent Organizations 5

Figure 2: Most Information Collections from Households and 

Individuals Have Relatively Modest Costs 7

Figure 3: Actions Taken to Address Constraints That Hamper 

Greater Use of Administrative Data 25

Abbreviations

ACS American Community Survey

BLS Bureau of Labor Statistics

CE Surveys Consumer Expenditure Surveys

CED Consumer Expenditure Diary Survey

CEQ Consumer Expenditure Quarterly Interview Survey

CIPSEA Confidential Information Protection and Statistical Efficiency

 Act 

ERS Economic Research Service

FCSM Federal Committee on Statistical Methodology

ICSP Interagency Council on Statistical Policy

NCHS National Center for Health Statistics

NCSES National Center for Science and Engineering Statistics

NHANES National Health and Nutrition Examination Survey

NHIS National Health Interview Survey

NSCG National Survey of College Graduates

OIRA Office of Information and Regulatory Affairs

OMB Office of Management and Budget

PRA Paperwork Reduction Act

ROCIS Regulatory Information Service Center and OIRA

 Consolidated Information System

SCOPE Statistical Community of Practice and Engagement

SIPP Survey of Income and Program Participation

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-54 Federal Statistical System

United States Government Accountability Office 

Washington, DC 20548

February 24, 2012

The Honorable Thomas R. Carper

Chairman

Subcommittee on Federal Financial Management, Government

 Information, Federal Services, and International Security

Committee on Homeland Security and Governmental Affairs

United States Senate

Dear Mr. Chairman:

Information is a critical strategic asset, and all levels of government, as 

well as businesses and private citizens, depend on relevant, accurate, 

and timely social, demographic, financial, and other federally funded datacollection efforts to inform their planning and other decisions. Collectively, 

this information plays a vital role in measuring the health and well-being 

of the nation, informing private-sector investment, allocating federal 

funding, and measuring the outcomes of government programs.

However, the federal statistical system, including (1) agencies that collect 

and analyze data, and (2) the Office of Management and Budget (OMB), 

which oversees the system, faces several challenges. Key among them is 

that the demand for information is increasing, especially as organizations 

look for ways to operate more cost-effectively, while the cost of collecting 

data is growing and response rates to surveys—both government and 

private-sector—are declining, driven in part by concerns over privacy and 

confidentiality. In the face of these challenges, it will be important for 

federal statistical agencies to identify opportunities to increase their 

efficiency, while maintaining or improving data quality and minimizing 

respondent burden and respecting privacy and confidentiality concerns. 

Greater use of administrative data, which includes information collected 

as part of the execution of government programs as well as information 

held by private companies, has been proposed as one approach to 

enhance efficiency and quality.1

 

1

Examples of administrative data include Social Security Administration records, state 

unemployment records, medical records, and store loyalty-card data.

Another potential approach is making 

greater use of the American Community Survey (ACS), a monthly survey 

 
 

Page 2 GAO-12-54 Federal Statistical System

that replaced the census long form and provides annual data on 

communities’ demographic, social, economic, and housing conditions.

At your request, this report (1) reviews the ways in which OMB and 

agencies identify opportunities for improvement and increased efficiency; 

(2) evaluates opportunities and constraints for the statistical agencies to 

use administrative data in conjunction with selected surveys; and (3) 

assesses the benefits and constraints of selected surveys making greater 

use of ACS data and resources.

To achieve our objectives, we focused our review on statistical 

information collections administered to households and individuals, as 

opposed to businesses or other entities, and subject to the Paperwork 

Reduction Act (PRA), which requires OMB approval of certain federal 

data collections.2

Additionally, to address all three objectives, we examined related statutes 

and regulations, applicable OMB guidance, documentation of the ACS 

and our case study surveys, papers and reports, and our own prior work.

Specifically, we performed case studies of five federal 

surveys: the Consumer Expenditure Surveys, sponsored by the Bureau of 

Labor Statistics (BLS); the National Health and Nutrition Examination 

Survey and the National Health Interview Survey, both sponsored by the 

National Center for Health Statistics (NCHS); the National Survey of 

College Graduates, sponsored by the National Center for Science and 

Engineering Statistics (NCSES), part of the National Science Foundation; 

and the Survey of Income and Program Participation, sponsored by the 

Census Bureau. We selected these surveys based on several factors, 

such as their size and cost and whether they use or have the potential to 

use administrative data or ACS data. We focused our selection on large 

surveys, in terms of both cost and number of respondents, because 

potential cost savings and efficiency gains are likely greatest for them.

3

 

2

The PRA is codified at 44 U.S.C. §§ 3501-3521. 

To gain an understanding of the information collections in our scope, we 

reviewed publicly available data from Reginfo.gov, a government website 

with information on agency requests for OMB approval of information 

3

For examples of our prior work, see: GAO, Federal Information Collection: A 

Reexamination of the Portfolio of Major Federal Household Surveys Is Needed, 

GAO-07-62 (Washington, D.C.: Nov. 15, 2006); American Community Survey: Key 

Unresolved Issues, GAO-05-82 (Washington, D.C.: Oct. 8, 2004). 
 

Page 3 GAO-12-54 Federal Statistical System

collections.4 We analyzed the subject matter of all of the collections in our 

scope and, for a representative sample of 106 surveys, analyzed 

agencies’ reported efforts to identify duplication and consult with persons 

outside of the agency. We interviewed experts on the federal statistical 

system and officials at OMB and the four agencies that administer the 

case-study surveys to learn about coordination among agencies, efforts 

agencies take to identify improvement, and experts’ and officials’ 

perspectives on current and potential uses of administrative data and 

ACS. We also interviewed and discussed these topics with officials at the 

Department of Agriculture’s Economic Research Service (ERS), which is 

a member of several interagency statistical committees and the lead 

agency for the Statistical Community of Practice and Engagement.5 In 

evaluating OMB, agency, and interagency actions to improve efficiency, 

we used as criteria the requirements of the PRA and practices identified 

in our prior work on agency collaboration.6

For the purposes of this review, we assessed the reliability of the data 

from the Reginfo.gov website and determined that they were reliable for 

some of our purposes but not others. Specifically, we reviewed related 

documentation, conducted interviews with OMB officials, and compared 

selected data elements from the Reginfo.gov website to supporting 

documents. We determined that the data were sufficiently reliable for 

purposes of identifying the collections within our scope and obtaining 

information on the collections’ subject matter and actions taken by 

agencies to identify duplication and solicit input. As described later in this 

report, data provided on the website were not sufficiently reliable for the 

purpose of assessing collections’ annual cost to the federal government 

and annual respondent burden hours. Appendix I includes additional 

information on our scope and methodology. Appendix II contains more 

detailed descriptions of our case-study surveys.

We conducted this performance audit from December 2010 to February 

2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

 

4

The website is maintained by OMB and the General Services Administration.

5

The Statistical Community of Practice and Engagement is an interagency committee that 

focuses on providing a collaborative community for agencies that focus on statistics. 

6

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005). 
 

Page 4 GAO-12-54 Federal Statistical System

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

In contrast to many other countries, the United States does not have a 

primary statistical agency.7

 

7

Examples of countries that have centralized statistical agencies include Australia, 

Canada, and Sweden. 

Instead, the statistical system is 

decentralized, with statistical agencies generally located in different 

government departments. This structure keeps statistical work within 

close proximity to the various cabinet-level departments that use the 

information. There are 13 federal agencies, referred to as the principal 

statistical agencies, which have statistical activities as their core mission. 

These agencies conduct much of the government’s statistical work, 

though there are more than 80 additional federal agencies that carry out 

some statistical work in conjunction with their primary missions. The 13 

principal statistical agencies are all attached to a cabinet-level department 

or an independent agency that reports to the president. As shown in 

figure 1, they are located at different levels within their respective 

departments and agencies.

Background
 

Page 5 GAO-12-54 Federal Statistical System

Figure 1: The Thirteen Principal Statistical Agencies and Their Parent Organizations

Note: The 13 principal statistical agencies’ names are displayed in boxes within the figure. 
 

Page 6 GAO-12-54 Federal Statistical System

For fiscal year 2011, $6.83 billion was requested for statistical work, 

which includes the collections in our scope as well as work that focuses 

on entities other than households and individuals, such as businesses 

and farms.8 This amount is about 0.2 percent of that year’s total federal 

budget request. Much of this work is concentrated in the 13 principal 

statistical agencies, which account for approximately 40 percent of 

requested funding. The budget request for the Census Bureau is among 

the highest of the principal statistical agencies. Excluding funding related 

to the decennial census, the fiscal year 2011 budget request for the 

Census Bureau was $558 million.9

Most of the collections in our scope have relatively modest annual costs. 

In a sample of 112 information collections that fell within our scope and 

were active as of September 22, 2011, the majority cost less than 

$500,000 annually, and fewer than one in five cost more than $1 million 

annually.

In addition to conducting its own 

statistical activities, the Census Bureau also performs statistical work for 

other agencies on a reimbursable basis.

10

 

8

The amount requested for statistical work includes requested funding for work done by 

federal agencies that have annual budgets of $500,000 or more for statistical work. OMB 

presented this information in Statistical Programs of the United States Government, Fiscal 

Year 2011, an annual report that it prepares on statistical program funding. This was the 

most up-to-date budget information available at the time of our review.

There are a few, more expensive, large and broad-based 

collections such as the Current Population Survey and National Health 

Interview Survey, both of which cost tens of millions of dollars each year, 

and the ACS, which costs over $200 million annually (see fig. 2).

9

When decennial census costs are included, the fiscal year 2011 budget request for the 

Census Bureau was $1.3 billion. 

10The sample of 112 collections was designed to be representative of the population of 

555 collections in our scope that were active as of September 22, 2011.
 

Page 7 GAO-12-54 Federal Statistical System

Figure 2: Most Information Collections from Households and Individuals Have 

Relatively Modest Costs

Various statutes and guidance from OMB and other entities establish 

standards for quality and privacy that apply to the federal statistical 

system. One of the most significant statutes is the PRA, which designates 

OMB as the coordinating body of the federal statistical system. The PRA 

establishes requirements that agencies must meet in order to administer 

information collections, and OMB must meet in overseeing the system, 

including that it issue guidance to agencies. Other entities also provide 

guidance to agencies that conduct statistical work.11

 

11For example, the Committee on National Statistics publishes “Principles and Practices 

for a Federal Statistical Agency” every 4 years in order to provide a current edition to 

newly appointed cabinet secretaries at the beginning of each presidential administration. 

This report outlines basic principles that statistical agencies should adhere to in order to 

carry out their missions effectively, as well as practices designed to help implement them.

In addition, use of 

information must be balanced with protection of privacy and 

confidentiality. Statutes such as the Confidential Information Protection 

and Statistical Efficiency Act (CIPSEA) apply to the federal statistical 
 

Page 8 GAO-12-54 Federal Statistical System

system and focus on ensuring the privacy and confidentiality of 

respondents’ information.12 Agency-specific statutes also protect the 

privacy and confidentiality of data collected by those agencies. For 

example, Title 13 of the U.S. Code authorizes the Census Bureau to 

request and collect information from individuals but also guarantees the 

confidentiality of these data and establishes penalties for unlawfully 

disclosing this information. Additional statutes are described in more 

detail in appendix III.

Under PRA, OMB, through its Office of Information and Regulatory Affairs 

(OIRA), has responsibility and broad authority to improve the efficiency 

and effectiveness of federal information resources.13

• Oversight and approval of information collections: OMB generally 

must approve information collections that are to be administered to 10 

or more people.

In this regard, OMB 

is charged with the oversight and coordination of federal agencies’ 

statistical activities. Specifically, these oversight functions are carried out 

by OIRA’s Statistical and Science Policy Branch, headed by the Chief 

Statistician, which includes five staff members who work closely on these 

oversight and coordination activities with approximately 25 other OIRA 

desk officers. OMB exercises four key authorities that contribute to the 

efficiency of the federal statistical system:

14

 

1244 U.S.C. § 3501 note.

OMB staff review agencies’ information collection 

1344 U.S.C. § 3504.

14Under PRA the term “person” includes, among others, individuals, partnerships, 

associations, corporations, and state and local governments. 

OMB and Agencies 

Take a Number of 

Steps to Ensure 

Efficient Information 

Collections, Though 

Opportunities Exist 

for Refinements

OMB Uses Its Oversight 

Authority to Improve 

Efficiency
 

Page 9 GAO-12-54 Federal Statistical System

requests to determine whether proposed collections meet PRA 

standards by assessing such factors as whether they are necessary 

for the mission of the agency and do not unnecessarily duplicate 

existing information. This review also enables OMB to identify 

opportunities for improvement. For example, according to OMB and 

agency officials, if it determines that it is necessary to ask similar 

questions in multiple collections, then OMB works to ensure that 

agencies ask them in a consistent manner, when appropriate.

• Standard-setting and guidance to agencies: OMB is responsible 

for developing and implementing governmentwide policies, principles, 

standards, and guidelines related to statistical issues, such as 

procedures and methods for collecting data and disseminating 

information. Specifically, OMB issues directives, guidance, and 

memorandums, and provides additional information through 

information sessions and presentations, to guide federal data 

collection and promote the quality and efficiency of information 

collections. For example, OMB published “Questions and Answers 

When Designing Surveys for Information Collections,” a set of 81 

questions and answers on the OMB review process for agency 

information collection requests required by PRA.15

• Budget development and reporting: Although agency budgets are 

initiated within agencies, OMB is responsible, under PRA, for ensuring 

that agency budget proposals are consistent with systemwide 

priorities for maintaining and improving the quality of federal statistics. 

In addition to the budgets themselves, OMB reports information to the 

public and Congress about the identification of key priorities through 

key documents. OMB annually reports on the paperwork burden 

federal collections impose on the public in the Information Collection 

Budget of the United States Government. In addition, OMB annually 

describes statistical program funding and proposed program changes 

for statistical activities in the Statistical Programs of the United States 

Government. 

OMB also issued 

Standards and Guidelines for Statistical Surveys, which outlines 20 

standards and related guidelines for the design and methodology of 

statistical surveys. Finally, OMB issues memorandums focusing on 

various topics, with recent ones clarifying the guidance for complying 

with PRA and encouraging agencies to coordinate efforts to share 

data.

 

15OMB, “Questions and Answers When Designing Surveys for Information Collections,” 

(January 2006).
 

Page 10 GAO-12-54 Federal Statistical System

• Other statistical-policy coordination activities: The Chief 

Statistician and staff in OMB’s Statistical and Science Policy Branch 

participate in both formal and informal coordination activities with 

agencies. OMB’s role and participation in the formal interagency 

committees are discussed later in this report. In general, it maintains 

regular contact with staff at principal statistical agencies. Additionally, 

OMB encourages agencies that are designing information collections 

to collaborate with principal statistical agencies because they can help 

improve survey design and methodology. For example, according to 

OMB and Census Bureau officials, OMB encouraged the Corporation 

for National and Community Service to work with the Census Bureau 

and BLS to sponsor a supplement to the Current Population Survey 

rather than a stand-alone survey. OMB indicated that sponsoring this 

supplement likely resulted in cost savings, improved data quality, and 

greater utility.

16

One tool that OMB uses to facilitate its oversight and coordination 

functions under PRA is an internal system called the Regulatory 

Information Service Center and OIRA Consolidated Information System 

(ROCIS), which contains information on all active collections and those 

pending OMB approval. Agencies use the system to submit information 

collection requests. This system also facilitates OIRA’s review of the 

requests and underlies the information provided on the public website 

Reginfo.gov. Agency submissions to OMB typically include a copy of the 

data-collection instrument (e.g., a survey) and supporting documentation 

that, in a standardized form, provides information on the collection, such 

as the estimated annual burden hours and cost to the federal 

government. Further, under PRA, agencies must certify that the collection 

satisfies the act’s standards, for example that the collection avoids 

unnecessary duplication. Making this information transparent and easily 

accessible to other agencies facilitates coordination and can potentially 

help agencies avoid duplication and identify opportunities for 

improvement. Furthermore, OMB uses the information contained in its 

internal system to track reviews of information collections, and to compile 

 

16Similar coordination could be fruitful for other surveys as well. For example, we have 

noted concerns about the surveys the Department of Labor uses for Davis-Bacon Act 

wage determination and have recommended that the department seek help from an 

independent statistical organization to ensure survey methods are sound and in 

accordance with best practices. See GAO, Davis-Bacon Act: Methodological Changes 

Needed to Improve Wage Survey, GAO-11-152 (Washington, D.C.: March 22, 2011). 

The Reliability of 

Information in OMB’s 

Information Collections 

Database Needs to Be 

Improved
 

Page 11 GAO-12-54 Federal Statistical System

quantitative data for the Information Collection Budget of the United 

States Government. 

Despite the benefits of this electronic system, our review identified some 

discrepancies between the Reginfo.gov website’s data and the underlying 

documentation for certain key variables. Specifically, we reviewed a 

systematic random sample of 56 of the 555 collections in our scope and 

checked the reported information for annual cost to the federal 

government and annual burden hours. For 11 of the 56 information 

collections, the information on cost or burden, or both, did not match 

between the two sources. In cases where annual cost did not match, the 

differences ranged from $1,000 to $19.3 million. In cases where annual 

burden hours did not match, the differences ranged from 30 to almost 

500,000 hours. OMB confirmed that the information in the external 

Reginfo.gov system is the same as in its internal ROCIS system. As a 

result, these discrepancies raise questions about the confidence that 

users can have in both the internal and external databases and may 

affect OMB’s ability to track information collection requests. OMB officials 

told us that responsibility for ensuring data reliability is shared between 

OMB and agencies. The Regulatory Information Service Center has 

issued detailed guidance to agencies on how to upload information into 

ROCIS, and the system has a function that allows agencies to check the 

completeness of data for individual information collections to ensure that 

no required data are missing. Entering this information is not always 

straightforward, however, and some interpretation of the underlying 

documentation may be required. The discrepancies that we identified 

indicate that additional actions, such as edit checks, review by an 

informed staff member, or increased clarification in supporting documents 

are necessary to ensure the reliability of Reginfo.gov and ROCIS data.

Our analysis indicated that agencies addressed PRA standards related to 

duplication and public comment in their information collection requests to 

OMB, and in many cases went beyond the actions specifically described 

in PRA and related OMB guidance.

The elements of PRA most directly related to our review were identifying 

duplication and soliciting external input on proposed collections. To 

analyze agencies’ actions in these two areas, we reviewed a 

generalizable sample of supporting statements from 106 active statistical 

Agencies Identify 

Duplication and Solicit 

Input to Enhance 

Efficiency
 

Page 12 GAO-12-54 Federal Statistical System

information collections administered to households and individuals.17

Although agencies must address how their proposed collections meet 

PRA standards, the act and OMB guidance do not prescribe many 

specific actions that agencies need to take in addressing these standards. 

Regarding duplication, PRA does not dictate how agencies should 

address the standard. Regarding external input, PRA does require that 

agencies at a minimum provide notice in the Federal Register to allow the 

public to comment on proposed collections as well as consult with

members of the public and affected agencies. OMB guidance expands 

somewhat on ways that agencies can address these standards, 

particularly in the case of surveys using statistical methods. However, just 

as with PRA, much is left to the discretion of agencies and little is 

specifically required. For example, OMB guidance states that agencies 

should review existing studies and consult with survey methodologists 

and data users.

Each of the supporting statements we reviewed addressed those PRA 

standards, as required, and in many cases included detailed descriptions, 

the content of which we analyzed in order to identify the range of actions 

that agencies took.

18

Identifying potential duplication: Our analysis showed that agencies 

took various steps to comply with the PRA requirement that information 

collections do not unnecessarily duplicate an available information 

source.19

• 77 percent included detailed explanations of the actions taken to 

identify potential duplication.

Specifically, based on our analysis, we estimated the following 

for the universe of collections in our scope:

20

 

17Information collections’ supporting statements contain a narrative section through which 

agencies describe their efforts to identify potential duplication. Our review focused on 

collections that were active as of May 17, 2011.

Those supporting statements that did 

18These directions are provided in OMB’s “Questions and Answers When Designing 

Surveys for Information Collections,” and OMB Circular No. A-130. 

19OMB defines unnecessary duplication as information similar to or corresponding to 

information that could serve the agency’s purposes and need and is already accessible to 

the agency. (OMB, The Paperwork Reduction Act of 1995: Implementing Guidance for 

OMB Review of Agency Information Collection, draft [Aug. 16, 1999]). 

20The 95 percent confidence interval for this estimate is (68, 85).
 

Page 13 GAO-12-54 Federal Statistical System

not include detailed explanations were generally for information 

collections that had unique scopes or other characteristics that made 

them unlikely to duplicate existing information.

• 57 percent reported reviewing other surveys when looking for 

duplication.21

• 46 percent indicated that the agency considered administrative data 

as a potential source of data.

For example, the National Cancer Institute identified 

seven other surveys that collected information similar to that of a 

Current Population Survey supplement on tobacco use and explained 

why the data from these surveys could not replace those collected 

through the supplement.

22

• About a quarter indicated that they consulted with other entities, such 

as agencies, and a similar number reported that they conducted 

literature searches.23

• In addition, for six of the information collections in our sample, 

agencies sponsored a collection in the form of a supplement to the 

Current Population Survey rather than creating a stand-alone survey, 

thus piggybacking onto another survey vehicle to potentially avoid 

duplication.

Despite these steps, the collection of similar data in different surveys is 

unavoidable for methodological reasons. In some cases, agencies need 

to ask the same or similar questions because different surveys target 

different populations. Both the National Survey of College Graduates and 

the Current Population Survey ask about respondents’ college degree 

and occupation, but the National Survey of College Graduates targets 

individuals in the United States who have bachelor’s degrees or higher in 

science or engineering, while the Current Population Survey targets a 

nationally-representative sample of U.S. civilians aged 16 and older. 

Furthermore, according to agency officials, assessing relationships 

among survey variables may require asking the same or similar questions 

in different surveys. For example, it is common for surveys to ask for 

respondents’ ages in order to analyze how responses to other questions 

vary according to this variable. In addition, asking the same question 

among surveys allows agencies to compare survey estimates and 

 

21The 95 percent confidence interval for this estimate is (46, 68).

22The 95 percent confidence interval for this estimate is (32, 59).

23Twenty-four percent of collections indicated that agencies consulted with another entity, 

and 25.5 percent reported that they conducted literature searches. The 95 percent 

confidence intervals for these estimates are (15, 35) and (16, 37), respectively.
 

Page 14 GAO-12-54 Federal Statistical System

evaluate surveys’ data quality. In order to facilitate comparisons among 

surveys, OMB encourages asking consistent questions, when possible, 

about certain characteristics such as race and ethnicity. Further, when 

considered from an individual’s perspective, duplication of survey 

questions is relatively rare. This is because in a given year a very small 

percentage of households are selected to participate in a single collection

within our scope.24

Soliciting input and feedback on information collections: Most 

agencies in our scope took steps to seek outside input beyond those 

prescribed by OMB guidance and the PRA. On the basis of our analysis, 

we estimated the following for the universe of collections in our scope:

The likelihood that a household would be selected for 

participation in more than one collection, and thus household members 

be asked the same question more than once, is considerably lower.

• 75 percent indicated that the agency reported obtaining external 

feedback in addition to publishing notices in the Federal Register.

25

• 57 percent indicated that agencies consulted with experts.26

• Agencies less frequently reported consulting with other agencies, 

contractors or subcontractors, or interagency or advisory 

committees.

For 

example, the sponsor of the National Survey of Women Veterans, a 

survey on the health-care needs, experiences, and preferences of 

women veterans, consulted with individuals representing a variety of 

research and clinical backgrounds, such as public health, social 

welfare, and psychology.

27 In addition, agencies reported soliciting feedback 

directly from former and potential survey respondents and data users 

and customers.28

 

24For example, the ACS is the largest survey in our scope and is administered annually to 

2.5 percent of households. 

They also reported conducting literature searches 

25The 95 percent confidence interval for this estimate is (65, 83).

26The 95 percent confidence interval for this estimate is (46, 67).

27Thirty nine percent of collections indicated that agencies consulted with other agencies, 

32 percent reported contacting contractors or subcontractors, and 15 percent described 

meeting with interagency or advisory committees. The 95 percent confidence intervals for 

these estimates are (30, 49), (22, 41), and (8, 25), respectively. 

28For example, we estimate that 15 percent reported soliciting input from data users and 

customers. The 95 percent confidence interval for this estimate is (8, 25). 
 

Page 15 GAO-12-54 Federal Statistical System

and sponsoring or participating in workshops, panels, or other 

events.29

Agencies in our sample reported making changes in response to input, 

potentially resulting in improvements to their information collections. For 

example, in response to recommendations made by the Committee on 

National Statistics on a Current Population Survey supplement about food 

security, ERS reported entering into an agreement with Iowa State 

University to study food security measurement issues. This collaborative 

project is exploring alternatives to an aspect of the supplement’s current 

design, which could result in alternatives to methods used to estimate 

food security prevalence and potentially improve measurement precision 

and reliability. The U.S. Geological Survey also reported incorporating 

changes in response to feedback on its Landsat Survey.30

Agencies’ actions to find duplication and solicit input that we identified in 

our review, as well as others that OMB may identify, could be useful for 

OMB to share with other agencies that sponsor information collections. 

Offering more-detailed guidance in a single document that outlines 

different actions agencies can take to identify duplication and solicit input 

would help ensure that agencies are aware of the various options. It 

would also allow them to easily access and reference this information. 

OMB could include this information in one of its periodic memorandums 

related to compliance with the PRA. We previously reported on the 

importance of establishing ways to operate across agency boundaries, 

and promoting these actions is one way OMB can do this.31

 

29Factors that facilitate interaction among agencies and between agencies and others in 

the statistical community include agency staff’s professional involvement in committee 

work, movement by some staff to other agencies during their careers, and training 

opportunities. For example, survey methodologists work together on various interagency 

subcommittees. Plus, their professional development also includes attending local and 

other conferences at which papers are presented describing uses and activities related to 

surveys in other agencies. These opportunities for cross-agency professional knowledge 

transfer facilitate collaboration and the identification of opportunities for efficiency.

Also, just as 

OMB’s guidance to agencies in complying with the Information Quality Act 

gives agencies flexibility to determine the most appropriate actions, it is 

important that any new guidance continue to give agencies discretion in 

30The Landsat Survey collects information from professional users of satellite imagery to 

better understand the uses and applications of moderate-resolution satellite imagery as 

well as information about the users. 

31GAO-06-15. 
 

Page 16 GAO-12-54 Federal Statistical System

the number and types of actions they take to identify duplication and 

solicit input. This is because the most appropriate actions will vary based 

on the characteristics of the collection.

Interagency statistical committees offer opportunities for broader 

collaboration to increase the efficiency of the federal statistical system. 

Three key committees are the Interagency Council on Statistical Policy 

(ICSP), the Federal Committee on Statistical Methodology (FCSM), and 

the Statistical Community of Practice and Engagement (SCOPE), all of 

which are either chaired or sponsored by OMB.32 Importantly, the 

activities of the interagency committees are consistent with key 

collaborative practices we identified in our previous work.

33 For example, 

each of these committees has defined roles and responsibilities, and the 

committees serve as a vehicle for the agencies to operate across agency 

boundaries. Specifically, ICSP serves an advisory function to the Chief 

Statistician and focuses on broader issues related to the federal statistical 

system. In addition, ICSP provides overarching guidance to FCSM and 

SCOPE. FCSM investigates statistical practices and methodologies used 

in federal statistical programs, while SCOPE focuses on cross-agency 

activities of data management and dissemination. Table 1 provides an 

overview of these committees.

 

32Outside of these interagency committees, there are nonfederal organizations, such as 

the Committee on National Statistics and the Council of Professional Associations on 

Federal Statistics, which serve as resources to identify opportunities for improving federal 

statistics. 

33GAO-06-15. 

Interagency Committees 

Facilitate Collaboration, 

but Better Communication 

Could Increase 

Effectiveness
 

Page 17 GAO-12-54 Federal Statistical System

Table 1: Overview of Interagency Statistical Committees

Interagency Council on 

Statistical Policy (ICSP) 

Federal Committee on Statistical 

Methodology (FCSM)

Statistical Community of Practice 

and Engagement (SCOPE)

Date established 1989 1975 a 2009

Membership The heads of the principal 

statistical agencies, plus the 

statistical unit at the 

Environmental Protection 

Agency.

About 20 members appointed by 

the Chief Statistician based on 

technical expertise and history of 

innovative contributions to the 

federal statistical system.

Appointed representatives from the 

principal statistical agencies, plus the 

statistical unit at the Environmental 

Protection Agency.

Mission • Coordinate statistical work, 

particularly when activities 

and issues cut across 

agencies.

• Exchange information 

about agency programs 

and activities.

• Provide advice and 

counsel to OMB on 

statistical matters.

• Communicate and 

disseminate information on 

statistical practice among all 

federal statistical agencies.

• Recommend the introduction 

of new methodologies in 

federal statistical programs to 

improve data quality.

• Provide a mechanism for 

statisticians in different federal 

agencies to meet and

exchange ideas.

• Provide a collaborative community 

for statistical agencies to produce 

relevant, accurate, timely, costeffective data and insightful 

research disseminated through 

shared state-of-the-art best 

practices to support data-driven 

decisions.

Description of selected 

projects

• Identifying the highestpriority statistical program 

improvements.

• Developing views on 

improving implementation 

of the PRA.

• Providing direction to 

FCSM’s subcommittees on 

privacy and administrative 

data.

• Discussing disclosure

limitation methods;

• Investigating nonresponse 

issues related to selected 

surveys. 

• Clarifying legal issues of 

confidentiality and informed 

consent.

• Examining issues related to 

the quality of administrative 

data. 

• Surveying tools used by statistical 

agencies to comply with 

standards for access to electronic 

and information technology 

procured by agencies, and 

recommending the best tools for 

use.

• Developing protocols for pilot 

testing of a secure cloud 

environment for storing data and 

recommended software.

Source: GAO analysis of OMB and agency data.

a

ICSP was established in 1989 and codified in the 1995 reauthorization of the PRA. 

The committees study statistical issues and methods through 

subcommittees and working groups, most of which rely on volunteers 

from member agencies who take on these responsibilities in addition to 

their current job duties. The work of the subcommittees and working 

groups has been useful to other agencies. For example, an FCSM

subcommittee produced a checklist that, according to OMB, is used 

around the world to determine whether a public-use data product 

sufficiently protects the confidentiality of individuals’ data.

The interagency committees use various methods to disseminate 

information on their activities and products, but they do not do so in a 
 

Page 18 GAO-12-54 Federal Statistical System

timely or comprehensive manner. The committees’ work is summarized in 

OMB’s annual report Statistical Programs of the United States 

Government, but the report does not always communicate key 

information about it. For example, the fiscal year 2011 report states that 

one of ICSP’s activities over the past year was identifying the highestpriority statistical-program improvements, but does not provide 

information about all of these improvements.34 In addition, interagency 

committees present information about their work at statistical seminars. 

For example, according to OMB officials, FCSM has presented work at 

the biennial FCSM Statistical Policy Seminars. Additionally, agency 

officials noted that members of interagency statistical committees utilize a 

limited-access web-based system to facilitate information sharing.

Information about FCSM’s work is also posted on the committee’s 

website or the FedStats website.35 Neither ICSP nor SCOPE has a 

dedicated website, though OMB believes that this is not necessary or 

appropriate because the work of these groups is deliberative. While the 

FCSM website offers the potential to effectively disseminate information, 

it is not comprehensive or timely. For example, it provides links to the 

sites of various interagency and advisory committees, including three 

FCSM permanent working groups, but does not have pages for any of the 

active FCSM subcommittees.36

Providing more-comprehensive and timely information on interagency 

activities could offer benefits. As identified in our previous work, 

developing mechanisms to monitor and report on results is a necessary 

Moreover, the websites do not appear to 

be regularly updated with new products produced by the committees that

could be useful for other agencies. For example, the subcommittee on the 

statistical uses of administrative data published a paper in April 2009 

highlighting examples of successful data-sharing projects using 

administrative data for statistical purposes, but this product is not yet 

available on the FCSM website.

 

34OMB staff noted that the specific program improvements are reflected in the President’s 

budget. 

35FedStats is a website that provides access to statistical information produced by the 

federal government. In addition, it includes all federal agencies listed in Statistical 

Programs of the United States Government that report a certain level of expenditures in 

statistical activities.

36FCSM has active subcommittees looking at statistical uses of administrative data and

privacy issues. In addition, FCSM has permanent working groups that discuss specific 

topic areas, such as nonresponse to household surveys. 
 

Page 19 GAO-12-54 Federal Statistical System

element of a collaborative relationship.37 In this case, better reporting of 

committee activities and products could offer benefits to those who are 

not involved in committee activities, as well as committee members. 

Membership in the committees is made up almost exclusively of 

representatives from the 13 principal statistical agencies, so most 

agencies are not directly involved in committee activities. It makes sense 

that agencies that have statistics as their primary focus are the mostheavily involved, but those agencies for which statistics is a supporting 

function to their primary mission, and possibly academics and the broader 

public, could benefit from greater access to information and products 

related to the committees’ work and priorities. More easily accessible 

information would also benefit member agencies, as it would offer a 

centralized place to maintain committee work and communicate priorities. 

Much work goes into developing the committees’ products, and making 

them easily accessible maximizes their value.

Administrative data, typically collected to administer a program or 

business, are a growing source of information on individuals and 

households. For example, the Social Security Administration collects data 

on the earnings of U.S. workers from employers and the Internal Revenue 

Service to calculate the amount of benefits for retired workers, spouses, 

children, and other beneficiaries, while businesses obtain data, for 

example, on item and amount of purchases when customers use credit 

cards and store loyalty cards. According to the Census Bureau, the 

amount of administrative data held by private companies exceeds the 

amount held by the government. Researchers recently estimated that the 

 

37GAO-06-15. 

Administrative Data 

Could Help Improve 

Federal Surveys, but 

Continued Progress Is 

Needed on Access 

and Quality Issues

Administrative Data Have 

Greater Potential to 

Supplement, Rather than 

Replace, Federal Surveys
 

Page 20 GAO-12-54 Federal Statistical System

amount of digital data in existence, which includes some types of 

administrative data such as retail customer databases, more than doubles 

every 2 years.38

For decades, agencies have been working to expand the use of 

administrative data in conjunction with data collected from surveys, but 

certain characteristics of administrative data make it difficult to use them 

to replace surveys or sections of surveys administered to households and 

individuals. There is interest in exploring how administrative data may be

used to improve data quality, hold down costs, and reduce respondent 

burden. For example, as part of the redesign of the Consumer 

Expenditure Surveys, BLS is investigating the potential for replacing 

some portions of the survey with external sources of expenditure data to 

reduce respondent burden and potentially improve data quality. However, 

agencies we contacted have not replaced surveys or sections of surveys 

administered to households and individuals with administrative data 

because data: (1) are often not representative of a survey’s population of 

interest; (2) may not correspond to information collected through survey 

questions; (3) are vulnerable to program cancellation or changes; and (4) 

may take a long time to obtain, which delays use and in some cases 

could cause agencies to miss required reporting dates.

Administrative data have been identified as an important 

resource for the future of the statistical system, as some of these publicly 

and privately held data may be analyzed or reported with survey data to 

yield greater value. Furthermore, the increasing capacity to store and 

process administrative data has facilitated this potential use.

Administrative data currently show greater promise for supplementing 

federal surveys. Indeed, the agencies we contacted identified four major 

opportunities to enhance surveys with administrative data in order to 

create efficiencies and enhance data quality.39

 

38John Gantz and David Reinsel, “Extracting Value from Chaos” (Framingham, Mass.: 

IDC Go-to-Market Services, June 2011).

Current uses of 

administrative data include the following:

39For the purposes of our report, we focused on the use of administrative data with 

surveys administered to households and individuals. However, agencies such as the 

Census Bureau and BLS also use administrative data with business surveys to produce 

business statistics. For example, by combining administrative and survey data, the 

Census Bureau produces an annual series on employment by county, and BLS produces 

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

Page 21 GAO-12-54 Federal Statistical System

• Creating new data products: Agencies link survey data and 

administrative data to create new, more robust, statistical data 

products, which increases efficiency in two key ways. First, according 

to OMB and agency officials, agencies can use these new data 

products to evaluate and potentially improve federal policies and 

programs, especially those related to the source of the administrative 

data, without adding to respondent burden. Second, combining 

administrative data with survey data can increase efficiency by 

enhancing previously collected survey data. For example, the National 

Center for Health Statistics’s (NCHS) record-linkage program links 

survey data from various health-related surveys to different 

administrative datasets to create new data products for studying 

factors that influence health-related outcomes, such as disability, 

health care, and mortality.

• Supplementing surveys’ sample frames: Using administrative data 

to supplement surveys’ sample frames—the sources from which a 

survey’s sample is drawn—can create efficiencies, reduce costs, and 

enhance the quality of surveys. For example, the National Household 

Food Acquisition and Purchase Survey uses administrative data from 

the Supplemental Nutrition Assistance Program to develop a sample 

frame of participating households to potentially include in the survey.

ERS officials said that using these data to help develop the survey’s 

sample frame costs less than the alternative of screening a broader 

group of respondents to determine if they are participating. In addition, 

agencies can use administrative data to augment sample frames in 

areas where the sample is not large enough to fully support a survey. 

For example, the Census Bureau’s pilot project studying the potential 

to use ACS data as a sample frame for the National Immunization 

Survey used commercial data to supplement ACS data in a county 

that had a limited ACS sample.

• Comparing data to improve survey accuracy and design: By 

comparing survey data to similar administrative datasets and 

identifying reasons for any discrepancies that may exist, agencies can 

improve the quality of survey data. For example, researchers 

identified opportunities for improving surveys’ designs and 

methodologies after agencies found that surveys of enrollment in 

health-insurance programs provided lower estimates than those 

compiled from administrative data. Agencies can also improve the 

efficiency of their surveys by using administrative data as part of 

nonresponse follow-up activities.

• Modeling estimates: Agencies combine administrative data and 

survey data to create, or model, estimates that are designed to be 

more accurate than estimates based on survey data alone. The main 

benefit of modeling is that it provides the ability to produce estimates 
 

Page 22 GAO-12-54 Federal Statistical System

for smaller geographic areas than is possible using a survey alone.

For example, the Census Bureau conducts the Small Area Income 

and Poverty Estimates Program to provide updated data on poverty 

and income, which is used to administer federal programs and 

allocate federal funds to local areas. The Census Bureau combines 

survey data from the ACS with population estimates and 

administrative data and has found that this approach produces 

consistent and reliable data more reflective of current conditions than 

data produced only by existing surveys.

Despite the benefits of using administrative data to supplement federal 

surveys, agencies face five key constraints related to data access and 

quality:

• Statutory restrictions on data sharing: Federal and state statutes 

sometimes prohibit or limit sharing of data for statistical purposes. In 

cases where specified authorized uses do not include statistical use, 

nothing short of a statutory change can overcome the constraint. In 

other cases, statutes limit sharing to purposes related to program 

administration. For example, the 2008 Farm Bill restricts access to 

data on participants in certain nutrition-assistance programs to uses 

for the “administration or enforcement” of the programs.40 Similarly, 

the Higher Education Act of 1965, as amended, restricts federal

student aid data to purposes related to the “application, award, and 

administration of aid.”41

 

407 U.S.C. § 2020(e)(8)(A)(i). The Department of Agriculture administers the program at 

the federal level through the Food and Nutrition Service, while state agencies administer 

the program at the state and local levels, including determination of eligibility and 

allotments.

However, agencies holding such restricted 

data can differ on whether statistical uses are related to program 

administration. The Census Bureau successfully negotiated access to 

the nutrition assistance data because it could demonstrate that the 

linked data would help the federal sponsor and state agencies 

develop better measures of outcomes, such as poverty, inequality, 

and the receipt of government transfers. Conversely, the Census 

Bureau was unable to gain access to the federal student aid data for 

statistical uses because the Department of Education did not consider 

that any of the planned uses related to the program’s administration.

4120 U.S.C. § 1090(a)(3)(E).

Agencies Are Addressing 

Issues That Hamper Use of 

Administrative Data, but 

Additional Actions Could 

Facilitate Progress
 

Page 23 GAO-12-54 Federal Statistical System

• Consent: Individuals’ consent to allow their administrative and survey 

data to be linked affects uses of administrative data for statistical 

purposes. Seeking consent derives from a core concept of personal 

privacy: the notion that each individual should have the ability to 

control personal information about himself or herself.42 Moreover, 

there can be issues regarding the privacy and confidentiality of data 

collected for one purpose and used for another, and agencies use 

different practices, wording, and level of detail to meet consent 

requirements, according to OMB officials. At the time administrative 

data are collected, an agency can inform individuals that their data 

may be used for statistical purposes, but, according to ERS officials, 

agencies collecting administrative data often do not consider possible 

future statistical uses and therefore may not provide such notice. 

Obtaining consent after data have been collected can be timeconsuming and costly. In addition, an agency can ask survey 

respondents for permission to link their survey data with certain 

administrative data. Some respondents may not consent, which can 

substantially limit the number of respondents eligible for linkage and 

as a result potentially affect the quality of the linked data.43

• Costs and infrastructure: Because the primary cost of collecting 

administrative data has already been incurred, using these data can, 

in some cases, be more efficient and less costly than new survey 

efforts. However, there still are costs to using administrative data for 

statistical purposes, including up-front and ongoing investments to 

purchase and maintain hardware and software to link data and protect 

their confidentiality. Agencies identified various factors that can affect 

costs. These include but are not limited to negotiations with the 

agency holding the data, the quality of the administrative data, and the 

ease with which they can be linked to other data. BLS officials said 

that in some cases the costs of using administrative data with survey 

data may outweigh any savings and that evaluation of administrative 

data options always requires careful consideration of a wide range of 

quality and cost issues, including the costs of specialized personnel 

and infrastructure. According to an FCSM study that profiled 

examples of successful statistical uses of administrative data, 

 

42GAO, Record Linkage and Privacy: Issues in Creating New Federal Research and 

Statistical Information, GAO-01-126SP (Washington, D.C.: April 2001).

43Agency officials noted that, if the survey respondents who consent differ from those who 

do not consent, analysis of the linked files may lead to misleading or biased results. Also, 

the reduced sample size from an analysis using data for those who consent may increase 

confidence intervals for calculated estimates. 
 

Page 24 GAO-12-54 Federal Statistical System

agencies wanting to share data also may not have the necessary 

staff, policies, or procedures. For example, negotiating data-sharing 

agreements may require significant time. Moreover, many key 

administrative datasets are held by states, further complicating the 

data-sharing process because agencies have to negotiate under 

different policies and procedures as well as work with numerous staff 

across states.

• Documentation of datasets: OMB and agency officials said that 

agencies holding administrative data do not uniformly document 

information about their datasets in a way that is always useful or 

efficient for use outside of the agency. This lack of documentation of 

datasets makes evaluating their potential for statistical uses 

challenging. For example, definitions of key variables of research 

interest or information about how frequently the agency updates the 

data may not be available. ERS officials also noted that private 

companies typically do not disclose detailed information about the 

sources of their data, making it difficult to assess their quality. As a 

result, agencies interested in using these data for statistical purposes 

may have to spend additional time and resources to understand the 

content and structure of the datasets.

• Quality of data: Agency officials and experts identified reasons why 

the quality of administrative data can vary, which can affect their 

potential use with survey data. Specifically, different agencies may 

use different systems, definitions, and time frames when collecting 

administrative data. For example, states may collect and evaluate the 

quality of data in different ways, making it complicated to aggregate 

the data across states as well as to compare state-level data. In 

addition, several factors can influence the accuracy of data reported in 

administrative data. For example, agencies that collect data for the 

purpose of program administration may be concerned with the 

accuracy of only the variables used for such purpose. Moreover, 

reporting incentives may influence data quality. For example, 

individuals may underreport income on tax forms, and program 

agencies may pay less attention to the accuracy of information 

collected from applicants when it does not affect their participation in a 

program. 

Agencies and interagency committees have been taking numerous 

actions to address these constraints. For example, ERS, in collaboration 

with the Census Bureau, NCHS, and OMB is undertaking a pilot project to 

address data quality concerns with state-level administrative data, and 

FCSM is working on a project to clarify legal requirements for informed 

consent (see fig. 3).
Interactive graphic Figure 3: Actions Taken to Address Constraints That Hamper Greater Use of Administrative Data

Page 25 GAO-12-54 Federal Statistical System

Source: GAO analysis of OMB and principal statistical agency data.

Directions:

[Click] on the types

of constraints within 

the graphic structure 

on the right to see 

descriptions and 

examples of selected 

actions taken by 

agencies to address 

each constraint type Constraints to 

statistical uses of 

administrative data

• Click to make view needed visible. In the “Print” dialog box, choose “Current page,” then “OK.” Repeat to print each view.

Print instructions • A text version of this graphic is available in appendix IV.
 

Page 26 GAO-12-54 Federal Statistical System

One theme that cuts across many of these efforts, and where additional 

short-term actions could accelerate progress, is identifying ways to 

facilitate the process of deciding whether to share data among agencies. 

FCSM published a paper describing successful data-sharing 

arrangements between various federal and state agencies. One of the 

four core elements of success that FCSM identified in these 

arrangements was mutual interest, in that each participant—in particular 

the agency providing the data—evaluates a proposed data-sharing 

agreement from its own perspective.44

The benefits of having more-comprehensive centralized guidance could 

include greater consistency, clarification, and efficiency. A morecomprehensive standardized framework that ties together existing tools 

with additional resources in order to cover major aspects of the datasharing process could bring consistency to the decision-making process. 

Similar to the checklist that FCSM is developing for agencies to use in 

evaluating data quality, the framework could include a template outlining 

a list of key questions for all agencies involved in the proposed data 

sharing, including federal and state agencies that hold data, to address 

issues such as: (1) the steps to take to ensure data reliability; (2) any 

statutory limitations on planned uses of the data (including confidentiality 

protections); (3) whether consent has already been obtained for additional 

On the one hand, agencies may 

share data because the linked data can benefit program administration, 

as noted earlier. On the other hand, OMB and agency officials noted that 

agencies may decide against sharing because perceived disadvantages, 

such as policy concerns and potential identification of weaknesses in 

program administration, outweigh the possible benefits. In such a case, 

an individual agency’s interests may be at odds with the broader 

efficiency of the whole federal statistical system. As illustrated in figure 3, 

FCSM and agencies are developing tools to approach these decisions in 

a more standardized way, such as developing checklists for evaluating 

the quality of administrative data and a template for executing datasharing agreements. However, these individual tools focus on particular 

aspects of data sharing—for example, the checklist focuses on data 

quality. Separately, they may not be sufficient for agencies to efficiently 

identify potential datasets with the greatest potential for mutual benefit 

and address all factors involved in the decision-making process.

 

44The three other core elements of success in these arrangements were (1) vision and 

support by agency leadership, (2) narrow but flexible goals, and (3) infrastructure.
 

Page 27 GAO-12-54 Federal Statistical System

use of the data, or how it will be obtained; and (4) methods to fully 

account for the costs associated with obtaining and using the data. To be 

comprehensive, such guidance would not need to be voluminous, but it 

should identify each of these major aspects of data sharing, provide 

advice to agencies, and reference any tools available to assist agencies 

during the process. It should also be kept up-to-date, reflecting changes 

in legislation or other factors that affect data sharing, as well as any new 

tools that are developed. Although such a framework may not lead to 

sharing in all cases, the framework could better ensure that agencies 

weigh the related benefits and costs in a more balanced, consistent, and 

transparent fashion. Such guidance could also clarify ways that agencies 

could resolve disagreements over data sharing. It could also improve 

efficiency, given that agency officials we spoke with cited examples in 

which it took multiple years to reach a resolution on data sharing, by 

helping agencies evaluate available data and determine those that have 

the greatest potential for mutual benefit.

While agencies can take steps to address some constraints on sharing 

data, in other cases only policy actions on the part of the executive 

branch or Congress can lift barriers. One of the primary examples of such 

action is Congress’s enactment of CIPSEA in 2002, which authorized the 

Census Bureau to share selected business data with BLS and the Bureau 

of Economic Analysis for statistical purposes. However, CIPSEA is limited 

because the Census Bureau’s business data are based in large part on 

tax data, and as a result the tax code would need to be amended for the 

Census Bureau to also share these data with other statistical agencies. 

There have been proposals to amend the tax code to further expand the 

scope and coverage of CIPSEA, but action has not yet been taken by 

Congress.

45

 

45As discussed in our recent report, Taxpayer Privacy: A Guide for Screening and 

Assessing Proposals to Disclose Confidential Tax Information to Specific Parties for 

Specific Purposes (GAO-12-231SP), Internal Revenue Code Section 6103 provides that 

federal tax information is to be kept confidential and used to administer federal tax laws 

except as otherwise specifically authorized by law. 
 

Page 28 GAO-12-54 Federal Statistical System

The Census Bureau’s full implementation of the ACS in 2005 was a major 

change to the statistical system. The survey is unique among other 

surveys of households and individuals because of its size—the monthly 

surveys add to an annual sample of 3.54 million addresses. The ACS 

provides annual estimates of social and economic characteristics for all 

areas of the country and is a primary source of information on small 

areas, such as towns and tribal lands, down to the neighborhood level. 

The ACS covers a broad range of topics, such as housing, education, and 

employment. The information provided by the ACS was previously only 

available once a decade from the decennial census long form, which the 

ACS replaced. Users of ACS information include all levels of government, 

the private and nonprofit sectors, and researchers. According to the 

Census Bureau, ACS estimates are currently used to help allocate more 

than $400 billion in federal funding annually. Table 2 lists some of the key 

characteristics of the ACS.

Prospects for 

Enhanced Use of the 

ACS with Other 

Surveys Are Mixed

The ACS Provides Unique 

Coverage of the Nation’s 

Population
 

Page 29 GAO-12-54 Federal Statistical System

Table 2: Key Characteristics of the ACS

Characteristic ACS

Response requirements Responses are required by law

Frequency of 

administration

Administered on a monthly basis

Frequency of data 

products

Annual

Reference point for data 

products

Period estimates: the period over which data are cumulated 

is determined by the population of the geographic area for 

which the estimate applies. Estimates for places with 

populations of more than 65,000 represent a 1-year period; 

places with populations of 20,000 to 65,000 represent 3-year 

periods; and places with populations smaller than 20,000 

represent 5-year periods. 

Number of questions 48 potential questions per person, plus 21 per housing unit

Respondent burden

a

38 minutes per respondent

Sample size

b

3.54 million addresses per year

Key uses Directing government funding, informing government and 

private-sector decision making, and research 

Source: Census Bureau.

a

Although there are 48 individual questions on the ACS, several questions only apply to respondents 

with certain characteristics, so respondents likely do not answer every question. For example, only 

ACS respondents who are female and age 15 to 50 are asked to answer a question about whether 

they have given birth in the past year. 

b

The Census Bureau estimates that the respondent burden is 38 minutes for the questionnaire it 

administers to households. Its estimates for other interviews, such as group quarters, are different. 

Several of the ACS’s characteristics lend to its appeal for use for other 

surveys, including that it produces annual estimates on a broad range of 

topics at finer geographic levels than other surveys, and agencies and 

others identified five areas of opportunity in which surveys can make use 

of ACS data and resources. Two of these areas, which generally rely on 

publicly-available ACS estimates and do not require changes to the 

survey’s design or methodology, have the greatest potential for 

widespread use. The Census Bureau has provided users with various 

resources to guide their use of ACS estimates. These include a guide to 

comparing estimates, handbooks directed to specific types of users, 

training presentations, and a tutorial. The two areas with the most 

potential for use are as follows:

• Evaluating and supplementing other surveys’ results: Survey 

administrators and data users can also use ACS estimates to 

evaluate information collected by other surveys. For example, survey 

administrators can use ACS information to evaluate the quality of 

Agencies Use the ACS to 

Inform the Design of Other 

Surveys and Analyze Their 

Results 
 

Page 30 GAO-12-54 Federal Statistical System

responses to other surveys that include some questions that are the 

same as or similar to ACS questions. Additionally, data users and 

survey administrators can use ACS data to supplement information 

collected by other surveys. For example, a recent report based on 

analysis of ACS data describes how median earnings vary by the field 

in which people obtain their bachelor’s degrees.46

• Designing other surveys: There is also widespread potential to use 

ACS data to more-efficiently design other surveys. Because many of 

the topics included in the ACS are covered in more detail by other 

surveys or relate to other surveys’ target populations, survey 

administrators can use ACS estimates at different demographic or 

geographic levels to stay up-to-date on changes that may affect their 

surveys. These estimates can also be used when designing and 

selecting a survey’s sample. Census Bureau officials told us that, 

when designing a survey, survey administrators can use the data to 

guide the selection of a survey’s sample so that it better represents 

individuals or households with certain characteristics. For example, 

the Survey of Income and Program Participation can use ACS 

estimates at different demographic or geographic levels to identify and 

more-efficiently sample geographic areas with disproportionately large 

numbers of low-income households because this is a population of 

interest for the survey. Because these data are available for small 

geographic areas, agencies can use the data when samples include 

more-local geographic levels.

Such information 

can complement results from other surveys. In this case, NCSES also 

produces information on earnings by degree type, based on 

information in its Scientists and Engineers Statistical Data System 

database, which contains data on people with a science or 

engineering degree and those who work in related fields. NCSES 

information collection is less frequent than ACS estimates and 

pertains to a more-narrowly defined population, but allows more 

detailed analysis of issues such as how people use their college 

degrees at work. Together, these two sources of information offer 

more-timely and more-detailed information than a single source.

 

46Anthony P. Carnevale, Jeff Strohl, and Michelle Menton, What’s It Worth? The 

Economic Value of College Majors, Georgetown University Center on Education and the 

Workforce (Washington, D.C.: May 24, 2011). 
 

Page 31 GAO-12-54 Federal Statistical System

Agencies and others identified three uses of ACS data and resources 

that, while offering potential benefits to other surveys, face such 

constraints that more widespread use is likely not possible under current 

ACS design. These uses are more intensive than the ones described 

above, in that they affect the survey’s design and methodology or 

respondent burden, or both. Because the ACS has a large sample size 

and a complex methodology, there are logistical challenges involved in 

changing its design and methodology. Additionally, any changes that 

affect the survey’s respondent burden also have limited potential, as there 

are already concerns about the burden that the ACS places on 

respondents. Uses with more-limited potential are as follows:

• Adding or modifying ACS content: Adding a question to the ACS or 

modifying existing questions can improve the efficiency of other 

surveys, though doing so involves trade-offs with factors such as 

respondent burden. This use of ACS could provide information that 

would inform the design of other surveys or facilitate the use of ACS 

data for another survey’s sample frame. For example, NCSES worked 

with the Census Bureau to add a question to the ACS about the field 

in which respondents earned their bachelor’s degrees in order to 

identify respondents that are in the target population for the National 

Survey of College Graduates. Despite the potential benefits of adding 

or modifying ACS content, adding a question to the ACS would 

increase respondent burden and have operational impacts, as it 

requires the Census Bureau to change the questionnaire design and 

processing and editing systems. If these actions result in additional 

pages for the questionnaire, it could affect costs and the response 

rate. Modifying questions poses an additional challenge because ACS 

estimates reflect multiple years of data, and a change in a question 

may affect the Census Bureau’s ability to cumulate data.

• Adding supplements to the ACS: Another possible use of the ACS 

by other surveys is adding supplements to the ACS, though this use 

faces several obstacles. While the ACS currently does not include 

supplements, doing so could enable surveys to leverage the 

resources of the ACS. Other surveys, such as the Current Population 

Survey, allow other agencies or entities to sponsor supplemental 

surveys that are added on to the survey’s core set of questions. 

According to officials at BLS, which sponsors the Current Population 

Survey, in their experience it costs less to add a supplement to an 

existing survey than to conduct a separate stand-alone survey.

Additionally, the agencies sponsoring the supplements gain the 

benefit of the experience of BLS or Census staff, or both, in designing 

and implementing surveys. Although the Current Population Survey 

successfully incorporates supplements, the ACS is different in several 

Uses of ACS That Require 

Design and Methodology 

Changes Have Limited 

Potential
 

Page 32 GAO-12-54 Federal Statistical System

key ways, and adding supplements to the ACS would involve 

significant challenges. For example, the ACS is mandatory, meaning 

that responses are required by law. Assuming a supplement to the 

ACS would be voluntary, Census Bureau officials told us that they 

would have to determine how to distinguish between the mandatory 

and voluntary sections, which would create complexity. Additionally, 

the Census Bureau processes ACS data on a yearly basis and does 

not have a process in place for producing estimates from a single 

month’s data, which would be a challenge if the supplement was 

administered along with only 1 month’s ACS mailout. Finally, including 

supplements raises concerns about respondent burden and 

respondent fatigue.47

• Creating sample frames: Using ACS data to develop sample frames 

for follow-on surveys has been identified as a potential use of ACS 

data, but several factors limit this use.

BLS officials noted the potential of matrix 

sampling, in which a set of additional questions, as in a supplement, is 

added to a month of collection (or all months) but differs from a 

supplement in that it is only administered to a subset of the survey 

sample in a given collection period. This option could reduce burden 

and increase efficiency; however, such an option involves logistical 

considerations in administering the survey and processing the data, 

and adds complexity for analysts using the data for research.

48 This involves using ACS data 

to identify ACS respondents with certain characteristics for potential 

inclusion in a follow-on survey and requires the approval of the 

Census Bureau and OMB.49

 

47Respondent fatigue occurs when respondents become tired of being surveyed and 

become more prone to refusal or the quality of their responses deteriorates.

At present only NCSES uses ACS data 

for this purpose. Agency officials told us that using ACS data to create 

a sample frame, as opposed to census long-form data, which they 

used previously, has improved the agency’s coverage of its target 

48A follow-on survey is one that is sent to ACS respondents after they have completed the 

ACS. Census Bureau policy prohibits sending an ACS respondent a follow-on survey 

within 6 months of his or her ACS interview.

49Using ACS for sample frame development is more intensive than using ACS estimates 

to inform the design of a survey’s sample frame, which does not involve contacting ACS 

respondents again. In determining whether a survey can use ACS data for its sample 

frame, the Census Bureau’s and OMB’s policy is to give priority to surveys that meet 

certain criteria, including those that could substantially reduce costs by doing so and those 

that produce estimates for populations that would otherwise have prohibitively expensive 

screening costs.
 

Page 33 GAO-12-54 Federal Statistical System

population and has reduced costs and respondent burden.50

In the long run, more-intensive uses of ACS data and resources may 

require difficult decisions and entail trade-offs with factors such as cost 

and respondent burden. Further, they risk affecting ACS response rates 

and overall data quality. However, redesign of the scope and 

methodology of ACS might overcome some of these constraints. After the 

release of the survey’s first 5-year data products in 2010, the Census 

Bureau and others began evaluating the survey and exploring options for 

increased uses. In addition to its own evaluation of the ACS, at the 

Census Bureau’s request the National Academy of Sciences is organizing 

workshops with data users to assess the survey. Also, OMB, in 

cooperation with the Census Bureau, created an ACS subcommittee of 

Another 

benefit of this use is expanded analysis, as agencies, under 

appropriate Title 13 restrictions, can analyze respondents’ answers to 

the ACS along with responses to the follow-on surveys, and can 

analyze the characteristics (from ACS data) of those who do and do 

not respond to the follow-on survey to determine if they have different 

characteristics, which might cause bias in the survey. Surveys such 

as the National Survey of College Graduates that focus on 

populations that are costly to identify are likely to realize higher gains 

in efficiency from using ACS data for this purpose. Despite these 

benefits, opportunities for other surveys to use ACS data for this 

purpose are limited. ACS’s sample size, although large compared to 

most surveys, can be too small for another survey to use for a 

sampling frame. This is especially an issue if a survey targets a rare 

population or targets members similar to those of surveys already 

drawing from the ACS for their frame, because there would be too 

much chance of drawing individuals into both follow-on surveys, and 

current policy does not allow for that. Census Bureau policy states 

that, when agencies conduct follow-on surveys, they may not contact 

any member of a household that has already responded to the ACS 

and also had a member selected for a follow-on survey. With certain 

households in the ACS excluded from potential selection, it becomes 

more difficult for other surveys to draw samples because the data no 

longer reflect respondents with certain characteristics.

 

50The census long form did not include a question that asked for the field in which 

respondents received their bachelor’s degree. NCSES used long-form data to identify 

respondents who had characteristics that made them likely to be in the survey’s target 

population, but it had to screen a larger sample in order to identify those who in fact 

belonged to the target population.
 

Page 34 GAO-12-54 Federal Statistical System

the ICSP with the goal of investigating trade-offs of options such as 

adding questions to the ACS and rotating questions in and out of the 

survey. If the Census Bureau changes the survey’s design or 

methodology, these changes may become more feasible.

To ensure the provision of high-quality, timely statistical data for publicand private-sector users, OMB and the agencies that make up the federal 

statistical system must continue to identify opportunities for efficiency in 

federal surveys of households and individuals. Most of the surveys and 

other information collections in our scope have relatively modest costs, 

but challenges such as declining survey response rates will strain 

available resources unless agencies find more-effective and less-costly 

ways to collect and analyze the needed information, while maintaining 

critical protections of respondents’ privacy and confidentiality. In the long 

term, addressing the key challenges and constraints that agencies have 

identified will necessitate broader public debates and policy decisions 

about balancing trade-offs among competing values, such as quality, 

cost, timeliness, privacy, and confidentiality. In the short term, our review 

indicated that two promising avenues to sustain the progress that OMB 

and agencies are making include (1) facilitating collaboration and 

coordination among agencies and (2) combining existing data from both 

survey and administrative sources.

The federal statistical system already exhibits many collaborative traits 

and practices, in particular through projects sponsored by OMB and 

interagency committees that facilitate coordination and the development 

of new policies and tools. However, additional efforts could help enhance 

the effectiveness of these efforts. Going forward, it will be important for 

OMB to supplement existing guidance to clarify the range of options 

available to address PRA standards. Supplementing the guidance could 

increase agencies’ awareness of these options, in particular those that 

were cited less frequently. At the same time, interagency committees 

could do more to improve accessibility and timeliness of their work 

products. Doing so could maximize the usefulness of committees’ work. 

Additionally, OMB’s ability to oversee and coordinate information 

collections across the government would benefit from additional steps to 

ensure the reliability of data on collections’ costs and burdens. Doing so 

would also benefit users of the information, whether they access it 

through the website or though OMB reports.

Agencies identified multiple ways that combining survey and 

administrative data can improve the efficiency and quality of their work, 

Conclusions
 

Page 35 GAO-12-54 Federal Statistical System

and they are already pursuing such opportunities. Importantly, they have 

demonstrated that using existing datasets to supplement each other can 

add value for all agencies involved in data sharing. But agencies also 

face serious constraints to expanded uses of existing data. One of the 

more-significant barriers is the complexity of the process through which 

they make decisions about sharing data. Though agencies and 

interagency committees are working to create tools to facilitate parts of 

this process, more-comprehensive and centralized guidance for agencies 

to follow when negotiating and making decisions regarding data-sharing 

opportunities could help facilitate the process.

A standard protocol or framework could accelerate progress in this area 

by helping agencies to (1) evaluate the growing array of administrative 

data to identify those datasets that have the greatest potential for mutual 

benefit of the participating agencies, and (2) consider a common set of 

criteria and key questions when weighing the pros and cons of sharing 

data. A key benefit would be to encourage agencies to consider, in a 

uniform manner, all relevant aspects of these decisions, such as whether 

or not proposed uses would be consistent with applicable law, maintain 

confidentiality protections, be cost-effective, and serve to increase the 

broader efficiency of the federal statistical system.

In order to maintain progress in maximizing the efficiency of existing data 

sources, we recommend that the Director of OMB, in consultation with the 

Chief Statistician, work with the ICSP to take the following four actions:

To improve the broader efficiency of the federal statistical system and 

improve communication among agencies and others, 

• when OMB next updates guidance on agency survey and statistical 

information collection and dissemination methods, include additional 

details on actions agencies can take to meet requirements to identify 

duplication, to consult with persons outside of the agency, and 

address other requirements as appropriate; and

• create new methods or enhance existing methods to improve the 

dissemination of information and resources produced by interagency 

statistical committees. For example, such enhancements could 

include increasing the timeliness and availability of information on 

websites to better capture the full range of products and identify 

committee priorities.

To increase the reliability of the information presented on the Reginfo.gov 

website and in OMB’s internal system, 

Recommendations for 

Executive Action
 

Page 36 GAO-12-54 Federal Statistical System

• implement quality-control procedures designed to identify and remedy 

any differences between cost and burden information provided on the 

website and in the related supporting statement documentation that 

underlies this information.

To accelerate progress in sharing administrative data for statistical 

purposes, where appropriate, 

• develop comprehensive guidance for both statistical agencies and 

agencies that hold administrative data to use when evaluating and 

negotiating data sharing, such guidance should include key questions 

focused on issues such as statutory authority, confidentiality, cost, 

and usefulness in order to ensure agencies consider all relevant 

factors and the broader interest of the federal government.

We provided a draft of this report to the Secretaries of Commerce and 

Health and Human Services, the Director of OMB, the Commissioner of 

BLS, the Administrator of ERS, and the Director of the National Science 

Foundation for their review and comment. We received written comments 

on the draft report from the Secretary of Commerce that are reprinted in 

appendix V. We also received comments from OMB staff that are 

summarized below. The Department of Health and Human Services,

BLS, National Science Foundation, OMB, and agencies on the ICSP also 

provided technical comments and suggestions that we incorporated as 

appropriate.

Commerce stated that our observations illuminate future opportunities for 

using administrative records within the federal statistical system to 

increase efficiency and better meet informational needs and that our 

suggested actions would enhance the ability of statistical agencies to 

realize these opportunities. Regarding our recommendation on standard 

protocols and procedures to facilitate data sharing, the department noted 

that policies and other initiatives can also play a role in achieving 

cooperation. Finally, the department noted that our report’s 

acknowledgement of related concerns about the quality of administrative 

data, and the level of support and resources necessary to maintain a 

statistical and administrative data infrastructure, underscore the 

importance of our recommendations.

OMB generally agreed with our recommendations and said that the 

agency hopes to pursue these in the future. More specifically, 

• OMB agreed that it is worth considering good practices for 

reducing duplication. As we suggested, OMB indicated that when 

Agency Comments 

and Our Evaluation
 

Page 37 GAO-12-54 Federal Statistical System

its survey guidance is next updated it will include additional details 

and examples of actions agencies can take to identify duplication 

and consult with persons outside the agency.

• OMB said that it shared our concerns about timely and easily 

accessible dissemination of information resources produced by 

interagency statistical committees, and that our recommendation 

underscores the need for addressing this issue.

• With respect to our recommendation that OMB implement qualitycontrol procedures designed to identify and remedy any 

differences between cost and burden information provided on 

Reginfo.gov and in the related supporting statement 

documentation that underlies this information, OMB noted that 

PRA requires OMB to weigh the burdens imposed on the public by 

information collections against the legitimate needs of the federal 

agencies. OMB said that this requires a careful assessment of the 

estimates of paperwork burden that agencies provide to OMB as 

part of their information collection requests and, further, that these 

estimates are subject to public scrutiny and comment in Federal 

Register notices, in the PRA statements provided on information 

collections, and on Reginfo.gov. OMB pointed out that, because 

the burden estimates provided on Reginfo.gov and in the 

underlying supporting statements are all made public, 

discrepancies such as those found by us are public as well. OMB 

said that it will investigate and address any such discrepancies 

that are brought to its attention by GAO or any member of the 

public.

• Finally, OMB concurred that administrative records can be a 

valuable supplement to, though usually not a replacement for, 

household surveys. OMB believes that our recommendation to 

develop comprehensive guidance for statistical and administrative 

agencies to use when evaluating and negotiating data-sharing 

agreements would be constructive, but cautioned that this involves 

a very complex set of issues and said it will take some time to 

develop such guidance. 

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

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

report date. At that time, we will send copies to the Commissioner of the 

Bureau of Labor Statistics (BLS), the Director of the U.S. Census Bureau, 

the Administrator of the Economic Research Service (ERS), the Secretary 

of Health and Human Services, the Director of the National Science 
 

Page 38 GAO-12-54 Federal Statistical System

Foundation, the Director of OMB, the Secretary of Commerce, and the 

Under Secretary of Economic Affairs. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov.

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

contact Robert Goldenkoff at (202) 512-2757 or goldenkoffr@gao.gov, or 

Ronald S. Fecso at (202) 512-7791 or fecsor@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors are listed in 

appendix VI. 

Sincerely yours,

Robert Goldenkoff

Director, Strategic Issues

Ronald S. Fecso

Chief Statistician
Appendix I: Scope and Methodology

Page 39 GAO-12-54 Federal Statistical System

The objectives of this report were to (1) review the ways in which the 

Office of Management and Budget (OMB) and agencies identify 

opportunities for improvement and increased efficiency of selected 

information collections; (2) evaluate opportunities and constraints for the 

statistical agencies to use administrative data in conjunction with selected 

surveys; and (3) evaluate ways in which American Community Survey 

(ACS) data and resources can be used in selected surveys, and the 

associated benefits and constraints.

To achieve our objectives, we focused on statistical information 

collections administered to households and individuals and subject to the 

Paperwork Reduction Act (PRA), which requires OMB approval of certain 

federal data collections. Although in many cases the information and 

views provided by agencies during our review and our general findings 

may also apply to statistical information collections outside of our scope, 

such as those administered to businesses, all of the specific collections 

and surveys we reviewed were administered to households and 

individuals. The majority of the collections within our scope include a 

survey, though some also include other methods of information collection 

such as focus groups. To examine the issues related to our objectives, 

we performed case studies of five federal surveys: the Consumer 

Expenditure Surveys, sponsored by the Bureau of Labor Statistics; the 

National Health and Nutrition Examination Survey and the National Health 

Interview Survey, both sponsored by the National Center for Health 

Statistics, part of the Centers for Disease Control and Prevention; the 

National Survey of College Graduates, sponsored by the National Center 

for Science and Engineering Statistics, part of the National Science 

Foundation; and the Survey of Income and Program Participation, 

sponsored by the Census Bureau. We selected these surveys based on 

several factors, such as their size and cost and whether they use or have 

the potential to use administrative data or ACS data.

For the first objective, to review the ways in which OMB and agencies 

identify opportunities for improvement and increased efficiency of 

selected statistical information collections, we examined the PRA, OMB 

guidance to agencies, and prior GAO work on the federal statistical 

system.1

 

1

GAO, Federal Information Collection: A Reexamination of the Portfolio of Major Federal 

Household Surveys Is Needed, 

We interviewed officials at OMB and the four agencies that 

GAO-07-62 (Washington, D.C.: Nov. 15, 2006)

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 40 GAO-12-54 Federal Statistical System

administer the case-study surveys to learn about coordination among 

agencies, efforts agencies take to identify improvement, and OMB’s role. 

We also interviewed officials at the Department of Agriculture’s Economic 

Research Service, which is a member of several interagency statistical 

committees and the lead agency for the Statistical Community of Practice 

and Engagement. In addition, we interviewed experts on the federal 

statistical system to learn about their perspectives on the efficiency of the 

federal statistical system and agency and OMB coordination. In 

evaluating OMB, agency, and interagency actions, we used as criteria the 

requirements of the PRA and practices identified in prior GAO work on 

agency collaboration.2

To address the second objective, to evaluate opportunities and 

constraints for agencies to use administrative data in conjunction with 

selected surveys, we reviewed statutes that govern the sharing and use 

of administrative data, documentation from case-study surveys, and 

various papers and reports. We interviewed officials at OMB and experts 

in the field of federal statistics to learn about their perspectives on the 

current and potential uses of administrative data. We also interviewed 

officials at the Economic Research Service and the agencies that sponsor 

the case-study surveys to learn about ways in which their surveys use or 

could potentially use administrative data. For this objective and the third 

we used OMB guidance, relevant statutes, and prior GAO work as criteria 

in our evaluation.

For the third objective, to evaluate the ways in which ACS data and 

resources can be used in selected surveys, we reviewed Census Bureau 

documentation, National Science Foundation reports, prior GAO work, 

and reports issued by the Committee on National Statistics. We 

interviewed officials at the Census Bureau, which sponsors the ACS, and 

at OMB to learn about their perspectives on potential uses of the survey 

and its data. We also interviewed officials at the Economic Research 

Service and the agencies that administer the case-study surveys to learn 

about ways in which their surveys use or could potentially use ACS data 

and resources, and experts in the field of federal statistics to learn about 

their assessment of the uses and potential uses of the ACS.

 

2

GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
Appendix I: Scope and Methodology

Page 41 GAO-12-54 Federal Statistical System

To gain a broader perspective on the information collections in our scope 

and to inform our work across all three objectives, we obtained and 

analyzed publicly-available data from Reginfo.gov, a government website 

that provides access to information on agency requests for OMB approval 

of information collections. We used the website’s search feature to 

download all of the collections that were classified as (1) active, meaning 

that they are currently approved by OMB for use by agencies; (2) 

employing statistical methods; and (3) directed to households and 

individuals. We downloaded data on all information collections that met 

these criteria from Reginfo.gov on two dates, May 17, 2011, and 

September 22, 2011.

We performed more in-depth analyses of the 507 information collections 

in our May 17, 2011, download. First, we reviewed the supporting 

statements for each of these collections, and on the basis of information 

in these documents classified them according to the subject matter on 

which they focus.3

We divided the 481 collections that included a survey component into 

three strata that reflect the type of sponsoring agency. Of the 481, we 

were not able to determine agency type for 7 collections so we dropped 

these records, leaving a population of 474 statistical information 

collections. The number of collections by stratum is shown in table 3. In 

Next, we grouped the collections into categories, 

based on information on the sponsoring agency in Reginfo.gov and the 

supporting statements. Depending on the sponsoring agency, we put the 

collections into one of four categories: (1) those that are sponsored by 

one of the 13 principal statistical agencies; (2) those that are sponsored 

by another agency that shares a parent agency with one of the 13 

principal statistical agencies (for example, agencies in the Department of 

Health and Human Services would fall into this category because it is the 

parent agency of the National Center for Health Statistics); (3) those that 

are not a principal statistical agency and do not share a parent agency 

with one; and (4) unknown, for those whose sponsoring agency we could 

not determine based on the available information. We also used the 

information in the supporting statements to determine if the collections 

included a survey component and found that 481 of the 507 did.

 

3

Agencies include supporting statements with each request for approval of an information 

collection. These statements must follow a prescribed format and include specified

information such as the circumstances that make the collection necessary and how, by 

whom, and for what purpose the information will be used.
Appendix I: Scope and Methodology

Page 42 GAO-12-54 Federal Statistical System

order to estimate the prevalence of certain characteristics in this 

population—for example, the percentage of information collections for 

which the sponsoring agency reported steps taken to identify potential 

duplication—we drew a stratified sample of 106 collections. Within each 

stratum, we estimated the sample size required to yield a 95 percent 

confidence interval of plus or minus 14 percent around such an estimate. 

For the overall population of 474, the approximate precision for an 

estimated percentage of 50 percent is plus or minus 8.4 percent, at the 95 

percent level of confidence.

Table 3: Number of Collections, by Stratum

Stratum 

Stratum 

population

Sample 

size

Principal statistical agency 60 27

Nonstatistical agency 139 37

Nonstatistical agency that shares a parent agency with a 

statistical agency

275 42

Total: 474 106

Source: GAO analysis of OMB data.

We reviewed the supporting statements of each of the information 

collections in our sample of 106, focusing on agencies’ reported efforts to 

identify duplication and to consult with persons outside the agency to 

obtain their views. Because agencies follow a standard format in 

preparing supporting statements, we focused our analysis on the sections 

of the supporting statements in which OMB instructs agencies to include 

this information (sections 4 and 8, respectively, of section A of the 

supporting statement). To review agencies’ reported actions, we used a 

data-collection instrument that contained a series of “yes-no” questions 

about the types of efforts reported. For example, we reviewed whether 

agencies had reported considering administrative data as a potential 

source of duplication, and whether agencies reported that they had 

consulted with other agencies when describing consultations outside of 

the agency. We did not evaluate whether agencies actually took the 

actions they reported taking. Estimates produced from the sample of the 

collections are subject to sampling error. We express our confidence in 

the precision of our results as a 95 percent confidence interval. This is the 

interval that would contain the actual population value for 95 percent of 

the samples we could have drawn. As a result, we are 95 percent 

confident that each of the confidence intervals in this report will include 

the true values in the study population.
Appendix I: Scope and Methodology

Page 43 GAO-12-54 Federal Statistical System

We took several steps to evaluate the reliability of the data we accessed 

through the Reginfo.gov website. We interviewed OMB officials and 

reviewed documentation of the Reginfo.gov website and the Regulatory 

Information Service Center and OIRA Consolidated Information System,4

We found a number of inconsistencies between the cost and burden 

information available on the website and that provided in supporting 

statement documentation. According to an official at OMB, the two 

sources should match, but the supporting statement documentation is 

more accurate than that on the website. On the basis of our assessment, 

we determined that the information from the website was not sufficiently 

reliable for the purpose of describing the annual cost or annual burden to 

respondents of the collections in our scope. However, through this review 

and the other steps we took, we found that the other information provided 

on the Reginfo.gov site was sufficiently reliable for our other intended 

purposes of identifying the collections within our scope and obtaining 

information on their subject matter and reported actions taken to identify 

unnecessary duplication and solicit input from outside persons and 

entities.

which is the system that agencies use to track information collection 

requests and that underlies information provided on Reginfo.gov. As part 

of our review of the subject matter of the collections in the May 17, 2011, 

download, we confirmed that the collections were within our scope. We 

also used the information in the September 22, 2011, download to 

evaluate the reliability of data on collections’ cost and annual burden. To 

do this, we drew a systematic random sample of 56 (approximately 10 

percent) of the 555 collections in the download.

Because the cost information on the Reginfo.gov website was not 

sufficiently reliable, we used cost information from the supporting 

statements of the collections in our sample to provide background 

information on the costs of the collections in our scope. In addition to 

using information from the supporting statements in our initial sample of 

56 collections, we drew another systematic random sample of 56 

additional collections from the September download. In total, we obtained 

cost information from the supporting statements of 112 (approximately 20 

percent) of the 555 collections in our scope that were active as of our 

September 22, 2011, download.

 

4

OIRA is the Office of Information and Regulatory Affairs within OMB.
Appendix I: Scope and Methodology

Page 44 GAO-12-54 Federal Statistical System

We conducted this performance audit from December 2010 until February 

2012 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audits 

to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.
Appendix II: Description of Case-Study 

Surveys

Page 45 GAO-12-54 Federal Statistical System

Purpose: To collect information on expenditures and households’ 

characteristics

Sponsoring agency: Bureau of Labor Statistics (BLS)

Annual sample size (estimated): CEQ: 14,725 households;1 CED: 12,075 

households2

Annual cost to the federal government (estimated): $41.8 million3

Annual burden hours (estimated): CEQ: 36,033hours;4 CED: 33,721 

hours5

Target population: Nationally-representative sample of the U.S.

population6

Uses of data: According to BLS documentation, the most important use of 

the CE Surveys is to provide expenditure data for updating the Consumer 

 

1

BLS estimates that 8,825 of the 14,725 households surveyed per quarter will complete 

the interviews. As a result, over the course of a year, BLS estimates that there will be 

35,300 completed interviews.

2

BLS estimates that 7,050 of the 12,075 households that receive the CED will complete 

the interview and diaries. Because each household completes two weekly diaries, BLS 

estimates that households will complete 14,100 diaries per year. 

3

This amount reflects the approximate fiscal year 2010 cost of collecting, processing, 

reviewing, and publishing data collected through the CE Surveys. Survey costs vary 

somewhat from year to year.

4

BLS estimates that respondents will take an average of 60 minutes to complete one 

interview survey of the CEQ. Since the CEQ is administered to the same sample of 

households four times in a year, the annual burden for respondents who complete all four 

surveys is roughly 4 hours. In addition, a certain number of respondents who complete the 

interview surveys are reinterviewed, a process that adds 10 minutes to these selected 

respondents’ burden times. 

5

BLS estimates that respondents will take approximately 105 minutes to complete one 

diary survey of the CED. In addition to the diary survey, respondents complete three 

interviews, each of which takes 25 minutes. Lastly, a certain number of respondents are 

reinterviewed, a process that adds 10 minutes to these selected respondents’ burden 

times. 

6

The CE Surveys are limited to the U.S. civilian, noninstitutionalized population, and as a 

result exclude certain segments of the population, such as active-duty military members 

living on bases and prisoners.

Appendix II: Description of Case-Study 

Surveys 

Consumer 

Expenditure (CE) 

Surveys: Quarterly 

Interview Survey 

(CEQ) and Diary 

Survey (CED)
Appendix II: Description of Case-Study 

Surveys

Page 46 GAO-12-54 Federal Statistical System

Price Index, the most widely used measure of inflation.7 In addition, 

government agencies, private companies, policymakers, and researchers 

use data from the CE Surveys in a variety of ways. For example, the 

Department of Defense uses data from the CE Surveys to update cost-ofliving adjustments for military families. Congressional committees also 

use the data to inform decision making, such as the potential effect of 

increases in the minimum wage.

Purpose: To assess the health and nutritional status of adults and 

children in the United States

Sponsoring agency: National Center for Health Statistics (NCHS), 

Centers for Disease Control and Prevention

Annual sample size (estimated): 5,180 individuals8

Annual cost to the federal government (estimated): $37.8 million9

Annual burden hours (estimated): 49,626 hours10

 

7

The Consumer Price Index produces monthly data on changes in the prices paid by 

urban consumers for a representative basket of goods and services.

8

Although a larger pool of respondents participates in a screener survey, NCHS estimates 

that 5,180 respondents participate in the screener, household interview, and physical 

examination. 

9

NCHS estimates that the annual cost to the federal government of NHANES for fiscal 

year 2010 was $37.8 million, including both direct and reimbursable funding provided by 

other agencies for NCHS statistical services. Survey costs vary somewhat from year to 

year.

10NCHS estimates that the total annual burden for the NHANES is 37,626 hours, including 

screening, household interviews, physical examinations, and any follow-up interviews. In 

addition, tests of procedures and special studies account for an additional 12,000 hours, 

for a total annual burden of 49,626 hours. NCHS estimates that respondents who 

participate in all aspects of the NHANES, including the screener survey, household 

interview, and physical examination, can expect a burden of 6.7 hours. In addition to those 

who complete all aspects of the NHANES, some respondents may only participate in the 

screener survey and be screened out of the sample, while other respondents may 

participate in the screener survey and the household interview but not the physical 

examination. NCHS includes all respondents at these varying levels of participation in its 

calculation of the annual burden hours. 

National Health and 

Nutrition 

Examination Survey 

(NHANES)
Appendix II: Description of Case-Study 

Surveys

Page 47 GAO-12-54 Federal Statistical System

Target population: Nationally-representative sample of individuals of all 

ages11

Uses of data: According to NCHS documentation, a variety of users, 

including federal agencies, research organizations, universities, healthcare providers, and educators, use NHANES data. For example, the Food 

and Drug Administration uses NHANES data to determine whether 

changes are needed to federal regulations. In addition, use of NHANES 

data informs key decision making. For example, according to NCHS 

documentation, NHANES data on lead levels in blood were instrumental 

in developing the policy to eliminate lead from gasoline and in food and 

soft drink cans. As part of its broader data-linkage program, NCHS links 

NHANES survey data to multiple administrative datasets, such as the 

National Death Index (a centralized index of state death record 

information) and Medicare and Medicaid claims from the Centers for 

Medicare and Medicaid Services. The National Death Index linkages give 

researchers an opportunity to analyze mortality differences among 

subgroups defined using the survey information. Similarly, the Medicare 

and Medicaid claim linkages provide an opportunity to examine health 

conditions, utilization, and costs among subgroups defined using the 

survey information. Additionally, according to NCHS officials, NCHS is 

currently conducting a pilot study to link NHANES data on participants 

from Texas to administrative data on food assistance.

Purpose: To monitor the health of the U.S. population

Sponsoring agency: National Center for Health Statistics (NCHS), 

Centers for Disease Control and Prevention

Annual sample size (estimated): 35,000 households12

 

11The NHANES is limited to the U.S. civilian, noninstitutionalized population, and as a 

result excludes certain segments of the population, such as active-duty military members 

living on bases and prisoners.

12NCHS estimates that the annual sample size in 2011 is 35,000 households, and that 

87,500 individuals will participate in the survey. NCHS plans to increase the sample size 

in the future. 

National Health 

Interview Survey 

(NHIS)
Appendix II: Description of Case-Study 

Surveys

Page 48 GAO-12-54 Federal Statistical System

Annual cost to the federal government (estimated): $32.2 million13

Annual burden hours (estimated): 34,977 hours14

Target population: Nationally-representative sample of households, 

collecting data on all members of each household15

Uses of data: According to NCHS documentation, government agencies, 

policymakers, researchers, and academics use NHIS data for a variety of 

purposes, such as identifying health problems and evaluating health 

programs. For example, policymakers used NHIS data to shape the 

Centers for Disease Control and Prevention’s cervical-cancer screening 

policy. In addition, other agencies can use the NHIS as a sample frame 

for their surveys. Lastly, as part of its broader data-linkage program, 

NCHS links NHIS survey data to multiple administrative datasets, 

including those it uses for linkages with NHANES data, such as the 

National Death Index and Medicaid and Medicare claims. 

Purpose: To provide information on the U.S stock of scientists and 

engineers

Sponsoring agency: National Center for Science and Engineering 

Statistics, National Science Foundation

Sample size per survey administration (estimated): 100,000 individuals

 

13NCHS estimates that the annual cost to the federal government of NHIS for fiscal year 

2010 was $32.2 million, including both direct and reimbursable funding provided by other 

agencies for NCHS statistical services. Survey costs vary somewhat from year to year.

14NCHS estimates that the total annual burden of the NHIS was 34,977 hours for 2010 

and 2011. NCHS estimates that a single respondent who completes all portions of the 

NHIS for a household can expect a time burden of one hour. Some respondents who 

complete all portions of the NHIS are asked to take a short reinterview survey, a process 

that adds 5 minutes to these selected respondents’ burden times. In addition to those who 

complete all portions of the NHIS, some respondents may only participate in a screener 

survey and be screened out of the sample, which NCHS estimates takes 5 minutes per 

respondent. NCHS includes all respondents at these varying levels of participation in its 

calculation of the annual burden hours. 

15The NHIS is limited to the U.S. civilian, noninstitutionalized population, and as a result 

excludes certain segments of the population, such as active-duty military members living 

on bases and prisoners.

National Survey of 

College Graduates 

(NSCG)
Appendix II: Description of Case-Study 

Surveys

Page 49 GAO-12-54 Federal Statistical System

Cost to the federal government (estimated): $13.3 million16

Burden hours per administration (estimated): 34,792 hours17

Target population: Individuals in the United States who have a bachelor’s 

degree in science, engineering, or health, and those who have a degree 

in another field but work in science, engineering, or health occupation.

Uses of data: According to National Science Foundation documentation, 

information from the NSCG is used by researchers and policymakers. 

Government agencies use the data to assess available scientific and 

engineering resources and inform the development of related policies. 

Additionally, educational institutions use NSCG data to inform the 

establishment and modification of curricula, and businesses use the data 

to develop recruitment and compensation policies.

Purpose: To provide information about status and principal determinants 

of individuals’ and households’ income and participation in government 

programs such as Social Security and Medicaid

Sponsoring agency: Census Bureau

Annual sample size (estimated): 45,000 households18

Annual cost to the federal government (estimated): $50 million19

 

16Survey costs vary somewhat from year to year. $13.3 million is the expected cost for the 

survey in 2012. 

17This estimate is based on the assumption that 83,500 individuals will respond to the 

survey and each respondent will take 25 minutes to complete it.

18The Census Bureau estimates that of the 65,300 households in its sample, 

approximately 52,900 are occupied at the time of interview and approximately 45,000 

households are interviewed. It estimates that each interview yields 2.1 individual 

interviews, for a total of 94,500 individual interviews per survey administration. The 

Census Bureau administered the SIPP three times to the same households in fiscal year 

2011, and estimates that each administration generated 94,500 interviews, for a total of 

283,500 in the fiscal year.

19The Census Bureau estimates that the production cost for all parts of the SIPP in fiscal 

year 2011 is $50.1 million. Survey costs vary somewhat from year to year.

Survey of Income and 

Program Participation 

(SIPP)
Appendix II: Description of Case-Study 

Surveys

Page 50 GAO-12-54 Federal Statistical System

Annual burden hours (estimated): 143,303 hours20

Target population: Nationally-representative sample of households.21

Uses of data: According to the Census Bureau, SIPP data are used by 

agencies such as the Department of Health and Human Services and the 

Department of Agriculture, as well as economic policymakers, Congress, 

and state and local governments, to plan and evaluate government 

social-welfare and transfer-payment programs. 

All 

household members 15 years old or over are interviewed for the survey.

 

20The bureau estimates the total burden to respondents in fiscal year 2011 as 143,303 

hours, which includes the time it takes respondents to fill out the core and topical module 

sections, as well as the reinterview of selected respondents. This estimate is based on the 

assumption that most respondents take 30 minutes to complete one administration of the 

survey. Since the SIPP was administered to the same sample of households three times 

in fiscal year 2011, the annual burden for most respondents was 90 minutes.

21The SIPP is limited to the U.S. civilian, noninstitutionalized population, and as a result 

excludes certain segments of the population, such as active-duty military members living 

on bases and prisoners.
Appendix III: Selected Statutes Related to 

Information Collection

Page 51 GAO-12-54 Federal Statistical System

Selected statutes that regulate the collection and dissemination of 

information include the following.

• The Information Quality Act of 2000 requires, among other things, that 

the Office of Management and Budget (OMB) develop and issue 

guidelines that provide policy and procedural guidance for federal 

agencies for ensuring and maximizing the quality of the information 

they disseminate. These guidelines include steps designed to assure 

objectivity and utility of disseminated information. See 44 U.S.C. § 

3504(d)(1); OMB guidelines are at 

http://www.whitehouse.gov/omb/info_quality_iqg_oct2002/. 

• The Privacy Act of 1974, as amended, and the privacy provisions of 

the E-Government Act of 2002 specify requirements for the protection 

of personal privacy by federal agencies. The Privacy Act places 

limitations on agencies’ collection, disclosure, and use of personal 

information maintained in systems of records. See 5 U.S.C. §§ 552a 

and 552a note. The E-Government Act requires agencies to conduct 

privacy impact assessments that analyze how personal information is 

collected, stored, shared, and managed in a federal system. See 44 

U.S.C. § 3501 note.

• The Confidential Information Protection and Statistical Efficiency Act 

(CIPSEA) of 2002 focuses on confidentiality protection and data 

sharing. It requires that information acquired by an agency under a 

pledge of confidentiality and for exclusively statistical purposes be 

used by the agency only for such purposes and not be disclosed in 

identifiable form for any other use, except with the informed consent 

of the respondent. It also authorizes identifiable business records to 

be shared for statistical purposes among the Bureau of Economic 

Analysis, Bureau of Labor Statistics, and the Census Bureau. See 44 

U.S.C. § 3501 note.

• Agency-specific statutes also guide federal data collection and use. 

For example, the Census Bureau conducts the census and censusrelated surveys such as the American Community Survey under Title 

13 of the U.S. Code, which gives the Census Bureau the authority to 

request and collect information from individuals but also guarantees 

the confidentiality of these data and establishes penalties for 

unlawfully disclosing this information. Unless specifically authorized, 

these provisions preclude the Census Bureau from sharing identifiable 

census information with other agencies. See 13 U.S.C. § 9. Title 15 of 

the U.S. Code permits the Secretary of Commerce to conduct studies 

on behalf of other agencies and organizations. Identifiable data from 

Appendix III: Selected Statutes Related to 

Information Collection

Governmentwide 

Statutes

Agency-Specific 

Statutes
Appendix III: Selected Statutes Related to 

Information Collection

Page 52 GAO-12-54 Federal Statistical System

surveys conducted under Title 15 authority are subject to the 

sponsoring agency’s legislation and confidentiality requirements. See 

15 U.S.C. § 176a. Statutes and regulations specific to other agencies 

also affect collection and sharing of data.

• Section 6103 of the Internal Revenue Code provides that federal tax 

information is confidential and may not be disclosed except as 

specifically authorized by law.

• Section 308(d) of the Public Health Service Act requires that 

identifiable information obtained by the National Center for Health 

Statistics be used only for the purpose for which it was collected 

unless consent is obtained for another purpose, and it prohibits the 

release of identifiable information without consent.

• Other legislation such as the Family Educational Rights and Privacy 

Act, which protects the privacy of student education records, can 

affect federal data-collection efforts. See 20 U.S.C. § 1232g.
Appendix IV: Printable Interactive Graphic 

Page 53 GAO-12-54 Federal Statistical System

This table reproduces the information in the interactive figure 3 earlier in 

this report.

Table 4: Actions Taken to Address Constraints That Hamper Greater Use of Administrative Data

Constraint

type Constraint Description Examples of actions taken

Access Statutory restrictions 

on data sharing

Statutes may not authorize 

statistical uses for data collected 

by a program.

• OMB [the Office of Management and Budget] has issued 

guidance encouraging greater sharing of data while 

protecting privacy; and

• FCSM [the Federal Committee on Statistical 

Methodology] produced a document, highlighting 

lessons learned when negotiating data-sharing 

agreements.

Consent Agencies may not have consent 

from respondents to use their 

administrative data for statistical 

purposes, or agencies may 

interpret the legal requirements 

for consent differently.

• When requesting consent to link respondents’ survey 

data with administrative data, NCHS [the National 

Center for Health Statistics] has moved from asking for 

respondents’ full Social Security numbers to only asking 

for part of their Social Security numbers (used to assure 

link quality), which has improved consent rates; and

• FCSM is working on a project to clarify legal 

requirements for informed consent and to examine the 

current practices agencies typically use to obtain 

consent.

Costs and 

infrastructure 

Agencies may not have the staff, 

policies, procedures, and systems 

in place to share or use 

administrative data for statistical 

purposes.

• FCSM is completing a template for agencies to use 

when negotiating data-sharing agreements;

• FCSM produced a document highlighting lessons 

learned when negotiating data sharing agreements; and

• The Census Bureau is using government and 

commercial administrative data to simulate the 2010 

Census results, as well as comparing the quality of the 

Census Bureau’s process for linking data from NCHS 

surveys with administrative data to NCHS’s current 

record-linkage process.

Quality Data documentation Agencies may not uniformly 

document information about 

administrative datasets.

• FCSM is investigating the potential for using a checklist 

to evaluate the quality of datasets, part of which focuses 

on documentation in order to assess potential for 

statistical uses.

Quality of data The quality of administrative data 

varies. 

• The Census Bureau is investigating the quality of 

administrative data held by private companies;

• FCSM and the Census Bureau are investigating the 

quality of administrative data and the potential for using 

a checklist to assess the quality of datasets; and

• ERS [the Economic Research Service] (in collaboration 

with the Census Bureau and NCHS) is undertaking a 

pilot project to address data- quality concerns with statelevel administrative data.

Source: GAO analysis of OMB and principal statistical agency data.

Note: Data are from related documentation and interviews with officials at OMB and selected principal 

statistical agencies. 

Appendix IV: Printable Interactive Graphic
Appendix V: Comments from the Department 

of Commerce

Page 54 GAO-12-54 Federal Statistical System

Appendix V: Comments from the Department 

of Commerce
Appendix V: Comments from the Department 

of Commerce

Page 55 GAO-12-54 Federal Statistical System
Appendix VI: GAO Contacts and Staff 

Acknowledgments

Page 56 GAO-12-54 Federal Statistical System

Ronald S. Fecso, (202) 512-7791 or fecsor@gao.gov

Robert Goldenkoff, (202) 512-2757 or goldenkoffr@gao.gov

In addition to the individuals named above, Tim Bober (Assistant 

Director), Carl Barden, Russell Burnett, Robert Gebhart, Jill Lacey, 

Andrea Levine, Jessica Nierenberg, Susan Offutt, Kathleen Padulchick, 

Tind Shepper Ryen, and Jared Sippel made key contributions to this 

report.

Appendix VI: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts

Staff 

Acknowledgments

(450880)
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