Paperwork Reduction Act: New Approaches Can Strengthen Information Collection and Reduce Burden
Published: 2006-03-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Americans spend billions of hours each year providing information to federal agencies by filling out forms, surveys, or questionnaires. A major aim of the Paperwork Reduction Act (PRA) is to minimize the burden that these information collections impose on the public, while maximizing their public benefit. Under the act, the Office of Management and Budget (OMB) is to approve all such collections. In addition, agency Chief Information Officers (CIO) are to review information collections before they are submitted to OMB for approval and certify that these meet certain standards set forth in the act. GAO was asked to testify on the implementation of the act's provisions regarding the review and approval of information collections. For its testimony, GAO reviewed previous work in this area, including the results of an expert forum on information resources management and the PRA, which was held in February 2005 under the auspices of the National Research Council. GAO also drew on its earlier study of CIO review processes (GAO-05-424) and alternative processes that two agencies have used to minimize burden. For this study, GAO reviewed a governmentwide sample of collections, reviewed processes and collections at four agencies that account for a large proportion of burden, and performed case studies of 12 approved collections.
section_title: What GAO Found
paragraphs: Among the PRA provisions aimed at helping to achieve the goals of minimizing burden while maximizing utility is the requirement for CIO review and certification of information collections. GAO's review of 12 case studies showed that CIOs provided these certifications despite often missing or inadequate support from the program offices sponsoring the collections. Further, although the law requires that support be provided for certifications, agency files contained little evidence that CIO reviewers had made efforts to get program offices to improve the support they offered. Numerous factors have contributed to these problems, including a lack of management support and weaknesses in OMB guidance. Because these reviews were not rigorous, OMB, the agency, and the public had reduced assurance that the standards in the act--such as minimizing burden--were consistently met. To address the issues raised by its review, GAO made recommendations to the agencies and OMB aimed at strengthening the CIO review process and clarifying guidance. OMB and the agencies report making plans and taking steps to address GAO's recommendations. Beyond the collection review process, the Internal Revenue Service (IRS) and the Environmental Protection Agency (EPA) have set up processes that are specifically focused on reducing burden. These agencies, whose missions involve numerous information collections, have devoted significant resources to targeted burden reduction efforts that involve extensive public outreach. According to the two agencies, these efforts led to significant reductions in burden. For example, each year, IRS subjects a few forms to highly detailed, in-depth analyses, reviewing all data requested, redesigning forms, and involving stakeholders (both the information users and the public affected). IRS reports that this process--performed on forms that have undergone CIO review and received OMB approval--has reduced burden by over 200 million hours since 2002. In contrast, for the 12 case studies, the CIO review process did not reduce burden. When it considers PRA reauthorization, the Congress has the opportunity to promote new approaches, including alternatives suggested by the expert forum and by GAO. Forum participants made a range of suggestions on information collections and their review. For example, they suggested that OMB's focus should be on broad oversight rather than on reviewing each individual collection and observed that the current clearance process appeared to be "pro forma." They also observed that it seemed excessive to require notices of collections to be published twice in the Federal Register, as they are now. GAO similarly observed that publishing two notices in the Federal Register did not seem to be effective, and suggested eliminating one of these notices. GAO also suggested that the Congress mandate pilot projects to target some collections for rigorous analysis along the lines of the IRS and EPA approaches. Such projects would permit agencies to build on the lessons learned by the IRS and EPA and potentially contribute to true burden reduction.

section_title: Letter
paragraphs: I am pleased to be here today to discuss the Paperwork Reduction  Act (PRA) and federal information collections. As you know, one of  the goals of the PRA is to help ensure that when the government  asks the public for information, the burden of providing this  information is as small as possible and the information itself is used  effectively. In other words, the goal is to minimize the paperwork  burden while maximizing the public benefit and utility of the  information collected. To achieve this goal, the PRA includes  provisions that establish standards and procedures for effective  implementation and oversight of information collections. Among  these provisions is the requirement that agencies not establish  information collections without having them approved by the Office  of Management and Budget (OMB), and that before submitting them  for approval, agencies’ Chief Information Officers (CIO) certify that  collections meet 10 specified standards—including that they avoid  unnecessary duplication and reduce burden as much as possible.
As you requested, I will discuss results from a May 2005 report that  we issued on PRA processes and compliance. In that work, we  reviewed agencies’ processes to certify that information collections  meet PRA standards, and we described alternative processes that  two agencies have used to minimize burden. I will also discuss  various suggestions for alternative approaches to burden reduction  that the Congress may wish to consider.
In preparing this testimony, we reviewed our previous work on PRA  issues, including the results of an expert forum on information  resources management and the PRA, which was held in February  2005. To convene this forum, we contracted with the National  Academies’ National Research Council, which recruited panelists  with expertise in the PRA and related areas. The 1½ day legislative  forum was attended by observers from our agency, OMB, the  Congressional Research Service, and staff of the House Government  Reform Committee. (Attachment 1 lists the participants.)
In reviewing our previous work, we focused particularly on our May  2005 report and a subsequent June testimony. For this report and  testimony, we performed detailed reviews of paperwork clearance  processes and collections at four agencies: the Department of  Veterans Affairs (VA), the Department of Housing and Urban  Development (HUD), the Department of Labor, and the Internal  Revenue Service (IRS). Together, these four agencies represent a  broad range of paperwork burdens, and in 2003, they accounted for  about 83 percent of the 8.1 billion hours of estimated paperwork  burden for all federal agencies. Of this total, IRS alone accounted for  about 80 percent. We also selected 12 approved collections as case  studies (three at each of the four agencies) to determine how  effective agency processes were. In addition, we analyzed a random  sample (343) of all OMB-approved collections governmentwide as of  May 2004 (8,211 collections at 68 agencies) to determine compliance  with the act’s requirements regarding agency certification of the 10  standards and consultation with the public. We designed the random  sample so that we could determine compliance levels at the four  agencies and governmentwide. Finally, although the Environmental  Protection Agency (EPA) was not one of the agencies whose  processes we reviewed, we analyzed documents and interviewed  officials concerning the agency’s efforts to reduce the burden of its  information collections. Further details on our scope and  methodology are provided in our report.
All work on which this testimony is based was conducted in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Collecting information is one way that federal agencies carry out  their missions. For example, IRS needs to collect information from  taxpayers and their employers to know the correct amount of taxes  owed. The U.S. Census Bureau collects information used to  apportion congressional representation and for many other  purposes. When new circumstances or needs arise, agencies may  need to collect new information. We recognize, therefore, that a  large portion of federal paperwork is necessary and serves a useful  purpose.
Nonetheless, besides ensuring that information collections have  public benefit and utility, federal agencies are required by the PRA  to minimize the paperwork burden that they impose. Among the  provisions of the act aimed at this purpose are requirements for the  review of information collections by OMB and by agency CIOs.
Under PRA, federal agencies may not conduct or sponsor the  collection of information unless approved by OMB. OMB is required  to determine that the agency collection of information is necessary  for the proper performance of the functions of the agency, including  whether the information will have practical utility. Consistent with  the act’s requirements, OMB has established a process to review all  proposals by executive branch agencies (including independent  regulatory agencies) to collect information from 10 or more persons,  whether the collections are voluntary or mandatory.
In addition, the act as amended in 1995 requires every agency to  establish a process under the official responsible for the act’s  implementation (now the agency’s CIO) to review program offices’  proposed collections. This official is to be sufficiently independent  of program responsibility to evaluate fairly whether information  collections should be approved. Under the law, the CIO is to review  each collection of information before submission to OMB, including  reviewing the program office’s evaluation of the need for the  collection and its plan for the efficient and effective management  and use of the information to be collected, including necessary  resources. As part of that review, the agency CIO must ensure that  each information collection instrument (form, survey, or  questionnaire) complies with the act. The CIO is also to certify that  the collection meets 10 standards (see table 1) and to provide  support for these certifications.
The paperwork clearance process currently takes place in two  stages. The first stage is CIO review. During this review, the agency  is to publish a notice of the collection in the Federal Register. The  public must be given a 60-day period in which to submit comments,  and the agency is to otherwise consult with interested or affected  parties about the proposed collection. At the conclusion of the  agency review, the CIO submits the proposal to OMB for review.  The agency submissions to OMB typically include a copy of the data  collection instrument (e.g., a form or survey) and an OMB  submission form providing information (with supporting  documentation) about the proposed information collection,  including why the collection is necessary, whether it is new or an  extension of a currently approved collection, whether it is voluntary  or mandatory, and the estimated burden hours. Included in the  submission is the certification by the CIO or the CIO’s designee that  the collection satisfies the 10 standards.
The OMB review is the second stage in the clearance process. This  review may involve consultation between OMB and agency staff.
During the review, a second notice is published in the Federal  Register, this time with a 30-day period for soliciting public  comment. At the end of this period, OMB makes its decision and  informs the agency. OMB maintains on its Web site a list of all  approved collections and their currently valid control numbers,  including the form numbers approved under each collection.
The 1995 PRA amendments also require OMB to set specific goals  for reducing burden from the level it had reached in 1995: at least a  10 percent reduction in the governmentwide burden-hour estimate  for each of fiscal years 1996 and 1997, a 5 percent governmentwide  burden reduction goal in each of the next 4 fiscal years, and annual  agency goals that reduce burden to the “maximum practicable  opportunity.” At the end of fiscal year 1995, federal agencies  estimated that their information collections imposed about 7 billion  burden hours on the public. Thus, for these reduction goals to be  met, the burden-hour estimate would have had to decrease by about  35 percent, to about 4.6 billion hours, by September 30, 2001. In fact,  on that date, the federal paperwork estimate had increased by about  9 percent, to 7.6 billion burden hours. As of March 2006, OMB’s  estimate for governmentwide burden is about 10.5 billion hours— about 2.5 billion hours more than the estimate of 7.971 billion hours  at the end of fiscal year 2004.
Over the years, we have reported on the implementation of PRA  many times. In a succession of reports and testimonies, we noted  that federal paperwork burden estimates generally continued to  increase, rather than decrease as envisioned by the burden  reduction goals in PRA. Further, we reported that some burden  reduction claims were overstated. For example, although some  reported paperwork reductions reflected substantive program  changes, others were revisions to agencies’ previous burden  estimates and, therefore, would have no effect on the paperwork  burden felt by the public. In our previous work, we also repeatedly  pointed out ways that OMB and agencies could do more to ensure  compliance with PRA. In particular, we have often recommended  that OMB and agencies take actions to improve the paperwork  clearance process.
section_title: Agency Processes for Reviewing Information Collections Were Not Effective
paragraphs: Governmentwide, agency CIOs generally reviewed information  collections before they were submitted to OMB and certified that  the 10 standards in the act were met. However, in our 12 case  studies, CIOs provided these certifications despite often missing or  partial support from the program offices sponsoring the collections.  Further, although the law requires CIOs to provide support for  certifications, agency files contained little evidence that CIO  reviewers had made efforts to get program offices to improve the  support that they offered. Numerous factors have contributed to  these conditions, including a lack of management support and  weaknesses in OMB guidance. Without appropriate support and  public consultation, agencies have reduced assurance that  collections satisfy the standards in the act.
subsections: section_title: Support for Certifications Was Often Missing or Partial, Despite CIO Reviews
paragraphs: Among the PRA provisions intended to help achieve the goals of  minimizing burden while maximizing utility are the requirements for  CIO review and certification of information collections. The 1995  amendments required agencies to establish centralized processes  for reviewing proposed information collections within the CIO’s  office. Among other things, the CIO’s office is to certify, for each  collection, that the 10 standards in the act have been met, and the  CIO is to provide a record supporting these certifications.
The four agencies in our review all had written directives that  implemented the review requirements in the act, including the  requirement for CIOs to certify that the 10 standards in the act were  met. The estimated certification rate ranged from 100 percent at IRS  and HUD to 92 percent at VA. Governmentwide, agencies certified  that the act’s 10 standards had been met on an estimated 98 percent  of the 8,211 collections.
However, in the 12 case studies that we reviewed, this CIO  certification occurred despite a lack of rigorous support that all  standards were met. Specifically, the support for certification was  missing or partial on 65 percent (66 of 101) of the certifications.  Table 4 shows the result of our analysis of the case studies.
For example, under the act, CIOs are required to certify that each  information collection is not unnecessarily duplicative. According to  OMB instructions, agencies are to (1) describe efforts to identify  duplication and (2) show specifically why any similar information  already available cannot be used or modified for the purpose  described.
Program reviews were conducted to identify potential areas of duplication; however, none  were found to exist. There is no known Department or Agency which maintains the  necessary information, nor is it available from other sources within our Department. is a new, nationwide service that  does not duplicate any single existing service that attempts to match employers with  providers who refer job candidates with disabilities. While similar job-referral services  exist at the state level, and some nation-wide disability organizations offer similar services  to people with certain disabilities, we are not aware of any existing survey that would  duplicate the scope or content of the proposed data collection. Furthermore, because this  information collection involves only providers and employers interested in participating in  the EARN service, and because this is a new service, a duplicate data set does not exist.
While this example shows that the agency attempted to identify  duplicative sources, it does not discuss why information from state  and other disability organizations could not be aggregated and used,  at least in part, to satisfy the needs of this collection.
We have attempted to eliminate duplication within the agency wherever possible.
This assertion provides no information on what efforts were made  to identify duplication or perspective on why similar information, if  any, could not be used. Further, the files contained no evidence that  the CIO reviewers challenged the adequacy of this support or  provided support of their own to justify their certification.
A second example is provided by the standard requiring each  information collection to reduce burden on the public, including  small entities, to the extent practicable and appropriate. OMB  guidance emphasizes that agencies are to demonstrate that they  have taken every reasonable step to ensure that the collection of  information is the least burdensome necessary for the proper  performance of agency functions. In addition, OMB instructions and  guidance direct agencies to provide specific information and  justifications: (1) estimates of the hour and cost burden of the  collections and (2) justifications for any collection that requires  respondents to report more often than quarterly, respond in fewer  than 30 days, or provide more than an original and two copies of  documentation.
With regard to small entities, OMB guidance states that the standard  emphasizes such entities because these often have limited resources  to comply with information collections. The act cites various  techniques for reducing burden on these small entities, and the  guidance includes techniques that might be used to simplify  requirements for small entities, such as asking fewer questions,  taking smaller samples than for larger entities, and requiring small  entities to provide information less frequently.
Our review of the case examples found that for the first part of the  certification, which focuses on reducing burden on the public, the  files generally contained the specific information and justifications  called for in the guidance. However, none of the case examples  contained support that addressed how the agency ensured that the  collection was the least burdensome necessary. According to agency  CIO officials, the primary cause for this absence of support is that  OMB instructions and guidance do not direct agencies to provide  this information explicitly as part of the approval package.
For the part of the certification that focuses on small businesses,  our governmentwide sample included examples of various agency  activities that are consistent with this standard. For instance, Labor  officials exempted 6 million small businesses from filing an annual  report; telephoned small businesses and other small entities to  assist them in completing a questionnaire; reduced the number of  small businesses surveyed; and scheduled fewer compliance  evaluations on small contractors.
For four of our case studies, however, complete information that  would support certification of this part of the standard was not  available. Seven of the 12 case studies involved collections that were  reported to impact businesses or other for-profit entities, but for 4  of the 7, the files did not explain either  ●  why small businesses were not affected or  ●  even though such businesses were affected, that burden could or  could not be reduced.
Referring to methods used to minimize burden on small business,  the files included statements such as “not applicable.” These  statements do not inform the reviewer whether there was an effort  made to reduce burden on small entities or not. When we asked  agencies about these four cases, they indicated that the collections  did, in fact, affect small business.
OMB’s instructions to agencies on this part of the certification  require agencies to describe any methods used to reduce burden  only if the collection of information has a “significant economic  impact on a substantial number of small entities.” This does not  appropriately reflect the act’s requirements concerning small  business: the act requires that the CIO certify that the information  collection reduces burden on small entities in general, to the extent  practical and appropriate, and provides no thresholds for the level  of economic impact or the number of small entities affected. OMB  officials acknowledged that their instruction is an “artifact” from a  previous form and more properly focuses on rulemaking rather than  the information collection process.
The lack of support for these certifications appears to be influenced  by a variety of factors. In some cases, as described above, OMB  guidance and instructions are not comprehensive or entirely  accurate. In the case of the duplication standard specifically, IRS  officials said that the agency does not need to further justify that its  collections are not duplicative because (1) tax data are not collected  by other agencies, so there is no need for the agency to contact  them about proposed collections, and (2) IRS has an effective  internal process for coordinating proposed forms among the  agency’s various organizations that may have similar information.  Nonetheless, the law and instructions require support for these  certifications, which was not provided.
In addition, agency reviewers told us that management assigns a  relatively low priority and few resources to reviewing information  collections. Further, program offices have little knowledge of and  appreciation for the requirements of the PRA. As a result of these  conditions and a lack of detailed program knowledge, reviewers  often have insufficient leverage with program offices to encourage  them to improve their justifications.
When support for the PRA certifications is missing or inadequate,  OMB, the agency, and the public have reduced assurance that the  standards in the act, such as those on avoiding duplication and  minimizing burden, have been consistently met.
section_title: Two Agencies Have Developed Processes to Reduce Burden Associated with Information Collections
paragraphs: IRS and EPA have supplemented the standard PRA review process  with additional processes aimed at reducing burden while  maximizing utility. These agencies’ missions require them both to  deal extensively with information collections, and their management  has made reduction of burden a priority.
In January 2002, the IRS Commissioner established an Office of  Taxpayer Burden Reduction, which includes both permanently  assigned staff and staff temporarily detailed from program offices  that are responsible for particular information collections. This  office chooses a few forms each year that are judged to have the  greatest potential for burden reduction (these forms have already  been reviewed and approved through the CIO process). The office  evaluates and prioritizes burden reduction initiatives by  ●  determining the number of taxpayers impacted;  ●  quantifying the total time and out-of-pocket savings for taxpayers;  ●  evaluating any adverse impact on IRS’s voluntary compliance  ●  assessing the feasibility of the initiative, given IRS resource  ●  tying the initiative into IRS objectives.
Once the forms are chosen, the office performs highly detailed, in- depth analyses, including extensive outreach to the public affected,  the users of the information within and outside the agency, and  other stakeholders. This analysis includes an examination of the  need for each data element requested. In addition, the office  thoroughly reviews form design.
The office’s Director heads a Taxpayer Burden Reduction Council,  which serves as a forum for achieving taxpayer burden reduction  throughout IRS. IRS reports that as many as 100 staff across IRS and  other agencies can be involved in burden reduction initiatives,  including other federal agencies, state agencies, tax practitioner  groups, taxpayer advocacy panels, and groups representing the  small business community.
The council directs its efforts in five major areas:  ●  simplifying forms and publications;  ●  streamlining internal policies, processes, and procedures;  ●  promoting consideration of burden reductions in rulings,  regulations, and laws;  ●  assisting in the development of burden reduction measurement  ●  partnering with internal and external stakeholders to identify areas  of potential burden reduction.
IRS reports that this targeted, resource-intensive process has  achieved significant reductions in burden: over 200 million burden  hours since 2002. For example, it reports that about 95 million hours  of taxpayer burden were reduced through increases in the income- reporting threshold on various IRS schedules. Another burden  reduction initiative includes a review of the forms that 15 million  taxpayers use to request an extension to the date for filing their tax  returns.
Similarly, EPA officials stated that they have established processes  for reviewing information collections that supplement the standard  PRA review process. These processes are highly detailed and  evaluative, with a focus on burden reduction, avoiding duplication,  and ensuring compliance with PRA. According to EPA officials, the  impetus for establishing these processes was the high visibility of  the agency’s information collections and the recognition, among  other things, that the success of EPA’s enforcement mission  depended on information collections being properly justified and  approved: in the words of one official, information collections are  the “life blood” of the agency.
According to these officials, the CIO staff are not generally closely  involved in burden reduction initiatives, because they do not have  sufficient technical program expertise and cannot devote the  extensive time required. Instead, these officials said that the CIO  staff’s focus is on fostering high awareness within the agency of the  requirements associated with information collections, educating and  training the program office staff on the need to minimize burden and  the impact on respondents, providing an agencywide perspective on  information collections to help avoid duplication, managing the  clearance process for agency information collections, and acting as  liaison between program offices and OMB during the clearance  process. To help program offices consider PRA requirements such  as burden reduction and avoiding duplication as they are developing  new information collections or working on reauthorizing existing  collections, the CIO staff also developed a handbook to help  program staff understand what they need to do to comply with PRA  and gain OMB approval.
In addition, program offices at EPA have taken on burden reduction  initiatives that are highly detailed and lengthy (sometimes lasting  years) and that involve extensive consultation with stakeholders  (including entities that supply the information, citizens groups,  information users and technical experts in the agency and  elsewhere, and state and local governments). For example, EPA  reports that it amended its regulations to reduce the paperwork  burden imposed under the Resource Conservation and Recovery  Act. One burden reduction method EPA used was to establish higher  thresholds for small businesses to report information required under  the act. EPA estimates that the initiative will reduce burden by  350,000 hours and save $22 million annually. Another EPA program  office reports that it is proposing a significant reduction in burden  for its Toxic Release Inventory program.
Both the EPA and IRS programs involve extensive outreach to  stakeholders, including the public. This outreach is particularly  significant in view of the relatively low levels of public consultation  that occur under the standard review process. As we reported in  May 2005, public consultation on information collections is often  limited to publication of notices in the Federal Register. As a  means of public consultation, however, these notices are not  effective, as they elicit few responses. An estimated 7 percent of the  60-day notices of collections in the Federal Register received one or  more comments. According to our sample of all collections at the  four agencies reviewed, the number of notices receiving at least one  comment ranged from an estimated 15 percent at Labor to an  estimated 6 percent at IRS. In contrast, according to EPA and IRS,  their efforts at public consultation are key to their burden reduction  efforts and an important factor in their success.
Overall, EPA and IRS reported that their targeted processes  produced significant reductions in burden by making a commitment  to this goal and dedicating resources to it. In contrast, for the 12  information collections we examined, the CIO review process  resulted in no reduction in burden. Further, the Department of  Labor reported that its PRA reviews of 175 proposed collections  over nearly 2 years did not reduce burden. Similarly, both IRS and  EPA addressed information collections that had undergone CIO  review and received OMB approval and nonetheless found  significant opportunities to reduce burden.
section_title: Agencies Could Strengthen CIO Review
paragraphs: In our 2005 report, we concluded that the CIO review process was  not working as Congress intended: It did not result in a rigorous  examination of the burden imposed by information collections, and  it did not lead to reductions in burden. In light of these findings, we  recommended (among other things) that agencies strengthen the  support provided for CIO certifications and that OMB update its  guidance to clarify and emphasize this requirement.
Since our report was issued, the four agencies have reported taking  steps to strengthen their support for CIO certifications:  ●  According to the HUD CIO, the department established a senior- level PRA compliance officer in each major program office, and it  has revised its certification process to require that before  collections are submitted for review, they be approved at a higher  management level within program offices.  ●  The Treasury CIO established an Information Management Sub- Council under the Treasury CIO Council and added resources to the  review process.   ●  According to the VA’s 2007 budget submission, the department  obtained additional resources to help review and analyze its  information collection requests.   ●  According to the Office of the CIO at the Department of Labor, the  department intends to provide guidance to components regarding  the need to provide strong support for clearance requests and has  met with component staff to discuss these issues.
OMB reported that its guidance to agencies will be updated through  a planned automated system, which is expected to be operational  by the end of this year. According to the acting head of OMB’s Office  of Information and Regulatory Affairs, the new system will permit  agencies to submit clearance requests electronically, and the  instructions will provide clear guidance on the requirements for  these submissions, including the support required. This official  stated that OMB has worked with agency representatives with direct  knowledge of the PRA clearance process in order to ensure that the  system and its instructions clearly reflect the requirements of the  process. If this system is implemented as described and OMB  withholds clearance from submissions that lack adequate support, it  could lead agencies to strengthen the support provided for their  certifications.
section_title: According to PRA Experts, the Current Approach to Paperwork Reduction Could Be Improved
paragraphs: In considering PRA reauthorization, the Congress has the  opportunity to take into account ideas that were developed by the  various experts at the PRA forum that we organized in 2005. These  experts noted, as we have here, that the burden reduction goals in  the act have not been met, and that in fact burden has been going  up. They suggested first that the goal of reducing burden by 5  percent is not realistic, and also that such numerical goals do not  appropriately recognize that some burden is necessary. The  important point, in their view, is to reduce unnecessary burden  while still ensuring maximum utility.
Forum participants also questioned the level of attention that OMB  devotes to the process of clearing collections on what they called a  “retail” basis, focusing on individual collections rather than looking  across numerous collections. In their view, some of this attention  would be better devoted to broader oversight questions. In their  discussion, participants mentioned that the clearance process  informs OMB with respect to its other information resource  management functions, but that this had not led to high-level  integration and coordination. It was suggested that the volume of  collections to be individually reviewed could impede such  integration.
Participants made a number of suggestions regarding ways to  reduce the volume of collections that OMB reviews, with the goal of  freeing OMB resources so that it could address more substantive,  wide-ranging paperwork issues. Options that they suggested  including limiting OMB review to significant and selected  collections, rather than all collections. This would entail shifting  more responsibility for review to the agencies, which they stated  was one of the avowed purposes of the 1995 amendments: to  increase agencies’ attention to properly clearing information  collection requests. One way to shift this responsibility, the forum  suggested, would be for OMB to be more creative in its use of the  delegation authority that the act provides. (Under the act, OMB has  the authority to delegate to agencies the authority to approve  collections in various circumstances.) Also, participants mentioned  the possibility of modifying the clearance process by, for example,  extending beyond 3 years the length of time that OMB approvals are  valid, particularly for the routine types of collections. This  suggestion was paired with the idea that the review process itself  should be more rigorous; as the panel put it, “now it’s a rather pro  forma process.” They also observed that two Federal Register  notices seemed excessive in most cases.
To reduce the number of collections that require OMB review,  another possibility suggested was to revise the PRA’s definition of  an information collection. For example, the current definition  includes all collections that contact 10 or more persons; the panel  suggested that this threshold could be raised, pointing out that this  low threshold makes it hard for agencies to perform targeted  outreach to the public regarding burden and other issues (such as  through customer satisfaction questionnaires or focus groups).  However, they had no specific recommendation on what the number  should be. Alternatively, they suggested that OMB could be given  authority to categorize types of information collections that did not  require clearance (for example, OMB could exempt collections for  which the response is purely voluntary).
Finally, the forum questioned giving agency CIOs the responsibility  for reviewing information collections. According to the forum, CIOs  have tended to be more associated with information technology  issues than with high level information policy.
Our previous work has not addressed every topic raised by the  forum, so we cannot argue for or against all these suggestions.  However, the work in our May 2005 report is consistent with the  forum’s observations in some areas, including the lack of rigor in the  review process and the questionable need for two Federal Register  notices. I would like to turn here, Madam Chairman, to the matters  for congressional consideration that we included in that report.
section_title: Our Work Suggests Ways to Explore New Approaches
paragraphs: We observed that to achieve burden reduction, the targeted  approaches used by IRS and EPA were a promising alternative.  However, the agencies’ experiences also suggest that to make such  approaches successful requires top-level executive commitment,  extensive involvement of program office staff with appropriate  expertise, and aggressive outreach to stakeholders. Indications are  that such an approach would also be more resource-intensive than  the current process. Moreover, such an approach may not be  warranted at all agencies, since not al agencies have the level of  paperwork issues that face IRS and similar agencies.
On the basis of the conclusions in our May 2005 report, we  suggested that the Congress consider mandating the development of  pilot projects to test and review the value of approaches to burden  reduction similar to those used by IRS and EPA. OMB would issue  guidance to agencies on implementing such pilots, including criteria  for assessing collections along the lines of the process currently  employed by IRS. According to our suggestion, agencies  participating in such pilots would submit to OMB and publish on  their Web sites (or through other means) an annual plan on the  collections targeted for review, specific burden reduction goals for  those collections, and a report on reductions achieved to date. We  also suggested that in view of the limited effectiveness of the 60-day  notice in the Federal Register in eliciting public comment, this  requirement could be eliminated.
Under a pilot project approach, an agency would develop a process  to examine its information collections for opportunities to reduce  burden. The experiences at IRS and EPA show that targeted burden  reduction efforts depend on tapping the expertise of program staff,  who are generally closely involved in the effort. That is, finding  opportunities to reduce burden requires strong familiarity with the  programs involved.
Pilot projects would be expected to build on the lessons learned at  IRS and EPA. For example, these agencies have used a variety of  approaches to reducing burden, such as  ●  sharing information—for example, by facilitating cross-agency  ●  standardizing data for multiple uses (“collect once—use multiple  integrating data to avoid duplication; and  ●  re-engineering work flows.
Pilot projects would be most appropriate for agencies for which  information collections are a significant aspect of the mission. As  the results and lessons from the pilots become available, OMB may  choose to apply them at other agencies by approving further pilots.  Lessons learned from the mandated pilots could thus be applied  more broadly.
In developing processes to involve program offices in burden  reduction, agencies would not have to impose a particular  organizational structure for the burden reduction effort. For  instance, the burden reduction effort might not necessarily be  performed by the CIO. For example, at IRS, the Office of Burden  Reduction is not connected to the CIO, whereas at EPA, CIO staff  are involved in promoting burden reduction through staff education  and outreach. However, the EPA CIO depends on program offices to  undertake specific initiatives. Under a mandate for pilot projects,  agencies would be encouraged to determine the approach that  works best in their own situations.
Finally, both IRS and EPA engaged in extensive outreach to the  public and stakeholders. In many cases, this outreach involves  contacts with professional and industry organizations, which are  particularly valuable because they allow the agencies to get  feedback without the need to design an information collection for  the purpose (which would entail its own review process, burden  estimate, and so on). According to agency officials, the need to  obtain OMB approval for an information collection if they contact  more than nine people often inhibits agencies’ use of questionnaires  and similar types of active outreach to the public. Agencies are  free, however, to collect comments on information posted on Web  sites. OMB could also choose to delegate to pilot project agencies  the authority to approve collections that are undertaken as part of  public outreach for burden reduction projects.
The work we reported in May and June 2005 strongly suggested that  despite the importance of public consultation to burden reduction,  the current approach is often ineffective. Federal Register notices  elicit such low response that we questioned the need for two such  notices (the 60-day notice during the agency review and the 30-day  notice during the OMB review). Eliminating the first notice, in our  view, is thus not likely to decrease public consultation in any  significant way. Instead, our intent was for agencies, through pilot  projects, to explore ways to perform outreach to information  collection stakeholders, including the public, that will be more  effective in eliciting useful comments and achieving real reductions  in burden.
In summary, Madam Chairman, the information collection review  process appeared to have little effect on paperwork burden. As our  review showed, the CIO review process, as currently implemented,  tended to lack rigor, allowing agencies to focus on clearing an  administrative hurdle rather than on performing substantive  analysis. Going further, the expert forum characterized the whole  clearance process as “pro forma.” The forum also made various  suggestions for improving the clearance process; many of these  were aimed at finding ways to reduce its absorption of OMB  resources, such as by changing the definition of an information  collection. Both we and the forum suggested removing one of the  current administrative hurdles (the 60-day Federal Register notice).
Although these suggestions refer to specific process improvements,  the main point is not just to tweak the process. Instead, the intent is  to remove administrative impediments, with the ultimate aim of  refocusing agency and OMB attention away from the current  concentration on administrative procedures and toward the goals of  the act—minimizing burden while maximizing utility. To that end,  we suggested that the Congress mandate pilot projects that are  specifically targeted at reducing burden. Such projects could help to  move toward the outcomes that the Congress intended in enacting  PRA.
Madam Chairman, this completes my prepared statement. I would  be pleased to answer any questions.
section_title: Contacts and Acknowledgments
paragraphs: For future information regarding this testimony, please contact  Linda Koontz, Director, Information Management, at (202) 512-6420,  or koontzl@gao.gov. Other individuals who made key contributions  to this testimony were Timothy Bober, Barbara Collier, David  Plocher, Elizabeth Powell, J. Michael Resser, and Alan Stapleton.
section_title: Attachment 1. Forum: The Legislative Framework for Information Resources Management
subsections: section_title: Forum Participants
paragraphs: Associate Executive Director Association  of Research Libraries  Princeton University; formerly National  Opinion Research Center  Founder and Executive Director, OMB  Watch  Administrative Law & Information Policy;  formerly OMB and IRS Privacy Officer  Vice President, SRA International;  formerly OMB  Director, Center for Technology in  Government, University at Albany, State  University of New York  Partner, Guerra, Kiviat, Flyzik and  Associates; formerly Department of  Treasury and Secret Service  Privacy & Information Policy Consultant;  formerly counsel to the House of  Representatives’ Subcommittee on  Information, Justice, Transportation and  Agriculture  Editor of Access Reports, FOIA Journal  Independent Consultant; formerly OMB  Professor and Independent Consultant;  formerly OMB  Manager, Regulatory Policy National  Federation of Independent Business  Director, Public Policy, Software &  Information Industry Association  Senior Scientist, Computer Science and  Telecommunications Board, The National  Academies  Fellow in Law and Government, American  University, Washington College of Law;  formerly Administrative Conference of the  U.S.
section_title: Others in Attendance
paragraphs: At the forum, others attending included GAO staff and a number of  other observers:  Deputy Administrator, Office of  Information and Regulatory Affairs  Minority Senior Legislative Counsel,  House Committee on Government Reform  Minority Counsel, House Committee on  Government Reform  Policy Analyst, Office of Information and  Regulatory Affairs  Director of Energy and Environment, U.S.  Chamber of Commerce  Senior Policy Analyst, Office of  Management and Budget  Policy Analyst, Office of Management and  Budget  Minority Professional Staff Member,  House Committee on Government Reform  Counsel, House Committee on  Government Reform  Policy Analyst, Office of Management and  Budget  Office of Information and Regulatory  Affairs  Senior Professional Staff Member, House  Committee on Government Reform  House Committee on Government Reform  Branch Chief, Statistics Branch, Office of  Information and Regulatory Affairs  In addition, staff of the National Academies’ National Research  Council, Computer Science and Telecommunications Board, helped  to develop and facilitate the forum: Charles Brownstein, Director;  Kristen Batch, Research Associate; and Margaret Huynh, Senior  Program Assistant.
section_title: Related GAO Products
paragraphs: Paperwork Reduction Act: Subcommittee Questions Concerning  the Act’s Information Collection Provisions. GAO-05-909R.  Washington, D.C.: July 19, 2005.
Paperwork Reduction Act: Burden Reduction May Require a New  Approach. GAO-05-778T. Washington, D.C.: June 14, 2005.
Paperwork Reduction Act: New Approach May Be Needed to  Reduce Government Burden on Public. GAO-05-424. Washington,  D.C.: May 20, 2005.
Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates  Due to Federal Actions Continue to Increase. GAO-04-676T.  Washington, D.C.: April 20, 2004.
Paperwork Reduction Act: Record Increase in Agencies’ Burden  Estimates. GAO-03-619T. Washington, D.C.: April 11, 2003.
Paperwork Reduction Act: Changes Needed to Annual Report.  GAO-02-651R. Washington, D.C.: April 29, 2002.
Paperwork Reduction Act: Burden Increases and Violations  Persist. GAO-02-598T. Washington, D.C.: April 11, 2002.
Information Resources Management: Comprehensive Strategic  Plan Needed to Address Mounting Challenges. GAO-02-292.  Washington, D.C.: February 22, 2002.
Paperwork Reduction Act: Burden Estimates Continue to Increase.  GAO-01-648T. Washington, D.C.: April 24, 2001.
Electronic Government: Government Paperwork Elimination Act  Presents Challenges for Agencies. GAO/AIMD-00-282. Washington,  D.C.: September 15, 2000.
Tax Administration: IRS Is Working to Improve Its Estimates of  Compliance Burden. GAO/GGD-00-11. Washington, D.C.: May 22,  2000.
Paperwork Reduction Act: Burden Increases at IRS and Other  Agencies. GAO/T-GGD-00-114. Washington, D.C.: April 12, 2000.
EPA Paperwork: Burden Estimate Increasing Despite Reduction  Claims. GAO/GGD-00-59. Washington, D.C.: March 16, 2000.
Federal Paperwork: General Purpose Statistics and Research  Surveys of Businesses. GAO/GGD-99-169. Washington, D.C.:  September 20, 1999.
Paperwork Reduction Act: Burden Increases and Unauthorized  Information Collections. GAO/T-GGD-99-78. Washington, D.C.: April  15, 1999.
Paperwork Reduction Act: Implementation at IRS.  GAO/GGD-99-4.  Washington, D.C.: November 16, 1998.
Regulatory Management: Implementation of Selected OMB  Responsibilities Under the Paperwork Reduction Act. GAO/GGD- 98-120. Washington, D.C.: July 9, 1998.
Paperwork Reduction: Information on OMB’s and Agencies’  Actions.  GAO/GGD-97-143R. Washington, D.C.: June 25, 1997.
Paperwork Reduction: Governmentwide Goals Unlikely to Be Met.  GAO/T-GGD-97-114. Washington, D.C.: June 4, 1997.
Paperwork Reduction: Burden Reduction Goal Unlikely to Be Met.  GAO/T-GGD/RCED-96-186. Washington, D.C.: June 5, 1996.
Environmental Protection: Assessing EPA’s Progress in  Paperwork Reduction. GAO/T-RCED-96-107. Washington, D.C.:  March 21, 1996.
Paperwork Reduction: Burden Hour Increases Reflect New  Estimates, Not Actual Changes. GAO/PEMD-94-3. Washington, D.C.:  December 6, 1993.
This  is  a  work  of  the  U.S.  government  and  is  not  subject  to  copyright  protection  in  the  United  States.  It  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.