Paperwork Reduction Act: Increase in Estimated Burden Hours Highlights Need for New Approach
Released: 2006-07-18T00:00:00

Letter

Background

Collecting information is one way that federal agencies carry out their missions. For example, IRS needs to collect information from taxpayers and their employers to know the correct amount of taxes owed. The U.S. Census Bureau collects information used to apportion congressional representation and for many other purposes. When new circumstances or needs arise, agencies may need to collect new information. We recognize, therefore, that a large portion of federal paperwork is necessary and often serves a useful purpose.

Nonetheless, besides ensuring that information collections have public benefit and utility, federal agencies are required by the PRA to minimize the paperwork burden that the collection of information imposes. Among the provisions of the act aimed at this purpose are requirements for the review of information collections by OMB and by agency CIOs.

Under PRA, federal agencies may not conduct or sponsor the collection of information unless approved by OMB; information collections for which OMB approval is expired or missing are considered violations of the PRA. Before approving collections, OMB is required to determine that the agency’s collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility. 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, certify that the collection meets 10 standards (see table 1), and provide support for these certifications.

In addition, the original PRA of 1980 (section 3514(a)) requires OMB to keep Congress “fully and currently informed” of the major activities under the act and to submit a report to Congress at least annually on those activities. Under the 1995 amendments, this report must include, among other things, a list of any increases in burden. To satisfy this requirement, OMB prepares the annual PRA report, which reports on agency actions during the previous fiscal year, including changes in agencies’ burden-hour estimates as well as violations of the PRA.

The 1995 PRA amendments also required OMB to set specific goals for reducing burden from the level it had reached in 1995: at least a 10 percent reduction in the governmentwide burden-hour estimate for each of fiscal years 1996 and 1997, a 5 percent governmentwide burden reduction goal in each of the next 4 fiscal years, and annual agency goals that reduce burden to the “maximum practicable opportunity.” At the end of fiscal year 1995, federal agencies estimated that their information collections imposed about 7 billion burden hours on the public. Thus, for these reduction goals to be met, the burden-hour estimate would have had to decrease by about 35 percent, to about 4.6 billion hours, by September 30, 2001. In fact, on that date, the federal paperwork estimate had increased by about 9 percent, to 7.6 billion burden hours.

Over the years, we have reported on the implementation of PRA many times. In a succession of reports and testimonies, we noted that federal paperwork burden estimates generally continued to increase, rather than decrease as envisioned by the burden reduction goals in PRA. Further, we reported that some burden reduction claims were overstated. For example, although some reported paperwork reductions reflected substantive program changes, others were revisions to agencies’ previous burden estimates and, therefore, would have no effect on the paperwork burden felt by the public. In our previous work, we also repeatedly pointed out ways that OMB and agencies could do more to ensure compliance with PRA. In particular, we have often recommended that OMB and agencies take actions to improve the paperwork clearance process.

Estimated Paperwork Burden Increased in 2005

After 2 years of slight declines, OMB reports that burden hours increased in fiscal year 2005 and are expected to increase again in fiscal year 2006. According to OMB’s most recent PRA report to Congress, the estimated total burden hours imposed by government information collections in fiscal year 2005 was 8.4 billion hours; this is an increase of 441 million burden hours (5.5 percent) from the previous year’s total of 8.0 billion hours. It is also almost a billion and a half hours larger than it was in 1995 and 3.8 billion larger than the PRA target for the end of fiscal year 2001 (4.6 billion burden hours). OMB’s report also states that burden will increase in fiscal year 2006 by an estimated 303 million hours to about 8.7 billion hours; however, according to OMB, most of this projected increase (250 million hours or 83 percent) is attributable to a new method of estimating burden that is being implemented by IRS, rather than to any increase in the actual burden. Finally, according to OMB, fewer violations of the act were reported than in previous years.

Changes in Paperwork Burden Estimates Can Be Attributed to Various Causes

Changes in paperwork burden estimates result from several causes, which OMB assigns to two main categories. OMB classifies all changes—either increases or decreases—in agencies’ burden-hour estimates as either program changes or adjustments. ● Program changes are the result of deliberate federal government action (e.g., the addition or deletion of questions on a form); these can occur as a result of ● agency-initiated actions, or ● the expiration or reinstatement of OMB-approved collections. ● Adjustments do not result from federal activities but from external factors. For example: ● an agency may reestimate the burden associated with a collection of information, or ● the population responding to a requirement may change—such as if the economy declines and more people complete applications for food stamps; the resulting increase in the Department of Agriculture’s paperwork estimate is considered an adjustment because it is not the result of deliberate federal action.

As shown above, within the category of program changes, OMB distinguishes between changes due to new statutes and changes due to agency action, which it also refers to as agency discretionary actions. However, this term should not imply that agencies have no discretion in how they implement new statutes. A major goal of the PRA is to ensure that agencies consider how to make the burden of information collections, whether old or newly established, as small as possible. In the second part of my statement, I will address one of the ways set forth in the PRA to help achieve this goal.

Table 2 shows the changes in reported burden totals from fiscal year 2004 to fiscal year 2005.

As the table shows, the change due to new statutes was by far the largest factor in the increase for fiscal year 2005. OMB reports that the statute having the largest impact on burden was the statute establishing voluntary prescription drug coverage under Medicare; implementing the program mandated by this statute required the collection of significant amounts of information, leading to an increase in burden of 224 million hours. An additional significant increase—about 116 million hours—resulted from the implementation by the Federal Communications Commission (FCC) of the CAN-SPAM Act, which requires disclosure of certain information contained in unsolicited commercial e-mails.

In contrast to changes due to new statutes, changes due to agency action did not contribute significantly to the overall change in burden this year, adding 180,000 hours out of the total rise of 441 million. Although the overall result was a slight increase, agencies did take many actions that decreased burden; without these actions, the governmentwide increase would have been greater. The annual report does not list all these actions, but it does highlight actions that led to significant paperwork reductions and increases. (These include increases and decreases in burden from statutory requirements and miscellaneous agency actions, as well as burden reductions from changing regulations, cutting redundancy, changing forms, and using information technology.) From both an individual agency perspective and a governmentwide perspective, the relatively small increase due to agency action is the result of large increases and decreases that mostly offset each other: ● From an individual agency perspective, the net change in an agency’s burden estimate is generally the result of disparate actions, some of which reduce burden and some of which increase it. An example is the IRS, which as an agency was responsible for a net decrease of about 3 million hours. Among the burden reductions that the annual report highlights are two IRS actions to change forms, both of which reduced burden by simplification and streamlining, for a reduction of about 19 million hours. The ICB also reports that in January 2006 IRS completed an initiative to simplify the process of applying for an extension to file an income tax return, which is associated with a burden reduction of 8 million hours. Elsewhere, on the other hand, five IRS actions are highlighted that together resulted in an increase of about 24 million hours. Examples of reasons IRS took these actions included increasing accuracy and improving the agency’s ability to monitor compliance with the law. ● Similarly, from a governmentwide perspective, the overall change is the result of some agencies whose actions produced a net decrease and others whose produced a net decrease. In fiscal year 2005, agencies with net decreases produced a reduction of about 14.02 million hours. This reduction was offset, however, by agencies with net increases, which totaled about 14.20 million hours.

Compared to program changes as a whole, adjustments to the estimates were a relatively small factor (as table 2 also shows), accounting for a net increase in the burden of about 19 million hours. In previous years, adjustments have had a much greater impact and have tended to decrease overall burden estimates, thus masking the effect of increases from program changes. In fiscal years 2003 and 2004, the impact of adjustments was large enough to lead to overall burden estimates that were lower than for the year before. In fiscal year 2004, OMB reported a decrease of about 156 million hours in adjustments versus an increase of about 29 million hours in program changes; the result was a lower overall burden estimate than for the previous year. Similarly, overall burden in fiscal year 2003 was slightly less than in fiscal year 2002, also as a result of a decrease in adjustments (about 182 million hours) that more than offset an increase in program changes (about 72 million hours).

Besides these large decreases due to adjustments, another reason for the slight decrease in total burden in fiscal years 2004 and 2003 was that increases due to program changes were relatively small, as shown in table 3. This year, both program changes and adjustments went up, so adjustments did not have the effect of masking increases in program changes. As the table also shows, fiscal year 2005 saw the largest net increase from program changes since 1998.

IRS Continues to Account for Largest Portion of Estimated Governmentwide Burden

In fiscal year 2005, IRS accounted for about 76 percent of the governmentwide paperwork burden: about 6.4 billion hours. As shown in figure 1, no other agency’s estimate approaches this level. Six agencies had burden-hour estimates of 100 million hours or more (the Departments of Health and Human Services, Labor, and Transportation; EPA; FCC; and the Securities and Exchange Commission). Thus, as we have previously reported, changes in paperwork burden experienced by the federal government have been largely attributable to changes associated with IRS.

OMB reports that starting in fiscal year 2006, IRS began using a new methodology based on a statistical model—the Individual Taxpayer Burden Model—to estimate the reporting burden imposed on individual taxpayers. Among other things, this new model, which was developed to improve the accuracy and transparency of taxpayer burden estimates, reflects the major changes over the past two decades in the way that taxpayers prepare and file their returns, including the use of electronic preparation methods. According to OMB, rather than estimating burden on a form-by-form basis, the new methodology takes into account broader and more comprehensive taxpayer characteristics and activities, considering how the taxpayer prepares the return (e.g., with or without software or a paid preparer) as well as the taxpayer’s activities, such as gathering tax materials, completing forms, recordkeeping, and tax planning. In contrast, the previous methodology primarily focused on the length and complexity of each tax form. OMB states that this new model will make it possible to estimate the burden implications of new legislative and administrative tax proposals.

OMB projects that these changes will create a one-time increase of about 250 million hours in the estimate of IRS burden levels in fiscal year 2006. This increase represents most (83 percent) of the total projected governmentwide increase for fiscal year 2006 of 303 million hours. However, according to OMB, this increase does not reflect any change in the actual burden experienced by taxpayers, but rather a change in the way the burden is measured.

In the past, we reported that IRS’s previous estimation model ignored important components of burden and had limited capabilities for analyzing the determinants of burden. The new model is the result of work that IRS has performed over the past several years to improve its model and address these and other limitations. At this time, we have not analyzed IRS’s new model to determine the extent to which it improves the accuracy of burden estimates, and we have not assessed the accuracy of the new model’s estimates. However, IRS’s efforts to increase the accuracy of its model appear to be an important step towards addressing the previous model’s shortcomings.

See GAO, EPA Paperwork: Burden Estimate Increasing Despite Reduction Claims, GAO/GGD-00-59 (Washington, D.C.: Mar. 16, 2000), for how one agency estimates paperwork burden. understood, these estimates can be useful as the best indicators of paperwork burden available.

Fewer Violations Reported in Fiscal Year 2005

OMB reports reductions in PRA violations for fiscal year 2005 compared to previous years. The PRA prohibits an agency from conducting or sponsoring the collection of information unless (1) the agency has submitted the proposed collection to OMB, (2) OMB has approved the proposed collection, and (3) the agency displays an OMB control number on the collection. According to OMB’s annual report, agencies have made great progress in recent years in reducing the number of violations of these conditions and in resolving them more promptly. OMB attributed this reduction to several initiatives it had taken, including meeting with agency officials to discuss ways to reduce violations and adding reporting requirements.

According to OMB, during fiscal year 2005, agencies reported a total of 97 violations: 60 information collections that expired during the year, and another 37 that had expired before October 1, 2004, and were not reinstated until fiscal year 2005. Of the 27 agencies included in the annual report, the three agencies with the greatest number of violations were the Departments of the Treasury and Homeland Security and the Small Business Administration. In addition, OMB reported no unresolved violations at the end of fiscal year 2005 and only 6 violations during the first 8 months of fiscal year 2006. The 97 violations reported in fiscal year 2005 is much less than the 164 violations in fiscal year 2004 and the 223 violations in fiscal year 2003.

Although the reduction in violations is a positive trend, we should note that the violations reported may not be comprehensive; they include only those that agencies identified and reported to OMB. As a result, the statistics would omit violations of which agencies were unaware. In our May 2005 review, we examined forms posted on Web sites for four agencies (VA, HUD, Labor, and IRS). We found examples of violations among these forms of which the agencies were generally unaware. Based on our examination, we projected that the four agencies overall had an estimated 69 violations: 61 collections in use without OMB approval and 8 expired collections. For example, we estimated 16 violations at VA; at that time, OMB’s report reflected VA’s belief that it had no violations. Based on these results, we recommended that the four agencies periodically review their Web sites to ensure that all forms comply with PRA requirements; we also recommended that OMB alter its guidance so that all federal agencies would be required to periodically review Web sites in this way. Since then, VA has reported to us that it removed forms from its Web site that were in violation of PRA. However, OMB has not yet issued governmentwide guidance directing these types of reviews, so it is possible that some PRA violations remain undetected.

Agency Processes for Reviewing Information Collections Were Not Effective

Among the PRA provisions intended to help achieve the goals of minimizing burden while maximizing utility are the requirements for CIO review and certification of information collections. The 1995 amendments required agencies to establish centralized processes for reviewing proposed information collections within the CIO’s office. Among other things, the CIO’s office is to certify, for each collection, that the 10 standards in the act have been met, and the CIO is to provide a record supporting these certifications.

The four agencies that we reviewed for our May 2005 report all had written directives that implemented the review requirements in the act, including the requirement for CIOs to certify that the 10 standards in the act were met. However, in the 12 case studies that we reviewed, this CIO certification occurred despite a lack of rigorous support that all standards were met. Specifically, the support for certification was missing or partial on 65 percent (66 of 101) of the certifications. Table 4 shows the result of our analysis of the case studies.

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

This assertion provides no information on what efforts were made to identify duplication or perspective on why similar information, if any, could not be used. Further, the files contained no evidence that the CIO reviewers challenged the adequacy of this support or provided support of their own to justify their certification.

A second standard mandated by the act is that each information collection should reduce burden on the public, including small entities, to the extent practicable and appropriate. OMB guidance emphasizes that agencies are to demonstrate that they have taken every reasonable step to ensure that a given collection of information is the least burdensome necessary for the proper performance of agency functions. In addition, OMB instructions and guidance direct agencies to provide specific information and justifications: (1) estimates of the hour and cost burden of the collections and (2) justifications for any collection that requires respondents to report more often than quarterly, respond in fewer than 30 days, or provide more than an original and two copies of documentation.

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 and OMB guidance give various techniques for reducing burden on these small entities.

Our review of the case examples found that for the certification on reducing burden on the public, the files generally contained the specific information and justifications called for in the guidance. However, none of the case examples contained support that addressed how the agency ensured that the collection was the least burdensome necessary. According to agency CIO officials, the primary cause for this absence of support is that OMB instructions and guidance do not direct agencies to provide this information explicitly as part of the approval package.

In addition, four of our case studies did not provide complete information that would support certification that the collection specifically addressed reducing burden for small entities. Specifically, 7 of the 12 case studies involved collections that were reported to impact businesses or other for-profit entities, but the files for 4 of these 7 did not explain either ● why small businesses were not affected, or ● even though such businesses were affected, that burden could or could not be reduced.

Instead, the files included statements such as “not applicable,” which do not inform the reviewer whether or not there was an effort made to reduce burden on small entities. When we asked agencies about these four cases, they indicated that the collections did, in fact, affect small business.

OMB’s instructions to agencies on minimizing burden on small entities require agencies to describe any methods used to reduce burden only if the collection of information has a “significant economic impact on a substantial number of small entities.” This does not appropriately reflect the act’s requirements concerning small business: the act requires that the CIO certify that the information collection reduces burden on small entities in general, to the extent practical and appropriate, and provides no thresholds for the level of economic impact or the number of small entities affected. OMB officials acknowledged that their instruction is an “artifact” from a previous form and more properly focuses on rulemaking rather than on the information collection process.

The lack of support for the 10 certifications required by the act appeared to be influenced by a variety of factors. In some cases, as described above, OMB guidance and instructions were not comprehensive or entirely accurate. In the case of the duplication standard specifically, IRS officials said that the agency did not need to further justify that its collections are not duplicative because (1) tax data are not collected by other agencies, so there is no need for the agency to contact them about proposed collections, and (2) IRS has an effective internal process for coordinating proposed forms among the agency’s various organizations that may have similar information. Nonetheless, the law and instructions require support for these assertions, which was not provided.

Further, agency reviewers told us that management assigns a relatively low priority and few resources to reviewing information collections. Further, program offices have little knowledge of and appreciation for the requirements of the PRA. As a result of these conditions and a lack of detailed program knowledge, reviewers often have insufficient leverage with program offices to encourage them to improve their justifications.

When support for the PRA certifications is missing or inadequate, OMB, the agency, and the public have reduced assurance that the standards in the act, such as those on avoiding duplication and minimizing burden, have been consistently met.

Two Agencies Have Developed Processes to Reduce Burden Associated with Information Collections

IRS and EPA have supplemented the standard PRA review process with additional processes aimed at reducing the burden while maximizing the public benefit and utility of the information collected. These agencies’ missions require them both to deal extensively with information collections, and their management has made reduction of burden a priority.

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 limitations; and ● 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, 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.

According to IRS, this targeted, resource-intensive process has achieved significant reductions in burden. For example, it reported that about 95 million hours of taxpayer burden were reduced through increases in the income reporting threshold on various IRS schedules. Another example, mentioned earlier, was given in OMB’s latest annual PRA report: in January 2006 IRS completed an initiative to simplify the process of applying for an extension to file an income tax return, which is associated with a burden reduction of 8 million hours. Another example from the annual PRA report is a reduction of about 19 million hours from a redesign of IRS form 1041 to streamline the requirements and make it easier to read and file.

Similarly, EPA officials stated that they have established processes for reviewing information collections that supplement the standard PRA review process. These processes are highly detailed and evaluative, with a focus on burden reduction, avoiding duplication, and ensuring compliance with PRA. According to EPA officials, the impetus for establishing these processes was the high visibility of the agency’s information collections and the recognition, among other things, that the success of EPA’s enforcement mission depended on information collections being properly justified and approved: in the words of one official, information collections are the “life blood” of the agency.

According to these officials, the CIO staff are not generally closely involved in burden reduction initiatives, because they do not have sufficient technical program expertise and cannot devote the extensive time required. 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 reported that it amended its regulations to reduce the paperwork burden imposed under the Resource Conservation and Recovery Act. One burden reduction method EPA used was to establish higher thresholds for small businesses to report information required under the act. EPA estimated that the initiative will reduce burden by 350,000 hours and save $22 million annually. Another example is an ongoing EPA initiative reported in this year’s PRA report, the Central Data Exchange; this is an e-government initiative that is designed to enable fast, efficient, and more accurate environmental data submissions and exchange from state and local governments, industry, and tribes through the use of electronic reporting procedures. The estimated reduction for this initiative, which is expected to be complete in 2008, is 166,000 hours.

Overall, EPA and IRS reported that they have produced significant reductions in paperwork burden by making a commitment to this goal and dedicating resources to it. In contrast, for the 12 information collections we examined, the CIO review process resulted in no reduction in burden. Further, the Department of Labor reported that its PRA reviews of 175 proposed collections 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 the paperwork burden.

Agencies Could Strengthen PRA Review and Try Alternative Approaches to Reducing Burden

In our 2005 report, we concluded that the CIO review process was not working as Congress intended: It did not result in a rigorous examination of the burden imposed by information collections, and it did not lead to reductions in burden. In light of these findings, we suggested options that Congress might want to consider when it next reauthorizes the act, including mandating pilot projects to test and review alternative approaches to achieving PRA goals. Such pilot projects could build on the lessons learned at IRS and EPA, which have used a variety of approaches to reducing burden, sharing information (for example, by facilitating cross-agency information exchanges), standardizing data for multiple uses, and integrating data to avoid duplication; and re-engineering work flows. Pilot projects would be most appropriate for agencies for which information collections are a significant aspect of the mission.

In addition, we recommended (among other things) that agencies strengthen the support provided for CIO certifications and that OMB update its guidance to clarify and emphasize this requirement (including that agencies provide support showing that they have taken steps to reduce burden, determined whether small entities are affected and reduced reporting burden on them, and established a plan to manage and use the information to be collected, including the identification of necessary resources). OMB and the agencies agreed with most of the recommendations, although they disagreed with aspects of GAO’s characterization of agencies’ compliance with the act’s requirements.

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 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 has updated parts of its guidance and plans to incorporate other guidance into an automated system to be used by agencies submitting information collections for clearance. In January 2006, OMB revised its guidance to agencies on surveys and statistical information collections. This guidance, among other things, is aimed at strengthening the support that agencies must provide for certifying collections, as we recommended. For example, the guidance requires agencies submitting requests for approval to include context and detail that will allow OMB to evaluate the practical utility of the information to be collected. However, this guidance does not apply to all information collections. Rather, it applies only to surveys that are used for general-purpose statistics or as part of program evaluations or research studies. In addition, it does not provide clear guidance on one of the topics mentioned in our recommendation: determining whether small entities are affected by the collection and reducing reporting burden on these entities.

OMB also reported that its guidance to agencies will be updated through a planned automated system that is to begin operating this month. According to the former acting head of OMB’s Office of Information and Regulatory Affairs, the new system will permit agencies to submit clearance requests electronically, and the instructions will provide clear guidance on the requirements for these submissions, including the support required. This official stated that OMB has worked with agency representatives with direct knowledge of the PRA clearance process in order to ensure that the system and its instructions clearly reflect the requirements of the process. If this system is implemented as described and OMB withholds clearance from submissions that lack adequate support, it could lead agencies to strengthen the support provided for their certifications.

In conclusion, Madam Chairman, the PRA puts in place mechanisms to focus agency attention on the need to minimize the burden that information collections impose—while maximizing the public benefit and utility of government information collections—but these mechanisms have not succeeded in achieving the ambitious reduction goals set forth in the 1995 amendments. Achieving real reductions in the paperwork burden is an elusive goal, as attested by years of OMB’s annual PRA reports, including the latest. That report shows the largest rise in estimated burden for the last several years, mostly due to new statutory requirements and how they have been implemented. As we have seen, the tendency is for burden to rise unless agencies take active steps to reduce it. Agencies have taken such actions—by cutting redundancy, changing forms, and using information technology, among other things—but these have not been enough to make up for the increases.

Besides demonstrating once again how challenging it is for the government to achieve true burden reduction, this year’s results highlight the need to look for new ways to achieve this and the other goals of the PRA. Among the mechanisms already in place is the CIO review and certification process. However, as it was implemented at the time of our review, this process had limited effect on the quality of support provided for information collections, and it appeared to have no appreciable impact on burden.

The targeted approaches to burden reduction used by IRS and EPA appear promising, but the experience of these agencies suggests that success requires top-level executive commitment, extensive involvement of program office staff with appropriate expertise, and aggressive outreach to stakeholders. However, such an approach would probably also be more resource-intensive than the CIO certification process, and thus it may not be warranted at agencies where paperwork issues do not rise to the level of those at IRS and similar agencies. Consequently, it is critical that efforts to expand the use of the IRS and EPA models take these factors into consideration.

Madam Chairman, this completes my prepared statement. I would be pleased to answer any questions.

Contacts and Acknowledgments

For future information regarding this testimony, please contact Linda Koontz, Director, Information Management, at (202) 512-6420, or koontzl@gao.gov. Other individuals who made key contributions to this testimony were Barbara Collier, Nancy Glover, and Alan Stapleton.

Attachment 1. Related GAO Products

Paperwork Reduction Act: New Approaches Can Strengthen Information Collection and Reduce Burden. GAO-06-477T. Washington, D.C.: March 8, 2006.

Paperwork Reduction Act: Subcommittee Questions Concerning the Act’s Information Collection Provisions. GAO-05-909R. Washington, D.C.: July 19, 2005.

Paperwork Reduction Act: Burden Reduction May Require a New Approach. GAO-05-778T. Washington, D.C.: June 14, 2005.

Paperwork Reduction Act: New Approach May Be Needed to Reduce Government Burden on Public. GAO-05-424. Washington, D.C.: May 20, 2005.

Paperwork Reduction Act: Agencies’ Paperwork Burden Estimates Due to Federal Actions Continue to Increase. GAO-04-676T. Washington, D.C.: April 20, 2004.

Paperwork Reduction Act: Record Increase in Agencies’ Burden Estimates. GAO-03-619T. Washington, D.C.: April 11, 2003.

Paperwork Reduction Act: Changes Needed to Annual Report. 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.

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