Agencies of the U.S. government collect a wide variety of information from many sources to carry out their missions. As we mentioned earlier, the IRS collects information from individuals and their employers to calculate the correct amount of taxes owed. The Census Bureau collects information through the decennial census and other surveys that is used to reapportion congressional representation, calculate federal funding formulas, and for other purposes. Regulatory agencies, such as EPA, collect information to ensure compliance with regulations, to evaluate the effectiveness of programs, to determine eligibility for program benefits, and for other purposes. While such information collection activities are important for the fulfillment of agency missions, they can impose significant burdens on the individuals, businesses, not-for-profit organizations, and other entities that are called upon to produce the information for the federal government. Research, recordkeeping, and time to read instructions—all can result in the devotion of considerable time and expense. As mentioned earlier, agency estimates indicated that the public spent about 8.1 billion hours in 2003 responding to requests for information from the federal government. The federal government has long recognized the tension between the benefits and costs of information collection and the need to reduce information collection burdens. The Federal Reports Act of 1942 first established a review process whereby the Bureau of the Budget—which became OMB in 1970—determined whether the collection of information by a federal agency was necessary for the agency’s proper performance or for any other proper purpose. In 1977, the Commission on Federal Paperwork reported that notwithstanding the Federal Reports Act process, the federal paperwork burden had continued to grow and that legislative exemptions over the years had exempted as much as 80 percent of the federal paperwork burden from the 1942 act’s clearance process. The Commission recommended reform of the old paperwork clearance process, along with addressing information collection as part of a broader approach to federal information resources management (IRM). In 1980, the Congress enacted the Paperwork Reduction Act, which largely followed the Commission’s recommendations. The act supplanted the Federal Reports Act, made virtually all federal agency information collection activities subject to OMB review, and established broad objectives for OMB oversight of the management of federal information resources. To achieve these objectives, the 1980 act established the Office of Information and Regulatory Affairs (OIRA) within OMB and gave this office a variety of oversight responsibilities over federal information functions, including general information policy, reduction of paperwork burden, federal statistical policy, records management, information privacy, disclosure and security, and the acquisition and use of information technology (then described as automatic data processing and telecommunications functions). The Paperwork Reduction Act of 1980 had three major purposes with regard to information collection: minimize the federal paperwork burden for individuals, small businesses, state and local governments, and other persons; minimize the cost to the federal government of collecting, maintaining, using, and disseminating information; and maximize the usefulness of information collected by the federal government. To achieve these purposes, the 1980 act required that federal agencies not conduct or sponsor the collection of information unless approved by OMB. Under the law, 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 established a process whereby its OIRA desk officers review proposals by executive branch agencies, including independent regulatory agencies, to collect information from 10 or more persons, whether the collections are voluntary or mandatory. The act gave OMB 60 days to approve or disapprove any collection request. If it approves the collection, OMB assigns a control number and an expiration date, which is limited to no more than 3 years. To assist agencies in fulfilling their responsibilities under the act, OMB took various steps. It issued a regulation, and it also provided agencies with instructions on filling out a standard form for submissions and providing supporting statements. Further, it developed guidance, which, while remaining in draft, is widely used as a handbook for agencies on compliance with the law, according to OMB officials. For example, the Department of Labor cited the handbook in responding to our questions about its PRA collections. Finally, in addition to the agency and OMB clearance process, the act encouraged public participation by requiring the solicitation of public comment on proposed collections and, through its “public protection clause,” by providing that individuals could not be penalized for failing to respond to an information collection request that either does not display a valid OMB control number or does not state that the request is exempt from the act. Implementation of the Paperwork Reduction Act has not been without controversy. Congressional hearings and reports, as well as our reports, have identified issues of concern, including the following: Reduction of paperwork burdens. Despite the act’s requirements, including specific percentage paperwork reduction goals, the federal paperwork burden has not declined over the life of the act but has generally continued to increase. Regulatory review. OMB’s conduct of paperwork clearance in close alignment with its review of agency regulations under presidential executive orders has periodically raised questions about the extent to which OMB review should affect the policies and substantive requirements of agency decisions. Public participation. The ability of the public to contribute to and be informed about agency and OMB paperwork clearance decisions has been a concern of those who questioned the extent to which the process affects the substance of agency program decisions, as well as those who argued that the process has not been sensitive enough to the burdens placed on respondents. Information resources management. OMB and agencies have been criticized for inadequate attention to the other information resources management requirements of the act, ranging from overall IRM strategic planning to specific functions such as information security and the management of information technology. The Congress addressed these and other issues when reauthorizing the act in 1986 and 1995. The 1986 reauthorization included relatively minor amendments. The 1995 reauthorization, however, included significant revisions in the paperwork reduction provisions, as well as new provisions regarding information dissemination, statistical policy, and information technology management. With regard to paperwork reduction, the legislation’s drafters stated that the intention was to revise the act to make a more thorough and open agency paperwork clearance process to improve the quality of paperwork reviews and public confidence in government decision making. The 1995 amendments to the act established detailed paperwork clearance requirements for agencies before OMB review. The 1995 law required 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. For example, the instrument must explain the reasons for the collection and provide an estimate of the burden of the collection. In addition, the agency is to provide an initial 60-day notice period (in addition to the notice period that was already required after the collection is forwarded to OMB for approval) and otherwise consult with members of the public and affected agencies to solicit comments on (1) whether the proposed collection is necessary for the proper performance of the agency’s functions, (2) the accuracy of the agency’s burden estimate, (3) ways to enhance the quality, utility, and clarity of the information to be collected, and (4) ways to minimize the burden on respondents, including through the use of automated collection techniques or other forms of information technology. Finally, according to the act, the CIO must certify that each proposed collection submitted to OMB for review meets the act’s 10 standards (presented in table 1) and provide support for these certifications. Following satisfaction of these requirements, an agency may submit for OMB review its proposed collections, whether for new collections or reapproval of existing collections. The 1995 amendments, as under the original 1980 act, then rely on OMB to determine whether each agency information collection is necessary for the proper performance of the agency’s functions. While not significantly altering OMB authorities, the 1995 amendments did modify the OMB provisions: for example, they shortened the public comment period while information collection submissions are under review at OMB from 60 days to 30 days (having added the 60-day initial comment period that agencies are required to provide before they submit collections to OMB). In addition, the amendments required OMB to make its clearance decisions publicly available; they specifically addressed extensions of current collections; and they clarified procedures for review of information collections required by a regulation. Under the act as amended in 1995, and as currently required by OMB regulations and guidance, the paperwork clearance process takes place in two stages. First, as required by the act, the agency CIO must review each proposed information collection. During this review, 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 for the second stage in the clearance process. The agency submissions to OMB typically include a copy of the data collection instrument (e.g., a form or survey) and a Paperwork Reduction Act Submission (Standard Form 83-I). The 83-I requires agencies to answer questions, and provide supporting documentation, about the proposed information collection, such as 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.