Summary

GAO commented on the "Proposed Office of Management and Budget (OMB) Procedures and Guidance on Implementing the Government Paperwork Elimination Act."

GAO noted that: (1) GAO supports the stated goals of the draft guidance and appreciates the difficulties in developing practical guidance for agency managers to implement these goals; (2) GAO concurs with OMB's approach of determining the internal controls based on a risk assessment; (3) however, GAO believes that additional guidance is needed to help the agencies determine the risk assessment methodology; and (4) specifically, GAO suggests that OMB: (a) require a quantitative as well as a qualitative risk analysis as part of any risk assessment process; and (b) provide additional information to help agencies properly consider the implications that historic weaknesses in agency internal controls have had on data integrity during the risk assessment process.