Summary
Americans spend billions of hours each year providing information to federal agencies by filling out information collections (forms, surveys, or questionnaires). A major aim of the Paperwork Reduction Act (PRA) is to balance the burden of these collections with their public benefit. Under the act, agencies' Chief Information Officers (CIO) are responsible for reviewing information collections before they are submitted to the Office of Management and Budget (OMB) for approval. As part of this review, CIOs must certify that the collections meet 10 standards set forth in the act. GAO was asked to assess, among other things, this review and certification process, including agencies' efforts to consult with the public. To do this, 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.
Governmentwide, agency CIOs generally reviewed information collections and certified that they met the standards in the act. However, GAO's analysis of 12 case studies at the Internal Revenue Service (IRS) and the Departments of Veterans Affairs, Housing and Urban Development, and Labor showed that CIOs certified collections even though support was often missing or partial. For example, in nine of the case studies, agencies did not provide support, as the law requires, for the standard that the collection was developed by an office with a plan and resources to use the information effectively. Because OMB instructions do not ask explicitly for this support, agencies generally did not address it. Further, although the law requires agencies both to publish notices in the Federal Register and to otherwise consult with the public, agencies governmentwide generally limited consultation to the publication of notices, which generated little public comment. Without appropriate support and public consultation, agencies have reduced assurance that collections satisfy the standards in the act. Processes outside the PRA review process, which are more rigorous and involve greater public outreach, have been set up by IRS and the Environmental Protection Agency (EPA), whose missions involve numerous information collections and whose management is focused on minimizing burden. For example, each year, IRS subjects a few forms to highly detailed, in-depth analyses, including extensive outreach to the public affected and the information users. 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. Without rigorous evaluative processes, agencies are unlikely to achieve the PRA goal of minimizing burden while maximizing utility.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change
from "In process" to "Implemented" or "Not implemented" based on our follow up work.
Director:
Team:
Phone:
Linda D. Koontz
Government Accountability Office: Information Technology
(202) 512-6240
Matters for Congressional Consideration
Recommendation: Given the identified weaknesses in current processes and the possibility of achieving significant paperwork reduction through other initiatives, the Congress may wish to consider mandating the development of pilot projects to test and review the value of approaches such as those used by IRS and EPA. In structuring these pilots, the Congress may wish to consider requiring the Director, OMB, to issue guidance to agencies on implementing this approach, including criteria for assessing collections along the lines of the process currently employed by IRS.
Status: In process
Comments: Congress has continued to show interest in new approaches to burden reduction. After the recommendation was made, GAO testified on burden reduction approaches both on March 8, 2006, and on July 18, 2006, before the Subcommittee on Regulatory Affairs, Committee on Government Reform, House of Representatives. We will continue to monitor developments in this area.
Recommendation: Given the identified weaknesses in current processes and the possibility of achieving significant paperwork reduction through other initiatives, the Congress may wish to consider mandating the development of pilot projects to test and review the value of approaches such as those used by IRS and EPA. In structuring these pilots, the Congress may wish to consider requiring agencies participating in pilots to 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.
Status: In process
Comments: Congress has continued to show interest in new approaches to burden reduction. After the recommendation was made, GAO testified on burden reduction approaches both on March 8, 2006, and on July 18, 2006, before the Subcommittee on Regulatory Affairs, Committee on Government Reform, House of Representatives. We will continue to monitor developments in this area.
Recommendation: In addition, in view of the few comments these notices elicit, the Congress may wish to consider eliminating the requirement to publish the initial 60-day notice in the Federal Register requesting public comments on proposed collections.
Status: In process
Comments: Congress has continued to show interest in new approaches to streamlining and burden reduction. After the recommendation was made, GAO testified on burden reduction approaches on both March 8, 2006, and on July 18, 2006, before the Subcommittee on Regulatory Affairs, Committee on Government Reform, House of Representatives. We will continue to monitor developments in this area.
Recommendations for Executive Action
Recommendation: The Director, OMB, should alter its current guidance to all federal agencies to emphasize the importance of information collection requirements and the need for management support.
Agency Affected: Executive Office of the President: Office of Management and Budget
Status: In process
Comments: On January 20, 2006, OMB updated parts of its guidance to agencies on surveys and statistical collections and plans to incorporate other guidance into an automated system to be used by agencies submitting information collections for clearance. The guidance is aimed at strengthening the support that agencies must provide for certifying collections, as we recommended. For example, it 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.
Recommendation: The Director, OMB, should alter its current guidance to all federal agencies to clarify the kinds of support it asks agency CIOs to provide for certifications, including that agencies have taken steps to (1) reduce burden on those providing the information, (2) determine whether small entities are affected by the collection and to reduce reporting burden on these entities, and (3) establish a plan for the management and use of information to be collected and identify necessary resources.
Agency Affected: Executive Office of the President: Office of Management and Budget
Status: In process
Comments: On Jan. 20, 2006, OMB updated parts of its guidance to agencies on surveys and statistical collections and plans to incorporate other guidance into an automated system to be used by agencies submitting information collections for clearance. The guidance is aimed at strengthening the support that agencies must provide for certifying collections, as we recommended. For example, it 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 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 reported burden on such entities.
Recommendation: The Director, OMB, should alter its current guidance to all federal agencies to direct agencies to consult with potential respondents beyond the publication of Federal Register notices.
Agency Affected: Executive Office of the President: Office of Management and Budget
Status: In process
Comments: OMB disagreed with this recommendation, stating that it interprets publication in the Federal Register as the principal means of agency consultation with the public, with PRA notices on forms providing an opportunity for further public input. OMB believes that additional consulting should occur on those collections that are particularly important. However, GAO continues to believe that the language of the act clearly requires consultation to occur on every collection.
Recommendation: The Director, OMB, should alter its current guidance to all federal agencies to require agencies to periodically review Web sites to (1) identify any forms that may not have been approved by OMB and (2) ensure that all approved forms include required information.
Agency Affected: Executive Office of the President: Office of Management and Budget
Status: In process
Comments: No substantive action on this recommendation has been taken to date.
Recommendation: To help ensure that program office staff, as well as CIO staff, is fully aware of the requirements and importance of the information process, the Director, OMB, should make the revised guidance available to all agency personnel.
Agency Affected: Executive Office of the President: Office of Management and Budget
Status: In process
Comments: No substantive action on this recommendation has been taken to date.
Recommendation: The Secretaries of Housing and Urban Development, Labor, the Treasury, and Veterans Affairs should direct responsible CIOs to strengthen agency support for CIO certifications, including with regard to the necessity of collection, burden reduction efforts, and plans for the use of information collected.
Agency Affected: Department of Housing and Urban Development
Status: Implemented
Comments: HUD established a "PRA Compliance Officer" in each major program office and raised the level of authority within program offices for approving information requests to be sent to the CIO.
Agency Affected: Department of Labor
Status: In process
Comments: In 2006, Labor reported that it planned to strengthen CIO certifications by creating an addendum to the OMB Form 83-I, used to submit information collection requests (ICR), that would provide guidance to ensure that ICRs contained strong support for the necessity of a collection, burden reduction efforts, and plans for the use of information collected. However, Labor did not create this addendum, stating in 2007 that it was deferring to OMB as the overall manager of the PRA process on how to address the recommendation. Since the recommendation was made, OMB has launched the ICR module of ROCIS (OMB's RISC and OIRA Consolidated Information System), which, among other things, provides an automated, more robust replacement for OMB Form 83-I. According to Labor, it is following OMB's direction for preparing and submitting ICRs to OMB through ROCIS.
Agency Affected: Department of the Treasury
Status: In process
Comments: The Treasury CIO reported that it established an Information Management Sub-Council, and that it added resources to the review process.
Agency Affected: Department of Veterans Affairs
Status: In process
Comments: On July 10, 2006, the department reported that new agency information collection requests were routed through the Office of Information and Technology and consultations with OMB on any questions about the proposed collections are encouraged. In addition, according to VA's 2007 budget submission, the department obtained additional resources to help review and analyze its information collections.
Recommendation: The Secretaries of Housing and Urban Development, Labor, the Treasury, and Veterans Affairs should direct responsible CIOs to ensure that consultation with potential respondents occurs beyond the publication of Federal Register notices.
Agency Affected: Department of Housing and Urban Development
Status: In process
Comments: HUD stated that while it agreed that consultation with potential respondents is beneficial and would make every effort to broaden such consultations, officials believed that extending efforts to engage program participants beyond the Federal Register notices was not practical in every instance. According to HUD, less significant collections, such as simple renewals, do not warrant the expenditure of resources required to initiate such consultations.
Agency Affected: Department of Labor
Status: In process
Comments: The department reports that such consultation efforts are not practical for routine extensions of collections.
Agency Affected: Department of the Treasury
Status: In process
Comments: No action has been taken to date.
Agency Affected: Department of Veterans Affairs
Status: In process
Comments: On July 10, 2006, the department reported that the Veterans Health Administration has increased public consultation by adding focus group testing for the yearly Survey of Veteran Enrollee Health Reliance.
Recommendation: The Secretaries of Housing and Urban Development, Labor, the Treasury, and Veterans Affairs should direct responsible CIOs to remove all forms from agency Web sites that have not been approved by OMB until such approval is obtained.
Agency Affected: Department of Housing and Urban Development
Status: Implemented
Comments: HUD removed the forms, began requiring better coordination between the staff running HUD's Web site and the CIO when posting forms to the site, and began improved monitoring of the Web site.
Agency Affected: Department of Labor
Status: Implemented
Comments: Labor has removed all public use forms from its Web sites that were not approved by OMB and is conducting an audit to ensure all forms display a valid OMB number.
Agency Affected: Department of the Treasury
Status: In process
Comments: No action has been taken to date.
Agency Affected: Department of Veterans Affairs
Status: Implemented
Comments: On July 10, 2006, the department reported that it removed all forms from its Web site that had no OMB approval.
Recommendation: The Secretaries of Housing and Urban Development, Labor, the Treasury, and Veterans Affairs should direct responsible CIOs to add required information to all forms on Web sites that we identified as lacking this information.
Agency Affected: Department of Housing and Urban Development
Status: Implemented
Comments: On July 14, 2006, the department reports that it has added all required information to its forms as we recommended.
Agency Affected: Department of Labor
Status: Implemented
Comments: The Department of Labor added the required information to all public use forms on its Web sites that were identified as lacking information required by the Paperwork Reduction Act. In addition, it has centralized the management of its Web sites within the Office of Public Affairs, plans to annually audit its agencies' Web sites to ensure that all forms display a currently valid OMB control number and other required information, is amending its policies to require that all discontinued forms be removed from the Web site within five business days and is developing a checklist of required PRA information to assure it is clearly displayed on forms.
Agency Affected: Department of the Treasury
Status: In process
Comments: No action has been taken to date.
Agency Affected: Department of Veterans Affairs
Status: In process
Comments: There has been no action taken on this recommendation.
Recommendation: The Secretaries of Housing and Urban Development, Labor, the Treasury, and Veterans Affairs should direct responsible CIOs to improve oversight by periodically reviewing the Web sites of agencies and their agents to ensure that all forms are approved and contain information required by PRA.
Agency Affected: Department of Housing and Urban Development
Status: Implemented
Comments: HUD has implemented a review of the department's Web site that will ensure that only currently approved forms are posted. Also, HUD program staff were sent to OMB training on the Paperwork Reduction Act and additional training has been developed internally for program support staff.
Agency Affected: Department of Labor
Status: Implemented
Comments: Labor's CIO is conducting an audit to ensure that all forms on its Web sites display a valid OMB control number.
Agency Affected: Department of the Treasury
Status: In process
Comments: No action has been taken to date.
Agency Affected: Department of Veterans Affairs
Status: In process
Comments: The department reported that the Veterans Health Administration has begun new procedures for review of Web surveys to ensure that they are in compliance with the Paperwork Reduction Act.
