Paperwork Reduction Act: New Approaches Can Strengthen		 
Information Collection and Reduce Burden (08-MAR-06,		 
GAO-06-477T).							 
                                                                 
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.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-477T					        
    ACCNO:   A48578						        
  TITLE:     Paperwork Reduction Act: New Approaches Can Strengthen   
Information Collection and Reduce Burden			 
     DATE:   03/08/2006 
  SUBJECT:   Chief information officers 			 
	     Data collection					 
	     Federal law					 
	     Federal regulations				 
	     Forms						 
	     Government information				 
	     Information resources management			 
	     Noncompliance					 
	     Paperwork reduction				 
	     Regulatory agencies				 
	     Standards						 
	     Surveys						 

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GAO-06-477T

     

     * Results in Brief
     * Background
     * Agency Processes for Reviewing Information Collections Were Not
       Effective
          * Support for Certifications Was Often Missing or Partial, Despite
            CIO Reviews
          * Two Agencies Have Developed Processes to Reduce Burden Associated
            with Information Collections
          * Agencies Could Strengthen CIO Review
     * According to PRA Experts, the Current Approach to Paperwork Reduction
       Could Be Improved
     * Our Work Suggests Ways to Explore New Approaches
     * Contacts and Acknowledgments
     * Attachment1. Forum: The Legislative Framework for Information
       Resources Management
          * Other in Attendance
     * Related GAO Products
     * PDF6-Ordering Information.pdf
          * Order by Mail or Phone

Madam Chairman and Members of the Subcommittee:

I am pleased to be here today to discuss the Paperwork Reduction Act (PRA)
and federal information collections.1 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.2 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.3 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 1 1/2 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.)

1 The Paperwork Reduction Act was originally enacted into law in 1980
(Pub. L. 96-511, Dec. 11, 1980). It was reauthorized with minor amendments
in 1986 (Pub. L. 99-591, Oct. 30, 1986) and was reauthorized a second time
with more significant amendments in 1995 (Pub. L. 104-13, May 22, 1995).

2 Such collections may have a range of purposes: applications for
government benefits, program evaluation, general purpose statistics,
audit, program planning or management, research and regulatory or
compliance all of which may occur in a variety of forms, including
questionnaires and telephone surveys.

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

In reviewing our previous work, we focused particularly on our May 2005
report and a subsequent June testimony.4 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.5 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.

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

5 Although IRS accounted for about 80 percent of burden, it did not
account for 80 percent of collections: it accounted for 808 out of the
total 8,211 collections governmentwide as of May 2004.

All work on which this testimony is based was conducted in accordance with
generally accepted government auditing standards.

                                Results in Brief

Among the PRA provisions aimed at the goal of minimizing burden while
maximizing utility is the requirement for CIO review and certification of
information collections. Governmentwide, agency CIOs generally reviewed
information collections before they were submitted to OMB and certified
that the required standards in the act were met. However, our 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 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 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
have reduced assurance that the standards in the act-such as avoiding
duplication and minimizing burden-were consistently met. 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. OMB and the agencies report
making plans and taking steps to address GAO's recommendations.

In relation to information collections, IRS and EPA have developed and
used additional evaluative processes that focus specifically on reducing
burden. These processes are targeted, resource-intensive efforts that
involved extensive outreach to stakeholders. According to these agencies,
their processes led to significant reductions in burden on the public
while maximizing the utility of the information collections. In contrast,
for the 12 case studies, the CIO review process did not reduce burden.

When it considers PRA reauthorization, the Congress should consider some
new approaches, including alternatives suggested by the expert forum and
by our findings. Forum participants developed several suggestions
regarding the review of information collections. For example, they
suggested that OMB should focus on broad oversight rather than on reviews
of each individual collection; they described this approach as a "retail"
process that appeared to have become "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. We too observed that
publishing two notices in the Federal Register seemed to be ineffective,
as they elicited very little public comment; we suggested eliminating one
of them. In addition, we 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.

                                   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 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.6 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 CIO7) 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.8 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.

6 44 U.S.C. 3508.

7 The 1995 amendments used the 1980 act's reference to the agency "senior
official" responsible for implementation of the act. A year later,
Congress gave that official the title of agency Chief Information Officer
(the Information Technology Management Reform Act, Pub. L. 104-106, Feb.
10, 1996, which was subsequently renamed the Clinger-Cohen Act, Pub. L.
104-208, Sept. 30, 1996).

8 44 U.S.C. 3506(c)(1)(A).

Table 1: Standards for Information Collections Set by the Paperwork
Reduction Act

Standards                                                                  
The collection is necessary for the proper performance of agency           
functions.                                                                 
The collection avoids unnecessary duplication.                             
The collection reduces burden on the public, including small entities, to  
the extent practicable and appropriate.                                    
The collection uses plain, coherent, and unambiguous language that is      
understandable to respondents.                                             
The collection will be consistent and compatible with respondents' current 
reporting and recordkeeping practices to the maximum extent practicable.   
The collection indicates the retention period for any recordkeeping        
requirements for respondents.                                              
The collection informs respondents of the reasons the information is       
collected; the way it is used; an estimate of the burden; whether          
responses are voluntary, required to obtain a benefit, or mandatory; and   
the fact that no person is required to respond unless a valid OMB control  
number is displayed.                                                       
The collection was developed by an office that has planned and allocated   
resources for the efficient and effective management and use of the        
information to be collected.                                               
The collection uses effective and efficient statistical survey methodology 
(if applicable).                                                           
The collection uses information technology to the maximum extent           
practicable to reduce burden and improve data quality, agency efficiency,  
and responsiveness to the public.                                          

Source: Paperwork Reduction Act, Pub. L. 104-13, 109 Stat. 173-4, sec.
3506(c)(3).

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
hours9-about 2.5 billion hours more than the estimate of 7.971 billion
hours at the end of fiscal year 2004.10

Over the years, we have reported on the implementation of PRA many
times.11 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.

9 Some of this increase may have arisen because IRS adopted a new
technique for estimating burden. As the IRS accounts for about 80 percent
of burden, as mentioned earlier, any change in IRS estimates has a major
impact on governmentwide totals. The IRS previously changed its formula
for calculating burden hours in 1989. At that time, the change resulted in
major increases: the agency's paperwork burden estimate increased by 3.4
billion hours, and the governmentwide burden-hour estimate nearly tripled.

10 The 7.971 billion hours as of the end of fiscal year 2004 was a slight
decrease (1.6 percent) from the previous year-end estimate of about 8.099
billion.

11We have included a list of related GAO products at the end of this
statement.

Agency Processes for Reviewing Information Collections Were Not Effective

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.

Support for Certifications Was Often Missing or Partial, Despite CIO Reviews

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.12 Table 4 shows the result of
our analysis of the case studies.

12 The total number of certifications does not total 120 (12 cases times
10 standards) because some standards did not apply to some cases.

Table 2: Support Provided by Agencies for Paperwork Reduction Act
Standards in 12 Case Studies

                                                  Support provided 
Standards                               Totala              Yes Partial No 
The collection is necessary for the         12                6       6  0 
proper performance of agency functions.                                 
The collection avoids unnecessary           11                2       2  7 
duplication.                                                            
The collection reduces burden on the        12                5       7  0 
public, including small entities, to                                    
the extent practicable and appropriate.                                 
The collection uses plain, coherent,        12                1       0 11 
and unambiguous language that is                                        
understandable to respondents.                                          
The collection will be consistent and       12                3       0  9 
compatible with respondents' current                                    
reporting and recordkeeping practices                                   
to the maximum extent practicable.                                      
The collection indicates the retention       6                3       3  0 
period for any recordkeeping                                            
requirements for respondents.b                                          
The collection informs respondents of       12                4       8  0 
the reasons the information is                                          
collected; the way it is used; an                                       
estimate of the burden; whether                                         
responses are voluntary, required to                                    
obtain a benefit, or mandatory; and the                                 
fact that no person is required to                                      
respond unless a valid OMB control                                      
number is displayed.b                                                   
The collection was developed by an          11                2       0  9 
office that has planned and allocated                                   
resources for the efficient and                                         
effective management and use of the                                     
information to be collected.                                            
The collection uses effective and            1                1       0  0 
efficient statistical survey                                            
methodology (if applicable).                                            
The collection uses information             12                8       4  0 
technology to the maximum extent                                        
practicable to reduce burden and                                        
improve data quality, agency                                            
efficiency, and responsiveness to the                                   
public.                                                                 
Totals                                     101               35      30 36 

Sources: Paperwork Reduction Act, GAO.

a The total number of certifications is not always 12 because not all
certifications applied to all collections.

b For these two standards, the presence on the forms of the information
indicated was categorized as support, the absence of some elements was
categorized as partial support, and the absence of all elements was
categorized as no support.

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.

In 2 of 11 cases, agencies provided the description requested; for
example:

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.

In an additional 2 cases, partial support was provided. An example is the
following, provided by Labor:

[The Employer Assistance Referral Network (EARN)] 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.

In 7 cases, moreover, support for these certifications was missing. An
example is the following statement, used on all three IRS collections:

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,13 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.

13 OMB's instructions to agencies state that a small entity may be (1) a
small business, which is deemed to be one that is independently owned and
operated and that is not dominant in its field of operation; (2) a small
organization, which is any not-for-profit enterprise that is independently
owned and operated and is not dominant in its field; or (3) a small
government jurisdiction, which is a government of a city, county, town,
township, school district, or special district with a population of less
than 50,000.

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.14 The act cites various techniques
for reducing burden on these small entities,15 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.

14 "Particularly for small businesses, paperwork burdens can force the
redirection of resources away from business activities that might
otherwise lead to new and better products and services, and to more and
better jobs. Accordingly, the Federal Government owes the public an
ongoing commitment to scrutinize its information requirements to ensure
the imposition of only those necessary for the proper performance of an
agency's functions." H. Report 104-37 (Feb. 15, 1995) p. 23.

15 These include (a) establishing different compliance or reporting
requirements or timetables for respondents with fewer available resources;
(b) clarifying, consolidating, or simplifying compliance and reporting
requirements; and (c) exempting certain respondents from coverage of all
or part of the collection.

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

           0M why small businesses were not affected or
           0M 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.

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 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.16

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

16 "IRS is committed to reducing taxpayer burden and established the
Office of Taxpayer Burden Reduction (OTBR) in January 2002 to lead its
efforts." Congressional testimony by the IRS Commissioner, April 20, 2004,
before the Subcommittee on Energy Policy, Natural Resources, and
Regulatory Affairs, House Committee on Government Reform.

           0M determining the number of taxpayers impacted;
           0M quantifying the total time and out-of-pocket savings for
           taxpayers;
           0M evaluating any adverse impact on IRS's voluntary compliance
           efforts;
           0M assessing the feasibility of the initiative, given IRS resource
           limitations; and
           0M 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.17

           The office's Director18 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:

           0M simplifying forms and publications;
           0M streamlining internal policies, processes, and procedures;
           0M promoting consideration of burden reductions in rulings,
           regulations, and laws;
           0M assisting in the development of burden reduction measurement
           methodology; and
           0M 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.19 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.20

           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.21 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 handbook22 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.23

           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.24 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.25 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.

17 In congressional testimony, the IRS Commissioner stated that OMB had
referred another agency to IRS's Office of Taxpayer Burden Reduction as an
example of a "best practice" in burden reduction in government.

18 The Director reports to the IRS Commissioner for the Small Business and
Self-Employed Division.

19 In addition, the office reports that IRS staff positions could be freed
up through its efforts to raise the reporting threshold on various tax
forms and schedules. Fewer IRS positions are needed when there are fewer
tax forms and schedules to be reviewed.

20 We did not verify the accuracy of IRS's reported burden-hour savings.
We have previously reported that the estimation model that IRS has used
for compliance burden ignored important components of burden and had
limited capabilities for analyzing the determinants of burden. See GAO,
Tax Administration: IRS Is Working to Improve Its Estimates of Compliance
Burden, GAO/GGD-00-11 (Washington, D.C.: May 22, 2000). IRS has recently
begun to introduce a revised methodology for computing burden that may
result in different estimates of burden-hour savings.

21 These officials added that in exceptional circumstances the CIO office
has had staff available to perform such projects, but generally in
collaboration with program offices.

22 EPA Office of Environmental Information, Collection Strategies
Division, ICR Handbook: EPA's Guide to Writing Information Collection
Requests Under the Paperwork Reduction Act of 1995, draft (revised March
2005).

23 We did not verify the accuracy of EPA's burden reduction estimates.

24 In our May 2005 report, we reported that agencies were only publishing
notices and performing no further consultation, and we took the position
that the PRA requires agencies both to publish a Federal Register notice
and to otherwise consult with the public. We recommended that OMB clarify
its guidance on this point and that agencies increase public consultation.
OMB, the Treasury, Labor, and HUD disagreed with our position on the
grounds that it was not a good use of agency resources to consult on every
collection; in their view, additional consultation should occur only on
those collections that are particularly important. We consider, however,
that the PRA's language is unambiguous: agencies shall "provide 60-day
notice in the Federal Register, and otherwise consult with members of the
public and affected agencies concerning each proposed collection..." Pub.
L. 104-13, 109 Stat. 173, 44 U.S.C. 3506(c)(2). We believe that agencies
should comply with current law. However, we are also concerned that public
consultation be efficient and effective; accordingly, we suggested that
pilot projects be developed to test and review alternative approaches to
achieving the PRA's goals.

Agencies Could Strengthen CIO Review

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:

           0M 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.
           0M The Treasury CIO established an Information Management
           Sub-Council under the Treasury CIO Council and added resources to
           the review process.
           0M According to the VA's 2007 budget submission, the department
           obtained additional resources to help review and analyze its
           information collection requests.
           0M 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,26 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.

25 These reviews did result in a 1.3 percent reduction in calculated
burden by correcting mathematical errors in program offices' submissions.

 According to PRA Experts, the Current Approach to Paperwork Reduction Could Be
                                    Improved

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.

26 The new system, ROCIS (the RISC/OIRA Consolidated Information System),
is operated for OMB's Office of Information and Regulatory Affairs (OIRA)
by the Regulatory Information Service Center (RISC) of the General
Services Administration.

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.

                Our Work Suggests Ways to Explore New Approaches

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

           0M sharing information-for example, by facilitating cross-agency
           information exchanges;
           0M standardizing data for multiple uses ("collect once-use
           multiple times");
           0M integrating data to avoid duplication; and
           0M 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.27 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.28 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.

27 OMB currently has this authority under PRA. As mentioned earlier, OMB
also has the authority to delegate to agencies the authority to approve
collections in various circumstances. It may choose to delegate such
authority at agencies whose pilot projects demonstrate success in reducing
burden through information management improvements of the types mentioned.

28 In certain instances, agencies may be able to get "generic clearances"
if they routinely conduct information collections using very similar
methods. For example, an agency may want to develop a generic customer
satisfaction survey that can be customized for use with different groups.
See Memorandum to the President's Management Council from the
Administrator, Office of Information and Regulatory Affairs, OMB,
"Guidance on Agency Survey and Statistical Information Collections"
(Washington, D.C.: Jan. 20, 2006).

                          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 Timothy Bober, Barbara Collier, David Plocher, Elizabeth Powell, J.
Michael Resser, and Alan Stapleton.

Attachment 1. Forum: The Legislative Framework for Information Resources
Management

                               Forum Participants

Prudence S. Adler Associate Executive Director Association of Research     
                     Libraries                                                
William Barron    Princeton University; formerly National Opinion Research 
                     Center                                                   
Gary Bass         Founder and Executive Director, OMB Watch                
Maya Bernstein    Administrative Law & Information Policy; formerly OMB    
                     and IRS Privacy Officer                                  
Daniel Chenok     Vice President, SRA International; formerly OMB          
Sharon S. Dawes   Director, Center for Technology in Government,           
                     University at Albany, State University of New York       
James Flyzik      Partner, Guerra, Kiviat, Flyzik and Associates; formerly 
                     Department of Treasury and Secret Service                
Robert M. Gellman Privacy & Information Policy Consultant; formerly        
                     counsel to the House of Representatives' Subcommittee on 
                     Information, Justice, Transportation and Agriculture     
Harry A. Hammitt  Editor of Access Reports, FOIA Journal                   
Jefferson Hill    Independent Consultant; formerly OMB                     
Sally Katzen      Professor and Independent Consultant; formerly OMB       
Andrew Langer     Manager, Regulatory Policy National Federation of        
                     Independent Business                                     
David LeDuc       Director, Public Policy, Software & Information Industry 
                     Association                                              
Herb Lin          Senior Scientist, Computer Science and                   
                     Telecommunications Board, The National Academies         
Jeffrey Lubbers   Fellow in Law and Government, American University,       
                     Washington College of Law; formerly Administrative       
                     Conference of the U.S.                                   
Charles McClure   Francis Epps Professor and Director, Information Use     
                     Management & Policy Institute, Florida State University  
David L. McClure  Research Director Gartner; formerly Council for          
                     Excellence in Government and GAO                         
Bruce McConnell   President and Founder, McConnell International; formerly 
                     OMB                                                      
Patrice McDermott Deputy Director, Office of Government Relations,         
                     American Library association                             
Michael McGill    McGill Associates and Internet2                          
Lynn McNulty      Consultant, McConnell International, LLC; formerly NIST  
Doug Robinson     Executive Director, National Association of State Chief  
                     Information Officers                                     
J. Timothy Sprehe President, Sprehe Information Management Associates      
Ari Schwartz      Associate Director, Center for Democracy and Technology  
Miron Straf       Deputy Director, Division of Behavioral and Social       
                     Sciences and Education, The National Academies           
Jeanne Young      Independent Consultant; formerly Federal Reserve Board   
                     of Governors Records Officer and NAGARA officer          

                              Others in Attendance

At the forum, others attending included GAO staff and a number of other
observers:

Donald Arbuckle   Deputy Administrator, Office of Information and          
                     Regulatory Affairs                                       
Michelle Ash      Minority Senior Legislative Counsel, House Committee on  
                     Government Reform                                        
Krista Boyd       Minority Counsel, House Committee on Government Reform   
Curtis Copeland   Congressional Research Service                           
Dan Costello      Policy Analyst, Office of Information and Regulatory     
                     Affairs                                                  
Michael Formica   Director of Energy and Environment, U.S. Chamber of      
                     Commerce                                                 
Eva Kleederman    Senior Policy Analyst, Office of Management and Budget   
Kristy Lalonde    Policy Analyst, Office of Management and Budget          
David McMillen    Minority Professional Staff Member, House Committee on   
                     Government Reform                                        
Jim Moore         Counsel, House Committee on Government Reform            
Kim Nelson        Policy Analyst, Office of Management and Budget          
Lew Oleinick      Office of Information and Regulatory Affairs             
Kenneth Peskin    U.S. Chamber of Commerce                                 
Victoria Proctor  Senior Professional Staff Member, House Committee on     
                     Government Reform                                        
Edward Schrock    House Committee on Government Reform                     
Katherine Wallman 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.

Related GAO Products

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.

(310753)

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United States Government Accountability Office

GAO

Testimony

Before the Subcommittee on Regulatory Affairs, Committee on Government
Reform, House of Representatives

For Release on Delivery

Expected at 2:00 p.m. EST Wednesday, March 8, 2006

PAPERWORK REDUCTION ACT

New Approaches Can Strengthen Information Collection and Reduce Burden

Statement of Linda D. Koontz, Director

Information Management

GAO-06-477T

www.gao.gov/cgi-bin/getrpt? GAO-06-477T .

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Linda Koontz at (202) 512-6240 or
[email protected].

Highlights of GAO-06-477T , a report to the Subcommittee on Regulatory
Affairs, Committee on Government Reform, House of Representatives

March 8, 2006

PAPERWORK REDUCTION ACT

New Approaches Can Strengthen Information Collection and Reduce Burden

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.

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.

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