Federal Information Collection: A Reexamination of the Portfolio 
of Major Federal Household Surveys Is Needed (15-NOV-06,	 
GAO-07-62).							 
                                                                 
Federal statistical information is used to make appropriate	 
decisions about budgets, employment, and investments. GAO was	 
asked to (1) describe selected characteristics of federally	 
funded statistical or research surveys, (2) describe agencies'	 
and Office of Management and Budget's (OMB) roles in identifying 
and preventing unnecessary duplication, (3) examine selected	 
surveys to assess whether unnecessary duplication exists in areas
with similar subject matter, and (4) describe selected agencies' 
efforts to improve the efficiency and relevance of surveys. GAO  
reviewed agency documents and interviewed officials. Using this  
information and prior GAO work, GAO identified surveys with	 
potential unnecessary duplication.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-62						        
    ACCNO:   A63387						        
  TITLE:     Federal Information Collection: A Reexamination of the   
Portfolio of Major Federal Household Surveys Is Needed		 
     DATE:   11/15/2006 
  SUBJECT:   Census						 
	     Data collection					 
	     Government information				 
	     Policy evaluation					 
	     Standards						 
	     Standards evaluation				 
	     Statistical data					 
	     Statistical methods				 
	     Strategic planning 				 
	     Surveys						 
	     Duplication of effort				 
	     Policies and procedures				 
	     Census Bureau American Community Survey		 
	     Dept. of Commerce American Housing 		 
	     Survey						 
                                                                 

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GAO-07-62

                 United States Government Accountability Office

Report to Congressional Requesters

GAO

November 2006

FEDERAL INFORMATION COLLECTION

 A Reexamination of the Portfolio of Major Federal Household Surveys Is Needed

GAO-07-62

FEDERAL INFORMATION COLLECTION

A Reexamination of the Portfolio of Major Federal Household Surveys Is
Needed

  What GAO Found

At the time of GAO's review, the Office of Management and Budget (OMB) had
approved 584 ongoing federal statistical or research surveys, of which 40
percent were administered to individuals and households. Under the
Paperwork Reduction Act, agencies are to certify to OMB that each
information collection does not unnecessarily duplicate existing
information, and OMB is responsible for reviewing the content of agencies'
submissions. OMB provides guidance that agencies can use to comply with
the approval process and avoid unnecessary duplication, which OMB defines
as information similar to or corresponding to information that could serve
the agency's purpose and is already accessible to the agency.

Based on this definition, the seven surveys GAO reviewed could be
considered to contain necessary duplication. GAO identified three subject
areas, people without health insurance, people with disabilities, and
housing, covered in multiple major surveys that could potentially involve
unnecessary duplication. Although they have similarities, most of these
surveys originated over several decades, and differ in their purposes,
methodologies, definitions, and measurement techniques. These differences
can produce widely varying estimates on similar subjects. For example, the
estimate for people who were uninsured for a full year from one survey is
over 50 percent higher than another survey's estimate for the same year.
While agencies have undertaken efforts to standardize definitions and
explain some of the differences among estimates, these issues continue to
present challenges. In some cases, agencies have reexamined their existing
surveys to reprioritize, redesign, combine, and eliminate some of them.
Agencies have also used administrative data in conjunction with their
surveys to enhance the quality of information and limit respondent burden.
These actions have been limited in scope, however. In addition, two major
changes to the portfolio of major federal household surveys are underway.
The American Community Survey is intended to replace the long-form
decennial census starting in 2010. This is considered to be the
cornerstone of the government's efforts to provide data on population and
housing characteristics and will be used to distribute billions of dollars
in federal funding. Officials are also redesigning the Survey of Income
and Program Participation which is used in estimating future costs of
certain government benefit programs.

In light of these upcoming changes, OMB recognizes that the federal
government can build upon agencies' practices of reexamining individual
surveys. To ensure that surveys initiated under conditions, priorities,
and approaches that existed decades ago are able to cost-effectively meet
current and emerging information needs, there is a need to undertake a
comprehensive reexamination of the long standing portfolio of major
federal household surveys. The Interagency Council on Statistical Policy
(ICSP), which is chaired by OMB and made up of the heads of the major
statistical agencies, is responsible for coordinating statistical work and
has the leadership authority to undertake this effort.

United States Government Accountability Office

                                    Contents

                                                                            1
Results in Brief                                                         5 
Background                                                               7 
More Than 500 Statistical or Research Surveys Have Been                    
Approved                                                                10 
Agencies and OMB Have Procedures Intended to Identify and                  
Prevent Unnecessary Duplication                                         17 
Duplicative Content in Selected Surveys Exists, but Survey                 
Purposes and Scope Differ                                               20 
Agencies Have Undertaken Efforts to Improve the Efficiency and             
Relevance of Surveys                                                    30 
Conclusions                                                             33 
Recommendation for Executive Action                                     34 
Agency Comments                                                         35 

Table 1: Selected Surveys That Cover Similar Content in Three        
Subject Areas                                                            4 
Table 2: Characteristics of Selected Research and Statistical              
Surveys                                                                 14 
Table 3: Uninsured Estimates from Selected Surveys                      23 
Table 4: Estimated Population of Persons with Disabilities, by Data        
              Source and Different Categories of Disability                26 

                                     Letter

                                     Tables

Figures                                                                 
                  Figure 1: Primary Purpose of OMB-approved Information    
            Collections                                                    11 
            Figure 2: Respondents to OMB-approved Statistical and Research    
            Surveys                                                        12 
              Figure 3: Burden Hour Ranges of the 584 Research and General    
                              Purpose Statistics Surveys                   13 

    Washington, DC 20548

November 15, 2006

The Honorable Tom Davis
Chairman, Committee on Government Reform
House of Representatives

The Honorable Michael R. Turner
Chairman, Subcommittee on Federalism and the Census
Committee on Government Reform
House of Representatives

Governments, businesses, and citizens depend on relevant and timely
statistical information from federal statistics to make appropriate
decisions about budgets, employment, investments, and many other essential
topics. Given the importance of federally funded surveys to the quality of
statistical information, and the ever-increasing demand for more and
better information within limited resources, it is essential to maximize
their utility. To this end, officials implementing federally funded
surveys must avoid unnecessary duplication with existing information
sources, as mandated by the Paperwork Reduction Act of 1980 (PRA), as
amended, and work to ensure efficiency in areas where subject matter is
similar.^1 As highlighted in our 21st Century Challenges report, the
federal government must address and adapt to a range of major trends and
challenges in the nation and the world--including, among other things, a
long-term structural fiscal imbalance and a transformation to a
knowledge-based economy.^2 Statistical programs are likely to continue to
face constrained resources in the future, and the changing information
needs of our society and economy raise important questions regarding the
portfolio of major federal household surveys--a portfolio that has been
developing for more than six decades in response to conditions and
information needs that have changed over time.

In light of the importance of minimizing unnecessary duplication between
statistical and research surveys, at your request this report (1)
identifies

1The PRA was enacted in 1980 and  has been amended several times. 44 U.  S.
C. SS 3501 - 3521.

2GAO,  21st  Century  Challenges:  Reexamining  the  Base  of  the  Federal
Government, [1]GAO-05-325SP (Washington, D.C.: February 2005).

      Page 1 GAO-07-62 Federal Information Collection

the number and selected characteristics of Office of Management and Budget
(OMB)-approved federally funded statistical or research surveys,

(2)        describes agencies' and OMB's roles in identifying and preventing
           unnecessary duplication, (3) examines selected surveys to assess
           whether unnecessary duplication exists in areas with similar
           subject matter, and

(4)        describes selected efforts agencies have used to improve the
           efficiency and relevance of surveys. OMB defines the term
           unnecessary duplication as information similar to or corresponding
           to information that could serve the agency's purpose and is
           already accessible to the agency. Therefore, as agreed, our review
           focused on several surveys that we identified as having the
           potential for being unnecessarily duplicative because they contain
           similar information.

To address the first objective to identify the number and characteristics
of OMB-approved federally funded surveys, we reviewed the information
collections that OMB approved under the PRA. We used information from the
database of OMB-approved federally funded information collections.^3 In
2005 we conducted a reliability assessment of the database of OMBapproved
information collections and concluded that the data were accurate and
complete for the purposes of that report.^4 Because this assessment was
recent, we decided that we would not repeat this assessment. As OMB's
approval can be in effect for a maximum of 3 years, and may be for a
shorter period, our review reflects a snapshot in time of all those
collections that OMB had approved for use as of August 7, 2006. We focused
on two categories of information collections: general purpose statistics,
which are surveys whose results are to be used for statistical
compilations of general public interest, and research surveys.^5

For the second objective to describe agencies' and OMB's roles in
identifying and preventing unnecessary duplication, we reviewed the PRA
requirements for both agencies and OMB. We interviewed clearance officers
from the Departments of Commerce, Labor, and Health and

3The database of OMB-approved federally funded information collections is
administered by the General Service Administration, which works closely
with OMB.

4GAO, Paperwork Reduction Act: New Approach May Be Needed to Reduce
Government Burden on Public, [2]GAO-05-424 (Washington, D.C.: May 20,
2005).

5OMB Form 83-I provides seven categories for agencies' use in designating
the purpose for the proposed information collection: application for
benefits, program evaluation, general purpose statistics, audit, program
planning or management, research, regulatory, and compliance.

Human Services to learn about their processes for submitting the
information collection packages to OMB. These agencies were the top three
agencies in terms of funding for statistical activities in fiscal year
2006. We also interviewed OMB officials regarding their role in approving
information collections.

For the third objective to examine selected surveys to assess whether
unnecessary duplication exists in areas with similar subject matter, we
reviewed our reports and literature and interviewed agency officials to
identify areas of similar content covered in multiple surveys. We
subsequently identified three subject areas with potentially unnecessary
duplication based on similar content in the surveys: (1) people without
health insurance, (2) those with disabilities, and (3) housing. Once we
had identified these three subject areas, we analyzed information from
literature and interviews we conducted to identify the current federally
funded surveys that were cited as the major surveys on people without
health insurance (Current Population Survey (CPS), National Health
Interview Survey (NHIS), Medical Expenditure Panel Survey (MEPS), and
Survey of Income and Program Participation (SIPP)) and disability (NHIS,
National Health and Nutrition Examination Survey (NHANES), MEPS, SIPP, and
the American Community Survey (ACS)) as shown in table 1. For the third
area, housing, we relied on our earlier report that identified the
potential unnecessary duplication between the ACS and American Housing
Survey (AHS).^6 One of the surveys we included, the Census Bureau's SIPP,
will be reengineered. However, the content of the redesigned SIPP has not
been determined, and as a result, it may continue to include questions on
disability and people without health insurance, so we have included
information relative to this long-standing survey in this report.

GAO, The  American  Community  Survey:  Accuracy  and  Timeliness  Issues,
[3]GAO-02-956R (Washington D.C.: Sept. 30, 2002).

        Page 3 GAO-07-62 Federal Information Collection

of Labor (DOL), the National Center for Health Statistics (NCHS) and the
Agency for Healthcare Research and Quality (AHRQ) at the Department of
Health and Human Services (HHS), and the Division of Housing and
Demographic Analysis at the Department of Housing and Urban Development
(HUD). We also interviewed experts from organizations that focus on
federal statistics, such as the Council of Professional Associations on
Statistics and the Committee on National Statistics, National Academies of
Science.

For the fourth objective, to describe selected agency efforts to improve
the efficiency and relevance of surveys, we analyzed information from
agency and OMB interviews, expert interviews as discussed above, and
literature. We conducted our work in accordance with generally accepted
government auditing standards from April 2005 through June 2006. Appendix
I provides a more complete description of our scope and methodology.

Results in Brief

At the time of our review, OMB had approved 584 new and ongoing federal
statistical or research surveys^7 of which 40 percent were administered to
individuals and households. About 35 percent of the approved statistical
and research surveys each required 1,000 or less annual estimated burden
hours (i.e., the amount of time for an average respondent to complete a
survey, multiplied by the total number of respondents).

Under the PRA, agencies are responsible for certifying to OMB that each
information collection does not unnecessarily duplicate existing
information. OMB defines unnecessary duplication as information that is
similar to or corresponding to information that could serve the agency's
purpose and is already accessible to the agency. In prior work, we found
that some of these certifications were made without complete supporting
information.^8 When approving a survey, OMB is required to review the
content of the agency's submission to ensure that each information
collection is not unnecessarily duplicative. OMB also provides guidance
that agencies can use to comply with the approval process, including
guidance on when it is acceptable to duplicate questions in other surveys.

7The data are  current as  of August  7, 2006.  OMB's approvals  may be  in
effect for  up  to  3  years  and  include  new  and  ongoing  information
collections.

8GAO, Paperwork  Reduction  Act:  New  Approach May  Be  Needed  to  Reduce
Government Burden  on Public,  [4]GAO-05-424  (Washington, D.C.:  May  20,
2005).

Page 5 GAO-07-62 Federal Information Collection

An agency may consult with OMB before it submits an information collection
for approval, and officials told us that early consultation can help
identify and prevent unnecessary duplication.

Based on OMB's definition of unnecessary duplication, the surveys we
reviewed could be considered to contain necessary duplication. The seven
surveys we reviewed have duplicative content and in some cases ask the
same or similar questions in three subject areas: (1) people without
health insurance (CPS, NHIS, MEPS, and SIPP), (2) people with disabilities
(NHIS, NHANES, MEPS, SIPP, and ACS), and (3) housing (AHS and ACS).
However, the agencies and OMB judged that this was not unnecessary
duplication given the differences among the surveys. The surveys
originated at various times over several decades, and some differ in their
purposes and methodologies (such as the sampling methodologies) as well as
in their definitions and measurement techniques (such as the time frames
used). In some instances, the ability to link this information with other
questions in the same survey can yield richer data that allow for a fuller
description or understanding of specific topics. However, the resulting
estimates of similar characteristics can be very different, which can be
confusing. For example, the 2004 CPS estimate for people who were
uninsured for a full year is over 50 percent higher than the NHIS estimate
of the number of uninsured for that year. Interagency groups have
undertaken efforts to explain or reconcile inconsistencies among surveys
that address the same subject area, such as explaining the differences
between estimates of the number of uninsured persons.

In some cases, agencies have taken steps to enhance the relevance and
efficiency of their surveys. For example, the Census Bureau undertook a
review of its portfolio of manufacturing surveys and decided to eliminate
several in order to undertake new surveys on the industrial sectors that
were of growing importance to the economy. Agencies have also used
administrative data in conjunction with their surveys, which has enhanced
the quality of the information and limited respondent burden.

At the same time, there are two major changes upcoming to the portfolio of
major federal household surveys. The ACS, which is intended to replace the
long-form decennial census in 2010, is considered to be the cornerstone of
the government's efforts to provide data on population and housing
characteristics and will be used to distribute billions of dollars in
federal funding. Efforts are also underway to redesign the SIPP, which is
used in estimating future costs of certain government benefit programs. In
light of these upcoming changes, OMB recognizes that the federal
government should build upon agencies' practice of reexamining individual
surveys. Providing greater coherence among surveys, particularly in
definitions and time frames, could help reduce costs to the federal
government and associated burden hours. The Interagency Council on
Statistical Policy, which is chaired by OMB and made up of the heads of
the major statistical agencies, is responsible for coordinating
statistical work and has the leadership authority to undertake a
comprehensive reexamination of the portfolio of major federal household
surveys.

The rollout of the ACS and the reengineering of the SIPP provide an
opportunity to go beyond these individual efforts to examine the
effectiveness and efficiency of the portfolio of major household surveys
that have developed over six decades. Therefore, we are recommending that
the Director of OMB work with the Interagency Council on Statistical
Policy to plan for a comprehensive reexamination to identify opportunities
for redesigning or reprioritizing the portfolio of major federal household
surveys. Such a reexamination would identify opportunities to ensure that
major federal household surveys initiated under conditions, priorities,
and approaches that existed decades ago are able to cost-effectively meet
current and emerging information needs.

OMB and HUD agreed with our recommendation but OMB officials expressed
concerns about the range of participants and the universe of surveys that
might be involved in such a reexamination. In response, we revised the
recommendation to clarify that OMB should work with the ICSP and focused
the recommendation on seven surveys that are considered to be major
federal household surveys. HHS stated that a reexamination was not
warranted without evidence of unnecessary duplication, but our
recommendation is based on other factors, including a need to provide
greater coherence among the surveys and to take advantage of changes in
the statistical system to reprioritize information needs and possibly help
reduce costs to the federal government and associated burden hours. HHS
also provided additional information that we incorporated as appropriate
in the report. In addition, we obtained written comments from the DOC and
informal electronic comments from the DOL, which we incorporated as
appropriate in the report.

Background

The purpose of the PRA is to (1) minimize the federal paperwork burden

for individuals, small businesses, state and local governments, and other
persons; (2) minimize the cost to the federal government of collecting,
maintaining, using, and disseminating information; and (3) maximize the
usefulness of information collected by the federal government. The PRA
also aims to provide for timely and equitable dissemination of federal

Page 7 GAO-07-62 Federal Information Collection

information; improve the quality and use of information to increase
government accountability at a minimized cost; and manage information
technology to improve performance and reduce burden, while improving the
responsibility and accountability of OMB and the federal agencies to
Congress and the public.

To achieve these purposes, the PRA prohibits federal agencies from
conducting or sponsoring an information collection unless they have prior
approval from OMB. The PRA requires that information collections be
approved by OMB when facts or opinions are solicited from 10 or more
people. Under the law, OMB is required to determine that an agency
information collection is necessary for the proper performance of the
functions of the agency, including whether the information will have
practical utility.

The PRA requires every agency to establish a process for its chief
information officer (CIO) to review program offices' proposed information
collections, such as certifying that each proposed collection complies
with the PRA, including ensuring that it is not unnecessarily duplicative.
The agency is to provide two public notice periods--an initial 60-day
notice period and a 30-day notice period after the information collection
is submitted to OMB for approval.^9 Agencies are responsible for
consulting with members of the public and other affected agencies to
solicit comments on, among other things, ways to minimize the burden on
respondents, including through the use of automated collection techniques
or other forms of information technology. According to an OMB official,
this could include asking for comments on a proposal to use administrative
data instead of survey data.

Following satisfaction of these requirements, an agency is to submit its
proposed information collection for OMB review, whether for new
information collections or re-approval of existing information
collections. Before an agency submits a proposed information collection
for approval, an agency may invest substantial resources to prepare to
conduct an information collection. An agency may undertake, among other
things, designing the information collection, testing, and consulting with
users. For example, over the last 8 years, BLS has led an interagency
effort

We have suggested that Congress eliminate the 60-day Federal Register
notice from the agency clearance process, since these notices elicit few
comments. GAO, Paperwork Reduction Act: New Approach May Be Needed to
Reduce Government Burden on Public, [5]GAO-05-424 (Washington, D.C.: May
20, 2005).

Page 8 GAO-07-62 Federal Information Collection

designed to develop a measure of the employment rate of adults with
disabilities pursuant to Executive Order 13078 signed by President Clinton
in 1998. This effort has entailed planning, developing, and testing
disability questions to add to the CPS. OMB is responsible for determining
whether each information collection is necessary for the proper
performance of the agency's functions. According to the Statistical
Programs of the United States Government: Fiscal Year 2006, an estimated
$5.4 billion in fiscal year 2006 was requested for statistical
activities.^10

The PRA also requires the establishment of the Interagency Council on
Statistical Policy (ICSP). According to the Statistical Programs of the
United States Government: Fiscal Year 2006, the ICSP is a vehicle for
coordinating statistical work, particularly when activities and issues cut
across agencies; for exchanging information about agency programs and
activities; and for providing advice and counsel to OMB on statistical
matters.

The PRA also requires OMB to annually report on the paperwork burden
imposed on the public by the federal government and efforts to reduce this
burden, which is reported in Managing Information Collection: Information
Collection Budget of the United States Government. For example, the 2006
Information Collection Budget reported on agency initiatives to reduce
paperwork, such as HHS's assessment of its information collections with a
large number of burden hours, which resulted in reducing the department's
overall burden hours by over 36 million in fiscal year 2005.

OMB produces the annual Statistical Programs of the United States
Government report to fulfill its responsibility under the PRA to prepare
an annual report on statistical program funding. This document outlines
the effects of congressional actions and the funding for statistics
proposed in the President's current fiscal year budget, and highlights
proposed program changes for federal statistical activities. It also
describes a number of long-range planning initiatives to improve federal
statistical

According to the Statistical Programs of the United States Government:
Fiscal Year 2006, approximately 40 percent of the funding for statistical
programs provides resources for 10 agencies that have statistical
activities as their principal mission. The remaining funding is spread
among almost 70 other agencies that carry out statistical activities in
conjunction with other program missions, such as providing services or
enforcing regulations.

Page 9 GAO-07-62 Federal Information Collection

programs, including making better use  of existing data collections  while
protecting the confidentiality of statistical information.

  More Than 500 Statistical or Research Surveys Have Been Approved

At the time of our review, OMB had approved 584 new and ongoing
statistical and research surveys as recorded in the database of
OMBapproved information collections. OMB uses the database for tracking
purposes, as it provides the only centralized information available on the
characteristics of the surveys that OMB has approved. The database
contains information on some, but not all, of the characteristics of the
information collections. The information that agencies provide in the
packages they submit to OMB for approval includes additional data, such as
the estimated cost.

Statistical and research surveys represent about 7 percent of the total
universe of 8,463 OMB-approved information collections, the majority of
which, as shown in figure 1, are for regulatory or compliance and
application for benefits purposes. Although there are certain surveys
funded through grants and contracts that are not approved by OMB under the
PRA, OMB stated that there is no comprehensive list of these surveys.^11

11

As referenced in OMB's draft guidance on agency information collections,
surveys conducted by recipients of federal funding generally do not
require OMB approval. However, there are circumstances where the survey
may require OMB approval. See appendix I for explanation.

Page 10 GAO-07-62 Federal Information Collection

       Figure 1: Primary Purpose of OMB-approved Information Collections

Forty percent  of  OMB-approved  statistical  and  research  surveys  were
administered to individuals and households, as shown in figure 2.

     Figure 2: Respondents to OMB-approved Statistical and Research Surveys

Annual estimated burden hours are defined as the amount of time for the
average respondent to fill out a survey times the number of
respondents.^12 Figure 3 shows the range of burden hours, for general
purpose research and statistics information collections, with about 35
percent of the surveys each accounting for 1,000 or fewer total burden
hours.

We have reported that it is important to recognize that burden-hour
estimates have limitations. Estimating the amount of time it will take for
an individual to collect and provide information or how many individuals
an information collection will affect is not a simple matter. Therefore,
the degree to which agency burden-hour estimates reflect real burden is
unclear. Nevertheless, these are the best indicators of paperwork burden
available, and we believe they can be useful as long as their limitations
are kept in mind. GAO, The Paperwork Reduction Act: Burden Increases and
Violations Persist [6]GAO-02-598T (Washington, D.C.: Apr. 11, 2002).

Figure 3:  Burden Hour  Ranges of  the 584  Research and  General  Purpose
Statistics Surveys

According to an OMB official, the electronic system, Regulatory
Information Service Center Office of Information and Regulatory Affairs
Consolidated Information System, has automated the agency submission and
OMB review process. This new system, which was implemented in July of
2006, is intended to allow OMB and agency officials to search information
collection titles and abstracts for major survey topics and key words.

Table 2 provides information from agency officials and documents for the
selected surveys that we reviewed in more depth. For these seven surveys,
the sample sizes ranged from 5,000 individuals for the NHANES to 55,000
housing units for the AHS. The NHANES has a much smaller sample size and
greater cost (as compared to the other surveys with similar burden hours)
because it includes both an interview and a physical examination in a
mobile exam center. The physical examination can include body measurements
and tests and procedures, such as a blood sample and dental screening, to
assess various aspects of respondents' health. Other

Page 13 GAO-07-62 Federal Information Collection

differences among the surveys we reviewed included their specific purposes
(e.g., to obtain health information or demographics data); the time period
considered (some of the surveys provide data as of a certain point in time
while others are longitudinal and follow the same respondents over a
period of time); and the frequency with which the surveys were conducted.

In addition, many of these surveys have been in existence for decades. Of
the seven surveys we reviewed, five are defined by the Statistical
Programs of the United States Government Fiscal Year 2006 as major
household surveys (ACS, AHS, CPS, NHIS, and SIPP), and in addition MEPS's
household sample is a sub-set of NHIS's sample. The ACS, unlike the other
surveys, is mandatory and will replace the decennial census long-form. In
addition to the surveys that we reviewed, two other surveys, the Consumer
Expenditure Surveys and the National Crime Victimization Survey, are also
defined by the Statistical Programs of the United States Government of
2006 as major household surveys.

Table 2: Characteristics of Selected Research and Statistical Surveys

Sponsoring Sample Survey agency Purpose size

Produces state-2006 Cost Annual level Survey (dollars in Date burden
estimates frequency Longitudinal millions) originated hours

ACS Census Will replace the 3,122,900 X Monthly $169 Fully 1,917,410

Bureau, decennial households^a Imple-

DOC Census long-mented

form, and January

monitors 2005

changes in

communities

AHS HUD Collect data on 55,000 Odd years X $16 1973 30,517

the nation's (average) for national

housing, housing sample

including units for [Every 6

]income, national [years for 47

]neighborhood component [metropolitan

]quality, costs, and about [areas

]equipment and 4,100

fuels, and housing

movement units for

each of the

47

metropolitan

areas

                                        Produces
                                 state                        2006 Cost            Annual 
Sponsoring         Sample level     Survey                 (dollars  Date       burden 
                                                              in                          
Survey agency Purpose  size  estimates frequency Longitudinal millions) originated  hours 

Sponsoring Sample Survey agency Purpose size Produces state-2006 Cost
Annual level Survey (dollars in Date burden estimates frequency
Longitudinal millions) originated hours

26,000 Continuing X $46.2 1983 148,028 households with monthly

                                   interviews

Source: GAO analysis.

Note: The costs data were rounded to the nearest tenth of a million.

aAlthough the ACS' annual sample size is 3,122,900, starting in 2006, data
will be available annually for all areas with populations of 65,000 or
more. For smaller areas, it will take 3 to 5 years to accumulate a large
enough sample to produce annual data. For example, areas of 20,000 to
65,000 can receive data averaged over 3 years. For rural areas, small
urban neighborhoods or population groups of less than 20,000, it will take
five years to accumulate a sample size comparable to the decennial census.
These averages will be updated every succeeding year.

bIn addition to the MEPS survey to households, MEPS also includes surveys
to public and private employers to collect data on the number and types of
private health insurance offered, benefits associated with those plans,
premiums, contributions by employers and employees, eligibility
requirements, and employer characteristics.

cAccording to a HHS official, depending on the year and the population
being estimated, NHIS can produce state-level estimates for most states,
with the exception of approximately 8 to10 smaller states. For example,
using the 2004 NHIS data to estimate the number of people who do not have
health insurance by state, HHS produced state-level data for all states
except District of Columbia, Delaware, Iowa, North Dakota, New Hampshire,
Rhode Island, South Dakota, and Wyoming.

SIPP Census Bureau, DOC

Collects source and amount of income, labor force information, program
participation and eligibility data, and general demographic
characteristics to measure the effectiveness of federal, state, and local
programs, to estimate future costs, and coverage for government programs.

  Agencies and OMB Have Procedures Intended to Identify and Prevent Unnecessary
  Duplication

Agencies and OMB have procedures intended to identify and prevent
unnecessary duplication in information collections. Agencies are
responsible for certifying that an information collection is not
unnecessarily duplicative of existing information as part of complying
with OMB's approval process for information collections. OMB has developed
guidance that agencies can use in complying with the approval process.
Once an agency submits a proposed information collection to OMB, OMB is
required to review the agency's paperwork, which includes the agency's
formal certification that the proposed information collection is not
unnecessarily duplicative.

    Agencies are Responsible for Identifying and Preventing Unnecessary
    Duplication

Under the PRA, agencies are responsible for certifying that a proposed
information collection does not unnecessarily duplicate an available
information source. According to OMB's draft Implementing Guidance for OMB
Review of Agency Information Collection, the term unnecessary duplication
is defined as information similar to or corresponding to information that
could serve the agency's purpose and need and is already accessible to the
agency. OMB guidance states the following:

"For example, unnecessary duplication exists if the need for the proposed
collection can be served by information already collected for another
purpose - such as administrative records, other federal agencies and
programs, or other public and private sources. If specific information is
needed for identification, classification, or categorization of
respondents; or analysis in conjunction with other data elements provided
by the respondent, and is not otherwise available in the detail necessary
to satisfy the purpose and need for which the collection is undertaken;
and if the information is considered essential to the purpose and need of
the collection, and/or to the collection methodology or analysis of
results, then the information is generally deemed to be necessary, and
therefore not duplicative within the meaning of the PRA and OMB
regulation." ^13

When an agency is ready to submit a proposed information collection to
OMB, the agency's CIO is responsible for certifying that the information
collection satisfies the PRA standards, including a certification that the
information collection is not unnecessarily duplicative of existing

13

Office of Management and Budget, The Paperwork Reduction Act of 1995:
Implementing Guidance for OMB Review of Agency Information Collection,
draft (Aug. 16, 1999).

Page 17 GAO-07-62 Federal Information Collection

information sources.^14 We have previously reported that agency CIOs
across the government generally reviewed information collections and
certified that they met the standards in the act. However, our analysis of
12 case studies at the Internal Revenue Service (IRS) and the Department
of Veterans Affairs, HUD, and DOL, showed that the CIOs certified
collections even though support was often missing or incomplete. For
example, seven of the cases had no information and two included only
partial information on whether the information collection avoided
unnecessary duplication. Further, although the PRA requires that agencies
publish public notices in the Federal Register and otherwise consult with
the public, agencies governmentwide generally limited consultation to the
publication of the notices, which generated little public comment. Without
appropriate support and public consultation, agencies have reduced
assurance that collections satisfy the standards in the act. We
recommended that the Director of OMB alter OMB's current guidance to
clarify the kinds of support that it asks agency CIOs to provide for
certifications and to direct agencies to consult with potential
respondents beyond the publication of Federal Register notices.^15 OMB has
not implemented these recommendations.

    OMB Is Responsible for Reviewing Agencies' Efforts to Identify and Prevent
    Unnecessary Duplication

OMB has three different guidance publications that agencies can consult in
the process of developing information collection submissions, according to
OMB officials. The three guidance publications address unnecessary
duplication to varying degrees. The draft, Implementing Guidance for OMB
Review of Agency Information Collection, provides, among other things,
instructions to agencies about how to identify unnecessary duplication of
proposed information collections with existing available information
sources.

OMB's Questions and Answers When Designing Surveys for Information
Collections discusses when it is acceptable to duplicate questions used in
other surveys. The publication also encourages agencies to consult with
OMB when they are proposing new surveys, major revisions, or large-scale

14

There are 10 information collection standards required by the PRA. The
packages agencies submit to OMB typically include a copy of the survey
instrument and a Paperwork Reduction Act Submission (Standard Form 83-I).
The 83-I requires agencies to answer questions, and provide supporting
documentation, about why the collection is necessary, whether it is new or
an extension of a currently approved survey, whether it is voluntary or
mandatory, and the estimated burden hours.

^15 [7]GAO-05-424 .

experiments or tests, before an information collection is submitted. For
example, when BLS was developing its disability questions for the CPS, BLS
officials stated that they consulted OMB on numerous occasions. OMB
officials also said that when they are involved early in the process, it
is easier to modify an agency's plan for an information collection.

OMB officials told us that an agency consultation with OMB before an
information collection is developed can provide opportunities to identify
and prevent unnecessary duplication. For example, according to an OMB
official, while OMB was working with the Federal Emergency Management
Agency (FEMA) to meet the need for information on the impact of Hurricane
Katrina, OMB identified a survey partially funded by the National
Institute of Mental Health (NIMH) that was in the final stages of design
and would be conducted by Harvard University--the Hurricane Katrina
Advisory Group Initiative. OMB learned that this survey, which was funded
through a grant (and was not subject to review and approval under the
PRA), planned to collect data on many of the topics that FEMA was
interested in. OMB facilitated collaboration between FEMA and HHS and
ultimately, FEMA was able to avoid launching a new survey by enhancing the
Harvard study.

OMB's draft of the Proposed Standards and Guidelines for Statistical
Surveys, which focuses on statistical surveys and their design and
methodology, did not require that agencies assess potential duplication
with other available sources of information as part of survey planning. We
suggested that OMB require that when agencies are initiating new surveys
or major revisions of existing surveys they include in their written plans
the steps they take to ensure that a survey is not unnecessary duplicative
with available information sources. OMB has incorporated this suggestion.

Under the PRA, OMB is responsible for reviewing proposed information
collections to determine whether a proposed information collection meets
the PRA criteria, which include a requirement that it not unnecessarily
duplicate available information. According to an OMB official responsible
for reviewing information collections, OMB's review process consists of
several steps. She said that once an agency has submitted the proposed
information collection package to OMB, the package is sent to the
appropriate OMB official for review. When there is a need for
clarification or questions exist, this OMB official told us that OMB
communicates with the agency either through telephone conferences or via
e-mail. After approval, OMB is required to assign a number to each
approved information collection, which the agencies are then to include on
their information collection (e.g., survey) forms.

In addition to its responsibilities for reviewing proposed information
collections, OMB also contributes to or leads a wide range of interagency
efforts that address federal statistics. For example, OMB chairs the ICSP.
The ICSP is a vehicle for coordinating statistical work, exchanging
information about agency programs and activities, and providing advice and
counsel to OMB on statistical matters. The council consists of the heads
of the principal statistical agencies,^16 plus the heads of the
statistical units in the Environmental Protection Agency, IRS, National
Science Foundation, and Social Security Administration (SSA). According to
an OMB official, the ICSP can expand its membership for working groups to
address specific topics. For example, the ICSP established an
employment-related health benefits subcommittee and included non-ICSP
agencies, such as HHS's AHRQ (which co-chaired the subcommittee). The ICSP
member agencies exchange experiences and solutions with respect to
numerous topics of mutual interest and concern. For example, in the past
year, the council discussed topics such as

        * the revision of core standards for statistical surveys
        *  o opportunities for interagency collaboration on information
          technology development and investment and

     o sample redesign for the major household surveys with the advent of the
       ACS.

  Duplicative Content in Selected Surveys Exists, but Survey Purposes and Scope
  Differ

On the basis of OMB's definition of unnecessary duplication, the surveys
we reviewed could be considered to contain necessary duplication. To
examine selected surveys to assess the extent of unnecessary duplication
in areas with similar subject matter, we looked at surveys that addressed
three areas: (1) people without health insurance (CPS, NHIS, MEPS, and
SIPP), (2) people with disabilities (NHIS, NHANES, MEPS, SIPP, and ACS),
and (3) the housing questions on the AHS and ACS. We found that the
selected surveys had duplicative content and asked similar questions in
some cases. However, the agencies and OMB judged that this was not
unnecessary duplication given the differences among the surveys. In some
instances, the duplication among these surveys yielded richer data,
allowing fuller descriptions of specific topics and providing additional

16

The principal statistical agencies are the Bureau of the Census, Bureau of
Economic Analysis, Bureau of Justice Statistics, Bureau of Labor
Statistics, Bureau of Transportation Statistics, Economic Research
Service, Energy Information Administration, National Agricultural
Statistics Service, National Center for Education Statistics, and National
Center for Health Statistics.

Page 20 GAO-07-62 Federal Information Collection

perspectives on a topic, such as by focusing on the different sources and
effects of disabilities. The seven surveys we reviewed originated at
different times and differ in many aspects, including the samples drawn,
the time periods measured, the types of information collected, and level
of detail requested. These factors can affect costs and burden hours
associated with the surveys. In addition, the differences can create
confusion in some cases because they produce differing estimates and use
different definitions.

Surveys That Measure People without Health Insurance Produce Differing Estimates

Although the CPS, NHIS, MEPS, and SIPP all measure people who do not 
have health insurance, the surveys originated at
different times and differ in several ways,
including the combinations of information
collected that relate to health insurance,
questions used to determine health insurance
status, and time frames. Health insurance status
is not the primary
purpose of any of these surveys, but rather one of
the subject areas in each
survey. In addition, because each survey has a
different purpose, each
survey produces a different combination of
information related to people's
health insurance. 
                          o The CPS originated in 1948 and provides data on
                           the population's  
                           employment status. Estimates from the CPS include
                           employment,       
                           unemployment, earnings, hours of work, and other
                           indicators.       
                           Supplements also provide information on a variety
                           of subjects, including
                           information about employer-provided benefits like
                           health insurance. CPS
                           also provides information on health insurance
                           coverage rates for
                           sociodemographic subgroups of the population. The
                           time frame within 
                           which data is released varies; for example, CPS
                           employment estimates are
                           released 2-3 weeks after collection while
                           supplement estimates are
                           released in 2-9 months after collection.
                         o The NHIS originated in 1957 and collects
                           information on reasons for lack
                           of health insurance, type of coverage, and health
                           care utilization. The
                           NHIS also collects data on illnesses, injuries,
                           activity limitations, chronic
                           conditions, health behaviors, and other health
                           topics, which can be linked
                           to health insurance status. HHS stated that
                           although health insurance data
                           are covered on other surveys, NHIS's data on
                           health insurance is key to
                           conducting analysis of the impact of health
                           insurance coverage on access
                           to care, which is generally not collected on other
                           surveys.          
                         o The MEPS originated in 1977 and provides data on
                           health insurance  
                           dynamics, including changes in coverage and
                           periods without coverage.
                           The MEPS augments the NHIS by selecting a sample
                           of NHIS respondents
                           and collecting additional information on the
                           respondents. The MEPS also
                           links data on health services spending and health
                           insurance status to other
                           demographic characteristics of survey respondents.
                           The MEPS data can 
                                             Federal Information Collection   
                           Page 21           GAO-07-62                        

also be used to analyze the relationship between insurance status and a
variety of individual and household characteristics, including use of and
expenditures for health care services.

o The SIPP originated in 1983 in order to provide data on income, labor
force, and government program participation. The information collected in
the SIPP, such as the utilization of health care services, child
well-being, and disability, can be linked to health insurance status. The
SIPP also measures the duration of periods without health insurance.

Because the surveys use different methods to determine health insurance
status, they can elicit different kinds of responses and consequently
differing estimates within the same population. To determine if a person
is uninsured, surveys use one of two methods: they ask respondents
directly if they lack insurance coverage or they classify individuals as
uninsured if they do not affirmatively indicate that they have coverage.
The CPS and the NHIS directly ask respondents whether they lack insurance
coverage. While the difference between these approaches may seem subtle,
using a verification question prompts some people who did not indicate any
insurance coverage to rethink their status and indicate coverage that they
had previously forgotten to mention.

The surveys also differ both in the time period respondents are asked to
recall and in the time periods measured when respondents did not have
health insurance. Hence, the surveys produce estimates that do not rely
upon standardized time or recall periods and as a result are not directly
comparable. The ASEC to the CPS is conducted in February, March, and April
and asks questions about the prior calendar year. An interviewer asks the
respondent to remember back for the previous calendar year which can be as
long as 16 months in the April interview. The other three surveys, in
contrast, asked about coverage at the time of the interview. Because a
respondent's ability to recall information generally degrades over time,
most survey methodologists believe that the longer the recall period, the
less accurate the answers will be to questions about the past, such as
exactly when health insurance coverage started or stopped, or when it
changed because of job changes. Another difference is the time period used
to frame the question. The CPS asked whether the respondent was uninsured
for an entire year, while NHIS, MEPS, and SIPP asked whether the
individual was ever insured, or was uninsured at the time of the
interview, for the entire last year, and at any time during the year.

Table 3 illustrates the differing estimates obtained using data from the
four selected surveys. While these differences can be explained, the wide
differences in the estimates are of concern and have created some

Page 22 GAO-07-62 Federal Information Collection

confusion. For example, the 2004 CPS estimate for people who were
uninsured for a full year is over 50 percent higher than the NHIS estimate
for that year. HHS has sponsored several interagency meetings on health
insurance data, which involved various agencies within HHS and the Census
Bureau. The meetings focused on improving estimates of health insurance
coverage and included, among other things, examining how income data are
used, exploring potential collaboration between HHS and the Census Bureau
on whether the CPS undercounts Medicaid recipients, examining health
insurance coverage rates, and discussing a potential project to provide
administrative data for use in the CPS. As a result, HHS created a Web
site with reports and data on relevant surveys and HHS's office of the
Assistant Secretary for Planning and Evaluation (ASPE) produced the report
Understanding Estimates of the Uninsured: Putting the Differences in
Context with input from the Census Bureau in an effort to explain the
differing estimates.^17

Table 3: Uninsured Estimates from Selected Surveys

Most recent Uninsured for full Point in time Ever uninsured Survey year
year estimate during the year

CPS 2004 45.8 million N/A N/A

NHIS 2004 29.2 million 42.1 million 51.6 million

MEPS 2003 33.7 million 48.1 million 62.9 million

SIPP 2001 18.9 million 38.7 million 66.5 million

Source: GAO extract of ASPE issue brief: Understanding Estimates Of the
Uninsured: Putting the Differences in Context (September, 2005).

Surveys that Measure Disability Status Differ in Definitions, Purposes, and
Methodologies Used

Similarly, although the NHIS, NHANES, MEPS, SIPP, and ACS all estimate the
percentage of the population with disabilities, the surveys define
disability differently and have different purposes and methodologies. In
addition to these five surveys, which measure aspects of disability, BLS
is also currently developing questions to measure the employment levels of
the disabled population. HHS also stated that disability is included on
multiple surveys so that disability status can be analyzed in conjunction
with other information that an agency needs. For example, disability
information is used by health departments to describe the health of the
population, by departments of transportation to assess access to

17

Department of Health and Human  Services, ASPE Issue Brief:  Understanding
Estimates of the Uninsured: Putting the Differences in Context (September,
2005).

Page 23 GAO-07-62 Federal Information Collection

transportation systems, and departments of education in the education
attainment of people with disabilities. The lack of consistent definitions
is not unique to surveys; there are over 20 different federal agencies
that administer almost 200 different disability programs for purposes of
entitlement to public support programs, medical care, and government
services. 

Although each of the surveys asks about people's impairments or
functionality in order to gauge a respondent's disability status, there
are some differences in how disability is characterized. For example, the
NHIS asks respondents if they are limited in their ability to perform
agedependent life and other activities. The NHIS also asks about the
respondent needing assistance with performing activities of daily living
and instrumental activities of daily living.^18 The NHANES measures the
prevalence of physical and functional disability for a wide range of
activities in children and adults. Extensive interview information on
selfreported physical abilities and limitations is collected to assess the
capacity of the individual to do various activities without the use of
aids, and the level of difficulty in performing the task. The MEPS
provides information on days of work or school missed due to disability.
The SIPP queries whether the respondent has limitations of sensory,
physical, or mental functioning and limitations on activities due to
health conditions or impairments. The ACS asks about vision or hearing
impairment, difficulty with physical and cognitive tasks, and difficulty
with self-care and independent living.

Because surveys produce different types of information on disability, they
can provide additional perspectives on the sources and effects of
disabilities, but they can also cause confusion because of the differences
in the way disability is being measured. The NHIS contains a broad set of
data on disability-related topics, including the limitation of functional
activities, mental health questions used to measure psychological
distress, limitations in sensory ability, and limitations in work ability.
Moreover, the NHIS provides data, for those persons who indicated a
limitation performing a functional activity, about the source or condition
of their functional limitation. The NHANES links medical examination
information

Activities of daily living include getting around inside the home, getting
in or out of bed or a chair, bathing, dressing, eating, and toileting.
Instrumental activities of daily living include going outside the home,
keeping track of money and bills, preparing meals, doing light housework,
taking prescription medicines in the right amount at the right time, and
using the telephone.

Page 24 GAO-07-62 Federal Information Collection

to disability. The MEPS measures how much individuals spend on medical
care for a person with disabilities and can illustrate changes in health
status and health care expenses. The SIPP provides information on the use
of assistive devices, such as wheelchairs and canes. Finally, the ACS
provides information on many social and economic characteristics, such as
school enrollment for people with disabilities as well as the poverty and
employment status of people with different types of disabilities.

However, the estimates of disability in the population that these surveys
produce can vary widely. A Cornell University study compared disability
estimates among the NHIS, SIPP, and ACS. A number of categories of
disability were very similar, such as the nondisabled population, while
others, such as the disabled population or people with sensory
disabilities, had widely varying estimates, as shown in table 4.^19 For
example, according to data presented in a Cornell University study that
used survey questions to define and subsequently compare different
disability measures across surveys, the SIPP 2002 estimate of people with
sensory disabilities for ages 18-24 was more than six times the NHIS
estimate for that year for ages 18-24. In commenting on this report, the
DOC and HHS acknowledged that comparing the NHIS and SIPP with respect to
sensory disabilities is problematic. HHS officials noted that the
confusion caused by these different estimates derives mostly from the lack
of a single definition of disability, which leads to data collections that
use different questions and combinations of information to define
disability status.

Benjamin H. Harris, Gerry Hendershot, and David C. Stapleton, A Guide to
Disability Statistics From the National Health Interview Survey (New York:
Cornell University Employment and Disability Institute, October 2005).

Page 25 GAO-07-62 Federal Information Collection

Table 4: Estimated Population of Persons with Disabilities, by Data Source
and Different Categories of Disability

Instrumental Activities Work activities of of daily Surveys No disability
Disability limitation daily living living Mental Physical Sensory

Ages NHIS 25,225,000 2,126,000 927,000 228,000 147,000 786,000 859,000
78,000 18-24 (2002)

SIPP 24,820,000 2,426,337 1,209,000 366,000 146,000 1,076,000 982,000
533,000 (2002)

ACS 24,194,401 1,667,355 714,229 399,423 187,904 953,448 535,666 356,820
(2003)

Ages NHIS 115,934,000 23,192,000 13,725,000 3,169,000 1,350,000 4,627,000
14,545,000 2,730,000 25-61 (2002)

SIPP 115,900,000 26,620,000 14,420,000 4,931,000 3,362,000 4,394,000
18,790,000 6,490,000 (2002)

ACS 126,649,510 17,146,845 9,854,223 4,227,427 2,925,715 5,745,569
10,819,521 3,944,388 (2003) Source: GAO extract of Cornell University's
Employment and Disability Institute report A Guide to Disability
Statistics from the National Health Interview Survey (2005).

Note: Instrumental activities of dally living (IADL) include a broader set
of participation restrictions than the `"go-outside-home" definition in
the ACS. It also includes participation restrictions that affect the
ability to: manage money and keep track of bills, prepare meals, and do
work around the house.

Because the concept of disability varies, with no clear consensus on
terminology or definition, and there are differing estimates, several
federal and international groups are examining how the associated measures
of disability could be improved. HHS's Disability Workgroup, which
includes officials from HHS and the Department of Education, examines how
disability is measured and used across surveys. The task of another
federal group, the Subcommittee on Disability Statistics of the
Interagency Committee on Disability Research, is to define and standardize
the disability definition. The Washington Group on Disability Statistics
(WGDS), an international workgroup sponsored by the United Nations in
which OMB and NCHS participate, is working to facilitate the comparison of
data on disability internationally. The WGDS aims to guide the development
of a short set or sets of disability measures that are suitable for use in
censuses, sample-based national surveys, or other statistical formats, for
the primary purpose of informing policy on equalization of opportunities.
The WGDS is also working to develop one or more extended sets of survey
items to measure disability, or guidelines for their design, to be used as
components of population surveys or as supplements to specialty surveys.
HHS added that the interest in standardizing the measurement of disability
status is also driven by the desire to add a

standard question set to a range of studies so that the status of  persons
with disabilities can be described across studies.

    The AHS and ACS Ask Some Similar Questions on Housing, but Their Purposes
    and Scope Differ

In 2002, we reported that the AHS and ACS both covered the subject of
housing.^20 Of the 66 questions on the 2003 ACS, 25 were in the section on
housing characteristics, and all but one of these questions were the same
as or similar to the questions on the AHS. For example, both the AHS and
the ACS ask how many bedrooms a housing unit has. However, the two surveys
differ in purposes and scope.

The purpose of the AHS is to collect detailed housing information on the
size, composition, and state of housing in the United States, and to track
changes in the housing stock over time, according to a HUD official. To
that end, the AHS includes about 1,000 variables, according to a HUD
official, such as the size of housing unit, housing costs, different
building types, plumbing and electrical issues, housing and neighborhood
quality, mortgage financing, and household characteristics. The AHS
produces estimates at the national level, metropolitan level for certain
areas, and homogenous zones of households with fewer than 100,000
households. The AHS is conducted every 2 years nationally and every 6
years in major metropolitan areas, except for six areas, which are
surveyed every 4 years.

In contrast, the level of housing data in the ACS is much less extensive.
The ACS is designed to replace the decennial Census 2010 long-form and
covers a wide range of subjects, such as income, commute time to work, and
home values. The ACS provides national and county data and, in the future,
will provide data down to the Census tract level, according to a Census
Bureau official. The ACS is designed to provide communities with
information on how they are changing, with housing being one of the main
topic areas along with a broad range of household demographic and economic
characteristics.

The AHS and ACS also have different historical and trend data and data
collection methods. The AHS returns to the same housing units year after
year to gather data; therefore, it produces data on trends that illustrate
the flow of households through the housing stock, according to a HUD
official, while the ACS samples new households every month. Historical
data are

^20 [8]GAO-02-956R .

also available from the AHS from the 1970s onward, according to a HUD
official.

Analysts can use AHS data to monitor the interaction among housing needs,
demand, and supply, as well as changes in housing conditions and costs. In
addition, analysts can also use AHS data to support the development of
housing policies and the design of housing programs appropriate for
different groups. HUD uses the AHS data, for example, to analyze changes
affecting housing conditions of particular subgroups, such as the elderly.
The AHS also plays an important role in HUD's monitoring of the lending
activities of the government-sponsored enterprises, Fannie Mae and Freddie
Mac, in meeting their numeric goals for mortgage purchases serving
minorities, low-income households, and underserved areas. AHS's
characteristic of returning to the same housing units year after year
provides the basis for HUD's Components of Inventory Change (CINCH) and
Rental Dynamics analyses. The CINCH reports examine changes in housing
stock over time by comparing the status and characteristics of housing
units in successive surveys. The Rental Dynamics program, which is a
specialized form of CINCH, looks at rental housing stock changes, with an
emphasis on changes in affordability. Another use of AHS data has been for
calculating certain fair market rents (FMR), which HUD uses to determine
the amount of rental assistance subsidies for major metropolitan areas
between the decennial censuses. However, HUD plans to begin using ACS data
for fiscal year 2006 FMRs. As we previously reported, this could improve
the accuracy of FMRs because the ACS provides more recent data that
closely matches the boundaries of HUD's FMR areas than the AHS.^21

In our 2002 report, which was published before the ACS was fully
implemented, we also identified substantial overlap for questions on place
of birth and citizenship, education, labor force characteristics,
transportation to work, income, and, in particular, housing
characteristics. We recommended that the Census Bureau review proposed ACS
questions for possible elimination that were asked on the AHS to more
completely address the possibility of reducing the reporting burden in
existing surveys.^22 The Census Bureau responded that they are always
looking for opportunities to streamline, clarify, and reduce respondent
burden, but

GAO, Rental  Housing: HUD  Can  Improve Its  Process for  Estimating  Fair
Market Rents, [9]GAO-05-342 (Washington, D.C.: Mar. 31, 2005).

^22 [10]GAO-02-956R .

Page 28 GAO-07-62 Federal Information Collection

that substantial testing would be required  before changes can be made  in
surveys that provide key national social indicators.

    The Advent of the ACS and the Proposed Reengineering of the SIPP Are Changes
    to the Portfolio of Major Household Surveys

In addition to efforts underway to try to reconcile inconsistencies among
surveys that address the same subject areas, a number of major changes
have occurred or are planned to occur that will affect the overall
portfolio of major household surveys. As previously discussed, the ACS was
fully implemented in 2005 and provides considerable information that is
also provided in many other major household surveys. The ACS is the
cornerstone of the government's effort to keep pace with the nation's
changing population and ever-increasing demands for timely and relevant
data about population and housing characteristics. The new survey will
provide current demographic, socioeconomic, and housing information about
America's communities every year, information that until now was only
available once a decade. Starting in 2010, the ACS will replace the
long-form census. As with the long-form, information from the ACS will be
used to administer federal and state programs and distribute more than
$200 billion a year. Detailed data from national household surveys can be
combined with data from the ACS to create reliable estimates for small
geographic areas using area estimation models.

Partly in response to potential reductions in funding for fiscal year
2007, the Census Bureau is planning to reengineer the SIPP with the intent
of ultimately providing better information at lower cost. SIPP has been
used to estimate future costs of certain government programs. For example,
HUD used SIPP's longitudinal capacity to follow families over time to
determine that households with high-rent burdens in one year move in and
out of high-rent burden status over subsequent years. Therefore, although
the overall size of the population with worst-case housing needs is fairly
stable, the households comprising this population change with considerable
frequency--an issue that HUD told us is potentially important in the
design of housing assistance programs.

Although the SIPP has had problems with sample attrition and releasing
data in a timely manner, which the reengineering is intended to
ameliorate, there has been disagreement about this proposal among some
users of SIPP data. Census Bureau officials said they are meeting with
internal and external stakeholders and are considering using
administrative records. Census Bureau officials told us that they could
develop a greater quality survey for less money, with a final survey to be
implemented in 2009. They also said that they may consider using the ACS
or CPS sampling frame.

Page 29 GAO-07-62 Federal Information Collection

  Agencies Have Undertaken Efforts to Improve the Efficiency and Relevance of
  Surveys

In addition to the seven surveys discussed previously, we also identified
examples of how, over the years, agencies have undertaken efforts to
enhance their surveys' relevance and efficiency through steps such as
using administrative data in conjunction with survey data, reexamining and
combining or eliminating surveys, and redesigning existing surveys.

    Agencies Have Used Administrative Data in Conjunction with Surveys

The Census Bureau and BLS have used administrative data collected for the
administration of various government programs in conjunction with survey
data. The Census Bureau and BLS have used the administrative data to
target specific populations to survey and to obtain information without
burdening survey respondents.

The Census Bureau uses administrative data in combination with survey data
to produce its Economic Census business statistics, which, every 5 years,
profile the U.S. economy from the national to the local level. The
Economic Census relies on the centralized Business Register, which is
compiled from administrative records from IRS, SSA, and BLS, along with
lists of multi-establishment businesses that the Census Bureau maintains.
The Business Register contains basic economic information for over 8
million employer businesses and over 21 million self-employed businesses.
The Economic Census uses the Business Register as the sampling frame to
identify sets of businesses with specific characteristics, such as size,
location, and industry sector.

BLS also uses a combination of administrative and survey data to produce
its quarterly series of statistics on gross job gains and losses. BLS uses
administrative data provided by state workforce agencies that compile and
forward quarterly state unemployment insurance (UI) records to BLS. These
state agencies also submit employment and wage data to BLS. The data
states provide to BLS include establishments subject to state UI laws and
federal agencies subject to the Unemployment Compensation for Federal
Employees program, covering approximately 98 percent of U.S. jobs. These
administrative data enable BLS to obtain information on many businesses
without having to impose a burden on respondents. BLS augments the
administrative data with two BLS-funded surveys conducted by the states.
The Annual Refiling Survey updates businesses' industry codes and contact
information, and the Multiple Worksite Report survey provides information
on multiple work sites for a single business, data that are not provided
by the UI records, enabling BLS to report on business statistics by
geographic location. Combining the data from these surveys

Page 30 GAO-07-62 Federal Information Collection

with administrative data helps BLS increase accuracy, update information,
and include additional details on establishment openings and closings.

However, because of restrictions on information sharing, BLS is not able
to access most of the information that the Census Bureau uses for its
business statistics because much of this information is commingled with
IRS data. The Confidential Information Protection and Statistical
Efficiency Act of 2002 (CIPSEA, 44 U.S.C. S 3501 note) authorized
identifiable business records to be shared among the Bureau Economic
Analysis (BEA), BLS, and the Census Bureau for statistical purposes.
CIPSEA, however, did not change the provisions of the Internal Revenue
Code that preclude these agencies from sharing tax return information for
statistical purposes. OMB officials stated that there is continued
interest in examining appropriate CIPSEA companion legislation on granting
greater access for the Census Bureau, BLS, and BEA to IRS data.

    Reexamination Has Led to Modification or Elimination of Surveys

Several agencies have reexamined some of their surveys, which has led to
their elimination or modification. The Census Bureau, for example,
reviewed its portfolio of Current Industrial Reports (CIR) program surveys
of manufacturing establishments, which resulted in the elimination and
modification of some surveys. Census Bureau officials said they decided to
undertake this reexamination in response to requests for additional data
that could not be addressed within existing budgets without eliminating
current surveys. They were also concerned that the character of
manufacturing, including many of the industries surveyed by the CIR
program, had changed since the last reexamination of the CIR programs,
which had been over 10 years earlier. Using criteria developed with key
data users, Census Bureau officials developed criteria and used them to
rank 54 CIR program surveys. The criteria included 11 elements, such as
whether the survey results were important to federal agencies or other
users, and the extent to which the subject matter represented a growing
economic activity in the United States. The recommendations the Census
Bureau developed from this review were then published in the Federal
Register and after considering public comments, the Census Bureau
eliminated 11 surveys, including ones on knit fabric production and
industrial gases.^23 The Census Bureau also redesigned 7 surveys, scaling
back the information required to some extent and updating specific

23Knit fabric is fabric made on a knitting machine, and industrial gases are
manufactured industrial organic and inorganic gases in compressed, liquid,
or solid forms.

Page 31 GAO-07-62 Federal Information Collection

product lists. As a result of this reexamination, the Census Bureau was
able to add a new survey on "analytical and biomedical instrumentation,"
and it is considering whether another new CIR program survey is needed to
keep pace with manufacturing industry developments. Census Bureau
officials told us that they plan on periodically reexamining the CIR
surveys in the future.

HHS has also reexamined surveys to identify improvements, in part by
integrating a Department of Agriculture (USDA) survey which covered
similar content into HHS's NHANES. For about three decades, HHS and USDA
conducted surveys that each contained questions on food intake and health
status (NHANES and the Continuing Survey of Food Intakes by Individuals,
respectively). HHS officials stated that HHS and USDA officials considered
how the two surveys could be merged for several years before taking
action. According to HHS officials, several factors led to the merger of
the two surveys, including USDA funding constraints, the direct
involvement of senior-level leadership on both sides to work through the
issues, and HHS officials' realization that the merger would enable them
to add an extra day of information gathering to the NHANES. Integrating
the two surveys into the NHANES made it more comprehensive by adding a
follow-up health assessment. According to HHS officials, adding this
component to the original in-person assessment allows agency officials to
better link dietary and nutrition information with health status.

Another mechanism HHS has established is a Data Council, which, in
addition to other activities, assesses proposed information collections.
The Data Council oversees the entire department's data collections to
ensure that the department relies, where possible, on existing core
statistical systems for new data collections rather than on the creation
of new systems. The Data Council implements this strategy through
communicating and sharing plans, conducting annual reviews of proposed
data collections, and reviewing major survey modifications and any new
survey proposals. According to HHS officials, in several instances,
proposals for new surveys and statistical systems have been redirected and
coordinated with current systems. For example, HHS officials stated that
when the Centers for Disease Control and Prevention (CDC) proposed a new
survey on youth tobacco use, the Data Council directed it to the Substance
Abuse and Mental Health Services Administration's National Survey of Drug
Use and Health. The Data Council stated that by adding questions on brand
names, CDC was able to avoid creating a new survey to measure youths'
tobacco use.

OMB recognizes that the federal government should build upon agencies'
practice of reexamining individual surveys to conduct a comprehensive
reexamination of the portfolio of major federal household surveys, in
light of the advent of the ACS. OMB officials acknowledged that this
effort would be difficult and complex and would take time. According to
OMB, integrating or redesigning the portfolio of major household surveys
could be enhanced if, in the future, there is some flexibility to modify
the ACS design and methods.^24 For example, an OMB official stated that
using supplements or flexible modules periodically within the ACS might
enable agencies to integrate or modify portions of other major household
surveys. OMB officials indicated that such an effort would likely not
happen until after the 2010 decennial census, a critical stage for ACS
when ACS data can be compared to 2010 Census data. OMB officials said and
their longrange plans have already indicated their expectation that there
will be improved integration of the portfolio of related major household
surveys with the advent of the ACS. For example, the Statistical Programs
of the United States Government: Fiscal Year 2006 describes plans for
redesigning the samples for demographic surveys, scheduled for initial
implementation after 2010, when the ACS may become the primary data
source.

                                  Conclusions
											 
In light of continuing budgetary constraints, as well as major changes
planned and underway within the U.S. statistical system, the portfolio of
major federal household surveys could benefit from a holistic
reexamination. Many of the surveys have been in place for several decades,
and their content and design may not have kept pace with changing
information needs. The duplication in content in some surveys, while
considered necessary, may be a reflection of incremental attempts over
time to address information gaps as needs changed. OMB and the statistical
agencies have attempted to address some of the more troublesome aspects of
this duplication by providing explanations of the differences in health
insurance estimates and with efforts to develop more consistent
definitions of disability. These efforts, however, while helpful, address
symptoms of the duplication without tackling the larger issues of need and
purpose. In many cases, the government is still trying to do business in
ways that are based on conditions, priorities, and approaches

24

At least 2 years before the decennial census is implemented,
census-proposed questions must be submitted to the committees of Congress
having legislative jurisdiction over the Census. 13 U.S.C. S 141(f).

Page 33 GAO-07-62 Federal Information Collection

that existed decades ago and are not well suited to addressing today's
challenges. Thus, while the duplicative content of the surveys can be
explained, there may be opportunities to modify long-standing household
surveys, both to take advantage of changes in the statistical system, as
well as to meet new information needs in the face of ever-growing
constraints on budgetary resources.

Some agencies have begun to take steps to reevaluate their surveys in
response to budget constraints and changing information needs. Agencies
have reexamined their surveys and used administrative data in conjunction
with survey data to enhance their data collection efforts. These actions,
however, focused on individual agency and user perspectives. By building
upon these approaches and taking a more comprehensive focus, a
governmentwide reexamination could help reduce costs in an environment of
constrained resources and help prioritize information needs in light of
current and emerging demands.

Given the upcoming changes in the statistical system, OMB should lead the
development of a new vision of how the major federal household surveys can
best fit together. OMB officials told us they are beginning to think about
a broader effort to better integrate the portfolio of major household
surveys once the ACS has been successfully implemented. Providing greater
coherence among the surveys, particularly in definitions and time frames,
could help reduce costs to the federal government and associated burden
hours. The Interagency Council on Statistical Policy (ICSP) could be used
to bring together relevant federal agencies, including those that are not
currently part of the ICSP. The ICSP has the leadership authority, and in
light of the comprehensive scope of a reexamination initiative, could draw
on leaders from the agencies that collect or are major users of federal
household survey data. While OMB officials have stated that the ACS may
not have demonstrated its success until after 2010, the complexity and
time needed to reexamine the portfolio of major federal household surveys
means that it is important to start planning for that reexamination.

  Recommendation for Executive Action

To deal with the longer term considerations crucial in making federally
funded surveys more effective and efficient, GAO recommends that the
Director of OMB work with the Interagency Council on Statistical Policy to
plan for a comprehensive reexamination to identify opportunities for
redesigning or reprioritizing the portfolio of major federal household
surveys.

Page 34 GAO-07-62 Federal Information Collection

  Agency Comments

We requested comments on a draft of this report from the Director of OMB
and the Secretaries of Commerce, HHS, HUD, and Labor or their designees.
We obtained oral and technical comments on a draft of this report from the
Chief Statistician of the United States and her staff at OMB, as well as
written comments from the Acting Deputy Under Secretary for Economic
Affairs at Commerce; the Assistant Secretary for Legislation at HHS; and
the Assistant Secretary for Policy Development and Research at HUD; and
technical comments from the Acting Commissioner of BLS at Labor, which we
incorporated in the report as appropriate. In commenting on a draft of the
report, OMB officials stated that the draft report presented an
interesting study that addresses an issue worth looking at. OMB officials
generally agreed with our recommendation, although they expressed concerns
about the range of participants that might be involved in such a
reexamination. We revised the recommendation to provide clarification that
OMB should work with the Interagency Council on Statistical Policy rather
than with all relevant stakeholders and decision makers. OMB officials
also expressed concerns about moving from examining selected surveys in
three subject areas to the conclusion that the entire portfolio of
household surveys should be reexamined. In response we clarified that we
were recommending a comprehensive reexamination of the seven surveys that
comprise the portfolio of major federal household surveys, most of which
were included in our review. OMB officials also provided clarification on
how we characterized their statements on reexamining the portfolio of
major household surveys, which we incorporated into the report.

Each of the four departments provided technical clarifications that we
incorporated into the report, as appropriate. In addition, HHS and HUD
officials offered written comments on our findings and recommendation,
which are reprinted in appendix II. HHS stated that a reexamination was
not warranted without evidence of unnecessary duplication and also
highlighted a number of examples of agency efforts to try to clarify
varying estimates. However we did not rely on evidence of duplication, but
rather based our recommendation on other factors, including a need to
provide greater coherence among the surveys and to take advantage of
changes in the statistical system to reprioritize information needs and
possibly help reduce costs to the federal government and associated burden
hours. Further, in light of the major upcoming changes involving the ACS
and SIPP, and in conjunction with constrained resources and changing
information needs, we believe that the major household surveys should be
considered from a broader perspective, not simply in terms of unnecessary
duplication.

HHS also provided a number of general comments. We incorporated additional
information to reflect HHS's comments on the different uses of disability
information, a standard set of disability questions, NHIS's coverage of
access to care, and the fact that MEP's sample is a subset of the NHIS
sample. HHS's comments on differences in estimates and the lack of a
single definition of disability were already addressed in the report. HHS
also stated that NCHS works through various mechanisms to ensure that
surveys are efficient. We support efforts to enhance efficiency and
believe that our recommendation builds upon such efforts.

HUD officials were very supportive of our recommendation, stating that
such a reexamination is especially important as the ACS approaches
fullscale data availability. In response to HUD's comments suggesting
adding more information on SIPP and AHS, we expanded the report's
discussion of the longitudinal dimension of SIPP and AHS.

As agreed with your office, unless you publicly announce the contents of
the report earlier, we plan no further distribution of it until 30 days
from the date of the report. We will then send copies of this report to
the appropriate congressional committees and to the Director of OMB, and
the Secretaries of Commerce, HHS, HUD, and Labor, as well as to other
appropriate officials in these agencies. We will also make copies
available to others upon request. In addition, the report will be
available at no charge on the GAO Web site at http:/www.gao.gov.

If you or your staff have any questions regarding this report, please
contact me at (202) 512-6543 or [email protected]. Contact points for
our Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix II.

Bernice Steinhardt
Director, Strategic Issues

Appendix I: Scope and Methodology

To answer our first
objective of identifying the number and characteristics of Office of
Management and Budget (OMB)-approved federally funded statistical and
research surveys, we obtained the database of information collections that
had been approved by OMB as of August 7, 2006. The information in the
database is obtained from Form 83-I which is part of an agency's
submission for OMB approval of an information collection. As the approval
is in effect for up to 3 years, this database reflects all those
collections with OMB approval for their use as of that date, and is thus a
snapshot in time.

Although OMB Form 83-I requires agencies to identify various types of
information about an information collection, including whether the
information collection will involve statistical methods, the form does not
require agencies to identify which information collections involve surveys
consequently the database of OMB-approved information collections does not
identify which information collections are surveys. Furthermore, the
definition of information collections contained in the Paperwork Reduction
Act (PRA) of 1980 is written in general terms and contains very few limits
in scope or coverage. On the form, agencies can select from seven
categories when designating the purpose of an information collection,
which are (1) application for benefits, (2) program evaluation,
(3) general purpose statistics, (4) audit, (5) program planning or
management, (6) research, and (7) regulatory or compliance. When
completing the form, agencies are asked to mark all categories that apply,
denoting the primary purpose with a "P" and all others that apply with an
"X." Since OMB does not further define these categories, the agency
submitting the request determines which categories best describe the
purpose(s) of the proposed collection. The choices made may reflect
differing understandings of these purposes from agency to agency or among
individuals in the same agency.

The list of surveys contained in this report was derived from the database
of OMB-approved information collections and therefore contains all
information collections that an agency designated as either "general
purpose statistics" or "research" in the primary purpose category that we
used as a proxy for the universe of surveys. The directions to agencies
completing the forms call for agencies to mark "general purpose
statistics" when the data are collected chiefly for use by the public or
for general government use without primary reference to the policy or
program operations of the agency collecting the data. Agencies are
directed to mark "research" when the purpose is to further the course of
research, rather than for a specific program purpose. We did not determine
how accurately or reliably agencies designated the purpose(s) of their
information
collections. It is also possible that the database may contain other
federally funded surveys that the agency did not identify under the
primary purpose we used to "identify" surveys, and these would not be
included in our list of surveys.

We have taken several steps to ensure that the database of OMB-approved
information collections correctly recorded agency-submitted data and
contained records of all Forms 83-I submitted to OMB. Our report, entitled

Paperwork Reduction Act: New Approach May Be Needed to Reduce Burden on
Public, [11]GAO-05-424 (Washington, D.C.: May 20, 2005), examined the
reliability of the database of OMB-approved information collections and
concluded that the data were accurate and complete for the purposes of
that report. Because this assessment was recent, we decided that we would
not repeat this assessment. We did, however, compare a sample of the
surveys from the Inventory of Approved Information Collection on OMB's Web
site to our copy of the database of OMB-approved collections. We found
that all of the surveys in the Inventory of Approved Information
Collection were contained in the database.

Not all information collections require OMB approval under the PRA. OMB's
draft Implementing Guidance for OMB Review of Agency Information
Collection explains that in general, collections of information conducted
by recipients of federal grants do not require OMB approval unless the
collection meets one or both of the following two conditions:

(1) the grant recipient is collecting information at the specific request
of the sponsoring agency or (2) the terms and conditions of the grant
require that the sponsoring agency specifically approve the information
collection or collection procedures. As also stated in the OMB draft,
information collections that are federally funded by contracts do not
require OMB approval unless the information collection meets one or both
of the following two conditions: (1) if the agency reviews and comments
upon the text of the privately developed survey to the extent that it
exercises control over and tacitly approves it or (2) if there is the
appearance of sponsorship, for example, public endorsement by an agency,
the use of an agency seal in the survey, or statements in the instructions
of the survey indicating that the survey is being conducted to meet the
needs of a federal agency. Although there are additional surveys funded
through grants and contracts that are not approved by OMB under the PRA,
OMB stated that there is no comprehensive list. In addition, the draft
guidance states that the PRA does not apply to current employees of the
federal government, military personnel, military reservists, and members
of the National Guard with respect to all inquiries within the scope of
their
employment and for purposes of obtaining information about their duty
status.

For the second objective describing current agency and OMB roles in
identifying and preventing unnecessary duplication, we took several
different steps. We reviewed the PRA requirements for agencies and OMB. We
also interviewed agency clearance officers at the Departments of Commerce,
Health and Human Services, and Labor about their processes for submitting
information collection packages to OMB. These agencies are the top three
agencies in terms of funding for statistical activities in fiscal year
2006. We also interviewed OMB officials about their role in approving
proposed information collections.

For the third objective, through reviewing our reports and literature and
by interviewing agency officials, we identified surveys with duplicative
content. We identified duplication by looking for areas of potential
duplication when several surveys contained questions on the same subject.
This duplication was strictly based on similar content in the surveys on
the same subject, specifically people without health insurance and those
with disabilities. We also looked at the duplication in the subject area
of housing between the American Community Survey and American Housing
Survey, which had been identified by our previous work. We also looked at
environmental surveys, but determined that there was not duplicative
content with our major surveys. Once we had identified the three subject
areas, we used literature and interviews to identify the current federally
funded surveys that were cited as the major surveys in each theme. We did
not focus on any particular type of survey, but rather chose the surveys
that were cited as the major surveys in each theme. To learn more about
the duplicative content between surveys related to these three themes, we
reviewed relevant literature and agency documents. We also interviewed
officials from OMB, and the Departments of Commerce, Labor, Health and
Human Services, and Housing and Urban Development. In addition, we
interviewed experts from organizations that focus on federal statistics,
such as at the Council of Professional Associations on Statistics and the
Committee on National Statistics, National Academies of Science.

Although we have included the Census Bureau's Survey of Income and Program
Participants as part of our assessment of potential duplication, the
fiscal year 2007 President's budget proposed to cut Census Bureau funding
by $9.2 million, to which the Census Bureau responded by stating that it
would reengineer the SIPP. Therefore, the fate of the SIPP is uncertain,
and reengineering has not been completed.

For the fourth objective, we also interviewed OMB officials, agency
officials, and organizations that focus on federal statistics. Through the
combination of agency and OMB interviews, expert interviews, and research,
we identified selected agency efforts to improve the efficiency and
relevance of surveys.

Appendix II: Comments from the Department of Housing and Urban Development

Appendix II: Comments from the Department of Housing and Urban Development

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Bernice Steinhardt, (202) 512-6543 or [email protected]

  Staff Acknowledgments 
  
In addition to the contact named above, key contributors to this report
were Susan Ragland, Assistant Director; Maya Chakko; Kisha Clark; Ellen
Grady; Elizabeth M. Hosler; Andrea Levine; Jean McSween;
Elizabeth Powell; and Greg Wilmoth.

(450414)

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References

Visible links
1. http://www.gao.gov/cgi-bin/getrpt?GAO-05-325SP
2. http://www.gao.gov/cgi-bin/getrpt?GAO-05-424
3. http://www.gao.gov/cgi-bin/getrpt?GAO-02-956R
4. http://www.gao.gov/cgi-bin/getrpt?GAO-05-424
5. http://www.gao.gov/cgi-bin/getrpt?GAO-05-424
6. http://www.gao.gov/cgi-bin/getrpt?GAO-02-598T
7. http://www.gao.gov/cgi-bin/getrpt?GAO-05-424
8. http://www.gao.gov/cgi-bin/getrpt?GAO-02-956R
9. http://www.gao.gov/cgi-bin/getrpt?GAO-05-342
  10. http://www.gao.gov/cgi-bin/getrpt?GAO-02-956R
  11. http://www.gao.gov/cgi-bin/getrpt?GAO-05-424
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