Federal Paperwork: General Purpose Statistics and Research Surveys of
Businesses (Letter Report, 09/20/1999, GAO/GGD-99-169).
Pursuant to a congressional request, GAO provided information on the
federal paperwork burden, focusing on the: (1) paperwork burden
associated with federal agencies' general purpose statistics and
research (GPS/R) surveys that are directed towards businesses; (2)
nature, use, and burden of selected GPS/R surveys; and (3) agencies'
efforts to reduce the burden associated with the selected surveys.
GAO noted that: (1) GPS/R surveys account for an extremely small
proportion of the estimated paperwork burden that federal agencies
impose on businesses; (2) nevertheless, federal agencies estimated that
businesses spent 12.6 million hours responding to 180 of these surveys
in fiscal year (FY) 1998; (3) GAO estimates that all businesses'
financial costs to complete these 180 surveys were between about $219
million and $305 million; (4) two federal agencies--the Bureau of the
Census and the Bureau of Labor Statistics (BLS)--accounted for more than
half of the estimated governmentwide GPS/R burden-hour total; (5) within
these two agencies, 14 large surveys, each with at least 100,000
estimated burden hours, accounted for nearly two-thirds of the
governmentwide GPS/R burden-hour estimate; (6) the characteristics of
the 14 large Census and BLS GPS/R surveys directed at businesses varied
widely; (7) six of these surveys were part of the Economic Census, which
is taken every 5 years, covers virtually all businesses, and serves to
update many other business statistics; (8) other large GPS/R surveys
were more frequent, more limited in the number of businesses surveyed,
covered only certain types of businesses, or addressed more specialized
topics; (9) survey topics ranged from changes in the selling prices of
goods and services to the characteristics of businesses owned by
minorities and women; (10) the statutes requiring or authorizing the
surveys generally provide the agencies with a substantial degree of
discretion to determine the scope, substance, and, in some cases,
frequency of the surveys; (11) all of the surveys provide economic
information that is widely used by federal, state, and local
governments, businesses, and the general public; (12) although the
agencies indicated that responses to 5 of the 14 surveys were voluntary,
some of these voluntary surveys are mandatory in certain states under
the laws of those states; (13) Census and BLS estimated that these 14
surveys imposed $179 million in financial costs on businesses in FY
1998; and (14) both BLS and Census have taken steps to minimize or
reduce the burden associated with these 14 GPS/R surveys, including: (a)
designing and administering the survey instruments to minimize burden on
the survey respondents; (b) using information technology to enable
businesses to respond to surveys electronically; and (c) using
administrative records in other agencies as a substitute for or a
supplement to surveying the businesses directly.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GGD-99-169
TITLE: Federal Paperwork: General Purpose Statistics and Research
Surveys of Businesses
DATE: 09/20/1999
SUBJECT: Data collection
Reporting requirements
Statistical data
Statutory law
Surveys
Projections
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United States General Accounting Office GAO Report
to the Honorable Sue W. Kelly Chairwoman, Regulatory Reform and
Paperwork Subcommittee, House Committee on Small Business
September 1999 FEDERAL PAPERWORK General Purpose Statistics and
Research Surveys of Businesses GAO/GGD-99-169 United States
General Accounting Office GAO Washington, D.C.
20548 General Government Division B-281700 September 20, 1999 The
Honorable Sue W. Kelly Chairwoman, Regulatory Reform and Paperwork
Reduction Subcommittee Committee on Small Business House of
Representatives Dear Madam Chairwoman: The information collected
by federal agencies is an integral tool for accomplishing their
missions. Agencies collect information for a variety of purposes,
including to verify regulatory and tax compliance, determine
eligibility for benefits, evaluate the effectiveness of federal
programs, develop economic statistics, and conduct research.
However, these information collections also impose a burden on
those individuals, businesses, and others asked or required to
provide the information. Federal paperwork is commonly measured in
terms of "burden hours," and federal agencies estimated that they
imposed nearly 7 billion burden hours of paperwork in fiscal year
1998.1 Previous studies have indicated that, among businesses,
small businesses can be disproportionately burdened by federal
regulatory requirements.2 Some small businesses have expressed
concerns about the number of surveys federal agencies ask them to
complete, the amount of time it takes them to complete the
surveys, and the compulsory nature of some of the surveys. To help
address these concerns, you asked us to describe (1) the paperwork
burden associated with federal agencies' general purpose
statistics and research (GPS/R) surveys that are directed towards
businesses; (2) the nature, use, and burden of selected GPS/R
surveys; and (3) the agencies' efforts to reduce the burden
associated with the selected surveys. GPS/R surveys account for an
extremely small proportion (0.3 percent) of Results in Brief
the estimated paperwork burden that federal agencies impose on
businesses. Nevertheless, federal agencies estimated that
businesses spent 12.6 million hours responding to 180 of these
surveys in fiscal year 1998. 1The burden-hour figures used in this
report are, unless otherwise indicated, for information
collections approved by the Office of Management and Budget (OMB)
at end of fiscal year 1998 (September 30, 1998). We refer to those
collections in this report as burden imposed in fiscal year 1998.
2Thomas D. Hopkins, A Survey of Regulatory Burdens, June 1995
report to the Small Business Administration. Page 1
GAO/GGD-99-169 Federal Paperwork B-281700 We estimate that all
businesses' financial costs to complete these 180 surveys were
between about $219 million and $305 million. However, the costs
imposed on an individual business to complete even several of
these surveys may be quite small. Businesses are frequently
required to respond to the surveys and may face possible criminal
or civil sanctions for failure to do so. Two federal agencies-the
Census Bureau in the Department of Commerce and the Bureau of
Labor Statistics (BLS) in the Department of Labor (DOL)-accounted
for more than half of the estimated governmentwide GPS/R burden-
hour total. Within these 2 agencies, 14 large surveys, each with
at least 100,000 estimated burden hours, accounted for nearly two-
thirds of the governmentwide GPS/R burden- hour estimate. The
characteristics of the 14 large Census and BLS GPS/R surveys
directed at businesses varied widely. Six of these surveys were
part of the Economic Census, which is taken every 5 years, covers
virtually all businesses, and serves to update many other business
statistics. Other large GPS/R surveys were more frequent, more
limited in the number of businesses surveyed, covered only certain
types of businesses, or addressed more specialized topics. Survey
topics ranged from changes in the selling prices of goods and
services to the characteristics of businesses owned by minorities
and women. The agencies' estimates of the time needed to complete
each survey varied from a few minutes to 6 hours. The estimated
number of respondents ranged from about 27,000 for one survey to
more than 2 million in others. The statutes requiring or
authorizing the surveys generally provide the agencies with a
substantial degree of discretion to determine the scope,
substance, and, in some cases, frequency of the surveys. All of
the surveys provide economic information that is widely used by
federal, state, and local governments; businesses; and the general
public. Although the agencies indicated that responses to 5 of the
14 surveys were voluntary, some of these "voluntary" surveys are
mandatory in certain states under the laws of those states. Census
and BLS estimated that these 14 surveys imposed $179 million in
financial costs on businesses in fiscal year 1998. Both BLS and
Census have taken steps to minimize or reduce the burden
associated with these 14 GPS/R surveys, including (1) designing
and administering the survey instruments to minimize burden on the
survey respondents, (2) using information technology to enable
businesses to respond to surveys electronically, and (3) using
administrative records in other agencies as a substitute for or a
supplement to surveying the businesses directly. However, both
agencies said that statutory confidentiality restrictions are an
obstacle to greater burden reduction Page 2
GAO/GGD-99-169 Federal Paperwork B-281700 through data sharing.
The executive branch has proposed and Congress has introduced
legislation to address this issue. The Paperwork Reduction Act of
1995 (PRA) requires federal agencies to Background minimize the
paperwork burden that they impose on individuals, small
businesses, and others through their collections of information.
At the same time, the PRA recognizes that information is a
critical resource enabling the federal government to perform its
most basic functions. The original PRA in 1980 established the
Office of Information and Regulatory Affairs (OIRA) within OMB to
provide central agency leadership and oversight of governmentwide
efforts to reduce unnecessary paperwork and improve the management
of information resources. The 1995 PRA gave OIRA and executive
branch agencies significant new responsibilities,3 but continued
the requirement that agencies obtain OIRA approval before
collecting information from the public. It also required OIRA to
set annual burden-reduction goals totaling at least 25 percent for
the 3-year period ending on September 30, 1998. As part of its
review process, OIRA requires that agencies submit a completed OMB
Form 83-I along with other materials to justify a proposed
information collection. The Form 83-I provides the agency's
estimate of the number of burden hours for the collection, which
is based on (1) the estimated amount of time needed by each
respondent to provide the requested information, (2) the number of
respondents for the collection, and (3) the frequency of the
collection. The Form 83-I also indicates the primary purpose of
the collection (e.g., general purpose statistics, research, or
regulatory or compliance monitoring); the primary target of the
collection (e.g., businesses, individuals, or state and local
governments); and whether responding to the survey is voluntary or
mandatory. When OIRA completes its review, information from the
Form 83-I is to be entered into a database maintained by the
Regulatory Information Service Center (RISC).4 OIRA uses the RISC
database and other information to develop its annual Information
Collection Budget, which contains governmentwide data on the
number of approved information collections each year and the
agencies' burden-hour estimates as of September 30 of each year.
3For a discussion of some of those responsibilities, see
Regulatory Management: Implementation of Selected OMB
Responsibilities Under the Paperwork Reduction Act (GAO/GGD-98-
120, July 9, 1998). 4RISC is part of the General Services
Administration but works closely with OMB to provide the
President, Congress, and the public with information on federal
regulations. RISC maintains a database that includes information
on all regulatory actions and all information collection review
actions by OIRA. Page 3
GAO/GGD-99-169 Federal Paperwork B-281700 The PRA also makes OIRA
responsible for governmentwide statistical policy and coordination
of the federal statistical system. The PRA requires OIRA to ensure
the efficiency and effectiveness of the system and the integrity,
objectivity, impartiality, utility, and confidentiality of data
collected for statistical purposes. The PRA also requires OIRA to
develop and oversee the implementation of governmentwide guidance
concerning statistical collection procedures and methods.
Additionally, the PRA mandated the establishment of an Interagency
Council on Statistical Policy, composed of the heads of major
statistical programs and representatives of other statistical
agencies, to advise and assist OIRA on statistical issues. We have
issued several reports and testimonies on the implementation of
Previous Reports and the PRA, noting that the burden reduction
goals envisioned in it were not Testimonies being
met.5 Agencies frequently pointed to new and existing statutory
requirements for information collection as impediments to
achieving the goals. We also noted a variety of problems with the
"burden-hour" measures that are used as indicators of the
paperwork burden and said that it is important to recognize the
difference between the government's "measured" paperwork burden
that is reflected by the number of burden hours an agency reports
and the "real" burden that is felt by the public. Users of
paperwork burden-hour estimates need to proceed with great caution
because it is often unclear exactly what the burden estimates
represent and what factors can cause changes in the totals.
Nevertheless, these measures are the best indicators of paperwork
burden available, and they can be useful as long as their
limitations are considered. Although one of the key purposes of
the PRA is to reduce paperwork and minimize burden on the public
and businesses, the PRA also requires agencies to balance burden
reduction goals against agencies' needs for information critical
to performing their missions. For the federal statistical system,
after years of retrenchment, there has been renewed national
recognition in the 1990's of the importance of federal statistics
and a commitment to improve the quality of the system. We have
issued several reports and testimonies on major initiatives to
improve the quality of federal economic statistics.6 In 1990 and
1991, the Council of Economic 5Paperwork Reduction: Burden
Reduction Goal Unlikely To Be Met (GAO/T-GGD/RCED-96-186, June 5,
1996); Paperwork Reduction: Governmentwide Goals Unlikely To Be
Met (GAO/T-GGD-97-114, June 4, 1997); and Paperwork Reduction Act:
Implementation at IRS (GAO/GGD-99-4, Nov. 16, 1998). 6For example,
Economic Statistics: Status Report on the Initiative to Improve
Economic Statistics (GAO/GGD-95-98, July 7, 1995); Federal
Statistics: Principal Statistical Agencies' Missions and Funding
(GAO/GGD-96-107, July 1, 1996); Statistical Agencies: Statutory
Requirements Affecting Government Policies and Programs (GAO/GGD-
96-106, July 17, 1996); Statistical Agencies: Consolidation and
Page 4
GAO/GGD-99-169 Federal Paperwork B-281700 Advisors, chaired by
Michael Boskin, reviewed national economic statistics and
announced a group of recommendations to improve the quality of
economic statistics. The recommendations from the two "Boskin
reports," formally known as the Economics Statistics Initiative,
have subsequently been a key part of the federal government's long
range statistical plan described in the Statistical Programs of
the United States Government: Fiscal Year 1999 that is produced
annually by OMB. Recommended improvements in those reports would
require more frequent collection of some data, revised measures of
key economic indicators, and the development of new measures for
emerging industries and services. However, collecting more
information to improve these economic statistics may conflict with
agencies' efforts to reduce paperwork burden. The Boskin reports
and OMB also recommended increased data sharing among statistical
agencies to reduce burden. OMB developed a legislative proposal to
permit greater data sharing while preserving the confidentiality
protections in existing law. Relatedly, data-sharing legislation
has been introduced in each recent session of Congress. We have
supported these proposals to revise existing law to permit greater
data sharing in our prior reports and testimonies. We used RISC
data to describe the paperwork burden associated with Scope and
federal agencies' GPS/R surveys that were directed toward
businesses as Methodology of September 30, 1998 (the end of
fiscal year date that OMB uses in its annual Information
Collection Budget). RISC provided data on agencies' burden-hour
estimates for all information collections, those directed
primarily at businesses, and business surveys whose primary
purpose was to develop general purpose statistics or conduct
research. Of the GPS/R surveys on business, RISC provided data by
agency, by whether responses were voluntary or mandatory, and by
individual collection within certain agencies with large burden-
hour totals. Using Census and BLS estimates of wage rates from 14
large information collections, we developed estimates of the
annual governmentwide costs to businesses of responding to all
GPS/R surveys. To describe the characteristics of the 14 large
GPS/R surveys within Census and BLS, we obtained information that
agencies submitted on the Form 83-I and in supplementary
information that described the need for the surveys, how the data
would be used, the agencies' burden-hour Quality Issues (GAO/T-
GGD-97-78, April 9, 1997); and Statistical Agencies: Proposed
Consolidation and Data Sharing Legislation (GAO/T-GGD-98-91, March
26, 1998). Page 5
GAO/GGD-99-169 Federal Paperwork B-281700 estimates, and the
agencies' efforts to reduce paperwork burden, particularly on
small businesses. We also reviewed the relevant federal statutory
provisions for the 14 surveys to determine the extent to which the
agencies had discretion in administering these surveys. We
discussed each of the 14 surveys with responsible agency officials
at BLS and Census (e.g., to determine whether these surveys were
mandatory or voluntary within certain states), and discussed
related issues (e.g., how national economic statistics are used)
with OIRA's chief statistician and staff from the statistics
branch. We obtained information on agencies' efforts to reduce the
burden associated with the 14 GPS/R surveys of businesses through
discussions with BLS, Census, and OIRA officials, and by reviewing
documentary evidence. We also asked these officials about barriers
to agencies sharing the data collected through these information
collections and initiatives to eliminate these barriers to data
sharing. Our review focused on GPS/R information collections in
effect at the end of fiscal year 1998. Because the burden
associated with the economic censuses is primarily imposed only
once every 5 years (which included fiscal year 1998), the burden-
hour estimates for the information collections would be less in
other years. Also, it is important to keep in mind that the
agencies' burden-hour estimates are estimates; it is unclear how
accurately they reflect the real burden felt by the targets of the
information collections. Some of the information in this report is
drawn from the RISC database. We did not verify the accuracy of
this database, but we did obtain updated and corrected information
for certain elements from BLS, Census, and other agencies. We did
not evaluate the effectiveness of the agencies' burden reduction
efforts or assess whether other reductions could have been made.
Neither did we independently determine how the information
collected through the GPS/R surveys is used. We conducted this
review between November 1998 and August 1999 in the Washington,
D.C., headquarters offices of Census, BLS, and OIRA in accordance
with generally accepted government auditing standards. We provided
a draft of this report to officials responsible for GPS/R surveys
policy and administration in Census, BLS, and OMB for comment.
Their responses are presented in the Agency Comments and Our
Evaluation section at the end of this report. Page 6
GAO/GGD-99-169 Federal Paperwork B-281700 The estimated paperwork
burden on businesses from GPS/R surveys in Most GPS/R Survey
fiscal year 1998 was a very small portion of the estimated burden
on Burden on Businesses businesses from all types of collections.
Nevertheless, the 180 GPS/R surveys approved by OIRA represented a
substantial aggregate burden on Was Imposed by
those businesses that had to complete the surveys-an estimated
12.6 Census and BLS million burden hours,
or between $219 million and $305 million in business' compliance
costs. Fourteen surveys administered by Census and BLS accounted
for nearly two-thirds of the governmentwide GPS/R burden-hour
estimate on businesses. As of September 30, 1998, OIRA had
authorized federal agencies to collect GPS/R Surveys Are Small
information from businesses, individuals, and others through a
total of Portion of Businesses' 6,755 information
collections. The agencies estimated that the paperwork Paperwork
Burden burden associated with all of these
information collections was nearly 7 billion burden hours. As
figure 1 shows, roughly two-thirds (4.6 billion) of these burden
hours were from information collections that were primarily
directed toward businesses. Figure 1: Burden Hours by Type of
Respondent Source: RISC database. As figure 2 shows, most of the
4.6 billion burden hours on businesses were associated with
information collections primarily intended for regulatory or
compliance reporting. About three-tenths of 1 percent of the 4.6
billion Page 7 GAO/GGD-99-
169 Federal Paperwork B-281700 burden hours on businesses (12.6
million burden hours) was from 180 information collections whose
primary purpose was to develop general purpose statistics or
research. Figure 2: Burden Hours on Businesses by Type of
Information Collection Source: RISC database. Most GPS/R Burden
Hours Are For more than three-quarters (9.8 million)
of the 12.6 million burden hours From Surveys With Mandatory
associated with GPS/R surveys primarily directed toward
businesses, the Responses
businesses were required to respond to the surveys. Although
failure to respond to the surveys could result in possible federal
criminal or civil sanctions, officials at OIRA, BLS, and Census
told us that they were unaware of any such sanctions being imposed
for failure to respond to a mandatory survey. In nearly all of the
remaining surveys (about 3 million burden hours), the respondents
were under no federal obligation to respond.7 However, as will be
discussed later in this report, some of these "voluntary" surveys
were made mandatory under the laws of certain states. 7Surveys
accounting for less than one-half of 1 percent of the
governmentwide GPS/R burden-hour estimate were coded in the RISC
database as voluntary but required for benefits. Page 8
GAO/GGD-99-169 Federal Paperwork B-281700 As shown in table 1,
more than 80 percent of the burden associated with Census and BLS
Imposed GPS/R surveys on businesses was from
collections administered by two Most GPS/R Survey Burden
departments-the Department of Commerce (about 66 percent) and DOL
on Businesses (about 15 percent).
Within the Department of Commerce, 7.8 million of the 8.3 million
GPS/R burden hours were associated with surveys administered by
Census. Similarly, BLS accounted for almost all of DOL's 1.9
million GPS/R burden hours and surveys on businesses. Table 1:
Number of Total Burden Hours
Burden hours Percent of total Number of by Agency
Department/Agency (millions) burden
hours surveys Commerce
8.3 66% 61 Bureau of the Census
(7.8) (62) (41) Labor
1.9 15 15 Bureau of Labor Statistics
(1.9) (15) (14) Treasury
0.6 5 24 Health and Human Services
0.5 4 18 Energy
0.5 4 12 Other departments and
agencies 0.8 6 50
Total 12.6
100 180 Source: RISC database. Within Census and BLS,
the paperwork burden is similarly concentrated in a few surveys.
Eight Census surveys and six BLS surveys account for about 85
percent of each bureau's GPS/R survey burden on businesses.
Together, these 14 surveys accounted for nearly two-thirds (8.4
million hours) of the governmentwide GPS/R burden-hour estimate.
Although paperwork burden has traditionally been reported in terms
of GPS/R Surveys Impose burden hours, federal
agencies' information collection requirements Substantial
Aggregate Labor impose real financial costs on individuals and
organizations providing the Costs on Businesses
information. For businesses, those costs include the (1) financial
resources expended to cover capital, operating, and maintenance
costs for equipment, supplies, and nonlabor services (e.g.,
information technology systems and monitoring equipment) and (2)
wages of employees responding to the collection. BLS and Census
officials indicated that employee wage costs account for virtually
all of GPS/R survey respondents' financial costs. In recent years,
OMB has required agencies to convert burden hours into dollar
costs and report these estimates in their submissions to OMB. To
do so, agencies must estimate a wage rate that would be applicable
to the burden hours associated with the collection, including
overhead and fringe benefit costs related to the employee's time
(e.g., health insurance and Page 9
GAO/GGD-99-169 Federal Paperwork B-281700 contributions to a
retirement plan).8 As will be discussed in detail later in this
report (see table 6), Census and BLS estimated respondents' wage
rates for the 14 large GPS/R surveys range from $9.59 per hour to
$30.00 per hour. Using these agency estimates, we calculated that
businesses' cost for completing all 14 of these surveys would be
about $179 million. The estimated wage rates in these 14 surveys
can serve as a rough guide for estimating the costs to businesses
of responding to all GPS/R surveys. As table 2 shows, if the wage
rates associated with the other 166 GPS/R surveys of businesses
(4.2 million burden hours) were as low as $9.59 per hour, the cost
associated with completing those surveys would be about $40
million. However, if the wage rates were as high as $30 per burden
hour, the businesses' cost for the surveys would be about $126
million. By adding these figures to the $179 million costs of the
14 largest surveys, we estimated that businesses' cost associated
with all 180 GPS/R surveys was between $219 million and $305
million. Table 2: Estimated Labor Costs of
Estimated range of labor GPS/R Surveys of Businesses
Burden costs (millions) Number
of hours Source
surveys (millions) Lower bound Upper bound Large BLS and Census
surveys 14
8.4 $179 $179 Other
surveys
166 4.2 $40a
$126b Total
180 12.6 $219
$305 aThis estimate assumes labor costs of $9.59 per hour. bThis
estimate assumes labor costs of $30.00 per hour. Source: The
number of surveys and burden hours are from the RISC database.
Cost estimates for the l4 large BLS and Census surveys are from
the agencies' Form 83-I packages. (See table 6.) Upper- and lower-
bound labor cost estimates are based on wage rate ranges from BLS
and Census surveys. The characteristics of the 14 large Census and
BLS GPS/R surveys varied Census and BLS GPS/R widely. Some of the
surveys applied to all businesses, but others were Surveys Vary
but limited to certain sectors or types of
businesses. The statutes requiring or authorizing the surveys
generally provide the agencies with a substantial Collectively
Impose degree of discretion to determine the
scope, substance, and in some cases, Substantial Burden on
frequency of the surveys. Survey topics ranged from changes in the
selling Businesses prices of goods and
services to the characteristics of businesses owned by minorities
and women. The agencies' estimates of the time needed to complete
each survey varied from a few minutes to 3.5 hours. Also, the
frequency of data collection differs across the surveys. Some of
the surveys are conducted monthly, but others are administered
only once 8In the fiscal year 1999 Information Collection Budget,
OIRA said "the proper accounting of such overhead and fringe
benefits has been an area of inconsistency and weakness in the
present system of burden estimation." Page 10
GAO/GGD-99-169 Federal Paperwork B-281700 every 5 years. The
number of respondents ranges from about 27,000 for one survey to
more than 2 million in others. All of the surveys provide economic
information that is widely used by federal, state, and local
governments; businesses; and the general public. Although the
agencies indicated that responses to 5 of the 14 surveys were
voluntary, some of these surveys are mandatory in certain states.
Together, Census and BLS estimate that these GPS/R surveys of
businesses account for about two-thirds of the governmentwide
burden-hour estimate for those surveys, or $179 million in
aggregate costs. As tables 3 and 4 show, the scope and subject
matter of the 14 Census and Surveys' Subject Matter and BLS
surveys of businesses that constitute the bulk of the agencies'
GPS/R Scope Differ burden-hour estimates
varied substantially. Some of the surveys collected information
about all businesses (e.g., the Producer Price Index), while
others focused on particular sectors (e.g., the various economic
censuses) or ownership groups (e.g., the Surveys of Minority- and
Women-Owned Business Enterprises). The topics covered by these
surveys were equally diverse, ranging from changes in businesses'
selling prices to comprehensive information on establishments'
employment, payroll, and geographic location. Page 11
GAO/GGD-99-169 Federal Paperwork B-281700 Table 3: Eight Surveys
Accounted for Most of Census' GPS/R Burden-Hour Estimate in Fiscal
Year 1998 Survey title
Description 1. Economic Census of the Wholesale Trade Sector
Every 5 years, this survey is to be conducted on the universe of
businesses in the wholesale trade industry. It is to collect facts
about the structure and functioning of the economy and features
unique to this industry, such as sales by commodity line and class
of customer, the number of establishments, sales, payroll,
employment, and geographic location. 2. Economic Census of
Manufactures Every 5 years, this
survey is to be conducted on the universe of businesses in the
manufacturing industry. It is to collect facts about the structure
and functioning of the economy and features unique to this
industry, such as materials consumed, inventories held, the number
of establishments, payroll, employment, and geographic location.
3. Economic Census of Utilities; Transportation;
Every 5 years, this survey is to be conducted on the universe of
businesses Information; Finance and Insurance; and Real Estate,
in all of the listed sectors. It is to collect facts about the
structure and Rental, and Leasing Sectors
functioning of the economy and features unique to these
industries, such as amounts and sources of revenues/receipts,
insurance benefits paid to policyholders, purchased
transportation, the number of establishments, payroll, employment,
and geographic location. 4. Economic Census of Retail Trade and
Food Services Every 5 years, this survey is to be
conducted on the universe of businesses in the retail trade and
food services industry. It is to collect facts about the structure
and functioning of the economy and features unique to this
industry, such as sales by merchandise line and customer class,
the number of establishments, receipts/revenues, payroll,
employment, and geographic location. 5. Economic Census of
Professional, Scientific, and Every 5 years, this
survey is to be conducted on the universe of businesses Technical
Services; Management, Support, Waste in all of the
listed industries. It is to collect facts about the structure and
Management, and Remediation Services; Educational
functioning of the economy and features unique to these
industries, such Services; Health and Social Assistance; Arts,
as the number of establishments, receipts/revenues, payroll,
employment, Entertainment, and Recreation; and Other Services,
and geographic locations. except Public Administration Sectors 6.
Economic Census of Transportation/Commodity Flow Every
5 years, this survey is to be conducted on a sample of businesses
in Survey
the commodity flow industry. It is to collect facts about the
structure and functioning of the economy and features unique to
this industry, such as the value of shipments, commodities
shipped, modes of transportation used, number of establishments,
receipts/revenues, payroll, employment, and geographic location.
7. Survey of Minority-Owned Business Enterprises
Every 5 years, this joint survey is to be conducted as part of the
economic (SMOBE) and Survey of Women-Owned Business
census program. Unlike the other economic censuses, it surveys
only a Enterprises (SWOBE)
sample of the businesses to obtain information on businesses owned
by minorities and women. 8. Shipper's Export Declaration (SED)
Program This survey is to collect information on
individual shipments exported from the United States. Shippers are
to complete a survey form for almost every shipment, and this
information forms the basis for the official export statistics
compiled by Census.a The form itself serves as the export control
document used by Customs, the Bureau of Export Administration, and
the State Department. a As discussed later in this report, exports
between the United States and Canada do not require a SED form to
be completed. The United States and Canada have an agreement that
the United States will rely on Canadian import data for its export
statistics. Source: Supplementary documentation to the Form 83-I
for each survey. Page 12
GAO/GGD-99-169 Federal Paperwork B-281700 Table 4: Six Surveys
Accounted for Most of BLS' GPS/R Burden-Hour Estimate in Fiscal
Year 1998 Survey title
Description 1. Current Employment Survey
This survey is to collect data each month on employment, hours,
and earnings from a sample of nonfarm establishments (including
governments). This is a joint effort between BLS and the State
Employment Security Agencies (SESA). 2. Occupational Employment
Statistics This annual survey is to collect
occupational employment data on workers in a sample of businesses
by industry. It is a joint effort between BLS, DOL's Employment
and Training Administration, and the SESAs, which collect the
data. 3. Multiple Worksite Report
This quarterly survey is to collect employment and wage data from
the universe of establishments of employers who operate more than
one establishment. This is a joint effort between BLS and the
SESAs. 4. Survey of Occupational Injuries and Illnesses
This annual survey is to collect information from a sample of
businesses on the characteristics of the most serious of nonfatal
cases (i.e., those involving lost work time) and the traits of
workers sustaining such injuries and illnesses. Participating
state agencies collect and process the data from the employers and
provide it to BLS. (In other states, BLS collects the data
directly from employers.) 5. Producer Price Index
This monthly survey, formerly known as the Wholesale Price Index,
of a sample of businesses is to measure average changes in selling
prices received by domestic producers for their goods and
services. 6. Annual Refiling Survey
This annual survey, formerly known as the Standard Industrial
Classification (SIC) form, is to collect and update information on
a sample of employer's worksites, products, or services covering
one-third of the businesses each year. It is a joint effort
between BLS and the SESAs. Source: BLS Handbook of Methods (April
1997) and supplementary documentation to the Form 83-I for each
survey. All 14 BLS and Census GPS/R surveys were based on
statutory provisions Underlying Statutes Give
that either require or authorize the agencies to collect and/or
report certain BLS and Census Survey
information. However, all of the underlying statutes give the
agencies at Design Discretion least
some discretion regarding how the surveys can be designed and
administered. For example, the agency may be able to decide
whether to collect information from all covered businesses or a
sample of those businesses, or determine the number and subject
matter of questions asked in the surveys. BLS' annual Occupational
Injuries and Illnesses Survey is based, in part, on provisions in
the Occupational Safety and Health Act of 1970 (29 U.S.C. 673).
The act requires the Secretary of Labor to "develop and maintain
an effective program of collection, compilation, and analysis of
occupational safety and health statistics," and to "compile
accurate statistics on work injuries and illnesses." However, the
act does not specify the frequency with which the survey should be
conducted, the number of businesses to be contacted, or the
particular data elements in the survey. The Occupational Injuries
and Illnesses Survey is also based on the general requirements in
29 U.S.C. 2, which says that BLS "shall collect, collate, and
report at least once each year, or oftener if necessary, full and
complete statistics on the conditions of labor and the products
and Page 13
GAO/GGD-99-169 Federal Paperwork B-281700 distribution of the
products of the same." Therefore, although BLS must collect the
information on workplace injuries and illnesses (and other
"conditions of labor") at least once each year, it could do so
more frequently if it determined that more frequent collection was
necessary. However, BLS has not done so. Other statutes underlying
the surveys are somewhat more specific, but still provide broad
discretion in survey design and administration. For example, the
Census Bureau's SED Survey is based on 13 U.S.C. 301, which
requires the Secretary of Commerce to submit statistics on exports
from the United States by country and product to certain
congressional committees on quarterly and cumulative bases, and to
report monthly and cumulative international trade balances for the
United States. The statute authorizes the Secretary to collect
information from all persons exporting from the United States, and
says the Secretary "shall compile and publish such information
pertaining to exports . . . as he deems necessary or appropriate."
Therefore, although required to report the export information by
country quarterly, the Secretary has substantial discretion
regarding the specific content of the survey. Also, 13 U.S.C. 131
says that the Secretary of Commerce "shall take, compile, and
publish censuses of manufactures, of mineral industries, and of
other businesses, including the distributive trades, service
establishments, and transportation . . ." The statute also
requires that the censuses be taken every fifth year after 1968,
and that the data "relate to the year immediately preceding the
taking thereof." Therefore, the Census Bureau has no discretion
regarding the frequency of the economic censuses, the sectors on
which information is to be collected, or the year for which the
data applies. On the other hand, the agency has broad discretion
regarding what specific information to collect, and whether to
contact all businesses or a sample of businesses within each
specified sector. According to information provided by BLS,
Census, and OMB, the data GPS/R Survey Data Are collected in
the 14 large GPS/R surveys are used for many different Used for
Many Purposes purposes by both the public and private sectors.
For example, the Department of Transportation, the Federal
Emergency Management Agency, the Army Corps of Engineers, and
other agencies use data from the Census Bureau's Commodity Flow
Survey to plan transportation infrastructure. Many localities also
used the data from this survey in responding to requirements in
the Intermodal Surface Transportation Efficiency Act of 1991.
Similarly, the data collected in BLS' monthly Producer Price Index
is used by the Federal Reserve Board's Open Market Page 14
GAO/GGD-99-169 Federal Paperwork B-281700 Committee in making
decisions on monetary policy and in developing and evaluating
monetary and fiscal measures for evaluating the general business
environment. These survey data are also used in the private sector
to evaluate escalating contract costs, inventory accounting
processes, and the condition of markets. In addition, industry,
academia, legal professionals, the news media, and the general
public use the data to evaluate businesses, markets, and
characteristics of firms; prepare business plans; make economic
decisions; and conduct economic research. Other examples of how
GPS/R survey data are used include the following. * The Small
Business Administration and the Minority Business Development
Agency use data from the SMOBE/SWOBE Surveys when allocating
resources for their business assistance programs. Others use data
from these surveys to evaluate the concentration of minority-owned
businesses in particular industries or geographic areas. * DOL's
Occupational Safety and Health Administration (OSHA) and its
state-level counterparts use the data from the Occupational
Injuries and Illnesses Survey to evaluate the effectiveness of
federal and state programs to improve workplace safety and to
prioritize federal and state funds. * BLS uses the data collected
in the Multiple Worksite Report to develop the Business
Establishment List, which is used as the sampling frame for
establishment surveys, such as the Producer Price Index. *
Various private enterprises, government agencies, and organized
labor use data from the Current Employment Survey to calculate
such indexes as the Composite Index of Leading Economic
Indicators. * Information from the Annual Refiling Survey is used
in developing BLS' Business Establishment List to help ensure that
the correct SIC code, name, and physical location are assigned to
the employers' worksites for unemployment insurance records and
labor market information purposes in a particular state. State and
local officials also use these data for industrial coding
classification. In addition, state employment security agencies
use the data to administer their unemployment insurance programs.
* The SED Survey serves as the official record of export
transactions for the United States. In addition, Customs and the
Bureau of Export Administration use the data to enforce export
regulations. The Census Bureau indicated that survey recipients
were required to Response to Most Large respond to all eight
of its large GPS/R surveys because the underlying GPS/R Surveys
Was statutes require Census to collect and/or report the
information. In Mandatory addition, Census
officials said that they tend to get higher response rates Page 15
GAO/GGD-99-169 Federal Paperwork B-281700 on surveys with
mandatory response requirements than on surveys with voluntary
responses. Census officials said that the mandatory response
requirement to their surveys is traceable to 13 U.S.C. 224, which
says [w]hoever, being the owner, official, agent, person in
charge, or assistant to the person in charge, of any company,
business, institution, establishment, religious body, or
organization of any nature whatsoever, neglects or refuses, when
requested by the Secretary or other authorized officer or employee
of the Department of Commerce or bureau or agency thereof, to
answer completely and correctly to the best of his knowledge all
questions relating to his company, business, institution,
establishment, religious body, or other organization, or to
records or statistics in his official custody, contained on any
census or other schedule or questionnaire prepared and submitted
to him under the authority of this title, shall be fined not more
than $500; and if he willfully gives a false answer to any such
question, he shall be fined not more than $10,000. The survey
recipients' obligation to respond to these mandatory Census GPS/R
surveys was communicated on the survey forms themselves and, in
some cases, in cover letters sent to the recipients. For example,
the Economic Census of Retail Trade and Food Services noted in
bolded capital letters that "your response is required by law." At
the bottom of the form, also in bolded capital letters were the
words "penalty for failure to report." The SED form required
shippers to certify that they understand "civil and criminal
penalties, including forfeiture and sale, may be imposed for
making false or fraudulent statements herein, failing to provide
the requested information or for violation of U. S. laws on
exportation." Although the statute allows for the imposition of
criminal penalties for failure to respond to a survey, Census
officials told us that they have never pursued any prosecutions.
In contrast to the Census surveys, response to five of the six BLS
GPS/R surveys of businesses was voluntary at the federal level.
BLS officials said that they prefer to use voluntary surveys, and
that response rates are generally higher when a survey is
voluntary. They said one of their surveys, the Occupational
Injuries and Illnesses Survey, is mandatory because of a specific
federal statutory provision. Some "voluntary" surveys were
Although the RISC database indicated that responses to five of the
six mandatory in certain states large BLS GPS/R surveys were
voluntary at the federal level, BLS officials said that some
states and territories made four of these surveys mandatory during
fiscal year 1998. Page 16
GAO/GGD-99-169 Federal Paperwork B-281700 * Response to the
Multiple Worksite Report Survey was mandatory in 21 states, Puerto
Rico, and the Virgin Islands. * Response to the Annual Refiling
Survey was mandatory in 19 states, Puerto Rico, and the Virgin
Islands. * Response to the Current Employment Survey was
mandatory in four states and Puerto Rico. * Response to the
Occupational Employment Survey was mandatory in North Carolina.
The officials said that survey recipients' obligation to respond
varied between levels of government because BLS and the states and
territories jointly administered these surveys, and states can add
requirements and make the respondents' obligation mandatory under
state law. Although the BLS survey instruments usually indicated
that responses were voluntary,9 at least some of the cover letters
that the states include with the surveys inform the recipients of
their mandatory nature. For example, on the first page of the
Multiple Worksite Report Survey, BLS stated that "[y]our voluntary
cooperation is needed to make the results of this survey
comprehensive, accurate, and timely." However, the cover letter
added by the State of California stated that "completion of this
form is required by section 320 and 320.5 of the California
Unemployment Insurance (UI) Code." As noted earlier in this
report, agencies' annual burden-hour estimates for Large GPS/R
Surveys an information collection are a function of three
elements: (1) the time Impose Substantial needed to
complete the information collection (including reviewing the
Aggregate Paperwork instructions, searching existing data
sources, and gathering and Burden On Businesses maintaining
the needed data); (2) the number of respondents to the collection;
and (3) the frequency with which the information is collected from
the respondents within the specified year. Table 5 shows that,
although the agencies estimated that each of the 14 large GPS/R
surveys directed at businesses would require more than 100,000
burden hours of paperwork, the surveys varied substantially in
terms of these three components. For example, the agencies
estimated that some of the surveys would take only a few minutes
to complete (e.g., the Annual Refiling Survey and the Current
Employment Survey), but others were expected to take hours (e.g.,
the Economic Census of Manufactures). Most of the surveys were
conducted only once during fiscal year 1998, but others were
administered quarterly (such as the Multiple Worksite Report) or
monthly (such as the Current Employment Survey and the Producer
Price Index). Several of the surveys that were administered during
1998 are not 9BLS indicated in the Current Employment Survey that
responses were mandatory in four states. Page 17
GAO/GGD-99-169 Federal Paperwork B-281700 scheduled to be repeated
for 5 years. The number of survey respondents varied from as few
as 27,000 (the Producer Price Index) to more than 2 million (the
Annual Refiling Survey and the SMOBE/SWOBE Survey). In most cases,
the surveys that the agencies expected to take the longest to
complete were administered less frequently and to fewer
respondents than surveys expected to take only a few minutes to
complete. Table 5: Burden-Hour Estimates for Selected BLS and
Census GPS/R Surveys of Businesses in Fiscal Year 1998 Est. survey
Est. number of Est. annual completion time
respondents burden hours Survey
(minutes) Survey frequency (thousands)
(thousands) Bureau of Labor Statistics Occupational Injuries and
Illnesses Survey 54
Annually 230 207
Multiple Worksite Report 10 to
60 Quarterly 113
167 Current Employment Survey 2
to 15 Monthly 437
596 Annual Refiling Survey 5
to 15 Annually 2,086
203 Occupational Employment Survey
45 Annually 337
251 Producer Price Index Initial Visit
120 Once (6)
(13) Monthly Repricing 5 to 30
Monthly 27 378
Total
3,230 1,802 Bureau of the Census SED
3 to 11 Each shipment 159
1,316 Economic Census of Manufactures
120 to 360 Once every 5 years
210 762 Economic Census of Wholesale
Trade Sector 70 Once every 5
years 540 634
Economic Census of Transportation/
Quarterly during a 1-year Commodity Flow Survey
120 period every 5 years 100
805 Economic Census of Retail Trade
46 Once every 5 years 1,291
993 Economic Census of Professionals
37 Once every 5 years 1,443
900 Economic Census of Utilities
74 Once every 5 years 625
766 SMOBE/SWOBE
10 Once every 5 years 2,500
417 Total
6,868 6,593 Total for BLS and Census
10,098 8,395 Note 1. The estimated annual
burden hour totals reported by the agencies do not always equal
the product of the estimated completion time, frequency, and
number of respondents. Average completion time is reported as a
range for some surveys and anticipated response rate may affect
the estimated number of respondents. Note 2. The Annual Refiling
Survey is required at 3-year intervals. BLS annually surveys a
different third of the universe so that at the end of the 3-year
period, it has administered this survey to the universe. Unlike
all the other surveys we reviewed, SED surveys are completed by
the shippers at the time of the export transaction and sent to
Census. All of the other surveys are administered to the
businesses by the agencies on a monthly, quarterly, or annual
basis. The economic censuses are required every 5 years, which
happened to fall during the time frame of our review. The Economic
Census of Transportation/Commodity Flow Survey is required during
each quarter in the year that the survey is taken. Source: BLS and
Census. Page 18
GAO/GGD-99-169 Federal Paperwork B-281700 Federal paperwork can
also be measured in terms of financial costs Agencies Indicate
Surveys imposed on respondents. For businesses, those costs can
be roughly Impose Substantial divided into the cost of
the employees' time to respond to the survey and Aggregate Costs
other costs, including capital and operating expenses (e.g., the
purchase of new hardware or software systems to produce the
required information). Both BLS and Census indicated that the 14
GPS/R surveys imposed no such "other" costs. BLS and Census
estimated the cost of employees' time to respond to an information
collection by multiplying the number of burden hours associated
with an information collection by the wage rate(s) of the types of
employees needed to produce the information. According to OMB,
agencies' estimates of the wage rates for respondents should
include overhead and fringe benefit costs associated with the
employee's time (e.g., health insurance and contributions to a
retirement plan). As shown in table 6, BLS' estimates of the
respondents' hourly rates for its six largest GPS/R surveys ranged
from $9.59 to $19.91. Census estimated the respondents' hourly
wage rates for its eight largest GPS/R surveys at between $12.73
and $30.00. Multiplying the agencies' estimates of the
respondents' wage rates times their burden-hour estimates for the
14 GPS/R surveys of businesses yields a total cost to businesses
of about $179 million in fiscal year 1998. Page 19
GAO/GGD-99-169 Federal Paperwork B-281700 Table 6: Estimated
Costs Associated
Respondents' Annual burden Total costs to with
Responding to Surveys in Fiscal
wage rate per hours businesses Year 1998
Survey title hour
(thousands) (millions) Bureau of Labor Statistics
Occupational Injuries and Illnesses $12.50
207 $ 3 Multiple Worksite Report
13.72 167 2 Current
Employment Survey 9.59
596 6 Annual Refiling Survey
13.04 203 3 Occupational
Employment Survey 19.03 251
5 Producer Price Index 19.91
391 8 Total for BLS
1,815 $ 27 Bureau of the Census SED
a 1,316 $ 14 Economic Census of
Manufactures 12.93 762
10 Economic Census of Wholesale Trade Sector
30.00 634 19 Economic
Census of Transportation/Commodity Flow Survey
30.00 805 24 Economic
Census of Retail Trade 30.00
993 30 Economic Census of Professionals
30.00 900 27 Economic
Census of Utilities 30.00
766 23 SMOBE/SWOBE
12.73 417 5 Total for
Census
6,593 $152 Total (BLS and Census)
8,408 $179 aThe estimated cost per hour to
complete a SED Survey ranges from $10 for a paper submission to
$15 for an electronic submission. Of the 1.3 million burden hours,
Census estimated that about 1.1 million burden hours were for
paper responses and about 0.2 million hours were for electronic
responses. Therefore, the burden-hour cost for the paper responses
would be $10.7 million and for the electronic responses $3.7
million. Source: BLS and Census data. It is important to remember
that these are aggregate burden-hour and cost estimates for all
businesses in fiscal year 1998. The cost borne by each business
that receives one of these surveys is significantly less. For
example, recipients of the Occupational Injuries and Illnesses
Survey take an estimated 54 minutes (.9 hour) each year filling
out the form, with an associated wage rate of $12.50 per hour.
Therefore, the estimated cost to each recipient of the survey is
$11.25 per year. Although a single business may receive more than
one of these surveys each year, its aggregate burden may still not
be substantial. For example, even if a single business received
all six of the BLS GPS/R surveys and the Census Bureau's
SMOBE/SWOBE Survey in 1 year, the estimated labor cost to complete
all of the surveys would be less than $134. Page 20
GAO/GGD-99-169 Federal Paperwork B-281700 Both BLS and Census have
taken a number of steps to minimize or reduce Census and BLS Have
the burden associated with the 14 large GPS/R surveys primarily
directed Attempted to Minimize toward businesses. These steps
include (1) designing and administering the survey instruments to
minimize burden on the survey respondents, (2) Burden of GPS/R
using various types of information technology to enable businesses
to Surveys on Businesses respond to surveys electronically, and
(3) using information found in administrative records in other
agencies as a substitute or a supplement to surveying the
businesses directly. However, both agencies said that statutory
confidentiality restrictions are an obstacle to greater data
sharing, which could result in further burden reduction. Census
and BLS have attempted to design and administer their largest
Survey Design and GPS/R surveys to minimize the
burden they impose on businesses, Administration
particularly small businesses. For example, both agencies have
developed versions of some of their surveys for small businesses
with fewer or less complicated questions than versions directed to
larger businesses. In the Economic Census of Wholesale Trade,
Census sends establishments with fewer than four paid employees a
simplified version of the survey form that requests less data than
the standard form that is sent to larger employers. Similarly,
businesses with only one owner receive shorter SMOBE and SWOBE
Surveys than businesses with more than one owner. BLS and Census
have also used sampling techniques to limit the number of
businesses to whom surveys are directed. The agencies also use
special sampling procedures in some surveys that reduce the
chances of a smaller business being selected compared to larger
businesses, or of the same businesses repeatedly being selected to
respond to the survey. For example, in its Occupational Injuries
and Illnesses Survey, BLS employs a stratified random sampling
approach in selecting survey recipients.10 As a result of using
this approach, less than 4 percent of all businesses actually
receive a survey. Also, small employers (10 or fewer employees)
are prenotified in the Occupational Injuries and Illnesses Survey
that they have been selected for the survey and will need to
maintain records. In the Annual Refiling Survey, BLS annually
surveys one-third of the universe of the eligible businesses. As a
result, an individual business can only be selected for the survey
once every 3 years. Similarly, to ensure that small businesses are
not unduly burdened by the Producer Price Index Survey, BLS
changes the sample of companies surveyed every 4 to 7 years. 10In
stratified random sampling, the researcher ensures that
appropriate numbers of elements are drawn from homogeneous subsets
of the population. Page 21
GAO/GGD-99-169 Federal Paperwork B-281700 The agencies have also
attempted to minimize the surveys' burden on business by making it
as easy as possible for the business to respond to the surveys.
For example, BLS' Occupational Injuries and Illnesses Survey is
designed to allow employers who have no worker injuries or
illnesses (many of whom are small employers) to simply check a "no
injuries/illnesses" box on the survey, provide the number of
employees and hours worked, and return the survey in a postage
paid envelope. Similarly, the Census Bureau incorporated several
changes into its Economic Census of Transportation/Commodity Flow
Survey to reduce burden on businesses. For example, Census reduced
the number of establishments that were surveyed by 50 percent;
reduced the shipping period covered by the questionnaire from 2
weeks to 1 week; reduced the number of shipments per questionnaire
that respondents had to report on by 20 percent (from 50 to 40
shipments); and allowed respondents to use estimates rather than
actual numbers, particularly when generating the actual numbers
would require the respondent to incur additional expenses.
Changing the frequency of administering the surveys is another
approach that could be used to reduce burden on business. However,
in some cases the agencies are already administering the survey as
infrequently as the underlying statutes allow. Also, BLS and
Census officials indicated that administering their large GPS/R
surveys any less frequently could have a negative effect on the
primary purposes of the data collections. For example, BLS
officials indicated that federal policymakers and economic
advisors use the monthly Producer Price Index in forming and
evaluating monetary and fiscal policy and helping to evaluate the
general business environment. They indicated that if this
information were collected less frequently it would take longer to
recognize and adapt to changes in the economy. Similarly, BLS
officials said that collecting the quarterly Multiple Worksite
Report data less frequently (such as annually or semiannually)
would not provide the data necessary for certain users to produce
important economic indicators or to administer various programs at
the local, state, or national levels. In addition, Census
officials stated that conducting economic censuses less frequently
than every 5 years would diminish the time lines and usefulness of
the statistics produced and diminish the usefulness of the
economic census as a source of comprehensive information for
economic policymaking, planning, and program administration.
Likewise, Census officials said it is very important to collect
export data through SED on an ongoing basis. They said that if SED
data were collected less frequently, the government would not be
able to produce monthly statistics on the trade balance. They
indicated that this information is a valuable Page 22
GAO/GGD-99-169 Federal Paperwork B-281700 component of the
merchandise trade balance, which is one of the most sensitive and
closely watched economic indicators produced by the federal
government. Slight movements in the deficit could affect public
policy, financial decisions, or congressional actions. Census and
BLS are also using information technology in some of their Use of
Technology surveys to minimize the burden imposed on businesses
through their GPS/R surveys, to increase survey response rates,
and to obtain more accurate and up-to-date information. One common
use of technology for these surveys was some type of electronic
filing of survey responses. For example, BLS collects more than 80
percent of the responses to its Current Employment Survey
electronically. Census collects nearly half of the SED responses
in this manner. Electronic submission of the SED form cut the
estimated time needed to complete the survey from about 11 minutes
to 3 minutes. The format of those electronic responses sometimes
includes a range of techniques for a single survey, including the
use of computers, telephones, and facsimiles. For example, BLS
collects responses to the Current Employment Survey via touch-tone
data entry, computer-assisted telephone interviews, electronic
data interchange, facsimile collection, and submission of tapes
and diskettes. The agencies are continuing to develop their uses
of technology in virtually all of these large GPS/R surveys, and
have begun to provide technical assistance to businesses in their
use. For example, in 1987, Census established a National
Clearinghouse for Exporter Data Processing Services to encourage
exporters to use technology when filing their SED reports. The
Clearinghouse provides technological support to exporters, freight
forwarders, and carriers who want to file electronically but do
not have the capability to do so. Census officials said that they
are replacing an antiquated electronic exports reporting system
with a new state-of-the-art system that includes the filing of
export documentation over the Internet. When this is completed,
there is to be one automated export tracking system that would
allow exporters to enter information into a single common system
that is used by Census, the Customs Service, and other agencies.
BLS identified several specific ways it is changing its data
collection procedures to allow businesses to make better use of
information technology. For example, employers with worksites in
more than one state must currently submit their Multiple Worksite
Reports to the relevant state agencies in each state. BLS is
encouraging the use of a program to permit these employers to
electronically submit the reports to a single data collection
center that would then distribute the report to all of the
relevant Page 23
GAO/GGD-99-169 Federal Paperwork B-281700 state agencies. BLS is
also working with several private organizations that prepare
businesses' payroll and reports commercially to enable them to
offer their clients the additional service of electronically
submitting the Multiple Worksite Reports directly to BLS. Finally,
BLS officials said the agency is developing a technology-based
system for administering the Producer Price Index that could
benefit both businesses and BLS. Under this system, BLS would be
able to send businesses the price quotation forms via the computer
and allow the businesses to respond by facsimile. For several of
the 14 large GPS/R surveys, Census and BLS obtained at Use of Data
From least some of the needed data from administrative
records kept by other Administrative Records federal agencies,
by state and local agencies, or by other organizations rather than
asking the respondents to provide the same information. In at
least some of these surveys, the use of administrative records
resulted in less paperwork burden on small businesses. For
example, the Economic Censuses on Manufactures, Professionals, and
Utilities exclude most small establishments from the mail surveys,
relying instead on information from administrative files kept by
the Internal Revenue Service and the Social Security
Administration. The Census Bureau obtains more than 40 percent of
the responses to the Economic Census of Manufactures through
administrative records and more than one-quarter of the responses
to the Professionals and Utilities Censuses in this manner. In the
SED program, the United States and Canada entered into an
agreement in 1990 to share data on imports and exports, thereby
reducing the paperwork burden on shippers. In this agreement, the
Census Bureau uses Canadian data on imports from the United States
as its measure of American exports to Canada. Similarly, Canada
uses U.S. data on Canadian imports to replace the same data it had
collected from its exporters. This data-exchange agreement has
resulted in the elimination of the requirement for business
exporting products from the United States to Canada to file SEDs
for each shipment, thereby saving American exporters from
preparing an estimated 3.5 to 4.0 million SEDs annually. BLS also
uses administrative data to reduce the paperwork burden associated
with some of its GPS/R surveys. For example, businesses typically
report workplace injuries and illnesses to both BLS through its
Occupational Injuries and Illnesses Survey and to state
governments through their workers' compensation programs. However,
version "W" of the Occupational Injuries and Illnesses Survey
enables businesses in six participating states to provide less
detail on their survey response if they have already reported the
detailed information to their states' workers' Page 24
GAO/GGD-99-169 Federal Paperwork B-281700 compensation programs.
BLS obtains this information from the worker compensation agencies
in those states. In the Information Collection Budget for fiscal
year 1999, OMB identified Statutory Restrictions on seven
categories of initiatives that agencies were undertaking to reduce
Data Sharing Prevent paperwork burden. Census and BLS have
begun or completed initiatives in Further Burden Reduction
most of these categories. However, Census and BLS are statutorily
prohibited from fully utilizing one of the seven categories-data
sharing. The Census Bureau's restrictions on data sharing are in
13 U.S.C. 9, which states that no officer or employee of the
Department of Commerce or bureau or agency thereof, may "(1) use
the information furnished under the provisions of this title for
any purpose other than the statistical purposes for which it is
supplied; or (2) make any publication whereby the data furnished
by any particular establishment or individual under this title can
be identified; or (3) permit anyone other than the sworn officers
and employees of the Department or bureau or agency thereof to
examine the individual reports." This and other statutory
prohibitions on data sharing were put in place to protect the
confidentiality of survey respondents. The original PRA in 1980
gave the director of OMB the authority to direct a statistical
agency to share information it had collected with another
statistical agency. However, this authority did not apply to
information covered by laws prohibiting such disclosures. In the
early 1980s, the statistical agencies, under OMB's leadership,
proposed legislation that would have extended their ability to
share data, but legislation was not enacted. For the past 2
decades, we and others have urged legislative changes that would
allow greater sharing of data and information on data sources
among agencies. In 1979, we recommended that existing law be
amended to allow the Bureau of the Census to share information on
business establishments with other government agencies.11 More
recently, in March 1998, we said that the inability of statistical
agencies to share data is one of the most significant issues
facing the statistical system and one of the major factors
affecting the quality of data, the efficiency of the system, and
the amount of burden placed on those who provide information to
the agencies.12 11After Six Years, Legal Obstacles Continue to
Restrict Government Use of the Standard Statistical Establishment
List (GAO/GGD-79-17, May 25, 1979). 12Statistical Agencies:
Proposed Consolidation and Data Sharing Legislation (GAO/T-GGD-98-
91, Mar. 26, 1998). Page 25
GAO/GGD-99-169 Federal Paperwork B-281700 Data sharing is still an
issue of concern in both the executive and legislative branches.
One of the Clinton administration's key initiatives identified in
the Statistical Programs of the United States Government: Fiscal
Year 1999 addresses needed changes in statistical confidentiality
and data-sharing statutes and practices. Also, legislation has
been introduced in the 106th Congress (S. 205), which would, among
other things, permit limited sharing of records among designated
agencies for statistical purposes under strong safeguards. Both
Census and BLS support administration proposals to revise the
confidentiality statutes to allow data sharing among statistical
agencies. Officials in both agencies said that proposed changes
permitting greater data sharing offered a major way to reduce
burden on businesses without compromising the confidentiality or
the quality of the information collected. However, neither BLS nor
Census is able to estimate how many burden hours might be reduced
in general or for specific surveys if data- sharing legislation
were enacted. A Census official told us that the extent of burden
reduction would depend on the specific provisions of the
legislation and on how data sharing was implemented. Among the 14
surveys that we examined, the official identified instances where
Census and BLS have duplication or overlap between collections and
could potentially reduce burden by sharing. However, he said the
greater potential for reducing burden would come from the agencies
jointly reengineering survey programs to increase standardization
and reduce duplication. GPS/R surveys directed at businesses are
extremely useful to federal Conclusions agencies, state and
local governments, and to the businesses themselves. For example,
the Producer Price Index is used to make decisions on monetary
policy and to evaluate the condition of markets. Information from
the Occupational Injuries and Illnesses Survey is used to
determine the effectiveness of federal and state safety programs.
The SED data are the official record of export transactions from
the United States. These surveys also contribute data to national
economic indicators that have been developed and refined over the
years to meet the needs of economic policymakers and others for
timely, accurate, and consistent information on the state of our
national economy. Although GPS/R surveys of businesses account for
a very small portion of federal agencies' total paperwork burden,
the 12.6 million hours that agencies estimated it took all
businesses to complete GPS/R surveys in fiscal year 1998 is a
substantial paperwork burden. We estimated that businesses'
aggregate labor costs to complete these surveys ranged from Page
26 GAO/GGD-99-169 Federal
Paperwork B-281700 roughly $219 million to about $305 million.
However, the burden imposed on any one business may be quite
small. Census and BLS, which account for the bulk of the burden
hours associated with GPS/R surveys, have taken and continue to
take steps to minimize or reduce the burden associated with these
information collections. However, Census, BLS, and other
statistical agencies are unable to minimize or reduce paperwork
burden as much as possible because of statutory restrictions on
sharing data collected for statistical purposes between the
agencies. We, OMB, and the statistical agencies have supported
revising those restrictions. Doing so could reduce information
collection costs to both respondents and the agencies collecting
the data. We provided a draft of this report to officials
responsible for GPS/R survey Agency Comments and policy and
administration in Census, BLS, and OMB for their review and Our
Evaluation comment. We received oral comments from
Census and BLS on August 20, 1999, and from OMB on August 30,
1999. Each agency agreed with our overall characterization of
GPS/R surveys of businesses and our conclusions and each suggested
technical and editorial changes, which we incorporated into the
final report as appropriate. We are sending copies of this report
to Representative William J. Pascrell, Jr., Ranking Minority
Member, House Committee on Small Business' Subcommittee on
Regulatory Reform and Paperwork Reduction; the Honorable Jacob J.
Lew, Director of OMB; the Honorable Alexis M. Herman, Secretary of
Labor; and the Honorable William M. Daley, Secretary of Commerce.
We will make copies available to others on request. Page 27
GAO/GGD-99-169 Federal Paperwork B-281700 If you have any
questions regarding this report, please contact me on (202) 512-
8676. Key contributors to this assignment were Curtis Copeland,
Elizabeth Powell, and Ellen Wineholt. Sincerely yours, L. Nye
Stevens Director, Federal Management and Workforce Issues Page 28
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