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United States Government Accountability Office: 

GAO: 

Testimony: 

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

For Release on Delivery: 

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

Paperwork Reduction Act: 

New Approaches Can Strengthen Information Collection and Reduce Burden: 

Statement of Linda D. Koontz, Director: 

GAO-06-477T: 

GAO Highlights: 

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

Why GAO Did This Study: 

Americans spend billions of hours each year providing information to 
federal agencies by filling out forms, surveys, or questionnaires. A 
major aim of the Paperwork Reduction Act (PRA) is to minimize the 
burden that these information collections impose on the public, while 
maximizing their public benefit. Under the act, the Office of 
Management and Budget (OMB) is to approve all such collections. In 
addition, agency Chief Information Officers (CIO) are to review 
information collections before they are submitted to OMB for approval 
and certify that these meet certain standards set forth in the act. 

GAO was asked to testify on the implementation of the act’s provisions 
regarding the review and approval of information collections. For its 
testimony, GAO reviewed previous work in this area, including the 
results of an expert forum on information resources management and the 
PRA, which was held in February 2005 under the auspices of the National 
Research Council. GAO also drew on its earlier study of CIO review 
processes (GAO-05-424) and alternative processes that two agencies have 
used to minimize burden. For this study, GAO reviewed a governmentwide 
sample of collections, reviewed processes and collections at four 
agencies that account for a large proportion of burden, and performed 
case studies of 12 approved collections. 

What GAO Found: 

Among the PRA provisions aimed at helping to achieve the goals of 
minimizing burden while maximizing utility is the requirement for CIO 
review and certification of information collections. GAO’s review of 12 
case studies showed that CIOs provided these certifications despite 
often missing or inadequate support from the program offices sponsoring 
the collections. Further, although the law requires that support be 
provided for certifications, agency files contained little evidence 
that CIO reviewers had made efforts to get program offices to improve 
the support they offered. Numerous factors have contributed to these 
problems, including a lack of management support and weaknesses in OMB 
guidance. Because these reviews were not rigorous, OMB, the agency, and 
the public had reduced assurance that the standards in the act—such as 
minimizing burden—were consistently met. To address the issues raised 
by its review, GAO made recommendations to the agencies and OMB aimed 
at strengthening the CIO review process and clarifying guidance. OMB 
and the agencies report making plans and taking steps to address GAO’s 
recommendations. 

Beyond the collection review process, the Internal Revenue Service 
(IRS) and the Environmental Protection Agency (EPA) have set up 
processes that are specifically focused on reducing burden. These 
agencies, whose missions involve numerous information collections, have 
devoted significant resources to targeted burden reduction efforts that 
involve extensive public outreach. According to the two agencies, these 
efforts led to significant reductions in burden. For example, each 
year, IRS subjects a few forms to highly detailed, in-depth analyses, 
reviewing all data requested, redesigning forms, and involving 
stakeholders (both the information users and the public affected). IRS 
reports that this process—performed on forms that have undergone CIO 
review and received OMB approval—has reduced burden by over 200 million 
hours since 2002. In contrast, for the 12 case studies, the CIO review 
process did not reduce burden. 

When it considers PRA reauthorization, the Congress has the opportunity 
to promote new approaches, including alternatives suggested by the 
expert forum and by GAO. Forum participants made a range of suggestions 
on information collections and their review. For example, they 
suggested that OMB’s focus should be on broad oversight rather than on 
reviewing each individual collection and observed that the current 
clearance process appeared to be “pro forma.” They also observed that 
it seemed excessive to require notices of collections to be published 
twice in the Federal Register, as they are now. GAO similarly observed 
that publishing two notices in the Federal Register did not seem to be 
effective, and suggested eliminating one of these notices. GAO also 
suggested that the Congress mandate pilot projects to target some 
collections for rigorous analysis along the lines of the IRS and EPA 
approaches. Such projects would permit agencies to build on the lessons 
learned by the IRS and EPA and potentially contribute to true burden 
reduction. 

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

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Linda Koontz at (202) 512-
6240 or koontzl@gao.gov. 

[End of section] 

Madam Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the Paperwork Reduction Act 
(PRA) and federal information collections.[Footnote 1] As you know, one 
of the goals of the PRA is to help ensure that when the government asks 
the public for information, the burden of providing this information is 
as small as possible and the information itself is used effectively. In 
other words, the goal is to minimize the paperwork burden while 
maximizing the public benefit and utility of the information collected. 
To achieve this goal, the PRA includes provisions that establish 
standards and procedures for effective implementation and oversight of 
information collections.[Footnote 2] Among these provisions is the 
requirement that agencies not establish information collections without 
having them approved by the Office of Management and Budget (OMB), and 
that before submitting them for approval, agencies' Chief Information 
Officers (CIO) certify that collections meet 10 specified standards-- 
including that they avoid unnecessary duplication and reduce burden as 
much as possible. 

As you requested, I will discuss results from a May 2005 report that we 
issued on PRA processes and compliance.[Footnote 3] In that work, we 
reviewed agencies' processes to certify that information collections 
meet PRA standards, and we described alternative processes that two 
agencies have used to minimize burden. I will also discuss various 
suggestions for alternative approaches to burden reduction that the 
Congress may wish to consider. 

In preparing this testimony, we reviewed our previous work on PRA 
issues, including the results of an expert forum on information 
resources management and the PRA, which was held in February 2005. To 
convene this forum, we contracted with the National Academies' National 
Research Council, which recruited panelists with expertise in the PRA 
and related areas. The 1½ day legislative forum was attended by 
observers from our agency, OMB, the Congressional Research Service, and 
staff of the House Government Reform Committee. (Attachment 1 lists the 
participants.) 

In reviewing our previous work, we focused particularly on our May 2005 
report and a subsequent June testimony.[Footnote 4] For this report and 
testimony, we performed detailed reviews of paperwork clearance 
processes and collections at four agencies: the Department of Veterans 
Affairs (VA), the Department of Housing and Urban Development (HUD), 
the Department of Labor, and the Internal Revenue Service (IRS). 
Together, these four agencies represent a broad range of paperwork 
burdens, and in 2003, they accounted for about 83 percent of the 8.1 
billion hours of estimated paperwork burden for all federal agencies. 
Of this total, IRS alone accounted for about 80 percent.[Footnote 5] We 
also selected 12 approved collections as case studies (three at each of 
the four agencies) to determine how effective agency processes were. In 
addition, we analyzed a random sample (343) of all OMB-approved 
collections governmentwide as of May 2004 (8,211 collections at 68 
agencies) to determine compliance with the act's requirements regarding 
agency certification of the 10 standards and consultation with the 
public. We designed the random sample so that we could determine 
compliance levels at the four agencies and governmentwide. Finally, 
although the Environmental Protection Agency (EPA) was not one of the 
agencies whose processes we reviewed, we analyzed documents and 
interviewed officials concerning the agency's efforts to reduce the 
burden of its information collections. Further details on our scope and 
methodology are provided in our report. 

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

Results in Brief: 

Among the PRA provisions aimed at the goal of minimizing burden while 
maximizing utility is the requirement for CIO review and certification 
of information collections. Governmentwide, agency CIOs generally 
reviewed information collections before they were submitted to OMB and 
certified that the required standards in the act were met. However, our 
review of 12 case studies showed that CIOs provided these 
certifications despite often missing or inadequate support from the 
program offices sponsoring the collections. Further, although the law 
requires CIOs to provide support for certifications, agency files 
contained little evidence that CIO reviewers had made efforts to get 
program offices to improve the support that they offered. Numerous 
factors contributed to these problems, including a lack of management 
support and weaknesses in OMB guidance. Because these reviews were not 
rigorous, OMB, the agency, and the public have reduced assurance that 
the standards in the act--such as avoiding duplication and minimizing 
burden--were consistently met. In light of these findings, we 
recommended (among other things) that agencies strengthen the support 
provided for CIO certifications and that OMB update its guidance to 
clarify and emphasize this requirement. OMB and the agencies report 
making plans and taking steps to address GAO's recommendations. 

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

When it considers PRA reauthorization, the Congress should consider 
some new approaches, including alternatives suggested by the expert 
forum and by our findings. Forum participants developed several 
suggestions regarding the review of information collections. For 
example, they suggested that OMB should focus on broad oversight rather 
than on reviews of each individual collection; they described this 
approach as a "retail" process that appeared to have become "pro 
forma." They also observed that it seemed excessive to require notices 
of collections to be published twice in the Federal Register, as they 
are now. We too observed that publishing two notices in the Federal 
Register seemed to be ineffective, as they elicited very little public 
comment; we suggested eliminating one of them. In addition, we 
suggested that the Congress mandate pilot projects to target some 
collections for rigorous analysis along the lines of the IRS and EPA 
approaches. Such projects would permit agencies to build on the lessons 
learned by the IRS and EPA and potentially contribute to true burden 
reduction. 

Background: 

Collecting information is one way that federal agencies carry out their 
missions. For example, IRS needs to collect information from taxpayers 
and their employers to know the correct amount of taxes owed. The U.S. 
Census Bureau collects information used to apportion congressional 
representation and for many other purposes. When new circumstances or 
needs arise, agencies may need to collect new information. We 
recognize, therefore, that a large portion of federal paperwork is 
necessary and serves a useful purpose. 

Nonetheless, besides ensuring that information collections have public 
benefit and utility, federal agencies are required by the PRA to 
minimize the paperwork burden that they impose. Among the provisions of 
the act aimed at this purpose are requirements for the review of 
information collections by OMB and by agency CIOs. 

Under PRA, federal agencies may not conduct or sponsor the collection 
of information unless approved by OMB. OMB is required to determine 
that the agency collection of information is necessary for the proper 
performance of the functions of the agency, including whether the 
information will have practical utility.[Footnote 6] Consistent with 
the act's requirements, OMB has established a process to review all 
proposals by executive branch agencies (including independent 
regulatory agencies) to collect information from 10 or more persons, 
whether the collections are voluntary or mandatory. 

In addition, the act as amended in 1995 requires every agency to 
establish a process under the official responsible for the act's 
implementation (now the agency's CIO) [Footnote 7] to review program 
offices' proposed collections. This official is to be sufficiently 
independent of program responsibility to evaluate fairly whether 
information collections should be approved. Under the law, the CIO is 
to review each collection of information before submission to OMB, 
including reviewing the program office's evaluation of the need for the 
collection and its plan for the efficient and effective management and 
use of the information to be collected, including necessary 
resources.[Footnote 8] As part of that review, the agency CIO must 
ensure that each information collection instrument (form, survey, or 
questionnaire) complies with the act. The CIO is also to certify that 
the collection meets 10 standards (see table 1) and to provide support 
for these certifications. 

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

Standards: 

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

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

[End of table] 

The paperwork clearance process currently takes place in two stages. 
The first stage is CIO review. During this review, the agency is to 
publish a notice of the collection in the Federal Register. The public 
must be given a 60-day period in which to submit comments, and the 
agency is to otherwise consult with interested or affected parties 
about the proposed collection. At the conclusion of the agency review, 
the CIO submits the proposal to OMB for review. The agency submissions 
to OMB typically include a copy of the data collection instrument 
(e.g., a form or survey) and an OMB submission form providing 
information (with supporting documentation) about the proposed 
information collection, including why the collection is necessary, 
whether it is new or an extension of a currently approved collection, 
whether it is voluntary or mandatory, and the estimated burden hours. 
Included in the submission is the certification by the CIO or the CIO's 
designee that the collection satisfies the 10 standards. 

The OMB review is the second stage in the clearance process. This 
review may involve consultation between OMB and agency staff. During 
the review, a second notice is published in the Federal Register, this 
time with a 30-day period for soliciting public comment. At the end of 
this period, OMB makes its decision and informs the agency. OMB 
maintains on its Web site a list of all approved collections and their 
currently valid control numbers, including the form numbers approved 
under each collection. 

The 1995 PRA amendments also require OMB to set specific goals for 
reducing burden from the level it had reached in 1995: at least a 10 
percent reduction in the governmentwide burden-hour estimate for each 
of fiscal years 1996 and 1997, a 5 percent governmentwide burden 
reduction goal in each of the next 4 fiscal years, and annual agency 
goals that reduce burden to the "maximum practicable opportunity." At 
the end of fiscal year 1995, federal agencies estimated that their 
information collections imposed about 7 billion burden hours on the 
public. Thus, for these reduction goals to be met, the burden-hour 
estimate would have had to decrease by about 35 percent, to about 4.6 
billion hours, by September 30, 2001. In fact, on that date, the 
federal paperwork estimate had increased by about 9 percent, to 7.6 
billion burden hours. As of March 2006, OMB's estimate for 
governmentwide burden is about 10.5 billion hours[Footnote 9]--about 
2.5 billion hours more than the estimate of 7.971 billion hours at the 
end of fiscal year 2004.[Footnote 10]  

Over the years, we have reported on the implementation of PRA many 
times. [Footnote 11]In a succession of reports and testimonies, we 
noted that federal paperwork burden estimates generally continued to 
increase, rather than decrease as envisioned by the burden reduction 
goals in PRA. Further, we reported that some burden reduction claims 
were overstated. For example, although some reported paperwork 
reductions reflected substantive program changes, others were revisions 
to agencies' previous burden estimates and, therefore, would have no 
effect on the paperwork burden felt by the public. In our previous 
work, we also repeatedly pointed out ways that OMB and agencies could 
do more to ensure compliance with PRA. In particular, we have often 
recommended that OMB and agencies take actions to improve the paperwork 
clearance process. 

Agency Processes for Reviewing Information Collections Were Not 
Effective: 

Governmentwide, agency CIOs generally reviewed information collections 
before they were submitted to OMB and certified that the 10 standards 
in the act were met. However, in our 12 case studies, CIOs provided 
these certifications despite often missing or partial support from the 
program offices sponsoring the collections. Further, although the law 
requires CIOs to provide support for certifications, agency files 
contained little evidence that CIO reviewers had made efforts to get 
program offices to improve the support that they offered. Numerous 
factors have contributed to these conditions, including a lack of 
management support and weaknesses in OMB guidance. Without appropriate 
support and public consultation, agencies have reduced assurance that 
collections satisfy the standards in the act. 

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

Among the PRA provisions intended to help achieve the goals of 
minimizing burden while maximizing utility are the requirements for CIO 
review and certification of information collections. The 1995 
amendments required agencies to establish centralized processes for 
reviewing proposed information collections within the CIO's office. 
Among other things, the CIO's office is to certify, for each 
collection, that the 10 standards in the act have been met, and the CIO 
is to provide a record supporting these certifications. 

The four agencies in our review all had written directives that 
implemented the review requirements in the act, including the 
requirement for CIOs to certify that the 10 standards in the act were 
met. The estimated certification rate ranged from 100 percent at IRS 
and HUD to 92 percent at VA. Governmentwide, agencies certified that 
the act's 10 standards had been met on an estimated 98 percent of the 
8,211 collections. 

However, in the 12 case studies that we reviewed, this CIO 
certification occurred despite a lack of rigorous support that all 
standards were met. Specifically, the support for certification was 
missing or partial on 65 percent (66 of 101) of the 
certifications.[Footnote 12] Table 4 shows the result of our analysis 
of the case studies. 

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

Standards: The collection is necessary for the proper performance of 
agency functions; 
Total[A]: 12; 
Support provided: Yes: 6; 
Support provided: Partial: 6; 
Support provided: No: 0. 

Standards: The collection avoids unnecessary duplication; 
Total[A]: 11; 
Support provided: Yes: 2; 
Support provided: Partial: 2; 
Support provided: No: 7. 

Standards: The collection reduces burden on the public, including small 
entities, to the extent practicable and appropriate; 
Total[A]: 12; 
Support provided: Yes: 5; 
Support provided: Partial: 7; 
Support provided: No: 0. 

Standards: The collection uses plain, coherent, and unambiguous 
language that is understandable to respondents; 
Total[A]: 12; 
Support provided: Yes: 1; 
Support provided: Partial: 0; 
Support provided: No: 11. 

Standards: The collection will be consistent and compatible with 
respondents' current reporting and recordkeeping practices to the 
maximum extent practicable; 
Total[A]: 12; 
Support provided: Yes: 3; 
Support provided: Partial: 0; 
Support provided: No: 9. 

Standards: The collection indicates the retention period for any 
recordkeeping requirements for respondents.[B]; 
Total[A]: 6; 
Support provided: Yes: 3; 
Support provided: Partial: 3; 
Support provided: No: 0. 

Standards: The collection informs respondents of the reasons the 
information is collected; the way it is used; an estimate of the 
burden; whether responses are voluntary, required to obtain a benefit, 
or mandatory; and the fact that no person is required to respond unless 
a valid OMB control number is displayed.[B]; 
Total[A]: 12; 
Support provided: Yes: 4; 
Support provided: Partial: 8; 
Support provided: No: 0. 

Standards: The collection was developed by an office that has planned 
and allocated resources for the efficient and effective management and 
use of the information to be collected; 
Total[A]: 11; 
Support provided: Yes: 2; 
Support provided: Partial: 0; 
Support provided: No: 9. 

Standards: The collection uses effective and efficient statistical 
survey methodology (if applicable); 
Total[A]: 1; 
Support provided: Yes: 1; 
Support provided: Partial: 0; 
Support provided: No: 0. 

Standards: The collection uses information technology to the maximum 
extent practicable to reduce burden and improve data quality, agency 
efficiency, and responsiveness to the public; 
Total[A]: 12; 
Support provided: Yes: 8; 
Support provided: Partial: 4; 
Support provided: No: 0. 

Standards: Totals; 
Total[A]: 101; 
Support provided: Yes: 35; 
Support provided: Partial: 30; 
Support provided: No: 36. 

Sources: Paperwork Reduction Act, GAO. 

[A] The total number of certifications is not always 12 because not all 
certifications applied to all collections. 

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

[End of table] 

For example, under the act, CIOs are required to certify that each 
information collection is not unnecessarily duplicative. According to 
OMB instructions, agencies are to (1) describe efforts to identify 
duplication and (2) show specifically why any similar information 
already available cannot be used or modified for the purpose described. 

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

Program reviews were conducted to identify potential areas of 
duplication; however, none were found to exist. There is no known 
Department or Agency which maintains the necessary information, nor is 
it available from other sources within our Department. 

In an additional 2 cases, partial support was provided. An example is 
the following, provided by Labor [The Employer Assistance Referral 
Network (EARN)] is a new, nationwide service that does not duplicate 
any single existing service that attempts to match employers with 
providers who refer job candidates with disabilities. While similar job-
referral services exist at the state level, and some nation-wide 
disability organizations offer similar services to people with certain 
disabilities, we are not aware of any existing survey that would 
duplicate the scope or content of the proposed data collection. 
Furthermore, because this information collection involves only 
providers and employers interested in participating in the EARN 
service, and because this is a new service, a duplicate data set does 
not exist. 

While this example shows that the agency attempted to identify 
duplicative sources, it does not discuss why information from state and 
other disability organizations could not be aggregated and used, at 
least in part, to satisfy the needs of this collection. 

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

We have attempted to eliminate duplication within the agency wherever 
possible. 

This assertion provides no information on what efforts were made to 
identify duplication or perspective on why similar information, if any, 
could not be used. Further, the files contained no evidence that the 
CIO reviewers challenged the adequacy of this support or provided 
support of their own to justify their certification. 

A second example is provided by the standard requiring each information 
collection to reduce burden on the public, including small 
entities,[Footnote 13] to the extent practicable and appropriate. OMB 
guidance emphasizes that agencies are to demonstrate that they have 
taken every reasonable step to ensure that the collection of 
information is the least burdensome necessary for the proper 
performance of agency functions. In addition, OMB instructions and 
guidance direct agencies to provide specific information and 
justifications: (1) estimates of the hour and cost burden of the 
collections and (2) justifications for any collection that requires 
respondents to report more often than quarterly, respond in fewer than 
30 days, or provide more than an original and two copies of 
documentation. 

With regard to small entities, OMB guidance states that the standard 
emphasizes such entities because these often have limited resources to 
comply with information collections.[Footnote 14] The act cites various 
techniques for reducing burden on these small entities,[Footnote 15] 
and the guidance includes techniques that might be used to simplify 
requirements for small entities, such as asking fewer questions, taking 
smaller samples than for larger entities, and requiring small entities 
to provide information less frequently. 

Our review of the case examples found that for the first part of the 
certification, which focuses on reducing burden on the public, the 
files generally contained the specific information and justifications 
called for in the guidance. However, none of the case examples 
contained support that addressed how the agency ensured that the 
collection was the least burdensome necessary. According to agency CIO 
officials, the primary cause for this absence of support is that OMB 
instructions and guidance do not direct agencies to provide this 
information explicitly as part of the approval package. 

For the part of the certification that focuses on small businesses, our 
governmentwide sample included examples of various agency activities 
that are consistent with this standard. For instance, Labor officials 
exempted 6 million small businesses from filing an annual report; 
telephoned small businesses and other small entities to assist them in 
completing a questionnaire; reduced the number of small businesses 
surveyed; and scheduled fewer compliance evaluations on small 
contractors. 

For four of our case studies, however, complete information that would 
support certification of this part of the standard was not available. 
Seven of the 12 case studies involved collections that were reported to 
impact businesses or other for-profit entities, but for 4 of the 7, the 
files did not explain either: 

* why small businesses were not affected or: 

* even though such businesses were affected, that burden could or could 
not be reduced. 

Referring to methods used to minimize burden on small business, the 
files included statements such as "not applicable." These statements do 
not inform the reviewer whether there was an effort made to reduce 
burden on small entities or not. When we asked agencies about these 
four cases, they indicated that the collections did, in fact, affect 
small business. 

OMB's instructions to agencies on this part of the certification 
require agencies to describe any methods used to reduce burden only if 
the collection of information has a "significant economic impact on a 
substantial number of small entities." This does not appropriately 
reflect the act's requirements concerning small business: the act 
requires that the CIO certify that the information collection reduces 
burden on small entities in general, to the extent practical and 
appropriate, and provides no thresholds for the level of economic 
impact or the number of small entities affected. OMB officials 
acknowledged that their instruction is an "artifact" from a previous 
form and more properly focuses on rulemaking rather than the 
information collection process. 

The lack of support for these certifications appears to be influenced 
by a variety of factors. In some cases, as described above, OMB 
guidance and instructions are not comprehensive or entirely accurate. 
In the case of the duplication standard specifically, IRS officials 
said that the agency does not need to further justify that its 
collections are not duplicative because (1) tax data are not collected 
by other agencies, so there is no need for the agency to contact them 
about proposed collections, and (2) IRS has an effective internal 
process for coordinating proposed forms among the agency's various 
organizations that may have similar information. Nonetheless, the law 
and instructions require support for these certifications, which was 
not provided. 

In addition, agency reviewers told us that management assigns a 
relatively low priority and few resources to reviewing information 
collections. Further, program offices have little knowledge of and 
appreciation for the requirements of the PRA. As a result of these 
conditions and a lack of detailed program knowledge, reviewers often 
have insufficient leverage with program offices to encourage them to 
improve their justifications. 

When support for the PRA certifications is missing or inadequate, OMB, 
the agency, and the public have reduced assurance that the standards in 
the act, such as those on avoiding duplication and minimizing burden, 
have been consistently met. 

Two Agencies Have Developed Processes to Reduce Burden Associated with 
Information Collections: 

IRS and EPA have supplemented the standard PRA review process with 
additional processes aimed at reducing burden while maximizing utility. 
These agencies' missions require them both to deal extensively with 
information collections, and their management has made reduction of 
burden a priority.[Footnote 16] 

In January 2002, the IRS Commissioner established an Office of Taxpayer 
Burden Reduction, which includes both permanently assigned staff and 
staff temporarily detailed from program offices that are responsible 
for particular information collections. This office chooses a few forms 
each year that are judged to have the greatest potential for burden 
reduction (these forms have already been reviewed and approved through 
the CIO process). The office evaluates and prioritizes burden reduction 
initiatives by: 

* determining the number of taxpayers impacted; 

* quantifying the total time and out-of-pocket savings for taxpayers; 

* evaluating any adverse impact on IRS's voluntary compliance efforts; 

* assessing the feasibility of the initiative, given IRS resource 
limitations; and: 

* tying the initiative into IRS objectives. 

Once the forms are chosen, the office performs highly detailed, in- 
depth analyses, including extensive outreach to the public affected, 
the users of the information within and outside the agency, and other 
stakeholders. This analysis includes an examination of the need for 
each data element requested. In addition, the office thoroughly reviews 
form design.[Footnote 17] 

The office's Director[Footnote 18] heads a Taxpayer Burden Reduction 
Council, which serves as a forum for achieving taxpayer burden 
reduction throughout IRS. IRS reports that as many as 100 staff across 
IRS and other agencies can be involved in burden reduction initiatives, 
including other federal agencies, state agencies, tax practitioner 
groups, taxpayer advocacy panels, and groups representing the small 
business community. 

The council directs its efforts in five major areas: 

* simplifying forms and publications; 

* streamlining internal policies, processes, and procedures; 

* promoting consideration of burden reductions in rulings, regulations, 
and laws; 

* assisting in the development of burden reduction measurement 
methodology; and: 

* partnering with internal and external stakeholders to identify areas 
of potential burden reduction. 

IRS reports that this targeted, resource-intensive process has achieved 
significant reductions in burden: over 200 million burden hours since 
2002. For example, it reports that about 95 million hours of taxpayer 
burden were reduced through increases in the income-reporting threshold 
on various IRS schedules.[Footnote 19] Another burden reduction 
initiative includes a review of the forms that 15 million taxpayers use 
to request an extension to the date for filing their tax 
returns.[Footnote 20] 

Similarly, EPA officials stated that they have established processes 
for reviewing information collections that supplement the standard PRA 
review process. These processes are highly detailed and evaluative, 
with a focus on burden reduction, avoiding duplication, and ensuring 
compliance with PRA. According to EPA officials, the impetus for 
establishing these processes was the high visibility of the agency's 
information collections and the recognition, among other things, that 
the success of EPA's enforcement mission depended on information 
collections being properly justified and approved: in the words of one 
official, information collections are the "life blood" of the agency. 

According to these officials, the CIO staff are not generally closely 
involved in burden reduction initiatives, because they do not have 
sufficient technical program expertise and cannot devote the extensive 
time required.[Footnote 21] Instead, these officials said that the CIO 
staff's focus is on fostering high awareness within the agency of the 
requirements associated with information collections, educating and 
training the program office staff on the need to minimize burden and 
the impact on respondents, providing an agencywide perspective on 
information collections to help avoid duplication, managing the 
clearance process for agency information collections, and acting as 
liaison between program offices and OMB during the clearance process. 
To help program offices consider PRA requirements such as burden 
reduction and avoiding duplication as they are developing new 
information collections or working on reauthorizing existing 
collections, the CIO staff also developed a handbook[Footnote 22] to 
help program staff understand what they need to do to comply with PRA 
and gain OMB approval. 

In addition, program offices at EPA have taken on burden reduction 
initiatives that are highly detailed and lengthy (sometimes lasting 
years) and that involve extensive consultation with stakeholders 
(including entities that supply the information, citizens groups, 
information users and technical experts in the agency and elsewhere, 
and state and local governments). For example, EPA reports that it 
amended its regulations to reduce the paperwork burden imposed under 
the Resource Conservation and Recovery Act. One burden reduction method 
EPA used was to establish higher thresholds for small businesses to 
report information required under the act. EPA estimates that the 
initiative will reduce burden by 350,000 hours and save $22 million 
annually. Another EPA program office reports that it is proposing a 
significant reduction in burden for its Toxic Release Inventory 
program.[Footnote 23] 

Both the EPA and IRS programs involve extensive outreach to 
stakeholders, including the public. This outreach is particularly 
significant in view of the relatively low levels of public consultation 
that occur under the standard review process. As we reported in May 
2005, public consultation on information collections is often limited 
to publication of notices in the Federal Register.[Footnote 24] As a 
means of public consultation, however, these notices are not effective, 
as they elicit few responses. An estimated 7 percent of the 60-day 
notices of collections in the Federal Register received one or more 
comments. According to our sample of all collections at the four 
agencies reviewed, the number of notices receiving at least one comment 
ranged from an estimated 15 percent at Labor to an estimated 6 percent 
at IRS. In contrast, according to EPA and IRS, their efforts at public 
consultation are key to their burden reduction efforts and an important 
factor in their success. 

Overall, EPA and IRS reported that their targeted processes produced 
significant reductions in burden by making a commitment to this goal 
and dedicating resources to it. In contrast, for the 12 information 
collections we examined, the CIO review process resulted in no 
reduction in burden. Further, the Department of Labor reported that its 
PRA reviews of 175 proposed collections over nearly 2 years did not 
reduce burden.[Footnote 25] Similarly, both IRS and EPA addressed 
information collections that had undergone CIO review and received OMB 
approval and nonetheless found significant opportunities to reduce 
burden. 

Agencies Could Strengthen CIO Review: 

In our 2005 report, we concluded that the CIO review process was not 
working as Congress intended: It did not result in a rigorous 
examination of the burden imposed by information collections, and it 
did not lead to reductions in burden. In light of these findings, we 
recommended (among other things) that agencies strengthen the support 
provided for CIO certifications and that OMB update its guidance to 
clarify and emphasize this requirement. 

Since our report was issued, the four agencies have reported taking 
steps to strengthen their support for CIO certifications: 

* According to the HUD CIO, the department established a senior-level 
PRA compliance officer in each major program office, and it has revised 
its certification process to require that before collections are 
submitted for review, they be approved at a higher management level 
within program offices. 

* The Treasury CIO established an Information Management Sub-Council 
under the Treasury CIO Council and added resources to the review 
process. 

* According to the VA's 2007 budget submission, the department obtained 
additional resources to help review and analyze its information 
collection requests. 

* According to the Office of the CIO at the Department of Labor, the 
department intends to provide guidance to components regarding the need 
to provide strong support for clearance requests and has met with 
component staff to discuss these issues. 

OMB reported that its guidance to agencies will be updated through a 
planned automated system,[Footnote 26] which is expected to be 
operational by the end of this year. According to the acting head of 
OMB's Office of Information and Regulatory Affairs, the new system will 
permit agencies to submit clearance requests electronically, and the 
instructions will provide clear guidance on the requirements for these 
submissions, including the support required. This official stated that 
OMB has worked with agency representatives with direct knowledge of the 
PRA clearance process in order to ensure that the system and its 
instructions clearly reflect the requirements of the process. If this 
system is implemented as described and OMB withholds clearance from 
submissions that lack adequate support, it could lead agencies to 
strengthen the support provided for their certifications. 

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

In considering PRA reauthorization, the Congress has the opportunity to 
take into account ideas that were developed by the various experts at 
the PRA forum that we organized in 2005. These experts noted, as we 
have here, that the burden reduction goals in the act have not been 
met, and that in fact burden has been going up. They suggested first 
that the goal of reducing burden by 5 percent is not realistic, and 
also that such numerical goals do not appropriately recognize that some 
burden is necessary. The important point, in their view, is to reduce 
unnecessary burden while still ensuring maximum utility. 

Forum participants also questioned the level of attention that OMB 
devotes to the process of clearing collections on what they called a 
"retail" basis, focusing on individual collections rather than looking 
across numerous collections. In their view, some of this attention 
would be better devoted to broader oversight questions. In their 
discussion, participants mentioned that the clearance process informs 
OMB with respect to its other information resource management 
functions, but that this had not led to high-level integration and 
coordination. It was suggested that the volume of collections to be 
individually reviewed could impede such integration. 

Participants made a number of suggestions regarding ways to reduce the 
volume of collections that OMB reviews, with the goal of freeing OMB 
resources so that it could address more substantive, wide-ranging 
paperwork issues. Options that they suggested including limiting OMB 
review to significant and selected collections, rather than all 
collections. This would entail shifting more responsibility for review 
to the agencies, which they stated was one of the avowed purposes of 
the 1995 amendments: to increase agencies' attention to properly 
clearing information collection requests. One way to shift this 
responsibility, the forum suggested, would be for OMB to be more 
creative in its use of the delegation authority that the act provides. 
(Under the act, OMB has the authority to delegate to agencies the 
authority to approve collections in various circumstances.) Also, 
participants mentioned the possibility of modifying the clearance 
process by, for example, extending beyond 3 years the length of time 
that OMB approvals are valid, particularly for the routine types of 
collections. This suggestion was paired with the idea that the review 
process itself should be more rigorous; as the panel put it, "now it's 
a rather pro forma process." They also observed that two Federal 
Register notices seemed excessive in most cases. 

To reduce the number of collections that require OMB review, another 
possibility suggested was to revise the PRA's definition of an 
information collection. For example, the current definition includes 
all collections that contact 10 or more persons; the panel suggested 
that this threshold could be raised, pointing out that this low 
threshold makes it hard for agencies to perform targeted outreach to 
the public regarding burden and other issues (such as through customer 
satisfaction questionnaires or focus groups). However, they had no 
specific recommendation on what the number should be. Alternatively, 
they suggested that OMB could be given authority to categorize types of 
information collections that did not require clearance (for example, 
OMB could exempt collections for which the response is purely 
voluntary). 

Finally, the forum questioned giving agency CIOs the responsibility for 
reviewing information collections. According to the forum, CIOs have 
tended to be more associated with information technology issues than 
with high level information policy. 

Our previous work has not addressed every topic raised by the forum, so 
we cannot argue for or against all these suggestions. However, the work 
in our May 2005 report is consistent with the forum's observations in 
some areas, including the lack of rigor in the review process and the 
questionable need for two Federal Register notices. I would like to 
turn here, Madam Chairman, to the matters for congressional 
consideration that we included in that report. 

Our Work Suggests Ways to Explore New Approaches: 

We observed that to achieve burden reduction, the targeted approaches 
used by IRS and EPA were a promising alternative. However, the 
agencies' experiences also suggest that to make such approaches 
successful requires top-level executive commitment, extensive 
involvement of program office staff with appropriate expertise, and 
aggressive outreach to stakeholders. Indications are that such an 
approach would also be more resource-intensive than the current 
process. Moreover, such an approach may not be warranted at all 
agencies, since not all agencies have the level of paperwork issues 
that face IRS and similar agencies. 

On the basis of the conclusions in our May 2005 report, we suggested 
that the Congress consider mandating the development of pilot projects 
to test and review the value of approaches to burden reduction similar 
to those used by IRS and EPA. OMB would issue guidance to agencies on 
implementing such pilots, including criteria for assessing collections 
along the lines of the process currently employed by IRS. According to 
our suggestion, agencies participating in such pilots would submit to 
OMB and publish on their Web sites (or through other means) an annual 
plan on the collections targeted for review, specific burden reduction 
goals for those collections, and a report on reductions achieved to 
date. We also suggested that in view of the limited effectiveness of 
the 60-day notice in the Federal Register in eliciting public comment, 
this requirement could be eliminated. 

Under a pilot project approach, an agency would develop a process to 
examine its information collections for opportunities to reduce burden. 
The experiences at IRS and EPA show that targeted burden reduction 
efforts depend on tapping the expertise of program staff, who are 
generally closely involved in the effort. That is, finding 
opportunities to reduce burden requires strong familiarity with the 
programs involved. 

Pilot projects would be expected to build on the lessons learned at IRS 
and EPA. For example, these agencies have used a variety of approaches 
to reducing burden, such as: 

* sharing information--for example, by facilitating cross-agency 
information exchanges; 

* standardizing data for multiple uses ("collect once--use multiple 
times"); 

* integrating data to avoid duplication; and: 

* re-engineering work flows. 

Pilot projects would be most appropriate for agencies for which 
information collections are a significant aspect of the mission. As the 
results and lessons from the pilots become available, OMB may choose to 
apply them at other agencies by approving further pilots.[Footnote 27] 
Lessons learned from the mandated pilots could thus be applied more 
broadly. 

In developing processes to involve program offices in burden reduction, 
agencies would not have to impose a particular organizational structure 
for the burden reduction effort. For instance, the burden reduction 
effort might not necessarily be performed by the CIO. For example, at 
IRS, the Office of Burden Reduction is not connected to the CIO, 
whereas at EPA, CIO staff are involved in promoting burden reduction 
through staff education and outreach. However, the EPA CIO depends on 
program offices to undertake specific initiatives. Under a mandate for 
pilot projects, agencies would be encouraged to determine the approach 
that works best in their own situations. 

Finally, both IRS and EPA engaged in extensive outreach to the public 
and stakeholders. In many cases, this outreach involves contacts with 
professional and industry organizations, which are particularly 
valuable because they allow the agencies to get feedback without the 
need to design an information collection for the purpose (which would 
entail its own review process, burden estimate, and so on). According 
to agency officials, the need to obtain OMB approval for an information 
collection if they contact more than nine people often inhibits 
agencies' use of questionnaires and similar types of active outreach to 
the public.[Footnote 28] Agencies are free, however, to collect 
comments on information posted on Web sites. OMB could also choose to 
delegate to pilot project agencies the authority to approve collections 
that are undertaken as part of public outreach for burden reduction 
projects. 

The work we reported in May and June 2005 strongly suggested that 
despite the importance of public consultation to burden reduction, the 
current approach is often ineffective. Federal Register notices elicit 
such low response that we questioned the need for two such notices (the 
60-day notice during the agency review and the 30-day notice during the 
OMB review). Eliminating the first notice, in our view, is thus not 
likely to decrease public consultation in any significant way. Instead, 
our intent was for agencies, through pilot projects, to explore ways to 
perform outreach to information collection stakeholders, including the 
public, that will be more effective in eliciting useful comments and 
achieving real reductions in burden. 

In summary, Madam Chairman, the information collection review process 
appeared to have little effect on paperwork burden. As our review 
showed, the CIO review process, as currently implemented, tended to 
lack rigor, allowing agencies to focus on clearing an administrative 
hurdle rather than on performing substantive analysis. Going further, 
the expert forum characterized the whole clearance process as "pro 
forma." The forum also made various suggestions for improving the 
clearance process; many of these were aimed at finding ways to reduce 
its absorption of OMB resources, such as by changing the definition of 
an information collection. Both we and the forum suggested removing one 
of the current administrative hurdles (the 60-day Federal Register 
notice). 

Although these suggestions refer to specific process improvements, the 
main point is not just to tweak the process. Instead, the intent is to 
remove administrative impediments, with the ultimate aim of refocusing 
agency and OMB attention away from the current concentration on 
administrative procedures and toward the goals of the act--minimizing 
burden while maximizing utility. To that end, we suggested that the 
Congress mandate pilot projects that are specifically targeted at 
reducing burden. Such projects could help to move toward the outcomes 
that the Congress intended in enacting PRA. 

Madam Chairman, this completes my prepared statement. I would be 
pleased to answer any questions. 

Contacts and Acknowledgments: 

For future information regarding this testimony, please contact Linda 
Koontz, Director, Information Management, at (202) 512-6420, or 
koontzl@gao.gov. Other individuals who made key contributions to this 
testimony were Timothy Bober, Barbara Collier, David Plocher, Elizabeth 
Powell, J. Michael Resser, and Alan Stapleton. 

[End of section] 

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

Forum Participants: 

Prudence S. Adler; 
Associate Executive Director Association of Research Libraries. 

William Barron; 
Princeton University; 
formerly National Opinion Research Center. 

Gary Bass; 
Founder and Executive Director, OMB Watch. 

Maya Bernstein; 
Administrative Law & Information Policy; formerly OMB and IRS Privacy 
Officer. 

Daniel Chenok; 
Vice President, SRA International; formerly OMB. 

Sharon S. Dawes; 
Director, Center for Technology in Government, University at Albany, 
State University of New York. 

James Flyzik; 
Partner, Guerra, Kiviat, Flyzik and Associates; 
formerly Department of Treasury and Secret Service. 

Robert M. Gellman; 
Privacy & Information Policy Consultant; 
formerly counsel to the House of Representatives' Subcommittee on 
Information, Justice, Transportation and Agriculture. 

Harry A. Hammitt; 
Editor of Access Reports, FOIA Journal. 

Jefferson Hill; 
Independent Consultant; 
formerly OMB. 

Sally Katzen; 
Professor and Independent Consultant; 
formerly OMB. 

Andrew Langer; 
Manager, Regulatory Policy National Federation of Independent Business. 

David LeDuc; 
Director, Public Policy, Software & Information Industry Association. 

Herb Lin; 
Senior Scientist, Computer Science and Telecommunications Board, The 
National Academies. 

Jeffrey Lubbers; 
Fellow in Law and Government, American University, Washington College 
of Law; 
formerly Administrative Conference of the U.S. 

Charles McClure; 
Francis Epps Professor and Director, Information Use Management & 
Policy Institute, Florida State University. 

David L. McClure; 
Research Director Gartner; 
formerly Council for Excellence in Government and GAO. 

Bruce McConnell; 
President and Founder, McConnell International; 
formerly OMB. 

Patrice McDermott; 
Deputy Director, Office of Government Relations, American Library 
association. 

Michael McGill; 
McGill Associates and Internet2. 

Lynn McNulty; 
Consultant, McConnell International, LLC; 
formerly NIST. 

Doug Robinson; 
Executive Director, National Association of State Chief Information 
Officers. 

J. Timothy Sprehe; 
President, Sprehe Information Management Associates. 

Ari Schwartz; 
Associate Director, Center for Democracy and Technology. 

Miron Straf; 
Deputy Director, Division of Behavioral and Social Sciences and 
Education, The National Academies. 

Jeanne Young; 
Independent Consultant; 
formerly Federal Reserve Board of Governors Records Officer and NAGARA 
officer. 

[End of table] 

Others in Attendance: 

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

Donald Arbuckle; 
Deputy Administrator, Office of Information and Regulatory Affairs. 

Michelle Ash; 
Minority Senior Legislative Counsel, House Committee on Government 
Reform. 

Krista Boyd; 
Minority Counsel, House Committee on Government Reform. 

Curtis Copeland; 
Congressional Research Service. 

Dan Costello; 
Policy Analyst, Office of Information and Regulatory Affairs. 

Michael Formica; 
Director of Energy and Environment, U.S. Chamber of Commerce. 

Eva Kleederman; 
Senior Policy Analyst, Office of Management and Budget. 

Kristy Lalonde; 
Policy Analyst, Office of Management and Budget. 

David McMillen; 
Minority Professional Staff Member, House Committee on Government 
Reform. 

Jim Moore; 
Counsel, House Committee on Government Reform. 

Kim Nelson; 
Policy Analyst, Office of Management and Budget. 

Lew Oleinick; 
Office of Information and Regulatory Affairs. 

Kenneth Peskin; 
U.S. Chamber of Commerce. 

Victoria Proctor; 
Senior Professional Staff Member, House Committee on Government Reform. 

Edward Schrock; 
House Committee on Government Reform. 

Katherine Wallman; 
Branch Chief, Statistics Branch, Office of Information and Regulatory 
Affairs. 

[End of table] 

In addition, staff of the National Academies' National Research 
Council, Computer Science and Telecommunications Board, helped to 
develop and facilitate the forum: Charles Brownstein, Director; 
Kristen Batch, Research Associate; 
and Margaret Huynh, Senior Program Assistant. 

[End of section] 

Related GAO Products: 

Paperwork Reduction Act: Subcommittee Questions Concerning the Act's 
Information Collection Provisions. GAO-05-909R. Washington, D.C.: July 
19, 2005. 

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

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

Paperwork Reduction Act: Agencies' Paperwork Burden Estimates Due to 
Federal Actions Continue to Increase. GAO-04-676T. Washington, D.C.: 
April 20, 2004. 

Paperwork Reduction Act: Record Increase in Agencies' Burden Estimates. 
GAO-03-619T. Washington, D.C.: April 11, 2003. 

Paperwork Reduction Act: Changes Needed to Annual Report. GAO-02-651R. 
Washington, D.C.: April 29, 2002. 

Paperwork Reduction Act: Burden Increases and Violations Persist. GAO- 
02-598T. Washington, D.C.: April 11, 2002. 

Information Resources Management: Comprehensive Strategic Plan Needed 
to Address Mounting Challenges. GAO-02-292. Washington, D.C.: February 
22, 2002. 

Paperwork Reduction Act: Burden Estimates Continue to Increase. GAO-01- 
648T. Washington, D.C.: April 24, 2001. 

Electronic Government: Government Paperwork Elimination Act Presents 
Challenges for Agencies. GAO/AIMD-00-282. Washington, D.C.: September 
15, 2000. 

Tax Administration: IRS Is Working to Improve Its Estimates of 
Compliance Burden. GAO/GGD-00-11. Washington, D.C.: May 22, 2000. 

Paperwork Reduction Act: Burden Increases at IRS and Other Agencies. 
GAO/T-GGD-00-114. Washington, D.C.: April 12, 2000. 

EPA Paperwork: Burden Estimate Increasing Despite Reduction Claims. 
GAO/GGD-00-59. Washington, D.C.: March 16, 2000. 

Federal Paperwork: General Purpose Statistics and Research Surveys of 
Businesses. GAO/GGD-99-169. Washington, D.C.: September 20, 1999. 

Paperwork Reduction Act: Burden Increases and Unauthorized Information 
Collections. GAO/T-GGD-99-78. Washington, D.C.: April 15, 1999. 

Paperwork Reduction Act: Implementation at IRS. GAO/GGD-99-4. 
Washington, D.C.: November 16, 1998. 

Regulatory Management: Implementation of Selected OMB Responsibilities 
Under the Paperwork Reduction Act. GAO/GGD-98-120. Washington, D.C.: 
July 9, 1998. 

Paperwork Reduction: Information on OMB's and Agencies' Actions. 
GAO/GGD-97-143R. Washington, D.C.: June 25, 1997. 

Paperwork Reduction: Governmentwide Goals Unlikely to Be Met. GAO/T- 
GGD-97-114. Washington, D.C.: June 4, 1997. 

Paperwork Reduction: Burden Reduction Goal Unlikely to Be Met. GAO/T- 
GGD/RCED-96-186. Washington, D.C.: June 5, 1996. 

Environmental Protection: Assessing EPA's Progress in Paperwork 
Reduction. GAO/T-RCED-96-107. Washington, D.C.: March 21, 1996. 

Paperwork Reduction: Burden Hour Increases Reflect New Estimates, Not 
Actual Changes. GAO/PEMD-94-3. Washington, D.C.: December 6, 1993. 

FOOTNOTES 

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

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

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

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

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

[6] 44 U.S.C. 3508. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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