Section 3 How Has the Total Burden of Federal The reported paperwork burden rose from 1.477 billion hours for fiscal year 1980 to 1.881 billion hours for fiscal year 1987, an increase of 27 percent (see figure 3.1). The reported burden went as low as 1.275 billion hours in fiscal year 1982 but reached a peak of 2.023 billion hours in fiscal year 1983. It declined for several years after that but has never fallen to its pre-1983 level. The projected burden for fiscal year 1988 is 1.815 billion hours. The burden hour values (termed the "paperwork burden base") referred to in this section reflect the total paperwork burden reported at the end of each fiscal year as given in the annual Information Collection Budget publications OMB produced for fiscal year 1980 through and including fiscal year 1987 "Values for fiscal years 1980 through 1987 are paperwork burden base values, calculated at the end of the fiscal year and reflecting the experience of that year. The 1980 value is a revised value and includes the burden of collections by agencies that were not included in the initial calculation of the 1980 best The 1988 value is the paperwork allowance value reflecting fiscal year 1988 information collection actre ity as anticipated at the end of fiscal year 1987 Source Information Collection Budget (ICB) Publications, Office of Management and Budget Washing ton DC 1980-87 A conclusion from these data that the 1980 act and the ICB process have been ineffective in controlling paperwork burden is unwarranted. These yearly reports are not an accurate guide to changes in total paperwork burden. While legislative, executive, and (in at least one instance) judicial action has led to substantial real changes in paperwork burden over this period, the apparent changes in reported burden between 1980 and 1987 are largely attributable to changes in the way OMB accounts for federal paperwork burden. These accounting procedures do not always reflect real changes in the amount of burden imposed on the public. Section 3 How Has the Total Burden of Federal Further, these changes are largely attributable to changes in a relatively small number of information collections. For instance, although more than 6,500 collections were active in 1985, and approximately the same number in 1987, 5 percent of them accounted for close to 95 percent of the total paperwork burden in each year, and changes in the burden of these large collections more than accounted for the net change in total burden between these two years. These are years for which complete data are available. Between April 1985 and December 1987, total reported burden fell by 142 million hours. Although the burden attributed to the most burdensome 5 percent of all collections fell 152 million hours, from 1.836 billion hours to 1.684 billion hours, the burden attributed to all other collections rose nearly 10 million hours, from 101 8 million to 1115 million hours. Section 4 What Factors Account for the Observed Year-to-year fluctuations in reported total burden are the result of many factors. Some of these changes have been the direct result of the passage of the Paperwork Reduction Act of 1980 and its implementation over a period of several years, while others simply reflect changes in burden accounting and represent no real reduction or increase in burden. Burden totals and events associated with them are indicated in figure 4.1. "Values for fiscal years 1980 through 1987 are paperwork burden base values, calculated at the end of Source Information Collection Budget publications, Office of Management and Budget Washington Section 4 What Factors Account for the Observed Changes in Burden Inclusion of Additional Reestimates of Burden Among the changes in burden accounting that have had a large effect on reported total paperwork burdens are (1) the inclusion of additional categories of information collection that had previously not been counted in the Information Collection Budget process, (2) reestimates of the burden associated with a number of very large information collections, and (3) other burden accounting changes, including the reclassification of some major information collections into special categories that have not been counted in many ICB Statistics (such reclassification had affected collections totaling more than 200 million burden hours by the end of 1987) and the inclusion of individual preexisting information collections that had previously been omitted. Under the 1980 act, three additional kinds of information collection were included in the paperwork burden base in fiscal year 1983: (1) requirements associated with government procurement of goods and services, (2) product testing and other actions associated with labeling and disclosure requirements, and (3) requirements contained in existing regulations. Primarily as a result of these inclusions, the total reported paperwork burden rose by 749 million hours (or by 59 percent) between fiscal year 1982 and fiscal year 1983. Among the agencies most affected by these inclusions were the Department of Defense, where reported burden rose from 7.5 million to 629.4 million hours between fiscal year 1982 and fiscal year 1983, an increase of 622 million hours; the Department of Energy, where reported burden rose 77 million hours, from 11.7 to 88.3 million; and the Federal Trade Commission (FTC), where reported burden rose 39 million hours, from 0.4 million to 39.4 million. Because information was collected before these changes were instituted, these increases do not necessarily reflect real increases in burden. The accounting system was simply made more accurate by their inclusion. In recent years, reestimates of the burden of major collections have had a considerable effect on total reported paperwork burden. For example, one reestimate of the burden of paperwork associated with Department of Defense procurement that was included in our case studies resulted in a reduction of 83 million hours in the estimated burden of such 'Examples of such reclassification are discussed below. They include Department of Health and Human Services (HHS) forms reclassified as government-wide standard forms and Department of Defense (DOD) procurement paperwork reclassified as part of the Federal Acquisition Regulation that was not counted in the burden of the regulation. |