Chapter 1 such areas as information policy, statistics, and the management of information resources.' Paperwork Control The Paperwork Reduction Act is most closely identified with OMB'S paperwork control review process, by which OIRA's desk officers determine "whether the collection of information by an agency is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility for the agency." (44 U.S.C. 3504(c)(2)) The basic requirements of the process are simple. OMB reviews all activi- Information collection requests submitted to OMB typically include a statement of justification (addressing each of 15 questions posed by OMB to guide the adequate description of the proposed data collection), a copy of the data collection instrument, and a copy of the form that formally requests approval for the collection from OMB (the Standard Form 83, or SF-83, reprinted in appendix II). The agency also must submit other relevant documentation such as regulations or statutes mandating data collection necessary to justify the need for the data to be collected, and may submit additional relevant documentation. OMB's paperwork control functions do not end with paperwork clearance. The 1980 act also requires OMB to inventory all information collection activities; designate agencies to collect information for other JU.S. General Accounting Office, Implementing the Paperwork Reduction Act, GAO/GGD-83-35 (Washington, D.C.: April 20, 1983). Chapter 1 agencies in order to reduce duplication; set goals for the reduction of the burdens of federal information collection activities; oversee the completion of action on the recommendations of the Commission on Federal Paperwork; design and operate FILS, in order to control duplication by providing an inventory of information collected by federal agencies; and report annually to the Congress regarding paperwork reduction efforts. The 1980 act also instructs OMB on the review of paperwork requirements emanating from regulations that executive agencies propose. OMB may review these regulations when agencies issue a notice of proposed rulemaking in the Federal Register. The results of OMB's review are to be treated as public comments that become part of the agency's rulemaking record and are considered by the agency as it drafts the final regulation. When the final rule is published in the Federal Register, the agency must explain how it has responded to OMB's comments. OMB's paperwork responsibilities include one other dimension, the information collection budget. First proposed by OMB under President Carter and implemented in fiscal years 1981-82, the budget works something like the fiscal budget. Agencies plan their information collection activities for the coming year and add up the resulting "paperwork burden" on the public (measured in burden hours). OMB then reviews the agencies' information collection plans and the burden associated with them and establishes a burden hour ceiling on each agency that sets a limit on the collections the agency can carry out. OMB may also suggest particular cuts in information collections that would allow an agency to meet burden reduction goals.2 The 1980 act sets specific goals for an overall reduction in the burden from existing information collections of 15 percent by the end of fiscal year 1982 and another 10 percent by the end of fiscal year 1983. OMB Set further goals for reductions in fiscal years 1984, 1985, and 1986. The Paperwork Reduction Reauthorization Act of 1986 called for an additional 5-percent decrease in the burden imposed by existing collections for each fiscal year between 1987 and 1990. *The same OIRA staff members who review individual information collection requests are also responsible for carrying out OMB's role in the process. Commenting on a draft of this report, OMB officials noted that the information collection budget is not binding and that OMB imposes no sanetions on agencies that exceed their negotiated budget ceilings. These officials view the budget as a planning document. Chapter 1 Concern About OMB's Objective There was considerable ambiguity, prior to our review, about how OMB handles information collection requests, although anecdotes abound regarding OMB's deficiencies in treating individual requests. For example, concerns have been raised about the limited technical abilities of OIRA's staff, delays associated with unnecessarily protracted reviews, disapprovals of information collection requests that appeared to be motivated by political rather than technical or practical grounds, and OMB's overemphasis on burden reduction and its insufficient attention to the value of proposed data collection efforts. OMB officials had taken the positions that agencies collect more information than is needed for national policymaking and that the federal government should not be in the business of producing information products and services that could be provided by the private sector. With few exceptions, these claims and counterclaims have not been systematically investigated. Observers have also argued that the paperwork review process has had subtle, adverse influences on executive departments and agencies. In particular, individuals have contended that in response to OMB's policies and practices, federal departments and agencies have stopped submitting requests or have devised ways of circumventing the review process entirely. Some of these circumvention strategies have reduced the quality of information that is collected. The extent to which these practices occur has not been systematically addressed, however. In response to these concerns, the chairman of the House Committee on 3M. Kritz, "Kibitzer with Clout," National Journal, May 30, 1987, p. 1407. "OMB Slows Up AIDS Survey," OMB Watch, Eye on Paperwork Action Alert, March 1989. iv. "K. Wallman, "Losing Count: The Federal Statistical System," No. 16, Population Reference Bureau, Inc., September 1988, p. L 7C. DeMuth, from an interview with Ann Crittenden, New York Times, July 11, 1982, n.p. See also D. Ginsburg, address before the Information Industry Association, n.p., September 20, 1984, pp. 4 and 19. *Kriz, "Kibitzer with Clout." Chapter 1 Scope and instruments modified or disapproved? Is OMB executing its responsibilities in a timely and technically adequate fashion? (2) How do OMB's policies and practices affect agencies' decisions regarding requests to gather information, particularly in nonstatistical agencies? (3) What influence have agency and OMB actions had on the availability of information? We answered the committee's questions by multiple methods summarized in table 1.1. In order to answer the first question-How are data collection requests handled in OMB?-we used four data collection methods. First, using OMB's reports management system, we constructed a longitudinal data base of the universe of information collection requests agencies submitted to OMB between 1982 and 1987. This provided evidence on OMB's overall performance, including the volume of submissions handled, approval rates, reasons for disapprovals and modifications, the duration of OMB's review, and other descriptive information regarding the information collection requests submitted by federal government agencies. As requested, we paid particular attention to the experiences of nonstatistical agencies, both regulatory and nonregulatory. "For the purposes of this report, the term "agency" refers to any unit that is assigned a unique fourdigit agency code in OMB's reports management system. A list of all such units that actually submitted information collection requests between 1982 and 1987 appears in appendix 1. Second, we interviewed a sample of 19 OMB officials responsible for paperwork clearance at various levels (desk officers, statistical policy analysts, assistant branch chiefs, and branch chiefs) to determine what happens to a data collection request once it enters OMB (who sees it, where it goes in the agency, and so on). In these interviews, we asked about the formal and informal procedures and criteria used to assess the data collection requests and the training required for this job. Our third method involved an in-depth look at 17 recent submissions (or case examples). Here, we selected a sample of research, evaluation, and statistics information collection requests that OMB had reviewed in 1987. The focus of these investigations was the processes associated with the OMB review. The sample represented various types of research-oriented information collection (new versus previously collected, both statistical and nonstatistical) as well as differing dispositions (such as approved, modified, and disapproved). Fourth, we convened a panel of experts to assess the technical adequacy of the submissions included in our case examples. (They are listed in appendix III.) The experts' decisions and rationale for those decisions |