Chapter 2 How Requests to Collect Information Are The Review Processes Interviews with OIRA personnel and an examination of formal and informal guidelines for reviews reveal a general logic and organization of the paperwork review process. Although practices have changed over time and differ among OIRA Staff, figure 2.1 schematizes how information collection requests are handled within OMB. The OMB review process begins when an agency submits a request (composed of an SF-83 Form and accompanying documentation) to the public docket library within OIRA (appendix II contains a copy of an SF-83). Simultaneously, the submitting agency issues a notice in the Federal Register stating that OMB's approval is being sought. This is intended to provide the public with an opportunity to comment. The docket library serves as the main distribution point, houses current requests, and maintains the report management system, which contains information on all actions involving information collection requests. For ongoing or recurrent data collection efforts (for example, the Census Bureau's Survey of Income and Program Participation), the system contains a history of all submissions and actions on them. According to OMB's procedures and our interviews with OMB's staff, information collection requests are distributed within 2 to 10 days to the desk officer who is assigned to the originating agency and to the office of statistical policy. The desk officer has primary responsibility for reviewing the submission package. This includes consulting OMB'S records of this data collection (for example, of prior submissions) and may include checking the Federal Information Locator System and the agency's information collection budget. They also may solicit input from other sources within OMB and outside it, clarify questions with the agency, and summarize any public comments OMB receives. The desk officer makes a recommendation on whether the submission should be approved and on the duration of the approval period. The Paperwork Reduction Act stipulates that information collections can be approved for a maximum of 3 years. Under OIRA's practices, who makes the final determination on a particu lar submission depends on several factors. The immediate supervisor of a desk officer, an assistant branch chief, and the branch chief have authority to approve a request. However, large submissions, those involving a million burden hours or more, must be approved by the dep uty administrator or a delegate. A recommendation to disapprove a submission must be authorized by a branch chief. Furthermore, desk officers are instructed to inform their branch chiefs of any collection "Solid lines indicate events that always occur; dotted lines indicate events that sometimes occur. Chapter 2 How Requests to Collect Information Are that "appears to warrant review." Highly sensitive matters go to the deputy administrator. After OMB's formal action, the agency is notified in a written "notice of action," and the submission is retained in the docket library. The Paperwork Reduction Act of 1980 allows OMB 60 calendar days to complete its review of a submission. With proper notification to the agency, this review period may be extended to 90 calendar days. However, the implementing regulations stipulate that if OMB has not acted, upon the 91st day of review the agency can request and shall receive approval. However, under these circumstances, the maximum approval period is 1 year.3 Variation in Practices Use of Written Guidance and Consultations OIRA employs approximately 35 desk officers to handle between 3,000 and 4,000 submissions each year. As seen in figure 2.1, these staff are the "front line" of the OMB review process. How they approach paperwork review depends on the characteristics of the particular agencies they are assigned and their individual backgrounds, styles, and preferences. Interviews with a sample of 15 desk officers revealed considerable variation in their (1) use of written guidelines, (2) use of consultation with different groups for input, (3) use of criteria for prioritizing submissions, and (4) informal practices. OMB has issued implementing regulations for the Paperwork Reduction Act, has developed statistical policy circulars, and has recently issued an information collection review handbook for desk officers. The latter was available only in draft form when we were interviewing desk officers. All 15 desk officers we interviewed relied on the act or the implementing regulations for guidance on administrative and procedural issues. Eight of the 15 indicated that they augmented these sources by referring to the draft handbook, other memos, or other OIRA staff, the last being reported as the most frequent means of augmenting written guidance. While 11 of the 15 desk officers were familiar with the draft handbook, only 6 had read it or consulted it as part of their work. With respect to technical issues (such as survey design), only 3 of the 15 desk officers One of the case example interviews indicated that agencies were reluctant to request this type of approval from OMB; furthermore, no instances of their being considered or requested were mentioned. Chapter 2 How Requests to Collect Information Are Input From Others Setting Priorities reported that they relied on statistics texts or the statistical policy circulars. Eight of those interviewed cited consultation with the office of statistical policy as their primary basis for technical guidance, and 4 also relied on personal training and experience. Desk officers are also responsible for obtaining information on incoming requests from relevant groups inside and outside OMB. They varied in the amount and extent of contact they reported having with these groups. In a typical month, the desk officers had about 65 to 70 contacts with such groups. About half (55 percent) of the contacts were with agency staff concerning active submissions; across desk officers, the percentage varied from 30 to 85 percent. In most cases, contacts with others inside OMB accounted for 5 to 10 percent of monthly contacts. There was a great degree of variability in this activity from one desk officer to the next. For example, while 10 percent of monthly contacts were with the office of statistical policy, this ranged from a high of 20 percent for 1 desk officer to little or no contact, less than 5 percent, for 7 other desk officers. Further, while 10 percent of monthly contacts were with private parties outside OMB (for example, lobbyists, users, state representatives), across desk officers this percentage ranged from a low of 1 percent to slightly over 40 percent of all contacts. Differences in the collections proposed by different agencies were partially responsi ble for the variation in practices we observed. However, comments derived from our interviews suggest that much of this variation stemmed from stylistic differences between the desk officers. Most desk officers are assigned to multiple agencies and may receive many submissions at the same time. Therefore, desk officers frequently have to decide which paperwork reviews to give top priority. When asked about the criteria they use in determining priorities among submissions, most desk officers indicated that they used various rules of thumb. For 8 of 15 desk officers, information collection requests entailing new data collections were given priority, while 6 (40 percent) focused on submissions that involved large public burden. Four of the desk officers reported using both of these criteria while 5 used neither. The staff also reported using a variety of other criteria or combinations of criteria. For example, 4 desk officers reported giving priority to controversial submissions. In one instance, this was the sole criterion offered. Three desk Chapter 2 How Requests to Collect Information Are Informal Practices Training officers indicated that they established their priorities on the basis of the track record of the agency's submissions. In general, 10 of the desk officers relied on two or fewer factors in prioritizing their reviews. While 2 very experienced staff (15 years with the agency) offered four or more bases for prioritization, there was no overall tendency for staff with 3 or more years of tenure to rely on multiple criteria or provide a differentiated rationale for prioritization. Two desk officers could offer no rules of thumb that were used to give priority to reviews in OIRA. Most of the desk officers we interviewed offered a variety of informal Of the desk officers in OIRA, 16 had been trained in public policy or public administration, 6 were trained in economics, 5 in law, and 4 in business. The remainder were educated in environmental policy (2), international relations (2), history (1), sociology (1), and American studies (1). Twenty percent held either a law degree or a Ph.D, and 83 percent held at least a master's degree. Most of the desk officers we interviewed (12 of 15) reported receiving no formal on-the-job training. One respondent characterized orientation to the job as a "sink or swim" process. However, there was mention of briefings-on changes in regulations, for example—as a primary source of on-the-job training. Despite the lack of formal on-the-job training, the majority of the desk officers (11 of 15) thought that their educational background prepared them well for the demands of the job. Individual desk officers stated |