Chapter 2 How Requests to Collect Information Are Turnover of Desk that they had been trained in economics or had "two graduate level statistics classes" as part of their master's programs. In identifying inadequacies in their educational backgrounds, desk officers mentioned lack of training in survey design and principles of public administration. Several other desk officers remarked that formal academic training was less important than experience and common sense. Turnover of desk officers at OMB was mentioned by agency and OMB officials as affecting the review process. We performed several analyses to get an indication of the extent of this turnover. We found that While years spent at OMB gives some indication of overall office turnover, it does not reflect the changes that occur when desk officers are assigned to different agencies or when other changes occur in their responsibilities, such as a change from a desk officer to a staff policy position, all of which result in a new person being responsible for the collections from a particular agency. For our sample of 50 agencies, we found that 68 percent had 3 or more primary reviewers during 1982-87. That is, for most of the agencies we examined, there is a considerable chance that desk officer turnover will occur between consecutive reviews of recurrent submissions; approvals are granted for only up to 3 years. Desk officer turnover was also seen in our case illustrations. In 13 of the 17 cases (76 percent), turnover occurred either prior or subsequent to action on the case. OMB's Formal Actions The outputs of the OMB review process were more predictable than the process that generated them. The great majority of submissions since 1982 (94 percent) have been approved. Further, as shown in table 2.2, the approval rate has increased somewhat from about 93 percent during the early years of implementation of the act to 95 percent in recent years. Similarly, the disapproval rate has declined from 4.5 percent in the early years to slightly more than 3 percent more recently. The remainder of the actions were withdrawals by the agency or decisions by an independent regulatory commission to override an OMB action. OMB's Modifications *Actions through December 22, 1987 Excludes 438 information collection requests pending on that date, independent regulatory commission overrides, and OMB rulings that specific information collec tion requests were not subject to OMB review Includes emergency approvals Includes disapprovals with continuation. Includes withdrawals with continuation With regard to reasons for the decline in disapprovals, several desk officers noted that one of the consequences of the act, and its regulations, and contact with OMB is to provide agencies with a clearer understanding of the review process, thereby reducing the number of inappropriate submissions. This interpretation is consistent with the data on reductions in the number of withdrawals. However, increased presubmission contact between some agencies and their desk officers could also be associated with the small decline in the number of withdrawals and disapprovals. OMB can approve a request or approve it with required modifications. Analysis of remarks recorded in the report management system for 423 research, evaluation, and statistics approvals and 422 other, nonresearch-oriented approvals shows roughly 12 percent of researchoriented submissions that were approved and 8 percent of nonresearch approvals were accompanied by formal modifications. Some of these were seemingly minor changes such as requiring an expiration date on a form or indicating that the collection is voluntary. However, some have been more extensive: about 20 to 27 percent of the subinissions that were formally modified had one or more questions deleted, and 7 to 8 percent had questions added. Ten to 14 percent had changes made in their respondent population or sampling plan, and 1 to 2 percent had the frequency of collection reduced. Overall, a relatively small fraction of approvals were accompanied by major modifications described in the reports management system files. However, basing an analysis on this source alone would understate the frequency and extent of modifications required by OMB. First, 3 percent of nonresearch approvals and nearly 10 percent of research-oriented Chapter 2 How Requests to Collect Information Are Reasons for approvals were accompanied by references in the system to a discussion elsewhere (for example, in an accompanying letter or in an earlier conversation) of unspecified conditions or modifications. From the reports management system alone, it is impossible to evaluate the nature of these conditions, and therefore they have not been included in our count of formal modifications. Second, OMB and the submitting agency may agree on changes in a collection during the course of other formal reviews that are not indicated in the reports management system. Third, OMB may have previously disapproved the collection while indicating the changes that would make it acceptable. If the agency incorporates these changes prior to resubmission, the system record is likely to show an approval without modifications. Similarly, if an agency consults informally with OMB prior to submitting a collection, it may receive guidance on changes in the collection that OMB would like to see made before submission; if the agency makes the changes, the system may not indicate these modifications. Evidence from the case examples suggests that OMB may shape information collections at least as much or more through these mechanisms as through the formal conditions of approval recorded in the system. Although we did not directly assess the extent to which these alterations improved or impaired these submissions, information obtained in our case studies suggests that agency officials believe these modifications generally improve the quality of the submission or reduce the amount of respondent burden. Formal and informal modifications have, however, delayed the review process. We examined the remarks recorded in the reports management system for all 481 disapprovals of information collection requests on record in 1982-84 and all 301 on record in 1985-87. As shown in table 2.3, the most common reasons given for disapprovals were that proposed collections lacked practical utility or were not necessary for proper agency performance. Deficiencies in the supporting statement, justification package, or proce dures (as when an information collection was submitted before the rule underlying it was approved or an agency failed to provide sufficient public notice of the proposed collection) were frequent among reasons given for disapprovals in 1982-84 but were somewhat less frequent in 1985-87. This may reflect increased experience of agency personnel with the procedural and formal aspects of the paperwork review process. Actual or possible duplication was cited as a reason for disapprov als in fewer than 1 case in 10. And excessive burden was explicitly raised as an issue in only a modest fraction of disapprovals (although a major reason for disapproving collections that lack practical utility or that are viewed as unnecessary is presumably to prevent avoidable paperwork burdens). Not only were research, evaluation, and statistics collections more likely than others to be disapproved, but the grounds for their disapprovals were somewhat different. Issues of practical utility and possible duplication as well as technical issues were more frequently cited in disapprovals of these collections, while procedural problems and questions about burden estimates were more likely to adversely affect other types of collections. Chapter 2 How Requests to Collect Information Are Duration of Approvals Although OMB is permitted to approve information collections for a Variations Across period of up to 3 years, many collections are approved for substantially The relatively high overall approval rate was not applicable to all agencies and types of submissions. There appeared to be a large number of Agencies and Types of agencies that have had perfect approval ratings in the OMB review proSubmission cess. We found, however, that a small number of agencies have had persistent difficulties in their relationships with OMB. Further, some types of submissions were less likely to be approved than others. Variations in Agencies Between 1982 and 1984, 25 percent of the agencies submitting requests to OMB had approval rates of 90 percent or less. The lowest approval rate was 38 percent; only 4 of every 10 submissions from this agency |