This official is the  agency’s CIO, who is to review each collection of information to  certify that the collection meets 10 standards (see table 1) and to  provide support for these certifications. In addition, the 1995 PRA amendments required 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. Reported Paperwork Burden Decreased Slightly in 2004

According to OMB’s most recent PRA report to Congress, the  estimated total burden hours imposed by government information  collections in fiscal year 2004 was 7.971 billion hours; this is a  decrease of 128 million burden hours (1.6 percent) from the  previous year’s total of about 8.099 billion hours. The reduction for fiscal year 2004 was a result of several types of  changes, which OMB assigns to various categories. These results are  similar to those for fiscal year 2003, in which adjustments of 181.7  million hours led to an overall decrease of 116.3 million hours (1.4  percent) in total burden estimated. Because of these limitations, the degree to which agency  burden-hour estimates reflect real burden is unclear, and so the  significance of small changes in these estimates is also uncertain. Nonetheless, these estimates are the best indicators of paperwork  burden available, and they can be useful as long as the limitations  are clearly understood. Agency Review Processes Were Not Rigorous

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. However, in the 12 case studies that we reviewed, this CIO  certification occurred despite a lack of rigorous support that all  standards were met. 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. 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. 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. 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. In contrast, for the 12 information  collections we examined, the CIO review process resulted in no  reduction in burden. Many factors have contributed  to these conditions, including lack of management support,  weaknesses in OMB guidance, and the CIO staff’s lack of specific  program expertise. In our report, we suggested options that the Congress may want to  consider in its deliberations on reauthorizing the act, including  mandating pilot projects to test and review alternative approaches  to achieving PRA goals. We also made recommendations to the  Director of OMB, including that the office alter its current guidance  to clarify and emphasize issues raised in our review, and to the  heads of the four agencies to improve agency compliance with the  act’s provisions.
Why GAO Did This Study

Americans spend billions of hours each year providing information to federal agencies by filling out information collections (forms, surveys, or questionnaires). A major aim of the Paperwork Reduction Act (PRA) is to minimize the burden that these 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 and to report annually on the agencies' estimates of the associated burden. In addition, agency Chief Information Officers (CIO) are to review information collections before they are submitted to OMB for approval and certify that the collections meet certain standards set forth in the act. For its testimony, GAO was asked to comment on OMB's burden report for 2004 and to discuss its recent study of PRA implementation (GAO-05-424), concentrating on CIO review and certification processes and describing alternative processes that two agencies have used to minimize burden. For its 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

The total paperwork burden imposed by federal information collections shrank slightly in fiscal year 2004, according to estimates provided in OMB's annual PRA report to Congress. The estimated total burden was 7.971 billion hours--a decrease of 1.6 percent (128 million burden hours) from the previous year's total of about 8.099 billion hours. Different types of changes contributed to the overall change in these estimates, according to OMB. For example, adjustments to the estimates (from such factors as changes in estimation methods and estimated number of respondents) accounted for a decrease of about 156 million hours (1.9 percent), and agency burden reduction efforts led to a decrease of about 97 million hours (1.2 percent). These decreases were partially offset by increases in other categories, primarily an increase of 119 million hours (1.5 percent) arising from new statutes. However, because of limitations in the accuracy of burden estimates, the significance of small changes in these estimates is unclear. Nonetheless, as the best indicators of paperwork burden available, these estimates can be useful as long as the limitations are clearly understood. 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 CIOs to provide support for certifications, agency files contained little evidence that CIO reviewers had made efforts to improve the support offered by program offices. 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. In contrast, the Internal Revenue Service (IRS) and the Environmental Protection Agency (EPA) have set up processes outside the CIO review process 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 outreach to stakeholders. According to the two agencies, these efforts led to significant reductions in burden on the public. In contrast, for the 12 case studies, the CIO review process did not reduce burden. In its report, GAO recommended that OMB and the agencies take steps to improve review processes and compliance with the act. GAO also suggested that the Congress may wish to consider mandating pilot projects to target some collections for rigorous analysis along the lines of the IRS and EPA approaches. OMB and the agencies agreed with most of the recommendations, but disagreed with aspects of GAO's characterization of agencies' compliance with the act's requirements.