The 1995 PRA amendments also 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. Estimated Paperwork Burden Increased in 2005

After 2 years of slight declines, OMB reports that burden hours  increased in fiscal year 2005 and are expected to increase again in  fiscal year 2006. According to OMB’s most recent PRA report to  Congress, the estimated total burden hours imposed by government  information collections in fiscal year 2005 was 8.4 billion hours; this  is an increase of 441 million burden hours (5.5 percent) from the  previous year’s total of 8.0 billion hours. OMB’s report also states that burden will increase in fiscal  year 2006 by an estimated 303 million hours to about 8.7 billion  hours; however, according to OMB, most of this projected increase  (250 million hours or 83 percent) is attributable to a new method of  estimating burden that is being implemented by IRS, rather than to  any increase in the actual burden. ●  Adjustments do not result from federal activities but from external  factors. In contrast to changes due to new statutes, changes due to agency  action did not contribute significantly to the overall change in  burden this year, adding 180,000 hours out of the total rise of 441  million. 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 minimizing burden on small  entities 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 the burden while  maximizing the public benefit and utility of the information  collected. Agencies Could Strengthen PRA Review and Try Alternative Approaches to Reducing Burden

In our 2005 report, we concluded that the CIO review process was  not working as Congress intended: It did not result in a rigorous  examination of the burden imposed by information collections, and  it did not lead to reductions in burden. In addition, we recommended (among other things) that agencies  strengthen the support provided for CIO certifications and that OMB  update its guidance to clarify and emphasize this requirement  (including that agencies provide support showing that they have  taken steps to reduce burden, determined whether small entities are  affected and reduced reporting burden on them, and established a  plan to manage and use the information to be collected, including  the identification of necessary resources). Since our report was issued, the four agencies have reported taking  steps to strengthen their support for CIO certifications:   ●  According to the HUD CIO, the department established a senior- level PRA compliance officer in each major program office, and it  revised its certification process to require that before collections are  submitted for review, they be approved at a higher management  level within program offices. OMB has updated parts of its guidance and plans to incorporate  other guidance into an automated system to be used by agencies  submitting information collections for clearance. The targeted approaches to burden reduction used by IRS and EPA  appear promising, but the experience of these agencies suggests  that success requires top-level executive commitment, extensive  involvement of program office staff with appropriate expertise, and  aggressive outreach to stakeholders. GAO-05-424. Regulatory Management: Implementation of Selected OMB  Responsibilities Under the Paperwork Reduction Act. Environmental Protection: Assessing EPA’s Progress in  Paperwork Reduction.
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 responding to these collections imposes 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 submitting them to OMB for approval and certify that the collections meet certain standards set forth in the act. GAO was asked to testify on OMB's burden report for 2005 and on a previous study of PRA implementation (GAO-05-424), which focused on the CIO review and certification processes and described alternative processes that two agencies have used to minimize paperwork burden. To prepare this testimony, GAO reviewed the current burden report and its past work in this area. For its 2005 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 at the four agencies.

What GAO Found

After 2 years of slight declines, OMB reports that paperwork burden grew in fiscal year 2005 and is expected to increase further in fiscal year 2006. Estimates in OMB's annual report to Congress show that the total paperwork burden imposed by federal information collections increased last year to about 8.4 billion hours--an increase of 5.5 percent from the previous year's total of about 8.0 billion hours. Nearly all this increase resulted from the implementation of new laws (for example, about 224 million hours were due to the implementation of voluntary prescription drug coverage under Medicare). The rest of the increase came mostly from adjustments to the estimates due to such factors as changes in estimation methods and in the numbers of respondents. Looking ahead to fiscal year 2006, OMB expects an increase of about 250 million hours because of a new model for estimating burden being implemented by the Internal Revenue Service (IRS). According to OMB, this expected rise does not reflect any real change in the burden on taxpayers, but only in how IRS estimates it. The PRA requires that CIOs review information collections and certify that they meet standards to minimize burden and maximize utility; however, these reviews were not always rigorous, reducing assurance that these standards were met. In 12 case studies at four agencies, GAO determined that CIOs certified collections proposed by program offices despite missing or inadequate support. Providing support for certifications is a CIO responsibility under the PRA, but agency files contained little evidence that CIO reviewers had made efforts to improve the support offered by program offices. Numerous factors contributed to these problems, including a lack of management attention and weaknesses in OMB guidance. Based on its review, GAO recommended (among other things) that agencies strengthen the support provided for certifications and that OMB update its guidance to clarify and emphasize this requirement. Since GAO's study was issued, the four agencies have reported taking steps to strengthen their support for CIO certifications, such as providing additional resources and guidance for the process, and OMB has updated parts of its guidance. In contrast to the CIO review process, which did not lead to reduced paperwork burden in GAO's 12 case studies, IRS and the Environmental Protection Agency (EPA) have set up alternative processes 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 have led to significant reductions in paperwork burden on the public. In light of these promising results, the weaknesses in the current CIO review process, and the persistent increases in burden, a new approach to burden reduction appears warranted. GAO suggested that Congress should consider mandating pilot projects to target some collections for rigorous analysis along the lines of the IRS and EPA approaches.