Under the law, the CIO is to review  each collection of information before submission to OMB, including  reviewing the program office’s evaluation of the need for the  collection and its plan for the efficient and effective management  and use of the information to be collected, including necessary  resources. During this review, the agency  is to publish a notice of the collection in the Federal Register. The 1995 PRA amendments also require 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. Agency Processes for Reviewing Information Collections Were Not Effective

Governmentwide, agency CIOs generally reviewed information  collections before they were submitted to OMB and certified that  the 10 standards in the act were met. However, in our 12 case  studies, CIOs provided these certifications despite often missing or  partial 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 get program offices to improve the  support that they offered. Numerous factors have contributed to  these conditions, including a lack of management support and  weaknesses in OMB guidance. Support for Certifications Was Often Missing or Partial, Despite CIO Reviews

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. 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. Once the forms are chosen, the office performs highly detailed, in- depth analyses, including extensive outreach to the public affected,  the users of the information within and outside the agency, and  other stakeholders. IRS reports that this targeted, resource-intensive process has  achieved significant reductions in burden: over 200 million burden  hours since 2002. In contrast, for the 12  information collections we examined, the CIO review process  resulted in no reduction in burden. Similarly, both IRS and  EPA addressed information collections that had undergone CIO  review and received OMB approval and nonetheless found  significant opportunities to reduce burden. According to PRA Experts, the Current Approach to Paperwork Reduction Could Be Improved

In considering PRA reauthorization, the Congress has the  opportunity to take into account ideas that were developed by the  various experts at the PRA forum that we organized in 2005. It was suggested that the volume of  collections to be individually reviewed could impede such  integration. This  suggestion was paired with the idea that the review process itself  should be more rigorous; as the panel put it, “now it’s a rather pro  forma process.” They also observed that two Federal Register  notices seemed excessive in most cases. Our previous work has not addressed every topic raised by the  forum, so we cannot argue for or against all these suggestions. Pilot projects would be expected to build on the lessons learned at  IRS and EPA. As our  review showed, the CIO review process, as currently implemented,  tended to lack rigor, allowing agencies to focus on clearing an  administrative hurdle rather than on performing substantive  analysis. To that end,  we suggested that the Congress mandate pilot projects that are  specifically targeted at reducing burden. Forum: The Legislative Framework for Information Resources Management

	Forum Participants

Associate Executive Director Association  of Research Libraries  Princeton University; formerly National  Opinion Research Center  Founder and Executive Director, OMB  Watch  Administrative Law & Information Policy;  formerly OMB and IRS Privacy Officer  Vice President, SRA International;  formerly OMB  Director, Center for Technology in  Government, University at Albany, State  University of New York  Partner, Guerra, Kiviat, Flyzik and  Associates; formerly Department of  Treasury and Secret Service  Privacy & Information Policy Consultant;  formerly counsel to the House of  Representatives’ Subcommittee on  Information, Justice, Transportation and  Agriculture  Editor of Access Reports, FOIA Journal  Independent Consultant; formerly OMB  Professor and Independent Consultant;  formerly OMB  Manager, Regulatory Policy National  Federation of Independent Business  Director, Public Policy, Software &  Information Industry Association  Senior Scientist, Computer Science and  Telecommunications Board, The National  Academies  Fellow in Law and Government, American  University, Washington College of Law;  formerly Administrative Conference of the  U.S.

	Others in Attendance

At the forum, others attending included GAO staff and a number of  other observers:  Deputy Administrator, Office of  Information and Regulatory Affairs  Minority Senior Legislative Counsel,  House Committee on Government Reform  Minority Counsel, House Committee on  Government Reform  Policy Analyst, Office of Information and  Regulatory Affairs  Director of Energy and Environment, U.S.  Chamber of Commerce  Senior Policy Analyst, Office of  Management and Budget  Policy Analyst, Office of Management and  Budget  Minority Professional Staff Member,  House Committee on Government Reform  Counsel, House Committee on  Government Reform  Policy Analyst, Office of Management and  Budget  Office of Information and Regulatory  Affairs  Senior Professional Staff Member, House  Committee on Government Reform  House Committee on Government Reform  Branch Chief, Statistics Branch, Office of  Information and Regulatory Affairs  In addition, staff of the National Academies’ National Research  Council, Computer Science and Telecommunications Board, helped  to develop and facilitate the forum: Charles Brownstein, Director;  Kristen Batch, Research Associate; and Margaret Huynh, Senior  Program Assistant. GAO-05-424.
Why GAO Did This Study

Americans spend billions of hours each year providing information to federal agencies by filling out forms, surveys, or questionnaires. A major aim of the Paperwork Reduction Act (PRA) is to minimize the burden that these information 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. In addition, agency Chief Information Officers (CIO) are to review information collections before they are submitted to OMB for approval and certify that these meet certain standards set forth in the act. GAO was asked to testify on the implementation of the act's provisions regarding the review and approval of information collections. For its testimony, GAO reviewed previous work in this area, including the results of an expert forum on information resources management and the PRA, which was held in February 2005 under the auspices of the National Research Council. GAO also drew on its earlier study of CIO review processes (GAO-05-424) and alternative processes that two agencies have used to minimize burden. For this 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

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 that support be provided for certifications, agency files contained little evidence that CIO reviewers had made efforts to get program offices to improve the support they offered. 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. To address the issues raised by its review, GAO made recommendations to the agencies and OMB aimed at strengthening the CIO review process and clarifying guidance. OMB and the agencies report making plans and taking steps to address GAO's recommendations. Beyond the collection review process, the Internal Revenue Service (IRS) and the Environmental Protection Agency (EPA) have set up processes 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 public outreach. According to the two agencies, these efforts led to significant reductions in burden. For example, each year, IRS subjects a few forms to highly detailed, in-depth analyses, reviewing all data requested, redesigning forms, and involving stakeholders (both the information users and the public affected). IRS reports that this process--performed on forms that have undergone CIO review and received OMB approval--has reduced burden by over 200 million hours since 2002. In contrast, for the 12 case studies, the CIO review process did not reduce burden. When it considers PRA reauthorization, the Congress has the opportunity to promote new approaches, including alternatives suggested by the expert forum and by GAO. Forum participants made a range of suggestions on information collections and their review. For example, they suggested that OMB's focus should be on broad oversight rather than on reviewing each individual collection and observed that the current clearance process appeared to be "pro forma." They also observed that it seemed excessive to require notices of collections to be published twice in the Federal Register, as they are now. GAO similarly observed that publishing two notices in the Federal Register did not seem to be effective, and suggested eliminating one of these notices. GAO also suggested that the Congress mandate pilot projects to target some collections for rigorous analysis along the lines of the IRS and EPA approaches. Such projects would permit agencies to build on the lessons learned by the IRS and EPA and potentially contribute to true burden reduction.