Regulatory review. As part of that review, the agency CIO must ensure that each information  collection instrument (form, survey, or questionnaire) complies with the  act. Agency Review Processes Were Not Rigorous, and Public Consultation Was Limited

Governmentwide, agency CIOs generally reviewed information collections  before they were submitted to OMB and certified that the 10 standards in  the act were met. 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. Without appropriate support and public  consultation, agencies have reduced assurance that collections satisfy the  standards in the act. In contrast, IRS and EPA have used additional evaluative processes that  focus on reducing burden and that involve potential respondents to a much  greater extent. Table 2 shows the result of our analysis of the case studies. Support for Certifications Concerning Duplication Was Often Missing or Partial

Under the act, CIOs are required to certify that each information collection  is not unnecessarily duplicative. 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. 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. OMB similarly disagrees with our  conclusion that “the standard PRA review process resulted in no  reduction in burden” in the 12 case studies, because we did not  demonstrate that burden reduction would have been feasible if the CIO  review of these collections had been more rigorous. 1320.8(b)(3) requires that each collection of information “informs and provides reasonable notice to the potential persons to  whom the collection of information is addressed of: “(i)  the reasons the information is planned to be and/or has been  “(ii) the way such information is planned to be and/or has been used to  further the proper performance of the functions of the agency; “(iii) an estimate, to the extent practicable, the average burden of the  collection (together with a request that the public direct to the  agency any comments concerning the accuracy of this burden  estimate and any suggestions for reducing this burden); “(iv) whether responses to the collection of information are voluntary,  required to obtain or retain a benefit (citing authority) or  mandatory (citing authority); “(v) the nature and extent of confidentiality to be provided, if any  (citing authority); and “(vi) the fact that an agency may not conduct or sponsor, and a person  is not required to respond to, a collection of information unless it  displays a currently valid OMB control number.”] “(h) has been developed by an office that has planned and allocated  resources for the efficient and effective management and use of the  information to be collected, including the processing of the  information in a manner which shall enhance, where appropriate, the  utility of the information to agencies and the public; “(i)  uses effective and efficient statistical survey methodology appropriate  to the purpose for which the information is to be collected; and “(j)  to the maximum extent practicable, uses appropriate information  technology to reduce burden and improve data quality, agency  efficiency and responsiveness to the public.”

Objectives, Scope, and Methodology

Our objectives were to assess  the extent to which, before information collections are submitted to the  Office of Management and Budget (OMB) for approval, agencies have  (1) established effective processes for Chief Information Officers (CIO)  to review information collections and certify that the 10 standards in the  act were met and (2) complied with the requirements to consult with the  public on such collections;  the extent to which agencies ensure that collection forms on agency  Web sites are properly approved by OMB and included in an inventory of  approved collections; and  the extent to which agencies ensure that collection forms on agency  Web sites disclose certain required information that the public needs to  exercise scrutiny of agency activities. At the detailed agency audit level, we compared the act’s requirements with  the paperwork clearance processes used at three departments and one  agency: the Departments of Veterans Affairs (VA), Housing and Urban  Development (HUD), and Labor, as well as the Internal Revenue Service  (IRS) in the Department of the Treasury. In addition to the 12 case studies, we randomly selected 343 cases from  over 8,200 collections at 68 agencies that we used to determine  compliance levels at the four agencies and governmentwide with the  act’s requirements to issue a notice in the Federal Register providing a  60-day public comment period; for the CIO to certify that the 10  information management standards in the act had been met; and for the  agency to consult with the public and affected agencies on ways to  minimize burden. 12.
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 balance the burden of these collections with their public benefit. Under the act, agencies' Chief Information Officers (CIO) are responsible for reviewing information collections before they are submitted to the Office of Management and Budget (OMB) for approval. As part of this review, CIOs must certify that the collections meet 10 standards set forth in the act. GAO was asked to assess, among other things, this review and certification process, including agencies' efforts to consult with the public. To do this, 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

Governmentwide, agency CIOs generally reviewed information collections and certified that they met the standards in the act. However, GAO's analysis of 12 case studies at the Internal Revenue Service (IRS) and the Departments of Veterans Affairs, Housing and Urban Development, and Labor showed that CIOs certified collections even though support was often missing or partial. For example, in nine of the case studies, agencies did not provide support, as the law requires, for the standard that the collection was developed by an office with a plan and resources to use the information effectively. Because OMB instructions do not ask explicitly for this support, agencies generally did not address it. Further, although the law requires agencies both to publish notices in the Federal Register and to otherwise consult with the public, agencies governmentwide generally limited consultation to the publication of notices, which generated little public comment. Without appropriate support and public consultation, agencies have reduced assurance that collections satisfy the standards in the act. Processes outside the PRA review process, which are more rigorous and involve greater public outreach, have been set up by IRS and the Environmental Protection Agency (EPA), whose missions involve numerous information collections and whose management is focused on minimizing burden. For example, each year, IRS subjects a few forms to highly detailed, in-depth analyses, including extensive outreach to the public affected and the information users. 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. Without rigorous evaluative processes, agencies are unlikely to achieve the PRA goal of minimizing burden while maximizing utility.