Protecting the Public From Unnecessary Federal Paperwork:
Does the Control Process Work?
GGD-79-70: Published: Sep 24, 1979. Publicly Released: Sep 24, 1979.
- Full Report:
As of March 1978, almost 5,000 reporting and recordkeeping requirements were being used by federal executive departments to collect information from the public. This paperwork imposes an estimated 785 million hours of burden on individuals, businesses, farmers, and state and local governments. Until the President's Burden Reduction Program was introduced, the clearance process was the only formal check on the federal requirements being imposed on the public. The clearance process, which has changed little since it was introduced 37 years ago, consists of a series of reviews by agency, departmental, and Office of Management and Budget (OMB) clearance officers. The clearance officer reviews the clearance package to determine whether it complies with the OMB guidelines. Each package must state the need for the requirement; the plan for collecting, tabulating, and using the data; the basis for the estimated burden; the outside organizations consulted; the reasons for "sensitive" questions; and, in some cases, the estimated cost to the federal government. In recent years, Presidential Burden Reduction Programs have emphasized the use of goal setting and ceilings to reduce both the number of federal information requirements and the time needed to complete them.
The OMB clearance process for evaluating proposed reporting demands is poorly structured and does not include an evaluation mechanism or followup on approved requirements. Agency clearance officers are unsure whether they can disapprove, or even revise, proposed requirements for information. As a result, the process of approving or rejecting agency requests for information from the public often has incomplete documentation and offers no assurance that reporting burdens are reasonable.
Recommendation for Executive Action
Comments: Please call 202/512-6100 for additional information.
Recommendation: The Director of OMB should shift the emphasis of the reports clearance process at OMB from reviews of individual requirements to (1) evaluations of the adequacy of controls at executive Departments and agencies, and (2) postaudits of proposed and approved requirements. The executive Departments and agencies should be required to conduct periodic internal audits of their clearance processes. The roles and authority of clearance officers at executive Departments and agencies should be clarified. The Director of OMB should delegate primary review authority to executive Departments and agencies which have demonstrated adequate capability. OMB guidelines should be revised to require complete documentation for all reporting requirements, including (1) survey and tabulation plans and schedules for applications, and (2) cost estimates for applications and other management reports. Exempt requirements on the inventory of public-use requirements should be identified and included.