Paperwork Reduction:

Mixed Effects on Agency Decision Processes and Data Availability

PEMD-89-20: Published: Sep 7, 1989. Publicly Released: Oct 12, 1989.

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Pursuant to a congressional request, GAO reviewed the Office of Management and Budget's (OMB) efforts to minimize the burden that information requests placed on the public, focusing on: (1) how OMB handled agency requests for data collection and the timeliness and technical adequacy of its reviews; (2) how OMB policies and practices influenced agencies' decisions to gather information; and (3) the influence of agency and OMB actions on information availability.

GAO found that: (1) OMB received over 20,000 information collection requests from 211 agencies between 1982 and 1987; (2) although OMB had a formal review process, its office staff did not consistently apply review policies; (3) the inconsistencies stemmed from the use of varying criteria for determining priority reviews and little or no on-the-job training for new staff; (4) despite the variability in the review processes, OMB approved 95 percent of agency submissions; (5) 12 percent of the research approvals and 8 percent of the nonresearch approvals were formally modified and an unknown percentage were informally modified during negotiations between OMB and agencies; (6) although many agencies had perfect approval rates, about 7 percent of the agencies had persistent difficulties in obtaining approvals; (7) although OMB reviewed the majority of submissions within the mandated time limits, the median time for reviews increased; (8) many submissions had such technical inadequacies as low expected response rates, the potential for response bias, underreliance on conventional sampling methodology, or inadequate questionnaire design; (9) OMB regulations and guidelines heavily influenced the processes that agencies used to make information-gathering decisions; (10) more than half of the managers interviewed stated that OMB reviews had a negative effect on their information collection; and (11) some agencies attempted to avoid OMB reviews through mechanisms that could decrease quality and increase information collection costs, while some agencies stopped collecting some data because of difficulties in the clearance process.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: The Director, OMB, should augment the Office of Information and Regulatory Affairs' capacity to perform technical reviews of new and recurrent collections. Measures appropriate to this end may include expansion of technical staff and consultation with external experts.

    Agency Affected: Executive Office of the President: Office of Management and Budget

    Status: Closed - Implemented

    Comments: In its response to open recommendations, OMB indicated that, consistent with overall resource limitations, it is committed to enhancing the number and quality of the technical staff at OMB. Independently, GAO has learned that OMB has established a new evaluation office.

    Recommendation: To facilitate sound reviews within OMB, the Director, OMB, should develop an ongoing training program for the agency's paperwork review staff to ensure that technical and nontechnical criteria are appropriately and consistently applied to submissions.

    Agency Affected: Executive Office of the President: Office of Management and Budget

    Status: Closed - Implemented

    Comments: In its response to open recommendations, OMB indicated that it began a mandatory training program for all Office of Information and Regulatory Affairs staff in February 1990. Topics include statistics, surveys, and review criteria for information collection requests. All staff have taken this training, which is now being given to all new staff as well.

    Recommendation: OMB should enhance its guidance and assistance to agencies for improving the efficiency and quality of their data collections through increased use of conventional sampling procedures, measures to improve response rates, safeguards to control response bias or estimate the bias, and more precise design of data collection instruments.

    Agency Affected: Executive Office of the President: Office of Management and Budget

    Status: Closed - Implemented

    Comments: In its response to open recommendations, OMB did not indicate any specific response to the items in the recommendation, but cited a monograph and a seminar on the quality of federal data, with attendance by about 250 agency personnel.

    Recommendation: Given that many agencies have developed systematic procedures for reviewing data collection requests, the Director, OMB, should employ existing authority to delegate primary review responsibility to the senior officials within designated agencies that have demonstrated capability. The performance of these agencies could be monitored through spot-checks conducted by OMB. For executive agencies with less effective internal means for procedural and technical review, OMB should help improve those means.

    Agency Affected: Executive Office of the President: Office of Management and Budget

    Status: Closed - Implemented

    Comments: In a November 21, 1990 letter to GAO, OMB indicated it agreed with the recommendation and had established four criteria for delegation. OMB reports that three agencies sought delegation, but in no case was it approved.

    Recommendation: OMB should conduct its review of information collection requests concurrently with the public comment period for these requests.

    Agency Affected: Executive Office of the President: Office of Management and Budget

    Status: Closed - Implemented

    Comments: In its response to open recommendations, OMB restated the agency policy, which was in effect at the time of data collection.

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