Paperwork Reduction:

Agency Responses to Recent Court Decisions

PEMD-93-5: Published: Feb 3, 1993. Publicly Released: Mar 5, 1993.

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Pursuant to a congressional request, GAO reviewed how agencies interpreted and responded to a Supreme Court decision on the paperwork clearance process, focusing on: (1) what guidance agencies received and what criteria they used to determine whether an information collection request (ICR) met information collection and disclosure requirements; (2) how broadly agencies interpreted the court decision; and (3) what changes agencies made in the number and type of ICR submissions sent to the Office of Management and Budget (OMB) for approval.

GAO found that: (1) the decision's impact varied among agencies; (2) OMB did not develop any guidance for agencies to use to decide how the decision affected OMB clearance of ICR; (3) none of the agencies had formal, written guidance for implementing the decision, but they did provide informal guidance on a case-by-case basis; (4) agency interpretations of the decision differed because some agencies based them on the degree of data collection involved, while another agency based its decisions on the intent to inform a third party; (5) the Federal Trade Commission decreased its ICR review submissions by the largest proportion of any agency; (6) the Department of Labor made the greatest change in its ICR submissions involving third-party actions; and (7) agencies could not determine how many ICR might be affected by the decision.

Recommendation for Executive Action

  1. Status: Closed - Implemented

    Comments: The clarification was included in the 1995 reauthorization of the Paperwork Reduction Act, which specifies that third-party disclosure is covered under the requirements of OMB review.

    Recommendation: Given GAO findings that agencies have interpreted the Steelworkers decision quite differently and in the absence of legislative changes, the Director, OMB, should issue guidance to clarify when agencies are required to submit ICR for review under the Paperwork Reduction Act.

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


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