B-180224.OM, JAN 23, 1981

B-180224.OM: Jan 23, 1981

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GGD: WE HAVE REVIEWED THE PROPOSED PROCEDURES FOR GAO HANDLING OF CLEARANCE REQUESTS FOR PROPOSALS BY INDEPENDENT FEDERAL REGULATORY AGENCIES TO CONDUCT AND SPONSOR COLLECTION OF INFORMATION PRIOR TO THE EFFECTIVE DATE OF THE PAPERWORK REDUCTION ACT OF 1980. THESE PROPOSED PROCEDURES ARE SET OUT IN THE DRAFT FEDERAL REGISTER NOTICE AND LETTER TO INDEPENDENT REGULATORY AGENCIES PREPARED IN COORDINATION WITH THIS OFFICE AND SUBMITTED BY MR. WE UNDERSTAND THAT THEY HAVE BEEN DISCUSSED INFORMALLY WITH OMB'S OFFICE OF GENERAL COUNSEL AND WITH THE OMB DEPUTY ASSISTANT DIRECTOR FOR REPORTS MANAGEMENT. WHO HAVE NO OBJECTION TO THEM. HEYL HAS INFORMED US THAT THE PROPOSED PROCEDURES ARE ESSENTIALLY THE SAME AS THE PROCEDURES FOLLOWED BY OMB WHEN WE ASSUMED RESPONSIBILITIES FROM OMB IN THIS AREA IN 1973.

B-180224.OM, JAN 23, 1981

SUBJECT: REVIEW OF PROPOSED PROCEDURE FOR IMPLEMENTATION OF PAPERWORK REDUCTION ACT OF 1980-B-180224-O.M.

DIRECTOR, GGD:

WE HAVE REVIEWED THE PROPOSED PROCEDURES FOR GAO HANDLING OF CLEARANCE REQUESTS FOR PROPOSALS BY INDEPENDENT FEDERAL REGULATORY AGENCIES TO CONDUCT AND SPONSOR COLLECTION OF INFORMATION PRIOR TO THE EFFECTIVE DATE OF THE PAPERWORK REDUCTION ACT OF 1980. THESE PROPOSED PROCEDURES ARE SET OUT IN THE DRAFT FEDERAL REGISTER NOTICE AND LETTER TO INDEPENDENT REGULATORY AGENCIES PREPARED IN COORDINATION WITH THIS OFFICE AND SUBMITTED BY MR. HEYL. WE UNDERSTAND THAT THEY HAVE BEEN DISCUSSED INFORMALLY WITH OMB'S OFFICE OF GENERAL COUNSEL AND WITH THE OMB DEPUTY ASSISTANT DIRECTOR FOR REPORTS MANAGEMENT, WHO HAVE NO OBJECTION TO THEM. ALSO, MR. HEYL HAS INFORMED US THAT THE PROPOSED PROCEDURES ARE ESSENTIALLY THE SAME AS THE PROCEDURES FOLLOWED BY OMB WHEN WE ASSUMED RESPONSIBILITIES FROM OMB IN THIS AREA IN 1973. THEREFORE, WE HAVE NO LEGAL OBJECTION TO THIS PROPOSAL.

THE LETTER TO THE AGENCIES SHOULD BE SENT AS SOON AS POSSIBLE, AND THE FEDERAL REGISTER NOTICE FORMALLY SUBMITTED FOR APPROVAL BY THE COMPTROLLER GENERAL.

ENCLOSURE

DIGEST

1. GENERAL COUNSEL HAS NO LEGAL OBJECTION TO PROPOSED PROCEDURES FOR TRANSFER OF GAO FEDERAL REPORTS ACT REVIEW FUNCTIONS TO OMB UNDER PAPERWORK REDUCTION ACT OF 1980, PUB. L. NO. 96-511, 94 STAT. 2 2, 44 U.S.C. 3501-3520.

2. SINCE EFFECTIVE DATE OF PAPERWORK REDUCTION ACT IS APRIL 1, 1981, AND GAO WILL HAVE UP TO 45 DAYS TO REVIEW REPORTS UNDER ITS PREDECESSOR STATUTE, 44 U.S.C. 3512, GAO CANNOT ASSURE REVIEW OF PROCESS REQUESTS RECEIVED AFTER FEBRUARY 13, 1981, WILL BE COMPLETED BY APRIL 1 AND WILL RETURN ANY REQUEST UPON WHICH FINAL ACTION HAS NOT BEEN TAKEN BY GAO ON MARCH 31, 1981 TO SUBMITTING AGENCY FOR SUBMISSION TO OMB IN ACCORDANCE WITH PUB. L. NO. 96-511. AFTER MARCH 1, ONLY EMERGENCY REQUESTS WILL BE ACCEPTED FOR REVIEW BY GAO.

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