Recommendation: The Director of OMB should ensure the consistent application of the requirement for respondent time costs, including clarifying instructions for when and how to include fringe benefits. (Recommendation 1)
Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Comments: In April 2019, we requested information from OMB on the agency's implementation of our recommendation but as of May 2019 have not received any status updates. We will continue to monitor OMB's efforts to address our recommendation.
Recommendation: The Director of OMB should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 2)
Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Comments: In April 2019, we requested information from OMB on the agency's implementation of our recommendation but as of May 2019 have not received any status updates. We will continue to monitor OMB's efforts to address our recommendation.
Recommendation: The Secretary of Agriculture should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 3)
Agency: Department of Agriculture
Status: Open
Comments: In June 2019, USDA provided an update on efforts to review its Paperwork Reduction Act (PRA) policies and procedures. To ensure that its PRA process is operating effectively, USDA reviewed and updated its internal guidance on preparing information collection request supporting statements, including sections regarding the calculation of respondent burden hour and cost estimates. This updated guidance encourages consultation with potential respondents to help develop these burden estimates. A new PRA consultation checklist directs agency officials to seek input from individuals outside of USDA regarding the agency's burden estimates for an information collection request, including the validity of the methodology and assumptions used in the estimate calculations. The updated guidance specifies that fringe benefits, such as paid leave, insurance, and retirement contributions, should be included in the wage rates used for respondent burden cost estimates. It also clarifies when roundtrip travel time and costs should be included in burden estimates. According to USDA officials, the agency meets with PRA Coordinators to ensure compliance with the updated guidance. These are positive steps toward improving USDA's burden calculation process. However, USDA has not yet provided evidence of a review or revision of its information collection request review process. A review or revision of this process could help USDA better identify errors in burden estimate calculations prior to the final information collection request being sent to OMB and released to the public.
Recommendation: The Secretary of Health and Human Services should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 5)
Agency: Department of Health and Human Services
Status: Open
Comments: In October 2018, HHS provided a statement of actions it had taken to address this recommendation. HHS stated that it had added reporting tools to its Common Data Element Repository (CDER) Library that could help improve tracking of information related to HHS's Information Collection Requests. HHS also stated that it had launched daily emails to Paperwork Reduction Act (PRA) staff to inform them of Office of Management and Budget (OMB) Notices of Action related to Information Collection Requests. Additionally, HHS released an information collection burden calculator tool in the CDER Library to give PRA staff the ability to create burden tables for consistent use across multiple platforms for a single Information Collection Request. According to HHS officials, this tool incorporates both wages and employee benefits in the burden calculations. As of August 2019, HHS's burden calculator tool has been included as a resource on PRA.Digital.gov, a new OMB website that serves as a PRA knowledge base for federal staff. While these are important steps, we are awaiting additional details on how these changes have affected HHS's PRA review process. We will continue to monitor HHS's progress toward addressing our recommendation.
Recommendation: The Secretary of Health and Human Services should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 6)
Agency: Department of Health and Human Services
Status: Open
Comments: In October 2018, HHS stated that it continues to leverage consultation mechanisms for input on the burdens imposed by information collections. According to the agency, it plans to increase the use of the eRulemaking program's Federal Docket Management System for all information collections, including non-rule Information Collection Requests. HHS also stated it plans to contact stakeholders to discuss potential information collections and receive burden estimates. As of August 9, 2019, we have not received an update about HHS's actions or plans. We will continue to monitor HHS's efforts to address our recommendation.
Recommendation: The Secretary of Transportation should review the policies, procedures, and related control activities to ensure that the agency's Paperwork Reduction Act review process is operating effectively. (Recommendation 7)
Agency: Department of Transportation
Status: Open
Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.
Recommendation: The Secretary of Transportation should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 8)
Agency: Department of Transportation
Status: Open
Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.
Recommendation: Congress may wish to consider amending the Paperwork Reduction Act to more explicitly require federal agencies to consult with potential respondents on each information collection beyond the publication of Federal Register notices using efficient and effective consultation methods. (Matter for Consideration 1)
Agency: Congress
Status: Open
Comments: As of July 2019, no relevant legislation has been enacted. We will continue to monitor legislation to see if it addresses our matter for congressional consideration.
Recommendation: The Secretary of Transportation should include enough information in Federal Register notices to allow the public to reasonably calculate or determine the number of respondents, the frequency of response, and the average burden time per response for each information collection activity. (Recommendation 9)
Agency: Department of Transportation
Status: Open
Comments: In its September 2018 recommendation implementation update, Department of Transportation (DOT) stated that the departmental Paperwork Reduction Act (PRA) Officer has reviewed the Notice templates and checklist with DOT component PRA Officers during monthly PRA meetings and has applied additional scrutiny in the review process. DOT officials stated that the department began an internal review of the Paperwork Reduction Act program operations, policy, and guidance that will include additional aids to support Notice development. Officials reported that they anticipate issuing an updated policy by September 30, 2019. We will continue to monitor DOT's efforts to address our recommendation.
Recommendation: The Commissioner of Internal Revenue should leverage existing consultation with stakeholders and the public to explicitly seek input on the estimated burden imposed by information collections. (Recommendation 10)
Agency: Department of the Treasury: Internal Revenue Service
Status: Open
Comments: According to IRS, agency officials met with representatives of external stakeholder organizations on the Information Reporting Program Advisory Committee (IRPAC) to seek input on the burden experience of their participants and the communities they represent. As a result of these discussions, the IRPAC has added the burden experience as defined by the PRA as a monthly agenda topic for the 2019 session. As of September 2019, IRS officials reported that the IRPAC has not yet met in 2019. Once we receive documentation confirming this action, we will update the status of the recommendation accordingly.
Recommendation: The Commissioner of Internal Revenue should include enough information in Federal Register notices to allow the public to reasonably calculate or determine the number of respondents, the frequency of response, and the average burden time per response for each information collection activity. (Recommendation 11)
Agency: Department of the Treasury: Internal Revenue Service
Status: Open
Comments: In October 2018, Internal Revenue Service (IRS) reported that it continues to standardize the review process by developing a checklist that ensures all required elements are included in the Federal Register notice. Agency officials stated that the agency will complete the development and delivery of training for employees with responsibility for PRA compliance in fiscal year 2019. We will continue to monitor IRS's progress toward completing these actions.
