When people speak of the burden imposed by
information collection requirements (i.e.,
"paperwork"), they often think of taking a pen to paper
and filling out a form. But paperwork burden is a
much more complex concept, and it is important to
consider all aspects of the burden imposed on
respondents by information collections.
For example, even when filling out a simple form, the
effort required (or time spent) to collect or otherwise
generate the information needed to fill out the form
often greatly exceeds the time spent answering the
questions or checking the boxes. Taxpayers usually
spend much more time calculating and documenting
their deductions than actually entering them on their
tax forms. Similarly, a firm reporting its inventory of
certain chemicals will inevitably spend a great deal of
time monitoring those levels.
Moreover, one can not speak meaningfully of burdens
without also speaking of benefits. Sometimes those
benefits are not immediately obvious. When a person
selects food products at a store, does the consumer
realize that the nutritional information on the container
is the result of an information collection requirement?
What would be the effect if no one had to certify the
safety of, e.g., meat and poultry, or if no one had to
provide the proof needed to qualify for federal benefits
or guaranteed loans?
These types of questions also illustrate why it is not
particularly informative to look at the aggregate
number of hours spent filling out government forms.
As noted below, the total paperwork burden for FY
1995 is a little under 7 billion hours. One could divide
that by the U.S. population and calculate that, on
average, each person spends roughly 26 hours
annually attributable to Federal information collection
requirements. Yet the information requirements come
in many different varieties and for many different
ends.
In some cases, the collection represents a legal
obligation to report information to the government to
verify compliance with government requirements.
The most familiar example of this would be the filing
of tax forms, which accounts for roughly 80% of the
total burden, but there are many other examples.
Nuclear power plants must submit information
documenting that operators are properly trained and
medically qualified for duty. Many firms are required
to prepare and/or submit information demonstrating
that they do not discriminate against potential
employees on the basis of race, sex, or national origin,
and many firms are required to submit information
confirming compliance with limits on air or water
pollution.
Some reporting requirements are for those who wish
to obtain some benefit or other service from the
government. Application forms and other supporting
documentation for those wishing to receive Medicare
reimbursement or food stamps would fall in this
category, as would applications for a passport, a
student loan, or a small business loan.
Other reporting requirements are for statistical
purposes. The most wellknown and comprehensive
statistical program is the decennial census, but there
are many other such collections. The Bureau of Labor
Statistics collects and reports data on the occurrence of
work related injuries and illnesses. The Bureau of
Justice Statistics collects, analyzes, publishes, and
disseminates statistical information on crime, criminal
offenders, victims of crime, and the operations of the
justice systems at all levels of government. The
National Highway Traffic Safety Administration and
the Federal Highway Administration collect
information on motor vehiclerelated accidents and
fatalities, and highway safety.
With growing frequency new requirements involve
reporting information not to the government, but to
third parties. The Paperwork Reduction Act of 1995
explicitly included thirdparty reporting requirements
within its scope and its definition of aggregate burden.
As a result of this change, many preexisting
thirdparty requirements that had not previously been
counted in the information collection budget are now
included. This produced a dramatic increase in the
information collection budget, although the change in
definition did not increase the actual burden of the
requirements themselves.
Thirdparty requirements take many forms.
Nutritional labeling on food products, as well as drug
labeling, are among the more common examples that
Americans see on a daytoday basis. Even the
clothing labels that many take for granted come from
an information collection requirement. Other such
requirements are not as obvious, although still
valuable. EPA, for instance, requires many firms to
disclose publicly their releases of hundreds of
potentially toxic substances, allowing nearby residents
to know what is happening in their local environment.
Some thirdparty requirements benefit specific
segments of the population. For example, employers
are required to inform employees about the nature of
hazardous substances with which the worker comes
into contact. This requirement takes the form of
information distributed to employees about the
possible hazards of a substance, and can obligate the
employer to hold training sessions where the employee
is advised on how to safely handle such material.
In some cases, a requirement is not for reporting of
information at all, but for the retention of information
by the individual or company for a specified period of
time -- record keeping. Once again, taxes are a good
example -- documentation used to claim tax
deductions must be kept by the taxpayer. There are
many other examples. Meat inspectors must keep
records of the results of tests for pathogens like E. coli
bacteria. Employers must keep records of employees'
medical histories under a number of occupational
safety and health regulations.
Also, some requirements are not requirements at all,
but are fully voluntary. Customer satisfaction surveys
are one important form of information collection.
Recently, government agencies submitted to OIRA
their plans for reducing and minimizing the burdens
they impose on the public through information
collections. In these Information Streamlining Plans,
the agencies have reflected the many factors involved
in making meaningful burden reductions. These
factors include the various forms of information
collections described above, the recent statutory
requirements mandating new collections, and the
complex nature of defining (or calculating) burden.
The agency plans have also reflected the tendency
toward electronic reporting -- taking the "paper" out of
paperwork -- in many cases allowing for a reduction
in burden by taking advantage of a much more
efficient means of gathering, analyzing and
transmitting required information.
Under the PRA, OIRA is charged not only with the
responsibility for assuring a proper weighing of the
burdens imposed by each collection on the public
against the legitimate needs and usefulness of the
information for the Federal agencies, but also with the
task of developing an annual Information Collection
Budget (ICB). The ICB is the vehicle through which
OIRA, in consultation with each agency, sets "annual
agency goals to reduce information collection burdens
imposed on the public." In addition, the ICB serves as
a management tool. Agency officials can use the ICB
in their internal planning and control processes to
review all of the collections of information their staff
plans to implement during the forthcoming year.
OMB uses the ICB in conjunction with management
reviews of other agency activities to assess
information collection priorities and to help maintain
the lowest necessary level of paperwork burden on the
public, consistent with the Federal Government's need
for information.
Since enactment of the original Paperwork Reduction Act of 1980, which established paperwork burden reduction goals, agencies have made progress in reducing paperwork burden. More recently, as part of the Administration's regulatory reform efforts, President Clinton directed the Federal agencies to increase their use of electronic means of information collection and, where feasible, to decrease the frequency of reporting by the public by onehalf. As a result, many initiatives have already been undertaken. For instance, during the 1997 tax season, the Internal Revenue Service (IRS) offered Telefile to most single filers who do not claim dependents, allowing over 4 million taxpayers who had previously filed the 1040EZ paper form to file their tax returns using a touchtone phone. In addition, as of September 30, 1996, agencies have taken 131 actions to reduce the frequency of reporting by the public, resulting in 3,380,000 hours of burden reduction.
The PRA set an annual governmentwide goal for the
reduction of the total information collection burden of
10% during each of fiscal years 1996 and 1997 and
5% during each of fiscal years 1998 through 2001.
The baseline is the total burden of information
collections as of the end of FY 1995. There have in
fact been many achievements in streamlining Federal
information requirements; agencies have lessened the
"hassle factor," simplified content, and worked to
identify and collect only information that is actually
needed and used in the administration of programs.
As demonstrated below in the information collection
burden reduction accomplishments for FY 1996 and
the planned initiatives for FY 1997, electronic
submission of information and overall improved
management of existing collected information
reduced, and will continue to reduce, the time that the
public spends to provide information for government
needs.
Table 3 reports the total information collection burden
of the Federal government as a whole, as well as for
each individual department or agency, for FY 1995
and FY 1996, and it represents the specific agency
goals estimated for FY 1997. As seen in Exhibit 6, the
Department of the Treasury, including the IRS,
continues to account for the great majority -- 80% --
of the Federal information collection burden in FY
1996. Because the Treasury Department accounts for
such a large percentage of the total information
collection burden imposed by the Federal government,
it is useful to present the exhibit excluding the
Treasury Department.
Exhibit 7 illustrates the share
that various agencies and departments contribute to the
information collection burden when Treasury is not
included. The Department of Labor is the second
largest agency in terms of information collection
burden, accounting for 18% of the nonTreasury
burden. The Defense Department is third, accounting
for more than 11% of the burden excluding Treasury.
The Federal Trade Commission and the Securities and
Exchange Commission are fourth and fifth,
respectively. The rest of the top ten are the
Department of Health and Human Services, the
Department of Agriculture, the Environmental
Protection Agency, the Department of Transportation,
and the Department of Education, ranking sixth
through ten, respectively.
Specific instances where agencies have made
significant reductions in their FY 1996 burden from
their FY 1995 baseline appear below:
Department of Agriculture. The Food and Consumer
Service published a final rule that established a new
system to help schools use nutrientbased menu
planning for meals in the National School Lunch and
School Breakfast Programs. The rule eliminated
regulatory requirements for edit checks and the
maintenance of records to prove the nonprofit status of
schools. As a result, paperwork burden was reduced
by almost 16 million hours.
Department of Commerce. The National Oceanic and
Atmospheric Administration (NOAA) eliminated
almost 130,000 hours of reporting and record keeping
requirements imposed on fishermen that accidentally
kill or injure marine mammals by streamlining the
Marine Mammal Protection Act (MMPA) regulations.
Commercial fishermen participating in fisheries with
interactions with marine mammals are no longer
required to keep a daily log of these interactions.
Participants now report only if and when any
incidental mortality or serious injury takes place
during commercial fishing operations.
Department of Defense. DoD has significantly
reduced the data delivery burdens imposed on its
contractors. As part of contract performance,
contractors are required to supply large amounts of
information, including drawings, maintenance
manuals, test reports, parts lists, software
documentation, and cost and scheduling data. DoD
has reduced the number of these data item descriptions
in its master catalog by 400 (of 1300), reducing the
burden on contractors by over 30 million hours.
Department of Education. Program changes within
the Federal Family Education Loan Program, such as
the phaseout of the Federal Insured Student Loan
program and the elimination of Teach Out
Requirements (that had obligated vocational schools to
designate backup schools where students could finish
their schooling in the event of the vocational school's
closure), have reduced burden by nearly 3.5 million
hours.
Department of Labor. The Benefits Accuracy
Measurement (BAM) program provides estimates of
the accuracy of benefit payments in the
Unemployment Insurance program and identifies the
sources of mispayments so that their causes can be
eliminated. DOL has reduced average sample sizes
and permitted States more flexibility in how they
verify information pertinent to the sampled payments,
resulting in a burden decrease of almost 60 thousand
hours.
Department of Transportation. During FY 1996, the
DOT amended its regulations governing the filing of
international passenger tariffs. Although air carriers
had been permitted to file tariff information
electronically since 1989, they were still required to
file some 42,000 pages of paper annually pertaining to
tariff rules (e.g., length of stay requirements). The
regulatory revisions now permit much of this
information to be filed electronically. As a result, the
annual information collection burden on air carriers
has been reduced by approximately 380 thousand
hours.
Department of the Treasury. The IRS made several
changes to the 1040 form and instructions that reduced
the paperwork burden of individual taxpayers by
almost 60 million hours. These changes included
producing a separate, streamlined set of instructions
for use by 10 million taxpayers that file the simplest
1040 returns and eliminating a net of 20 lines from the
1040 form and instructions.
Environmental Protection Agency. The Office of
Water efforts to reduce reporting focused on the
National Pollutant Discharge Elimination System
(NPDES) Monitoring Report. Guidance was
developed to reduce existing monitoring and reporting
requirements for facilities that consistently comply
with their permit limits, consistently discharge higher
quality water than required by their permits, or
implement strong facility management plans. The
burden associated with the NPDES Monitoring Report
will be reduced by about 4.7 million hours once the
program is fully implemented.
Federal Deposit Insurance Corporation. The FDIC
eliminated its Forms 3320/14 and 3320/19, which
were part of its acquisition services information
requirements, thereby streamlining the procurement
process and reducing the paperwork burden on firms
wishing to do business with the FDIC.
Securities and Exchange Commission. The SEC has
reduced the paperwork burden it imposes on the public
by 25 percent since FY 1995. This reduction has been
achieved, in part, with the elimination of 44 rules and
4 forms that the Commission's Task Force on
Disclosure Simplification found were no longer
necessary or appropriate for the protection of
investors. The rules and forms that the Commission
eliminated included Regulation F and accompanying
Form 1F, which had been used by investors and
issuers to claim a conditional limited exemption from
Securities Act registration for assessments levied on
certain stock. This exemption was made obsolete by
the availability of other exemptions. Also eliminated
was Form 10C, which required issuers to report to
the Commission changes in corporate name and other
information that is typically reflected in an issuer's
financial statements.
The following highlights of planned initiatives for FY
1997 illustrate the agencies' efforts to continue to
reduce burden on the public.
Department of Agriculture. USDA plans to reduce the
required number of acreage reports and certifications
of compliance, which is expected to reduce burden by
almost 1.5 million hours.
Department of Commerce. After having streamlined
its grant procedures, the Economic Development
Administration (EDA) intends in FY 1997 to
consolidate three application forms into a single
application for all programs under the Public Works
and Economic Development Act. In addition to
reducing burden by almost 40 thousand hours, EDA's
associated regulations are more user-friendly and more
consistently applied among its regional offices.
Department of Defense. Defense FAR Supplement
Part 239 prescribes the policies and procedures for
DoD to follow during the exchange or sale of Federal
information processing services, security and privacy
for computer systems, automatic data processing
equipment, and telecommunications services. During
FY 1997, DoD is deleting DFARS language
containing references to an obsolete cost principle
pertaining to automatic data processing equipment
leasing costs and removing corresponding contractor
documentation and Government oversight
requirements. As a result, burden is being reduced by
about 106 thousand hours.
Department of Health and Human Services. Increased
electronic claims and the elimination of the physician
attestation on individual claims will reduce the burden
resulting from the Medicare/Medicaid Health
Insurance Common Claim Form by roughly 4 million
hours.
Department of Interior. The Office of Surface Mining
Reclamation and Enforcement intends to issue a rule
on Valid Existing Rights that will reduce the amount
of information reported by respondents, reducing their
burden per response from 210 hours to 14 hours. The
Bureau of Land Management (BLM) will review the
information collections associated with onshore oil
and gas operations to eliminate duplicative requests of
lessees and operators and ensure maximum use of
existing information. BLM's efforts are expected to
reduce reporting burden by over 6 thousand hours.
Department of Justice. In FY 1997, the Justice
Department will begin a pilot test to automate the
Arrival Departure Record (I94) and determine the
feasibility of expanding the automated collection
system nationwide and consolidating the I94, I94T,
and I94W. Justice estimates that, if fully
implemented, the automation and consolidation of this
collection will reduce burden by almost 700 thousand
hours.
Department of Transportation. In FAA's Antidrug
Program for Personnel Engaged in Specified Aviation
Activities, requirements are being simplified for
submitting antidrug plans and MIS reports, and some
requirements for plan amendments are being
eliminated. These change will result in a reduction of
65 thousand hours.
Department of Treasury. The IRS will raise the
threshold for record keeping requirements for
businesses required to report travel, gift, or
entertainment expenses. Businesses will have to
maintain receipts for expenses of $75 or more, instead
of $25, which will exclude many business lunches and
dinners. By easing this record keeping requirement,
IRS will reduce the burden on business taxpayers by
almost 13 million hours.
Department of Veterans Affairs. VA collects
information from veterans and their spouses to
determine eligibility for medical and other benefits.
VA plans to revise the collections to eliminate certain
data elements (for example, simplifying the Financial
Worksheet) and expects the burden to decrease by
about 700 thousand hours.
Environmental Protection Agency. EPA has proposed
regulations designed to reduce reporting frequency,
shorten records retention, and streamline reporting
requirements in its stationary source air programs.
The proposed revisions to existing standards would
reduce record keeping and reporting burdens by
approximately 1 million hours per year.
Federal Deposit Insurance Corporation. As a result
of a change in the statutory requirements relating to
the Fair Lending Monitoring System, the FDIC will
reduce by more than 50 percent the number of
financial institutions required to file under this
authority. The statutory change increased the asset
size of institutions required to file under this provision,
thereby exempting many smaller institutions and
reducing the annual burden estimate by approximately
50 percent.
Federal Communications Commission. The FCC's
Common Carrier Bureau will no longer require or
allow nondominant interexchange carriers to file
tariffs for their interstate, domestic, or interexchange
services. The Bureau's elimination of this requirement
will reduce burden by almost 290 thousand hours in
FY 1997.
Securities and Exchange Commission. The SEC will
be issuing rules to implement provisions of the
Investment Advisers Supervision Coordination Act
that would result in a shift of regulatory
responsibilities from the Commission to the States.
Since fewer investment advisers would register with
the Commission, the burden associated with the
Investment Advisers Act of 1940 will be reduced by
over 4 million hours, although they will be subject to
new regulatory burdens imposed by the States.
Department of Treasury/Bureau of Alcohol,
Tobacco, and Firearms (ATF)
Title: Firearms Transaction Record, Part I,
Over-the-Counter, and Firearms Transaction Record,
Part II, Non-Over-the-Counter (ATF F 4473, Parts I
and II (5300.9))
Violation: Unauthorized Collection
How Discovered by OMB: In February 1997, the
public notified OMB that ATF had revised Form 4473,
Part I, without OMB approval.
OMB Action: ATF's submission of the revised forms
to OMB, requesting an extension without change.
were designated by OMB as improperly submitted.
Agency Response: ATF resubmitted the forms to
obtain OMB approval of the revisions. Treasury has
assured OMB that ATF will reexamine its internal
procedures to ensure future compliance with the PRA.
Department of Labor
Title: Minimum Wage Toll-Free Survey
Violation: Unauthorized collection.
How discovered by OMB: OMB discovered this
violation by reading news releases. Congressional
staff also discovered the violation.
OMB Action: OMB notified the DOL of the violation.
Agency Response: The DOL submitted a paperwork
package that was later withdrawn. The survey is no
longer in use.
Department of Commerce/Patent and Trademark
Office (PTO)
Title: Trademark Processing
This is the basic application form and subsequent
forms used to process trademark applications.
Violation: Expiration of ongoing collection
How discovered by OMB: The Department notified
OMB that the collection would expire on September
30, 1995.
OMB Action: OMB notified the agency that it was in
violation of the PRA once it allowed the collection to
expire because trademark applications and others
continue to be processed daily by the PTO.
Agency Response: The Department published the first
notice required by the PRA in the Federal Register on
February 21, 1996, and is working to bring the
collection back into compliance.
Department of Agriculture
Title: Various Information Collections
Violation: Expiration of ongoing collections
How Discovered by OMB: OMB discovered this
violation in the course of preparing for a meeting on
USDA's Information Streamlining Plan.
OMB Action: OMB raised the issue with USDA and
discussed the organizational problems that led to the
incidents.
Agency Response: USDA has committed to bringing
these collections into compliance with the PRA.
Department of Labor
Title: Annual Report (5500 Form)
Violation: The DOL made substantive modifications
to the 5500 form without prior OMB review and
approval.
How discovered by OMB: OMB discovered the
violation during review of the emergency paperwork
clearance.
OMB Action: OMB commented on the violation in
the terms of clearance for the emergency approval.
Agency Response: DOL agreed not to commit this
violation again.
Department of Labor
Title: Paperwork associated with the rule on
Guidelines, Federal Transit Law --Section 5333 (b)
Violation: Unauthorized collection.
How discovered by OMB: OMB discovered this
violation during the review of the rule.
OMB Action: OMB notified the DOL of the violation.
Agency Response: Since the information is originally
collected by the Department of Transportation, it was
agreed among OMB, DOL and DOT that DOT would
submit a paperwork clearance package for the Federal
financial assistance applications.
Department of Labor
Title: Office of Federal Contract Compliance
Programs: Affirmative Action Plan Scheduling Letter
Violation: Changed the form without OMB approval.
How discovered by OMB: The public alerted OMB
to the violation.
OMB Action: OMB requested an action from DOL
(some form of announcement to inform the public).
Agency Response: DOL sent memo to regions stating
which forms had OMB approval and reminded them
about the PRA.
Department of Labor
Title: Variety of lapsed clearances within the
Employment and Training Administration (ETA)
Violation: Expiration of ongoing collections.
How Discovered by OMB: OMB discovered these
violations when ETA submitted numerous
reinstatement requests for clearance.
OMB Action: OMB notified DOL and requested a list
of all ETA expired collections with information on
their status.
Agency Response: DOL submitted a list of expired collections and is working to come into compliance.
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