Paperwork reduction scam

This year is the 20th anniversary of the Paperwork Reduction Act, and the law will be up for re-authorization next year. This seems an opportune time for laying out the case that, in its essential aim of reducing government paperwork, the PRA is badly broken and needs an overhaul.

The PRA aims to diminish federal information collection from the public and thereby reduce the cost the government imposes for doing business. As currently written and administered, the law does not accomplish that goal.

Far from reducing government paperwork, the PRA has put into play a silly numbers game that revolves around a squishy concept called "information burden hours." Information burden hours are the number of hours an agency estimates it takes the public to fill out a form. Agencies must estimate the dollar value of the burden hours it imposes on the public.

Information burden hours and their monetary value are concepts easily susceptible to gaming. Executive branch agencies pretend to make burden hours smaller, while, in fact, Congress keeps passing laws to increase the amount of information the government collects, driving burden hours upward. When things don't look quite right, everyone jiggles the numbers and looks the other way.

Also, no one examines the cost to the public of administering the PRA. It takes as much time and paperwork to get clearance for a questionnaire imposing 15 burden hours as it does for a document that imposes 1.5 million burden hours. The law allows for no distinction between critical statistical and economic data and essentially frivolous information collections.

When applying for an information collection, an agency must publish two notices in the Federal Register, at $375 per page, for every separate information collection. The notices are mandatory, despite the fact that almost no one in the public ever comments on them. So the government wastes millions of dollars every year administering a law that only a few special interest groups care about.

The law as written contains no sense of scale and balance. Why can't we have a PRA that balances the costs to the taxpayer of administering the law against the presumed benefits of the law to the taxpayer?

Worst of all, as its name states, the PRA is totally focused on paper. Today is the age of the Internet — the days of e-mail, e-commerce and World Wide Web sites. At present, it takes at least six months for an agency to get clearance from the Office of Management and Budget to collect information, substantially slowing down and making more costly the business of government. If an Internet year is now three months, that is the equivalent of two years to get OMB approval for an information collection. This is Ice Age government, not the streamlined, technology-enhanced processes we have come to expect.

As it considers PRA reauthorization, Congress should go back to the drawing board. Lawmakers should measure the PRA's intended benefits against the costs of administering the law in its fatally flawed form. They should radically rethink the meaning of government information collection in the Internet Era.

—Sprehe is president of Sprehe Information Management Associates, Washington, D.C. He can be reached at jtsprehe @jtsprehe.com.

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