Paperwork reduction scam
- By Timothy Sprehe
- May 01, 2000
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.