Misguided guidance

The Office of Management and Budget recently issued its guidance for implementing

the Government Paperwork Elimination Act. The guidance is founded on the

premise that moving to electronic transactions can reduce the government's

cost of collecting and processing information.

I applaud the onrush of electronic government, but I want to make two

points about the GPEA guidance published by OMB's Office of Information

and Regulatory Affairs.

The first point is a message directed specifically to OIRA: Physician,

heal thyself!

When agencies submit information collection requests to OMB for approval

under the Paperwork Reduction Act, OIRA requires that the requests be submitted

only on paper, despite agencies' pleas for electronic re-engineering of

the process. OIRA still insists on three copies of every page of every PRA

submission. That's three copies of OMB Form 83-I, the supporting statement,

the information collection instrument itself and all supporting laws and


It is not uncommon for a single PRA submission to run more than 1,000

pages. By its stubborn refusal to change its own corporate behavior, OIRA

is needlessly costing the government untold thousands of dollars every year.

Not to mention the fact that for OIRA to issue GPEA guidance for other agencies

is an act of monumental hypocrisy.

My second point revolves around the fact that the bulk of the GPEA guidance

addresses this question: How can agencies improve service delivery and reduce

burden through the use of electronic signatures and electronic transactions?

"Burden" is defined as the amount of time and money the public spends

in supplying information to the government. OIRA does not show any evidence

to substantiate the notion that electronic signatures and transactions reduce


To be sure, benefits may accrue from doing business electronically and

they may be substantial. But the benefits are principally cost reductions

in terms of more efficient processing and improvements in service delivery,

not reduced response burden for the public.

The truth is that electronic collection of information probably does

little to reduce respondent burden, but it may embody other benefits that

render electronic transactions and signatures compelling on their own merits.

For OIRA to adopt this reasoning, however, would be to admit a more

sophisticated view: The costs to the public of respondent burden can be

outweighed by the benefits to the public of more efficient government, better

service delivery and the intrinsic value of the information collected.

OIRA would have agencies move mindlessly toward electronic government

without examining why they are doing so and whether, on a case-by-case basis,

the electronic juice is worth the squeeze.

—Sprehe is president of Sprehe Informa-tion Management Associates, Washington,

D.C. He can be reached at jtsprehe@jtsprehe.com.


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