- By Timothy Sprehe
- Jun 19, 2000
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,
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 email@example.com.