Keeping information collection in check

As federal agencies labor to respond to the Government Paperwork Elimination Act, it is a good time to review GPEA in the context of collecting information from the public.

GPEA sets an October 2003 deadline for agencies to provide the public with the option of submitting government forms electronically whenever possible. The Office of Management and Budget is requiring agencies to submit their GPEA plans by Oct. 31.

The call for GPEA plans falls in the context of information collections — data collected from the public — because implementing electronic forms has policy and procedural constraints.

Information collection policies put the emphasis on minimizing the amount of data collected from the public, thus the term information collections "budget" comes into use. Similarly, OMB Circular A-130 — which provides uniform governmentwide information resources management policies — often uses the term "burden" when talking about information collections from the public.

Whenever information is collected from 10 or more members of the public, OMB requires a certification number. Information on information collections and certification can be found at the following OMB Web page: www.whitehouse.gov/OMB/inforeg.

In addition, OMB Circular A-130 provides significant implementation and policy guidance on information collections from the public.

Before starting on electronic forms, you should check with your agency's designated information collection budget officer to find out if there are other additional requirements your agency has implemented internally.

In general, open-ended questions on your agency Web site — such as seeking comments on the site's usefulness or identifying any problems, such as bad links — are generally not considered the type of information collection that requires a certification number. However, if the request takes on the form of a survey, it is more likely to be an information collection requiring certification.

To find out what information collections are already approved by department, check out www.whitehouse.gov/library/omb/OMBINV.html.

I found navigating through the inventories extremely interesting. It was surprising to see the number of information collections and the magnitude of some of these. For example, I had not connected tax forms and Securities and Exchange Commission filings as information collections that require OMB certification.

For more GPEA guidance, see the federal CIO Council's GPEA Resources Web page.

Kellett is founder of the Federal Web Business Council, co-chairman of the Federal WebMasters Forum and is director of GSA's Emerging IT Policies Division.