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Chapter 28. MINIMIZING THE REPORTING BURDEN OF

STATISTICAL INQUIRIES

Introduction

Government statisticians have long been concerned about minimizing the burden of providing information required for statistical inquiries. This concern has been expressed in various efforts to eliminate duplication, to develop uniform classifications, definitions and standards so that data are comparable, and to design increasingly efficient sampling methodologies.

Administration of the Federal Reports Act of 1942 is one of the important control mechanisms for reducing reporting burden for all types of Federal inquiries, including grant applications for participation in Federal programs, program administration forms, evaluation studies, and statistical surveys. It has traditionally been linked with the statistical policy function in the Office of Management and Budget. However, few people realize that the statisticians' concern about consistency in data collection and minimizing reporting burden predates the Federal Reports Act by several years. In fact, the Central Statistical Board in 1936 developed a procedure by which it would informally review all data collection instruments to identify data which might be available in other agencies, to make suggestions concerning statistical procedures, and to make recommendations concerning classification concepts. While the agencies were not required to follow the suggestions from the Central Statistical Board, they did actively participate in the cooperative process since the statistician's advice was usually very helpful. It is a consequence of this early involvement with standardizing data collection that administration of the Federal Reports Act was linked with the statistical policy function which, at that time, was in the Bureau of the Budget.

There have been many attempts to respond to the public's concern about the burden of data collection. One of the early attempts was in 1887, when a high level investigative commission was appointed to analyze the problem.' The Central Statistical Board,

at the request of President Franklin D. Roosevelt, undertook a study of reporting burden.?

Other studies of paperwork burden include the Mills-Long Report (1948), the Federal Paperwork Jungle Hearings of the Subcommittee on Census and Population (1965-1966), the Kaysan Committee (1966), and the President's Commission on Federal Statistics (1971).'

The most recent investigation of reporting burden was undertaken by the Commission on Federal Paperwork which was established by Public Law 93556 (December 27, 1974). The Commission began operation in October 1975 and completed its work in October 1977. The overall materials in A Framework for Planning U.S. Federal Statistics for the 1980's were made available to the Commission staff for their use and for comments on specific chapters. The personnel in the Statistical Policy Division of the Office of Management and Budget (now the Office of Federal Statistical Policy and Standards in the U.S. Department of Commerce) worked closely with the Commission staff throughout the course of the Commission's study. Therefore, this particular chapter reflects the findings of the Commission in relation to the topics which are discussed throughout the Framework.

The Commission on Federal Paperwork

The Commission on Federal Paperwork was established by the Congress as a result of its view that “Federal information reporting requirements have placed an unprecedented paperwork burden upon

See Joseph W. Duncan and William C. Shelton, Revolution in United States Governmental Statistics, 1926-1976, Chapter 5.

'These studies are discussed in the report of the Commission on Federal Paperwork entitled Statistics, pp. 45-49. See also the report of the Commission on Federal Paperwork entitled History of Paperwork Reform Efforis.

Reporting burden has been also the subject of the following Statistical Reporter articles: (1) “The Paperwork Predicament" (September 1974); “Seeking Reductions in the Federal Paperwork Burden” (July 1975); “Measuring the Burden of Reporting to the Federal Government" (October 1975); “President's Reporting Reduction Program" (April 1976); and “President Ford Opens Second Phase of Reporting Reduction Program" (August 1976).

'Paul Feldman, “Commissions on Statistics: Statistics on Commissions,” Statistical Reporter, November 1970, pp. 73-79.

private citizens, recipients of Federal assistance, businesses, governmental contractors, and State and local government." In establishing the Commission, the Congress emphasized that reporting burden was to be minimized, consistent with the Government's needs for information to set policy and operate its lawful programs. The emphasis throughout the Commission's studies was on Federal information gathering in its broadest sense. Its studies cover all types of Federal reporting, of which statistics is only one relatively small part.

The Commission was established to consider (as stated in Public Law 93-556): 1. the nature and extent of current Federal

requirements for information from other public and private entities;

limitations in the present clearance system. Among these deficiencies, the Commission points out that: 1. The clearance process focuses on symptoms:

paperwork and not primarily or principally on

causal factors; 2. The clearance process is largely a piecemeal

process which examines reporting forms rather than the larger paperwork and management

systems of which the paperwork is a part; 3. Review generally occurs too late in the

developmental process of a program to be effective in stopping unnecessary information

requirements; 4. Coverage of informational requirements is

incomplete and the authority is split among

three agencies; 5. The process is slow, adversarial and does not

differentiate important from unimportant data

burdens and projects; 6. There is no detailed listing of all data

requirements; 7. There is little in the way of compliance

sanctions on the data collection agencies; 8. The Federal Report Acts does not specify the

management control responsibilities of the data collecting agencies.

2. the effect of existing statutes on the

information requirements of the Federal Government and authorities of existing Federal agencies to collect information;

3. the nature and extent of management and

control over the determination of Federal information needs and the choice of information gathering, processing, and dissemination methods;

4. the nature and extent to which Federal

agencies cooperate with State and local governments and private agencies in collecting, processing, and disseminating information;

5. the procedures used and the extent to which

considerations of economy and efficiency impact upon Federal information activities, particularly as these matters relate to costs burdening the Federal Government and providers of information;

The Commission points out that the clearance process is in itself but a step in the life cycle of information and that it takes place too late in that cycle to be effective. Effective information resources management must start at the front end of the process as an integral part of the planning stage and continue throughout strategic points along the line to final implementation. The Commission proposes three general steps:• 1. Redesigning the clearance process to eliminate

overlap and duplication among agency requests through strengthened guidelines and standards.

6. the ways in which policies and practices

relating to the maintenance of confidentiality of information impact upon Federal information activities, and

7. such other matters as the Commission may

decide affect Federal reporting requirements.

2. Developing and implementing more effective

methodologies for determining information requirements, and for weighing the cost to the

Review and Clearance Process Problems and

Recommendations

•Commission on Federal Paperwork, The Reports Clearance Process, Statistics, History of Paperwork Reform Efforts, and Information Resources Management.

'Commission on Federal Paperwork, Information Resources Management, pp. 20-21.

'Ibid., pp. 21-22.

In a series of reports, the Commission on Federal Paperwork has identified a number of flaws and

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public of data collection against the values data to the operating and administrative problems of expected from the use of the data.

Federal programs. 3. Decentralization of the routine clearance These recommendations and findings clearly

workload to the Federal agencies, with indicate an intent to both increase the responsibilities prescribed policy guidelines and standards, of the agencies for assuring the compliance of their and a concentrated focus on policy data collection activities to the guidelines and development, oversight and politically standards of the Federal central review and clearance sensitive issues in statistical activities at the system and to provide greater oversight of the central review level.

planning process and the utilization of the data col

lected from the public. It also clearly indicates a need Included in the Commission's reports are an

for further development of guidelines and standards extensive set of recommendations for improvement in the central review and clearance process. Basically

for statistical and research activity and for the

expansion of resources to implement both the early these are intended to shift the focus of review from

planning, coordination and development stages of the symptoms, as evidenced by excessive and

the review process and the assessment of data utiliunnecessary paperwork, to the causes, exemplified as

zation through the post-audit process. “bad organization, poor, management, and poorly designed information requirements." The recom

The Public Burden of Statistical Surveys mendations include actions to: end exemptions from the Federal Reports Act; end split jurisdiction The completion of statistical reports to the between OMB and GAO; provide tools to eliminate executive agencies of the Federal Government by duplication through a Federal Information Locator individuals and businesses throughout our society System and the assignment of coordination or col- requires millions of man-hours of time. There is no lection responsibility to a single agency in specific single statistical summary of all of the inquiries which programmatic areas; use of best available

are made of individuals, businesses, and institutions. methodologies in information resources An important indicator is provided, however, by management; provide consultation services for

those inquiries which are subject to the Federal Restatistical and research design and development; ports Act. Statistics compiled by the Office of place increased responsibility for information Management and Budget show that in June 1976, management on the agencies, with improved nearly 27.5 million man-hours were spent in replying statistical guidelines and standards and the to statistical inquiries. continuation of central statistical review of general

While this is a substantial number, it is a small purpose surveys and forms; expand the examination of the practical utility of selected reports, through

proportion of the total reporting burden placed on postaudit assessment of the uses made of the data col

the public by Government inquiries. This point is lected, with increased resources for these audit

clearly made by the Commission on Federal functions; develop administrative and information

Paperwork which stated: standards to reduce paperwork; improve guidelines

Statistics constitute a fairly small share of Federal and standards for agencies to follow in developing

reports as a whole. On June 30, 1976, they and designing programs and information

represented about one-fourth of the number of rerequirements; and improve the methodology for

porting forms of systems and about 13 percent of measuring costs to the public and the benefits to

the annual hours spent by respondents in replying Federal programs of the data requirements.

to Federal requests coming from the agencies

under the Federal Reports Act. (This total exThese recommendations and the overall scope of

cludes tax returns to the Internal Revenue Service the findings of the Commission clearly indicate the

and reports to the bank regulatory agencies, which need for an expanded scope to the review and clearance activity. This review would focus on the

are exempt from the Federal Reports Act.)' planning and development stages of projects and pro- It is apparent, the, that statistical agencies are not grams for data collection to a greater extent that has the principal creators of Federal paperwork. The been possible previously; it would extend into the assessment of the practical utility of the data collected, through postaudits of the application of the 'Commission on Federal Paperwork, Statistics, p. 7.

'Ibid., p. 7. For a more complete discussion see a technical paper

developed by Aryness Joy Wickens for the Commission entitled Commission on Federal Paperwork, The Reports Clearance “Profile of Federal Paperwork-A Graphic Summary.” Copies are Process, pp. 45-59.

available from Office of Federal Statistical Policy and Standards. '' Ibid., pp. 40-41. "Ibid., pp. 40-41.

reports involved in management, operation, and evaluation of Federal programs constitute the bulk of the reports. Collection of data for the longestablished economic and social statistics impose minimal reporting burdens on respondents, although minor exceptions offer opportunities for some economies. In some of the newer statistical programs where Federal activity has expanded rapidly, serious paperwork problems are evident. But the overriding problem in reducing the burden of Federal statistics lies in the mechanisms for planning and coordinating the Federal statistical

lest extent possible, those data which are available from other administrative sources.

In the next section of this review, a number of the specific recommendations of the Commission on Federal Paperwork relating to statistics will be presented in relation to the Framework itself. The interested reader is encouraged to review the full report of the Commission entitled Statistics since it provides considerable elaboration of the rationale behind the recommendations as well as additional background information about the problems under discussion. Further, many other Commission reports in topical areas have recommendations relating to statistical programs. Since the Commission's report is widely available, the following section will be somewhat abbreviated. The recommendations are discussed below, in the order in which they are presented in the Commission's report on Statistics.

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system.

Discussion of Commission on Federal

Paperwork Recommendations for Reducing Reporting Burden in Statistical

Agencies

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In summarizing its analysis of paperwork required for statistics, the Commission stated:

In the full picture of all Federal reports, however, statistical reports probably play an even smaller role than depicted by the OMB and GAO figures because of the importance of nonstatistical forms issued by exempt agencies (chiefly the Internal Revenue Service and the financial and banking regulatory agencies).... By any test...statistics play a comparatively minor role in overall Federal reporting. Statistical surveys accounted for about 26 percent of the forms, but only 13 percent of the estimated hours spent in reporting and less than 10 percent of the annual responses in the inventories for June 30, 1976."

While statistical reports are only a small part of total governmental reporting, the very size of the statistical establishment and its decentralization in many government agencies indicates that it is essential that continual scrutiny be given to problems of reporting burden, especially for voluntary statistical surveys where the respondent is not receiving a direct benefit as a result of program participation. While it is true that all citizens benefit from improved statistics which make it possible to have enlightened policy, it is often difficult, in a specific case, for the respondent to appreciate the value of his contribution. Consequently, if overall governmental demands for information are viewed as excessive, the voluntary statistical inquiries are likely to be among the first to be ignored, especially in comparison with those reporting burdens associated with applying for a Federal grant or benefit or with required reporting on the use and application of such a benefit. Therefore, it is essential for the statistical system to make every effort to minimize reporting burden and to utilize, to the ful

In this section the actual wording of the Commission on Federal Paperwork recommendations will be presented in italics. The discussion which follows is a perspective in the context of the overall Framework except where quotes indicate background or elaborating material from the Commission's report itself.

Recommendation No. 1. The Director of the Office of the Management and Budget should revise the staffing and other resources applied to statistical coordination in a strong central coordinating unit for the Nation's statistical system.

This recommendation became somewhat out of date just as the Commission report was being issued. This is acknowledged in the "Foreword” to the Commission report on Statistics in which it is noted that Presidential Reorganization Plan No. 1 of 1977 for reorganization of the Executive Office of the President which transferred statistical policy functions from the Office of Management and Budget to the Department of Commerce would "affect some of the recommendations which the Commission made in this report. Accordingly, the Commission made some observations on issues which it believed should be considered as the reorganization plans developed."

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"Ibid., p. 1.

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