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GAO-02-651R 1 (2002-04-29)

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      Accountability * Integrity * Reliability
United States General Accounting Office
Washington, DC 20548



         April 29, 2002

         The Honorable Mitchell E. Daniels, Jr.
         Director
         Office of Management and Budget

         Subject: Paperwork Reduction Act: Changes Needed to Annual Report

         Dear Mr. Daniels:

         On April 11, 2002, we testified before the House Committee on Government Reform's
         Subcommittee on Energy Policy, Natural Resources and Regulatory Affairs about the
         implementation of the Paperwork Reduction Act (PRA) of 1995.' Our testimony was
         based in part on information that was collected by the Office of Management and
         Budget's (OMB) Office of Information and Regulatory Affairs (OIRA) to prepare its
         annual report to Congress on the implementation of the PRA. As was mentioned in
         our testimony, OIRA's fiscal year 2002 report differed from the agency's previous
         reports in two important respects. First, the report provided agency-specific
         information on paperwork burden-hour estimates and violations only for the cabinet
         departments and the Environmental Protection Agency (EPA), and did not include
         any such information for 12 independent agencies that had been included in previous
         reports. Second, the report merged data on the causes of changes in agencies'
         burden-hour estimates that previously had been presented separately. This letter is
         intended to bring those issues directly to your attention and to recommend corrective
         actions.

         Most Independent Agencies Not Included in Annual Report

         In previous annual reports on the PRA, OIRA provided agency-specific burden-hour
         estimates and information on PRA violations for 27 departments and agencies,
         including 13 independent agencies that are not cabinet-level departments. However,
         OMB Bulletin No. 02-02 (Oct. 17, 2001) asked only one independent agency-EPA-to
         submit the information used to compile the fiscal year 2002 report. OIRA did not
         indicate in the bulletin why other agencies were not required to provide information.
         However, in his prepared statement at the April 11, 2001, hearing, the OIRA
         administrator said the agencies were excluded because (1) OMB's authority over the
         independent agencies is limited, so its ability to influence their information
         collection policies through OMB oversight is constrained; (2) most independent

         'U.S. General Accounting Office, Paperwork Reduction Act: Burden Increases and Violations Persist,
         GAO-02-598T (Washington, D.C.: Apr. 11, 2002).


GAO-02-651R Annual Paperwork Report

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