Currently, agencies estimate and report the burden of these activities in terms of the time, or burden hours, and the financial costs that the public devotes to reporting, recordkeeping, and disclosure requirements. In estimating the time and resources devoted to information collections, agency Chief Information Officer offices typically consult agency program staff, who are responsible for managing the information and thus possess the substantive knowledge that is essential to estimating the number of respondents to an information request relating to that program. The agency then uses its knowledge of the program to consider how much time a respondent would need to respond to the information request. Multiplying the amount of time per respondent by the number of respondents and the number of times the information is submitted each year produces the total annual burden hours imposed by a given collection.

After agencies produce a preliminary burden estimate, several reviews of its accuracy take place. First, agencies solicit public feedback on the accuracy of their estimates in Federal Register notices that provide for an initial 60day public comment period. Any comments received by the agency are used to refine the estimate that is submitted for OMB review. Second, OMB analysts who review agency information collection requests (ICRs) can provide comments on the agency's estimate. Finally, OMB review is accompanied by a second, 30 day public comment period (initiated with a second Federal Register notice), during which the public can again submit comments on the burden estimates.

Agencies have worked hard to improve their burden estimates, and several agencies have undergone extensive studies to do so. For example, the Internal Revenue Service accounts for a large share (over 76 percent) of the Federal Government's total paperwork burden. In light of this fact, the IRS has devoted considerable resources to measuring the burden it imposes on taxpayers so that policymakers and the public can better understand the cost to society of tax collection and compliance with the Internal Revenue Code. The IRS has made efforts to improve the accuracy and transparency of taxpayer burden estimates. Starting in FY 2006, the IRS began using a new methodology based on a statistical modelthe Individual Taxpayer Burden Model (ITBM)to estimate the reporting burden imposed on individual taxpayers. The ITBM's approach to measuring burden focuses on the characteristics and activities of individual taxpayers rather than the forms they ultimately use.

Despite public input and certain common methodological techniques, agency estimation methodologies can sometimes produce imprecise and inconsistent burden estimates. Some agencies have relied on program analysts to generate burden estimates based on their individual consideration of, for example, the number and types of questions asked, what records will need to be created and maintained, how long it will take people to complete these and other tasks, and how many people will be performing the tasks. These officials are often experts in their areas of responsibility and are usually familiar with the public's experience with responding to information collections they oversee. In some cases, however, it is not clear that their estimates are based on sufficiently rigorous or internally consistent methodologies. This is a particular concern in the case of large collections, the burden of which may be measured in millions of hours or tens of millions of dollars.\1\
\1\ For more information on how agencies estimate their paperwork burden, please refer to pages 2939 of the Information Collection Budget of the United States Government, FY 1999, Office of Management and Budget, which can be found at http:// www.whitehouse.gov/omb/assets/omb/inforeg/icbfy99.pdf.

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In addition, OMB is aware of the possibility that information collections may impose significant burdens on small businesses. Because of economies of scale, a collection may be more burdensome for a small entity than for a large one. However, currently there is no uniform method for agencies to account for situations in which a collection may have a disproportionate impact on a particular type of respondent, such as a small entity.

In summary, there is some variation across individual agencies in the methodologies used for estimating the time and financial burden associated with their collections. This variation makes it difficult to ensure accurate assessment on the part of all individual agencies and to upgrade governmentwide performance in implementing the PRA. OMB Seeks Comment on How To Improve the Current Situation, Including:

In submitting comments to this notice, please provide supporting evidence where feasiblewith data, specific examples of information collections, and, if possible, the collections' OMB Control Numbers along with concrete recommendations.
Reducing Paperwork Burden and Maximizing the Utility of Information Collected by the Federal Government

Over the years, the number of hours that the public has spent responding to Federal Government information collections has been steadily increasing. In FY 2000, the public spent an estimated 7.4 billion hours responding to information collections subject to the PRA. In FY 2007, the number of hours grew to an estimated 9.64 billion, an increase of more than 30 percent. Much of this increase is attributed to factors that make it difficult for agencies to control their paperwork burden, such as new statutory requirements and demographic and economic changes. A much smaller portion is a result of discretionary decisions made by agencies that increase burden.

While the overall trend in paperwork burden has been rising, several agencies have dramatically reduced the burden of their collections, and in some cases improved the utility of a collection in the process. The following are examples of successful initiatives by agencies to reduce burden on the public:

Agencies also often undertake efforts to improve the utility of information that they collect through relatively small increases in burden. For example, statistical agencies routinely pretest new surveys or new items for existing surveys to ensure that respondents understand the question being asked, have the information to be able to respond, and are able to convey their response in accordance with the options provided by the agency. Similarly, agencies conducting program evaluations or research studies often engage in smallscale formative or exploratory research to inform largerscale investigations. With increasing use of the Internet to collect and disseminate information, more agencies are also engaging in usability testing to improve their Web sites and electronic forms and questionnaires.

OMB is committed to helping agencies build on these initiatives and to ensuring that the PRA is implemented in a way that suits current conditions. OMB is also aware that concerns have been expressed about unintended consequences of the administration of the Act, including delays in the conduct of surveys and research in contexts in which citizens are asked, but not required, to respond to information collection requests by the Federal Government.

In this notice, OMB is seeking public comment to provide new ideas for reducing paperwork burden and ensuring practical utility. As part of its efforts to improve this situation, OMB invites comments from the public on all issues relating to improvement of the implementation of the PRA, including but not limited to the following topic areas:

FOR FURTHER INFORMATION CONTACT

Mabel Echols, Office of Information and Regulatory Affairs, Records Management Center, Office of Management and Budget, Room 10102, NEOB, 725 17th Street, NW., Washington, DC 20503, Telephone: (202) 3956880.