September 17, 1998

OMB BULLETIN NO. 98-09

TO THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES

SUBJECT: Fiscal Year 1999 Information Collection Budget

1. Purpose. Under the Paperwork Reduction Act of 1995, the OMB Office of Information and Regulatory Affairs (OIRA) is responsible for oversight of Federal agencies' use of information resources to improve the efficiency and effectiveness of governmental operations to serve agency missions, including burden reduction and service delivery to the public. As part of this oversight, and as required by statute, OIRA publishes an annual report describing the information collection burden imposed by the Federal government on the public, progress of the agencies towards the burden reduction goals set forth in the statute (a governmentwide burden reduction of 5% in FY 1998, FY 1999, and FY 2000), and agency activities to improve the public's access to Federal information resources. This bulletin instructs agencies how to submit information to OIRA that will be the basis for the annual report and the agency targets to be set by OMB to achieve the "maximum practicable" burden reduction consistent with the agency's statutory and program responsibilities.

2. Summary. This Bulletin sets, in accordance with the Paperwork Reduction Act, the governmentwide goal for the reduction of information collection burdens for Fiscal Year 1999, and instructs Executive departments and agencies:

   1. to prepare an Information Collection Budget (ICB) for FY 1999, including: a narrative description of the agency's need to collection information; a description of the agency's management of information collections within its information resource management infrastructure; descriptions of significant burden reduction accomplishments; and planned initiatives for these and future years;

   2. to describe how the agency calculates the information collection burden estimates reported to OMB as part of the information collection request; and

   3. to document agency violations of the information collection provisions of the Paperwork Reduction Act of 1995 and implementing regulations (5 CFR 1320).

   These efforts will be led by the agencies' Chief Information Officers (CIOs) and carried out by senior-level agency officials. Note that this bulletin requires different reporting than was required in the past. The Appendices highlight these differences.

3. Authority. This Bulletin is issued pursuant to the Budget and Accounting Act of 1921, as amended; the Budget and Accounting Procedures Act of 1950, as amended; and the Paperwork Reduction Act of 1995.

4. Governmentwide Paperwork Reduction Goal for FY 1999. The Paperwork Reduction Act of 1995 requires OMB to "set an annual Government-wide goal for the reduction of information collection burdens by at least . . . 5 percent during each of the fiscal years 1998, 1999, 2000, and 2001." 44 U.S.C. 3505(a)(1). In accordance with the Act, and in light of the agencies' statutory and programmatic requirements as reflected in prior ICBs, OMB hereby sets a "Government-wide goal for the reduction of information collection burdens" for FY 1999 of 5%.

5. Required Submissions. Executive department and agency reporting should be consistent with OMB fiscal and policy guidance. Agencies are to submit the following information in accordance with the instructions and formats provided:
   1. The agency's Information Collection Budget and supporting material, prepared in accordance with the instructions in Appendix A.

   2. Data regarding agency compliance with the information collection provisions of the Paperwork Reduction Act, prepared in accordance with the instructions in Appendix B.

   3. A description of how the agency prepares estimates of information collection burden for submission to OMB, prepared in accordance with instructions in Appendix C

   4. Data regarding agency compliance with Section 9(a)(10) of OMB Circular No. A-130 "Management of Federal Information Resources," prepared in accordance with the instructions in Appendix D.

   For the first time, agencies are asked to submit this information electronically together with one paper copy. Please use file format WordPerfect, versions 6.1 or 7.0, or Microsoft Word, version 5.0, on a 3.5" diskette. Please label the disk with the agency name and the filename(s) of the submission.

6. Submission Date. Not later than December 15, 1998, each agency listed in Part VIII (Coverage) shall provide the reports required by this Bulletin.

   The reports should be delivered to:

   David Rostker
   
   
   Office of Information and Regulatory Affairs
   
   Office of Management and Budget
   
   725 17th Street, NW - Room 10202
   
   Washington, D.C. 20503
   
   

7. OMB Hearings on Submissions. In previous years, OMB held hearings with many agencies on their progress toward burden reductions goals and agency compliance with the Paperwork Reduction Act. OMB intends to continue this practice and will schedule, as needed, hearings covering material submitted under this bulletin.

8. Coverage. The following agencies are subject to the requirements of this Bulletin:

   Department of Agriculture
   Department of Commerce
   Department of Defense
   Department of Education
   Department of Energy
   Department of Health and Human Services
   Department of Housing and Urban Development
   Department of the Interior
   Department of Justice
   Department of Labor
   Department of State
   Department of Transportation
   Department of the Treasury
   Department of Veterans Affairs
   Environmental Protection Agency
   Federal Acquisition Regulation (FAR Secretariat)
   Federal Communications Commission
   Federal Deposit Insurance Corporation
   Federal Emergency Management Agency
   Federal Energy Regulatory Commission
   Federal Trade Commission
   National Aeronautics and Space Administration
   National Science Foundation
   Nuclear Regulatory Commission
   Securities and Exchange Commission
   Small Business Administration
   Social Security Administration
   

9. Information Contacts. Questions about specific agency matters should be directed to the agency's Desk Officer in OMB's Office of Information and Regulatory Affairs.

   Questions about this Bulletin should be directed to David Rostker, tel. (202) 395-3897, E-mail: David_Rostker@omb.eop.gov.

10. Expiration Date. This Bulletin expires September 30, 1999.

Attachments

1. Summary. This appendix explains what an Information Collection Budget (ICB) must include and what you must submit to OMB. You should note that the requirements for this year differ from previous years.

   The first document you will need to prepare, described in section III, is a description of your agency's strategic plan to improve the management of information collection activities and your accomplishments to minimize burden on the public. This information will help OMB prepare the Information Collection Budget and set targets for burden reduction in FY 1999.

   The second document of your submission, described in section IV, will serve as a starting point for OMB's preparation of your agency's section in the Information Collection Budget. This narrative should be written in a format and manner similar to chapter 4 of the Information Collection Budget of the United States, Fiscal Year 1998, published by OMB in July 1998. Other information you submit in response to sections V, VI, and VII, will support this narrative.

   Many agencies now report paperwork burden in terms of dollar costs, as well as burden hours. For example, the burden of a regulatory recordkeeping requirement is more readily estimated in terms of the dollar cost (e.g., for the space and equipment needed for storage) than time. Similarly, the burden of a third-party disclosure (e.g., the table describing the nutritional content of packages foods on food containers) is also more readily estimated in terms of cost. (These dollar costs are separate from hour burdens and are not hour burdens that are converted into dollars.) Starting with this ICB, OMB intends to begin reporting both the hour and financial burdens of information collections as reported by the agencies in their information collection requests. Thus, in submitting information concerning paperwork burden, you should include, as appropriate, both burden hours and dollar costs. The following instructions for agency submissions reflect this change.

2. Preparation. In preparation for developing your agency's ICB, you will need to:

   1. review the program changes and adjustments your agency made during FY 1998;

   2. review and update your agency's burden reduction efforts and plans to achieve the "maximum practicable" burden reduction during FY 1999, given your agency's statutory and program responsibilities; and

   3. plan for program changes and adjustments to your agency's inventory during FY 1999 and estimate your FY 1999 total information collection burden.

   OMB has already requested that errors in the paperwork inventory be corrected based upon the July 31, 1998, and August 31, 1998, monthly inventories already sent to your agency. As OMB stated:

   "We'd also like to request your assistance in eliminating errors in the inventory early. In past years, in preparing for the Information Collection Budget, we sent a hard copy of the inventory to you to review and submit corrections. This is no longer necessary because of the monthly electronic transmittal of the inventory. Please review the monthly inventories for errors as soon as you receive them, so that we do not need to adjust the September 30 numbers for publication. We would also like to ensure that, wherever appropriate, actual cost information is reported."

   OMB did this in order to allow you to begin reviewing the correcting errors in the paperwork inventory early, thus permitting you to develop the submissions for the 1999 ICB based on a corrected September 30, 1998, inventory.

3. Agency's Strategic Plans for Information Collection Management. In a separate document, provide a description, in narrative form, of primary goals, objectives, and strategies for minimizing burden on the public; these goals should be consistent with improving agency management of the information collection review process and agency statutory and program missions. The goals should also contribute to the "maximum extent practicable," given your agencies' statutory and program responsibilities, towards OMB's goal of a government-wide 5% reduction for FY 1999 and FY 2000. The description will be used by OMB to prepare the Information Collection Budget, including your agency's burden reduction targets, and to evaluate your agency's management of information collection resources.

   This document should be a strategic plan for reducing burden and improving information resources management. The narrative should be centered on the big picture, looking at ways the CIO is working to improve information collection activities and reduce information collection burden. This would include efforts such as electronic reporting and recordkeeping, intra- and inter-agency coordination, and public participation.

   Support this strategic plan with descriptions of specific actions your agency will take to find opportunities for burden reduction, including which target programs, your timetables for performing such actions, and the CIO's role in these actions. Describe any circumstances beyond your control, including new statutes and government-wide initiatives, which may prevent or reverse burden reduction efforts. If your strategy requires interagency or OMB assistance, this document should highlight that need and explain exactly how OMB can assist the process. If your agency desires changes in statute to accomplish reduction, provide specific citations and recommendations for OMB's consideration.

   Finally, this document should document your agency's work on this strategic plan by summarizing your burden reduction efforts in FY 1998. Include specific examples of reduction which have come about through agency initiatives to improve information resources management, even if burden reduction was not the primary goal.

4. Agency's Information Collection Budget. Following the format of your agency's entry in Chapter 4 of the Information Collection Budget of the United States Government, Fiscal Year 1998, write your agency's proposed contribution to the Information Collection Budget of the United States Government, Fiscal Year 1999. This entry should be written in plain language and should be appropriate for a general audience in both style and content. Please do not assume familiarity with your programs or missions.

   1. Information Collection Burden for FY 1999: State the estimated total information collection burden for FY 1999, including both the hour and cost estimates.
      

   2. Need for Information: Why does your agency collect information and how does it use the information it collects to further its mission? Relate the collection of information to the goals and objectives your agency has developed in compliance with GPRA. If you wish, you may include a small number of illustrative examples. This description should be no longer than 3 paragraphs.
      

   3. Internal Management of Information Collection: What process does your agency use to fulfill its requirements under the PRA for the management of information collection activities? Explain the role of the Chief Information Officer and staff in your agency's processes. Describe how many people review information collection submissions on behalf of the CIO. Describe any coordination activities the CIO performs with regard to information collections.
      

   4. Internal Management of Information Dissemination: How does your agency manage the dissemination of information, as required by OMB Circular A-130? Describe your agency's progress in implementing the Government Information Locator System. Provide examples of your more important dissemination initiatives and how the information provided benefits the public.
      

   5. Burden Reduction Efforts and Goals: What has your agency been doing to reduce burden on the public? Summarize your agency's response to section III of this appendix for a general audience. Give specific examples of reductions that occurred in FY 1998 or are planned for FY 1999 and FY 2000 as part of these initiatives. You may also describe reasons the agency has not achieved burden reduction, but if you do, you should describe any efforts the CIO has made to ensure any new burdens are minimized.
      

   6. Significant Changes in Information Collection Burden During FY 1998: Explain your agency's change in total information collection burden between FY 1997 and FY 1998 by explaining specific changes to information collections. Make these descriptions relevant for a general audience by focusing on the effects of the collections and changes on individual respondents before you discuss their effects on the agency.

      Provide an entry (one or two paragraphs) for each significant program change or adjustment giving the title of the collection, OMB control number, a brief description of the collection, a brief description of the change and its reasons, and the change in burden (hours and costs). You may combine several changes of a like nature into a single entry, but be sure to give the title and OMB control number of each collection changed. All of these entries together should account for the vast majority of the total change between FY 1997 and FY 1998.
      
      

   7. Significant Changes in Information Collection Burden Planned For FY 1999: Explain your agency's planned change in total information collection burden between FY 1998 and FY 1999 by explaining specific changes to information collections. Make these descriptions relevant for a general audience by focusing on the effects of the collections and changes on individual respondents before you discuss their effects on the agency.

      Provide an entry (one or two paragraphs) for each significant program change or adjustment giving the title of the collection, OMB control number, a brief description of the collection, a brief description of the change and its reasons, and the change in burden (hours and costs). You may combine several changes of a like nature into a single entry, but be sure to give the title and OMB control number of each collection changed. All of these entries together should account for the vast majority of the total change between FY 1998 and FY 1999.
      

   8. Recent Statutes that Affect Information Collection Activities: Describe any statutes which the agency is currently implementing which require changes to your information collections. Include a Public Law citation and give the OMB number (if available) and title for the specific collections that are affected. Do not include statutes for which recent action is a result of the agency's reinterpretation or subject to agency discretion.

5. Significant Burden Changes for FY 1998. Using the format in Exhibit 1, document your agency's significant changes in information collection burden. This should include those changes that were described for section IV.f.

   For each action, list the OMB numbers affected and the dates of OMB action, describe the specific changes (e.g., more frequent reporting, consolidation of several forms, cross-cutting activities), the causes for action (e.g., new statutes, initiatives, policy changes, change in the number of respondents), a breakdown of the hours affected by each change, and whether each change was due to program changes or adjustments to the reported burden. Use the comments section to explain any additional details, including specific statutory changes which led directly to changes in paperwork burden, and link these reductions to the strategic plan described for section III of this appendix. Please be specific. Attach additional sheets as necessary.

6. Significant Burden Changes for FY 1999. Using the format in Exhibit 2, document your agency's significant changes in information collection burden. These should include those that were described for section IV.g.

   For each action, list the OMB numbers to be affected, describe the specific changes (e.g., more frequent reporting, consolidation of several forms, cross-cutting activities), the causes for action (e.g., new statutes, initiatives, policy changes, change in the number of respondents), a breakdown of the hours affected by each change, and whether each change was due to program changes or adjustments to your reported burden. Use the comments section to explain any additional details and link these reductions to the strategic plan described for section III of this appendix. Please be specific. Attach additional sheets as necessary.

7. Burden Changes due to Statute. In a separate document, describe in detail the changes to information collections due to the statutes you describe in section IV.h.

   Summarize the statute's major effects. Describe each information collection affected (including OMB number if the collection already exists) and the specific changes required, including changes in burden. Quote and cite the specific statutory language which requires changes. Describe the actions the CIO is taking to minimize the burden imposed by statutory changes.

8. Supplementary Materials. To assist you in reviewing your agency's actions over FY 1998 for PRA violations, OMB will send at the end of FY 1998 a series of reports generated from the official computer records. The first report will summarize the total burdens for your agency by purpose (as reported on the OMB Form 83-I). The second report will be a summary of all transactions for your agency during FY 1998 that changed burden, sorted by OMB number and date. The third and fourth lists will be similar to the second, except they will be sorted by the size of the program change and size of adjustment, respectively. This will help you identify large increases and decreases which should be described in the ICB and in your submissions to OMB.

Title(s): U.S. Survey

OMB Number(s): 0000-0000

Change in Hours	Change in Cost	Type of Change	Description of Change
-	+$3,000,000	Program	Estimated previously unreported costs.
+4,000,000	+$2,000,000	Program	[Describe specific agency action, causes for action, and, if this page covers multiple OMB numbers, which OMB number is affected.]
-3,000,000	-	Program	[Describe specific agency action, causes for action, and, if this page covers multiple OMB numbers, which OMB number is affected.]
+1,000,000	-	Adjustment	Increase in eligible recipients for aid from 25,000,000 to 26,000,000.

Comments: [Use this section to provide additional information about the actions described on this sheet. Please include specific language or cites, if appropriate. Describe how this action relates to your strategic plan for burden reduction and the improvement of information collection management.]

[You may use this format to describe changes in a single collection, changes in a series of related collections, or changes through a coordinated agency initiative.]

Title(s): U.S. Survey

OMB Number(s): 0000-0000

	Total Burden Hours	Total Cost Burden
End of FY 1998	12,000,000	0
End of FY 1999	14,000,000	5,000,000

Change in Hours	Change in Cost	Type of Change	Description of Change
-	+$3,000,000	Program	Estimated previously unreported costs.
+4,000,000	+$2,000,000	Program	[Describe specific agency action, causes for action, and, if this page covers multiple OMB numbers, which OMB number is affected.]
-3,000,000	-	Program	[Describe specific agency action, causes for action, and, if this page covers multiple OMB numbers, which OMB number is affected.]
+1,000,000	-	Adjustment	Increase in eligible recipients for aid from 25,000,000 to 26,000,000.

Comments: [Use this section to provide additional information about the actions described on this sheet. Please include specific language or cites, if appropriate. Describe how this action relates to your strategic plan for burden reduction and the improvement of information collection management.]

[You may use this format to describe changes in a single collection, changes in a series of related collections, or changes through a coordinated agency initiative.]

1. Summary.This appendix explains what you must submit to OMB to report violations of the information collection provisions of the Paperwork Reduction Act (PRA) of 1995 and OMB's implementing regulations, 5 C.F.R. 1320, over the last fiscal year. OMB is required to report PRA violations to Congress. See Appendix A of OMB's Information Collection Budget of the United States, Fiscal Year 1998.

2. Instructions. Provide two tables. For each violation due to the expiration of an existing collection, provide the OMB number, title, date of expiration, and date of reinstatement. (See Table A-1 in OMB's Information Collection Budget of the United States, Fiscal Year 1998 for a suggested format.)

   For all other violations that occurred during FY 1998, provide the following information:

   1. Title of the collection and OMB control number if ever assigned;
   2. Nature of the violation, (for example:
      • unapproved collection;
      • modification of an approved collection without prior OMB approval; or
      • failure to display OMB control number);
   3. How the violation was discovered; and
   4. How and when the violation was remedied (provide the date and type of OMB action if applicable).

   (See Table A-2 of OMB's Information Collection Budget of the United States, Fiscal Year 1998 for a suggested format.)
   

   If you discover any violations during the preparation of this report, please contact your OIRA desk officer and remedy the violation immediately.

3. Supplementary Materials. To assist you in reviewing your agency's actions over FY 1998 for PRA violations, OMB will send at the end of FY 1998 a list generated from the official computer records. The list will detail collections that expired during the last fiscal year and had not been reinstated as of September 30, 1998, and collections that were reinstated during the fiscal year.

1. Summary. This appendix describes what you must submit to OMB to describe the methods your agency uses to estimate the burdens of information collections. OMB plans to review the way the agencies estimate and OMB reports burden. This information is requested to help OMB develop a strategy for this review and contribute to a discussion of burden in the FY 1999 Information Collection Budget.

2. Description of Agency's Burden Estimation Methodology. Describe, in narrative form, your agency's methodology for estimating the burden of information collections. Describe all methods your agency or its components use. This description should explain the techniques (e.g., statistical, mathematical, anecdotal) used by your agency to estimate the time and financial resources the public expends in meeting your agency's information collection requirements. The description should demonstrate how the burden of activities identified in the PRA (e.g., reviewing instructions, utilizing technology, searching data sources, completing and transmitting information) is accounted for by your agency.
   
   In FY 1989, the Internal Revenue Service began using a detailed burden estimation methodology to standardize estimates across its numerous collections. A description of this methodology is attached as an example.
   

IRS' estimates of taxpayer burden are calculated using a series of mathematical models--which are installed on personal computers--that were developed from regression analysis of survey data on the amount of time that individuals, partnerships, corporations, and paid tax preparers spend performing activities that are necessary to meet tax filing requirements. These activities, which correspond to the Paperwork Reduction Act's definition of burden (44 U.S.C. 3502(2)), are: (1) recordkeeping, (2) learning about tax law, (3) preparing tax forms, and (4) copying, assembling, and sending tax forms to IRS. A burden equation for each activity takes into account basic characteristics of tax forms and instructions, form and line usage by taxpayers, and characteristics of the taxpayer populations using the forms. There is a separate set of burden equations for individual and business taxpayers. IRS accounts for the use of paid preparers by estimating (1) the equivalent time that would have been spent by individual taxpayers who used paid preparers if those taxpayers had instead prepared their returns themselves and (2) the actual time of paid preparers used by business taxpayers.

The data used to construct the burden models were collected from three surveys conducted in 1984. The data for individual burden models were obtained from a diary study in which approximately 750 individual taxpayers kept track daily of the time they spent completing their tax returns and a mail survey in which about 6,200 taxpayers were asked to report the amount of time they spent performing various tax-preparation activities. Data for business taxpayers were obtained from a survey of 4,000 corporations and partnerships and their paid tax preparers. These businesses reported how much time they spent performing activities that they undertook for the express purpose of meeting their tax filing requirements. Multiple linear regression analysis of the data collected from the surveys was used to identify variables that correlated with time spent on preparing tax returns. Through careful model specification, more than 100 variables likely to have a causal relation with time spent were tested.

The individual burden models predict the average burden to file a given form by type of activity (i.e., recordkeeping, learning, preparing, sending). The total burden for all individual taxpayers filing the form is calculated by multiplying the average form burden for each activity by the total number of taxpayer responses filed during a given tax year and then aggregating the burden over all activities. Some of the predictor variables in the individual burden models include (for a given form):

• the total number of annual taxpayer responses filed;
• the total number of line items on the form;
• the usage rate of each line item;
• the total number of references to the Internal Revenue Code or regulations in both the general and line-by-line instructions;
• the number of words in the instructions;
• the number of pages for the form;
• the number of items that require recordkeeping; and
• the total number of items that require records of income only.

The business burden models predict by type of activity (i.e., recordkeeping, learning, obtaining materials, locating/using a preparer, preparing, sending) and by preparer (paid vs. self) the average business taxpayer paperwork burden to file a given form. The method for obtaining the aggregate burden of all business taxpayers is the same one used for individual taxpayers described above. A separate set of business burden models predicts the preparation time for certain information returns, such as the W-2 and 1099 series. Some of the predictor variables in the business burden models include (for a given form):

• the total number of annual taxpayer responses filed;
• the fraction of taxpayers using paid preparers;
• the total number of line items on the form;
• the total number of references to the Internal Revenue Code and regulations appearing on the form and its instructions; and
• the total number of attachments requested that are IRS forms.

1. Summary. This appendix explains what you must submit to OMB to demonstrate compliance by your agency with Section 9(a)(10) of OMB Circular No. A-130 "Management of Federal Information Resources," as revised on February 8, 1996 (61 Federal Register 6434, February 20, 1996), which requires you to report to OMB all alleged failures to comply with this Circular.

2. Alleged Failures to Comply with OMB Circular No. A-130. Section 9(a)(10) of the Circular provides that the head of each agency shall:

   (10) Direct the senior official [CIO] appointed pursuant to 44 U.S.C. 3506(b) to monitor agency compliance with the policies, procedures, and guidance in this Circular. Acting as an ombudsman, the senior official shall consider alleged instances of agency failure to comply with this Circular and recommend or take corrective action as appropriate. The senior official shall report annually, not later than February 1st of each year, to the Director [of OMB] those instances of alleged failure to comply with this Circular and their resolution.

   Include this report in your submission to OMB under this bulletin. If you have received no complaints for FY 1998, state that fact at the end of your submission.

3. Additional information. Copies of OMB Circular A-130 are available via the Internet on OMB's homepage at /OMB/circulars.

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