The Paperwork Reduction Act of 1995 (PRA) is perhaps one of the least well-known data collection, management, and sharing authorities in the Federal government. In its own right, the PRA upholds important principles for government data through accountability and transparency mechanisms. The PRA is most widely recognized as the law that requires federal agencies to develop Information Collection Requests (ICRs). ICRs apply to information collected from 10 or more respondents and are a central component for PRA’s governing of the government’s data collection processes.
The PRA is intended to enable agencies to meet the government’s legitimate need for information without unduly burdening those who have and can supply that information. While the PRA is a powerful and useful instrument, there are real frustrations about its implementation for government employees, public stakeholders, and government contractors alike. Clearance processes can be burdensome and time-consuming, resulting in delays in data collections necessary for agencies to fulfill their missions. At a minimum, the normal process takes four months to satisfy existing statutory and administrative requirements, though six to nine months is considered more realistic for new, non-emergency requests.
This year, a group of experts convened by the Data Coalition considered potential reforms to address identified challenges and barriers to effective implementation of the PRA’s purpose and intent. Building on the recommendation from the Commission on Evidence-Based Policymaking—suggesting some modifications may be needed to the PRA to support evidence-building activities as well as other expertise—the following proposals are intended to advance a system that enhances the value of government-collected information, eases the burden and costs imposed on agencies, and prioritizes data as an asset, all while encouraging transparency and public trust in government data.
The Working Group recommends the following:
Recommendation #1: Congress should review and propose modifications to the existing public comment procedures for the PRA
Recommendation #2: Congress should establish a more streamlined process for ICR review and adjust the scope of the PRA applicability.
Recommendation #3: Congress must clarify the expectation for the Chief Data Officers to coordinate ICRs under the data governance process within individual agencies.
Recommendation #4: OMB should accelerate the implementation of a government-wide automated tool for ICRs that support agency data inventories.
Recommendation. #5: OMB should issue clarifying guidance to agencies on pain points in implementing the PRA
The Data Coalition calls on Congress and the Executive Branch to prioritize modest improvements to the Paperwork Reduction Act to improve the efficiency of government data collection and management. Modernizing the Paperwork Reduction Act is long overdue. Small changes to the existing legal framework can offer substantial improvements for reducing the burden on the American public and the value of government-collected data.