Paperwork Reduction Act

Question 1

Paperwork Reduction Act and OIRA

Answer 1

• OIRA can’t be disbanded by the President because it now has a statutory role in the Paperwork Reduction Act
• anytime an agency wants to collect info from more than 10 people, it needs to get permission from OIRA, even if the info collection is voluntary

Question 2

Paperwork Reduction Act

Answer 2

• governs how fed agencies collect info from American public

Goals:
- manage the info agencies request of the public (PRA clearance involves calculating burden hours - goal of being good stewards of public time)
- making decisions based on high-quality data (how does the info you’re collecting relate to your goals)
- protecting private info (don’t want to ask for private info that’s not relevant or necessary -> OIRA asks for extra detail if you’re collecting personally identifying info)

Question 3

PRA Process

Answer 3

• unless w/in narrow exceptions, process looks like APA rulemaking (need notice + comment)
• plays out over a pretty long period of time
• OIRA has to comment on info collection, + comments need to be responded to in final rule
• can only get collections approved for three years max

Question 4

Import of PRA for Timing

Answer 4

• compliance can slow down rulemaking if agencies not careful

Question 5

PRA - Agency Noncompliance

Answer 5

• Agency can’t impose any penalty on beneficiary for failure to comply with info collection if agency itself didn’t comply with PRA
• Noncompliance can be complete defense for party that was supposed to provide info, + if dealing with a benefit, that benefit cannot be withheld for failure to provide info if agency didn’t comply with PRA

Question 6

PRA - EPA Description

Answer 6

• generally provides that every fed agency must obtain approval from OMB before using identical q’s to collect info from 10 or more persons

If EPA decides to gather info, it needs to prepare an Information Collection Request (ICR), which:
- Describes info to be collected,
- Gives reason info is needed
- Estimates the time + cost for public to answer request

After reviewing request, OMB may approve or disapprove the ICR, or define conditions that must be met for approval.

Question 7

Ex’s of Info Collections Covered by PRA

Answer 7

• surveys
• permits
• questionnaires
• reports

Question 8

CDC + PRA

Answer 8

• basically, we discussed an article re form design for eviction moratorium (figuring out who’s eligible)
• emergency, so normal process not followed, but CDC came back + tried to see if form could be made better
  -> ex of phrase indicating perjury penalty - concept that don’t want people to become afraid of providing info
  -> OIRA employee - trying to think through how to make the form easier, so people don’t become too frazzled to request relief

Question 9

Time Tax - General Issue

Answer 9

• barrier to access even when you’re eligible – amount of time it takes to fill out gov forms in order to get benefits
• many people give up benefits to which they’re entitled because of the time tax, creates psychological stress too
• eroding trust in gov

Question 10

Time Tax - Other Side of Debate

Answer 10

• designing programs to optimize take up while protecting program integrity against fraud, waste, + abuse (pandemic as giant experiment in whether we should alter this balance)
• Pandemic unemployment insurance program – simplifying eligibility + application processes
  -> But also unprecedented fraud – billions of dollars stolen by primarily foreign entities
  -> Query whether more complex forms would’ve prevented sophisticated + tech enabled fraud that plagued that program