The Paperwork Reduction Act Created a Paperwork Explosion
Legislators love misnomers. The USA PATRIOT Act “increased patriotism” by reducing domestic freedoms. The Inflation Reduction Act increased inflation before our eyes. And since its introduction in 1980, the Paperwork Reduction Act (PRA) has dramatically increased the amount and complexity of government paperwork.
The PRA was last updated in 1995. Websites back then were extremely basic: mostly text with the occasional grainy image that took a full minute to load. There was no concept of online forms or accessing government services over the internet. The Clinton administration had launched whitehouse.gov a mere seven months earlier, and the federal government did not even begin managing the .gov top-level domain until 1997.
The world has changed. Most forms are filled out online—increasingly, on mobile devices. A typical form is not a static set of fields but rather dynamic, showing or hiding questions based on prior responses, enforcing required elements, and ensuring your response meets criteria. Forms are often rigorously tested and tweaked to increase submission rates, with improvements like removing extraneous fields, swapping jargon for plain language, and prefilling known data. Mainstream analytics tools can measure exactly at which field users are pausing or abandoning the page altogether, and many organizations hire user researchers to watch and collect feedback about a form’s usability among its target audience.
What hasn’t changed is the PRA. Still lumbering under a definition of “information technology” from 1949, it forces government agencies to frame information collection as individual static (paper) forms. It threatens employees who want to get feedback from the public. It forces every proposed change, however small, through a rigid process that can take years and adds no value. The PRA even causes the government to break its own laws by making it impossible to meet congressionally mandated deadlines.
If you want a smaller government that does less, the PRA does the opposite: It drives the proliferation of more paperwork and stands in the way of efficiencies and subtractions. If you want government to successfully deliver on its mission, whatever that mission may be, the PRA is quietly dragging down the whole ship—and it’s time to break free of it.
How the PRA Works
Per the PRA, when a government agency wants to create or update an “information collection”—typically a form, though its grasp has extended to user logins and profiles, customer satisfaction surveys, and user research—the central Office of Information and Regulatory Affairs (OIRA) must approve it first.
Approval involves completing forms about the form (which all require several layers of internal agency approval), then submitting that package to an agency’s “desk officer.” The desk officer’s job is to forward the package on to OIRA, a role that the Bobs of Office Space would certainly call into question. Desk officers often contract out this work, though, and prioritize their own efficiencies by submitting one enormous package once a year. A recent submission from the Forest Service contained 151 forms.
Once OIRA receives the package, it (eventually) publishes it in the government’s newspaper, the Federal Register—a staple at every breakfast table. The proposal must be available for public comment for 60 days. The originating agency then compiles responses to any comments received, though it doesn’t have to actually do anything about them. OIRA reviews this package, and the proposal (whether changed or not) is reposted to the Federal Register for 30 more days. After an additional period of OIRA review, it might be approved. This can take years in the worst of circumstances.
Approved collections must be reapproved every three years, even if you don’t change a thing, generating an endless cycle of paperwork—about paperwork.
How It Doesn’t Work
When I joined the federal government in 2012, navigating the PRA was the first thing I heard about in my onboarding. The PRA was a major barrier to improving veterans’ access to benefits and health care when I served as chief technology officer (CTO) of the U.S. Department of Veterans Affairs (V.A.).
Reason could run Brickbats only on my experience of the PRA at the V.A. and never run out of content. Some examples:
- The V.A. disability application form contains all the information necessary to determine V.A. health care eligibility. Instead of having veterans complete two entirely separate (and duplicative) applications, the V.A. proposed adding a simple checkbox to the disability form to also
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