My OSTP Blog Comments on Changing the PRA

I have just now started contributing to Phase II of the Open Government Directive. CrisisCamp pretty much took up all of my spare time, but I’m going to try making up for it in the next few days. Here’s my comments I just made on fixing the Paperwork Reduction Act.

The movement toward two-way, participatory government is a significant shift in government processes and service delivery. Nowhere is this more evident than the Paperwork Reduction Act (PRA). The PRA, originally written during the Carter Administration and enacted right after Reagan was sworn in, codifies the notion that one-way government is the ideal state - that the Federal government’s job is to provide the service and the citizen’s is merely to receive it. Perfect government in PRA-speak is really a one-way communication, where the only thing the government should be requesting of the public is what additional information it wants. Anything else asked of citizens is considered a “burden”, and must be quantified, and ultimately, eliminated to the greatest extent practicable. There are goals embedded in the PRA that request this burden to the citizens be reduced each year.

The movement toward two-way participatory government introduces the notion of an “opportunity” for the citizen (and perhaps even a new civic responsibility). More so, it dramatically shifts the govt-service provider/citizen-receiver relationship. In short, in a transparent, open government, the PRA as its currently enacted is no longer valid. Time expended by the public in “generating, maintaining or providing information to or for a Federal agency” is a key part of participatory government. Furthermore, the notion of a collection of information, as defined in the PRA is no longer valid. Previously, collections of information (facts or opinions for reporting or recordkeeping requirements imposed on ten or more persons, or answers to questions posted to agencies) were part of a serial decision making process - one in which the process of gathering input truly was burdensome on both the citizen and the agency. Surveys, which used to be incredibly cumbersome, are now far more often quick hit question-answer-instant “public results” type things we see on every participatory website on the internet. Asking the same question to more than 10 people is no longer a “burden” in the sense it used to be.

One needs only conduct a quick analysis of the Federal Registry to see that the implementation of the PRA has turned into nothing more than a “Check the box” function to ensure the law is being followed. The vast majority of the new information collection requests to OMB are just re-submittals due to their mandatory expiration after 3 years. Worse, OMB’s guidance and yearly reports say in effect, “We know we weren’t very diligent in responding previously, but we’ll do a much quicker job today.” It appears as if very few of the resubmittals are ever rejected - which begs the question whether there is any real review taking place. As the interactions with the public increase, the problem will only get worse. OMB probably only has a fraction of the capability today needed to do a the thorough job prescribed in Statute - they certainly won’t have the situational awareness or requisite variety to do this in an open government model.

So what is the Remedy? I think there are both some short and long term things we can do to fix the situation. Long term solutions involve significant revisions to the statute. Here’s some options.

1. Quick Legislative Fix - Remove “Voluntary” requirement: The most annoying thing the PRA does is make basic web usability a nightmare in that you cannot even ask the basic “did you get what you need?” question to those who come to Federal sites. The only place the PRA mentions voluntary collections is Title 44, Chapter 35, Section 3506 (c)(1)(B)(iii)(IV), which in talking about the person receiving the collection of information states that, “whether responses to the collection of information are voluntary, required to obtain a benefit, or mandatory…”. If on any random upcoming bill, Congress included a request to have this line removed from Title 44, OMB could update its policies to say that only “Mandatory” information collections must adhere to the PRA. This would free virtually all website usability and open government conversations from PRA constraints.

2. Update OMB Guidelines to allow the “Prototype Collections” and allow citizen crowdsourcing to determine if the prototype collection is duplicative, non-usable or a burden: Title 44, Chapter 3507(a) clearly states that “an agency shall not conduct or sponsor the collection of information unless in advance of the adoption or revision of the collection of information, the agency has (done all the junk we request including the delays, etc.). If OMB allowed prototype information collections to go up right away, while they paperwork followed, this would allow the agency to get their “prototype feedback” immediately, and would only act on that feedback in an official matter once the official approval from OMB came. More interesting, you could perhaps have the raw data from these prototype collections immediately accessible via Data.gov.

The second half of this is for OMB to update its review and approval process. Its fairly clearly that they just don’t have the resources to adequately review all information requests that will be coming. But in a transparent, participative and collaborative PRA process, they wouldn’t need to. The answer is to allow the citizens to review and approve all information collections in real time. Literally, put the prototype collection forms online, and include a link at the bottom that says something to the order of, “Do you consider this information collection burdensome, confusing, or duplicative with existing collections? If so, engage us in discussion here to review this.” Using this approach, the adjudication process would happen transparently, in real time in a participative, collaborative environment. This puts in place a formal feedback loop for improvement, and more importantly, the agency could immediately get their feedback and interaction started with the public.

3. Redefine the word “Form”: If neither of those two options are palatable, the third, while somewhat devious, also works. Nowhere in any of the PRA guidance is the word “Form” defined. If we really think about it, burdensome processes almost always involve actual workflows where data is processed, transformed, and where eventually decisions are made, and temporary or permanent records (essential transactions of the agency) are kept. This includes things like requests for educational assistance, changes in benefits, etc. The rest of the stuff being slowed down by the PRA really includes input templates that feed back-end data structures that are used for various situational awareness activities. If we include two new definitions, “form” and “input template”, where a “form” as defined essentially as a workflow form, we could probably write language in the guidance that says the PRA is required for forms, but not for information templates that just feed back-end data sources. In effect, we would make the argument that those back-end data structures are not in fact information collections as defined in the PRA, and therefore do not need to follow the PRA procedures.


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NoelDickover

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