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Regulating the flow of data: OMB and the control of government information.

The United States government collects, analyzes, and disseminates a wide variety of information that is important and useful for decision makers in both the public and private sectors. Information that is accurate, timely, and relatively comprehensive can enhance the quality of decisions, while its absence, inadequacy or inaccuracy can cripple or diminish the capacity for intelligent decision making. This article is concerned with the information policy of the U. S. government, and particularly with the role that the Office of Management and Budget (OMB) in the Reagan administration played in shaping and implementing that policy. In particular, I focus on the effect OMB's efforts have had on Centralized Statistical Agencies (CESTAs). I argue that OMB tried to shrink the role of the federal government in data collection and dissemination and discuss the consequences of these efforts.(1) I conclude with a suggestion that more attention should be paid to the public-goods nature of information when considering the role of government in data collection and dissemination.

I focus on CESTAs because they are not directly involved in the administration of regulatory or welfare programs. The goals of the Bureau of Labor Statistics (BLS) illustrate the purposes of CESTAs:

The Bureau strives to have its data satisfy a number of

criteria, including relevance to current social and economic

issues, timeliness in reflecting today's rapidly

changing economic conditions, accuracy and consistently

high statistical quality, and impartiality in both

subject matter and presentation (Office of Federal Register,

1989a, p. 425).

A list of the eight major agencies in CESTAs and the type of data they collect is in the grey box on page 435. A more complete discussion of the political environments of four CESTAs is provided by Morin (1989).

Government information is a valuable resource in policy implementation. For example, in fiscal year 1979, "150 domestic assistance programs in 18 departments and agencies" relied on statistical data to allocate their funds (Emery, Campbell, and Freedman, 1980, p. 74). Under these programs, $122 billion were allocated in fiscal year 1979 (p. 74), of which 15 "had obligations in excess of $1 billion [each] ..." (p. 75).

Because many decisions depend on government information, and because its collection is often time consuming and intrusive, many actors attempt to influence the manner in which CESTAs generate information. For example, data users, data providers, and a variety of organizations have a concern about or try to influence the manner in which the Energy Information Administration (EIA) carries out its responsibilities. EIA's first administrator supported a growing EIA. During the Reagan administration, EIA administrators had a somewhat different view, clearly illustrated by EIA'S continual effort to rid the agency of one of its most controversial forms (Morin, 1989, chapter 5).

One of the most important actors in the process of generating government information is OMB, which exerts an influence on the flow of information and statistical data through four interrelated means. The first involves its philosophy of, and role in, information collection. The second relates to its well-known budgetary responsibilities. The third involves the forms approval process, through which forms used by agencies to collect information must pass before they can be used. Finally, OMB basically controls the Information Collection Budget, which regulates the amount of time it takes a respondent to complete a form of the federal government.

OMB's Philosophy of Government's Role in Data Collection

It is important to note that in carrying out its duties for the development and implementation of information and statistical policy, OMB was underscoring and more aggressively pursuing a direction that the federal government had been following for decades.(2) Important statutes and efforts include the 1942 Federal Reports Act, which aimed at greater coordination, elimination of duplication, and reduction of collection burden (Federal Reports Act, 1942, chap. 811 56 Stat., p. 1078); the 1950 Accounting and Procedures Act, which was a "general mandate for the President to oversee and coordinate of the statistical agencies of the executive branch the activities of the statistical agencies of the executive branch..." (Griffith 1986, p. 245); increased rigor in the forms review process (Smith 1986, p. 238); establishment within OMB of the Office of Federal Information Policy (Smith, p. 239); the Paperwork Reduction Act (PRA) of 1980 (Paperwork Reduction Act, 1980, pp. 2815, 2816; (Smith, 1986, p. 240); and the 1986 Paperwork Reduction Reauthorization Act, 1986 (Paperwork Reduction Reauthorization Act Pub. L. 99 99-591, 100 Stat. 3335-3341). This last act tied budget proposal reviews more closely to the government's responsibility for statistics, set targets for more reductions of the Information Collection Budget, and required that information about a proposed form "be made available to the public" (pp. 3341-3338).

The general intention of the Reagan administration was to aggressively pursue paperwork reduction (more on this later) and shrink the role of the federal government in generating information. The Reagan administration's efforts drew complaints about increased prices for government publications (Rowe 1990, p. 15), narrowing the scope of information that could be collected by the federal government, greater dependence on user fees (Andes, 1988; Rowe, 1990), emphasis on regulatory and paperwork responsibilities rather than the development of statistical policy (Sy and Robbin, 1990, p. 7; U.S. Congress House Committee on Government Operations, 1983, p. 55; and Smith, 1986, p. 244), failure to aggressively pursue the development of statistical policy (Griffith, 1986, p. 252), and privatization (Rowe, 1990).(3) Although the remainder of this section provides some information about U.S. information policy, a more comprehensive discussion of descriptions of and prescriptions for U.S. information policy is beyond the scope of this article.(4)

The relative unimportance of statistical programs to the Reagan administration is perhaps reflected in the fact that those programs "have expanded greatly in size and complexity over the last three decades, [while] the size of the office charged with overseeing statistical activities has declined" (Griffith, 1986, p. 255). In 1947, the office responsible for statistical policy had a staff of 69. This number shrank to 29 in 1977, 15 in 1980, and 6 in 1983 (pp. 248, 249).

Efforts to reduce the flow of government data in the early part of the Reagan administration met with concern. An example of this was the reaction to OMB's effort, via its Circular A-130, to narrowly define the information for which the federal government had collection responsibilities. OMB's first attempts at drafting A-130 met with strong reactions from COPAFS (Council of Professional Associations on Federal Statistics Annual Report, 1985, pp. 6-8) and others (Staff and Corson, 1987, p. 444; footnote 47).(5) COPAFS's efforts to voice "concerns of irs member organizations" to OMB led COPAFS to seek "to obtain modifications in the tone and content of the circular [which efforts] met with considerable success" (Starr and Corson, p. 7). Indeed, COPAFS claimed the changes made by OMB "reflected in large measure the views expressed by COPAFS and many of its members" (p. 8).

Even so, the modification and release of Circular A-130 in 1985 showed that OMB still wanted to exert a strong role in the implementation of statistical and information policy. OMB was trying to give some direction "regarding dissemination of information for which Congress [had) not provided explicit statutory guidance" (Sprehe, 1987, p. 189). OMB still believed Congress meant it to "discharge the general information policy function" (p. 191). Indeed, "[t]he Deficit Reduction Act of 1984 ... required Federal agencies to reduce their publication budgets by 29 percent during the 1986 fiscal year" (Shattuck, 1988, p. 371). It was, Shattuck says, "[i]n that spirit ... [that OMB] adopted" A-130 (p. 371).

Although Circular A-130 has been defended by OMB officials (Sprehe, 1987; OMB, 1984c), it has also been subjected to severe criticism. Some saw it as potentially limiting access to government information (Andes, 1988; Leacy, 1984; Owens, 1986; Pelzman, 1989). Others worried that the generality of the language in the circular left OMB with too much discretion (Hernon, 1986, p. 280; Relyea, 1986, pp. 637, 638). There was also some criticism of OMB's efforts to develop a policy "on the management of Federal information resources" (U.S. Congress House Committee on Government Operations, 1985a, p. 1).

Congressional criticism of OMB's efforts to shape statistical policy resulted in OMB agreeing to be more cooperative with others (Council of Professional Associations on Federal Statistics Annual Report, 1988, pp. 11 and 12).

One final note about the Reagan administration's information policy. An OMB official suggested that the Paperwork Reduction Act in actuality required review of all information gathering efforts, even with regard to "routine administrative information..." (U.S. Congress House Committee on Government Operations, 1985a, pp. 83 and 84). OMB did not intend to enforce this broad meaning "in any way remotely resembling the way in which we are required ..." (p. 76). Of course, that broad interpretation of the law would make any narrower interpretation look less intrusive.(6)

OMB has been subjected to conflicting forces. Nevertheless, evidence suggests that if it had been left on its own, OMB would have reduced the amount of data collected by the federal government even further than was the case.

The Fiscal Budget

The second way in which OMB influences the collection, analysis, and dissemination of government information is the development and management of the fiscal budget. Specific OMB officials are assigned die responsibility of monitoring the fiscal budgets of particular agencies. Other OMB officials make sure agencies in certain program/policy areas comply with the federal government's statistical policy. OMB also monitors testimony that will be presented to Congress by agency officials, although oversight testimony is not necessarily cleared.(7)

For CESTAs, smaller budgets mean less data. Budget changes can have the force of reordering agency preferences and performances. Such changes can reflect the programmatic preferences of the President. Budget reductions in the early 1980s did not go unnoticed. Stanfield (1981, pp. 2118, 2119) pointed out that BLS, Bureau of the Census (BOC) and EIA had been subjected to budget cuts, with EIA's budget dropping from $104 million to $70.4 million. However, in 1982 an OMB official claimed that from fiscal years 1981 to 1983 "most statistical programs [were] holding their own" (U.S. Congress House Committee on Government Operations, 1983, p. 149).

Others were less sanguine. Representative Brooks (D-TX) claimed in 1982 that budget cuts "threaten the existence of entire areas of data as well as planned analyses and anticipated reports" (House Government Operations, 1983, p. 1). According to Dr. Stephen Fienberg, chair of the Statistics Department at Carnegie-Mellon, "recent and projected budget cuts" threatened precision and accuracy of "statistical services" (p. 6). BOC was said to be hindered by the budget restrictions facing BJS, BLS, and NCHS (pp. 7, 8). Fienberg claimed that some of the "programs of the National Center for Health Statistics have been so drastically restructured, the data the Government has relied upon for years will not be available ..." (p. 33).

Judging just by total budget figures, most CESTAS did not fare too poorly during the Reagan administration (Table 1). In terms of constant (1980) dollars, all CESTA budgets experienced a decline, at least until FY 1986. From 1980 to 1982, the combined budgets of BEA, BOC, and BLS "were cut more than 7 percent in real terms ... " (House Government Operations, 1983, p. 16). In constant dollars, total budget figures for all CESTAs were $386.(6) million in FY 1980, $305.2 million in FY 1983, $319.5 million in FY 1985; and $305.4 million were requested in FY 1986 (U.S. Congress House Committee on Government Operations 1985b, p. CRS-6; Table 1b).

[TABULAR DATA 1 OMITTED]

Forms Approval Process

Almost every form developed and used by a federal agency to gather information must be approved by OMB, if the form is to be sent to ten or more respondents. Every form thus approved must be reapproved approximately every three years. If the form is approved, the agency can use the form to collect the desired information. If the form is not approved, the agency can either appeal the OMB decision or resubmit a modified form. The latter step would basically delay the use of any form for a year.(8) Each such form receives an OMB control number (Rosenberg, 1986, p. 207; Paperwork Reduction Act, p. 2815).

PRA explicitly provides an appeal process only to regulatory agencies, saying nothing about other kinds of agencies (Paperwork Reduction Act, p. 2820). Rosenberg interprets this as meaning only regulatory agencies can appeal (Rosenberg, 1986, pp. 207, 208). Bass and Plocher (1989, p. 421) claim that "only independent regulatory commissions are permitted to overrule OMB decisions." The Government Accounting Office (GAO), however, points out an appeals process "is available through the deputy administrator when new information is available but [this process] is rarely invoked" (Government Accounting office, 1989b, p. 70). This suggests an appeals process is open to nonregulatory agencies as well.

The forms approval process has been around for quite some time. In earlier years, responsibility for the process rested with the Office of Statistical Standards of the Bureau of Budget (Office of Statistical Standards, 1952, pp. 8, 9). The Federal Reports Act of 1942 required a forms approval process (Bureau of Budget, 1968, p. 5), a duty which led to OMB getting "broad authority over all types of information collection [with some exceptions]" (Office of Management and Budget, 1976, p. 38). PRA "[returned] to OMB all final authority over forms clearance, an authority that had been progressively fragmented since 1973" (President's Reorganization Project for the Federal Statistical System, 1981, p. 135). Thus a more centralized clearance process coincided with a strong commitment on the part of the Reagan administration to exercise greater control over that process.

In 1989, GAO conducted a study for a subcommittee in the House of Representatives. In a hearing where the report was discussed, there was an indication of some positive consequences of the Reagan administration's statistical policy (House Committee Science, Space, and Technology, 1989, pp. 17, 18). On the other hand, GAO's study did suggest OMB favored reducing the flow of government information (pp. 26, 27). OMB's efforts to "encourage public comment in the review process" increased the median review time to 55 days in 1987, up from "39 days between 1982 and 1984, ..." (p. 17). According to GAO, "interviews with desk officers suggest that the most likely reason for the increases in review time ... was congressional interest in greater public participation in the clearance process" (Government Accounting Office 1989b, p. 83). However, OMB desk officers interviewed by GAO "indicated infrequent ... comment [from the general public]" (pp. 83, 84).

GAO compared approval rates for three kinds of forms: regulatory, benefit applications, and statistical/research evaluation. The last kind had the lowest approval rate. Still, their approval rate was very high: 95 percent of the recurrent forms were approved and 85 percent of the new forms were approved, for a total approval rate of 90 percent (Government Accounting Office, 1989b, p. 79).

The lower approval rate of statistical/research evaluation forms, a category in which CESTAs would fall, could have been due, in part, to the increased number of reports submitted by statistical agencies. The number went from 545 in the 1982-1984 period to 589 in the 1985-1987 period (Government Accounting Office, 1989b, p. 99). Only this type of agency submitted more new forms in 1985 to 1987-24 percent more (p. 101). If OMB was less likely to approve forms submitted by statistical agencies because a proportionately higher number were newer forms, it underscores my argument that OMB was not a champion of government data collection. OMB officials interviewed by GAO seemed to imply that greater understanding of the review process resulted in fewer "inappropriate submissions." GAO pointed out that "increased presubmission contact ... could also be associated with the small decline in the number of [form] withdrawals and disapprovals" (Government Accounting Office, 1989b, p. 75). I am not certain of the degree to which agencies circumvented the forms clearance process, nor of the consequences such action may have had for reporting burden or other oversight matters. In a study of 17 agencies, GAO indicated that 14 had "used ways to circumvent the OMB review process.... [But the] implementation of these practices was rare to occasional ..." (pp. 106, 95). According to GAO, "there were no substantial differences in the use of circumvention by agencies with high versus low approval rates" (p. 106).

Nevertheless, OMB "was willing to indicate in advance of formal submission what modifications an agency should make to ensure approval" (Sy and Robbin, 1990, pp. 10, p. 15; U.S. Congress House Committee on Science, Space and Technology, 1989, pp. 16, 17).

Given OMB's commitment to reducing the reporting burden, it seems likely that the informal review process was a way agency officials had of getting a "read" on OMB before submitting a request. Such a process would screen out undesirable requests and result in a reduction of information collection activities. According to Sy and Robbin (1990, p. 15), "agencies now anticipate OMB's reaction to requests by seeking feedback from [OMB] staff prior to formal submission of requests, and some agencies withhold requests likely to be disapproved" (Government Accounting Office, 1989b, p. 89).

The Information Budget

The fourth means by which OMB influences the flow of information is through the Information Collection Budget (ICB).(9) ICB is the basic mechanism through which OMB controls reporting burden--the burden borne by those who fill out federal forms. OMB sets the ICB for each year and distributes this time between departments and agencies subject to the ICB process. Agencies and departments must adhere to these budgets. Congress plays no formal role in calculating or setting these budgets.

Each agency provides an estimate of how much time it will take a respondent to complete a particular form. Each agency then calculates its total information collection budget by adding together the amount of time it will take to complete all its forms. OMB decides whether to accept the estimations during the forms clearance process. OMB can also decide that a particular form is too onerous and require the agency to streamline the form.

OMB's responsibility for response burden was expanded by Executive Order 12174, issued in November 1979 (President's Reorganization Project for the Federal Statistical Program, 1981, pp. 193, 194). That order established the ICB process (p. 194), although a procedure for controlling ICB existed a year or two earlier (Office of Management and Budget, 1978, p. 20). OMB "assumed the task of monitoring ceilings on reporting burden, providing guidelines to agencies, and attempting to ensure that exceptions to controls and guidelines are justified and endorsed at the top level of each Department or agency" (President's Reorganization Project for the Federal Statistical Program 1981, p. 195).

The Reagan administration made no secret of its opposition to reporting burden, noting that "President Reagan's campaign had stressed the need for ... putting an end to unbridled regulatory and paperwork growth" (Office of Management and Budget, 1984b, p. 3). In its first three years, the Reagan administration "pursued an aggressive paperwork reduction program..." (p. 3). That opposition was also manifested in the letter OMB Director James Miller submitted with the FY 1986 ICB. The letter noted the ICB reduction for FY 1986 was not as substantial as that for FY 1985, blaming legislation that resulted in more information gathering. Although OMB "would not propose the repeal of these laws," the letter claimed there were "less burdensome or intrusive alternatives ... [available to achieve congressional intent]." OMB's goal was to try to restrict "the paperwork imposed by statutory or regulatory changes" (Office of Management and Budget 1986, cover letter).

OMB estimated that the reporting burden shrunk by 33 percent between 1980 and 1983, with a further reduction of 4.3 percent in 1984 (Rosenberg, 1986, p. 212). In 1986, OMB estimated an annual reduction in paperwork of 500 million since 1981 (p. 212). PRA set goals of reducing the reporting burden 15 percent "by October 1, 1982"; and an additional 10 percent by the following year (Paperwork Reduction Act, 1980, p. 2818). PRA required OMB to set "goals for reduction of the burdens of Federal information collection requests; ..." (p. 2818). The 1986 reauthorization act, "set a goal to reduce, by September 30, 1987, the burden of Federal collections of information existing on September 30, 1986, by at least 5 percent"; and asked for a 5 percent reduction in "each of the next two fiscal years, ..." (Paperwork Reduction Reauthorization Act, 1989, pp. 3341-337). Thus, at least during the first years of the Reagan administration, OMB did better than the law required (Table 2).
Table 2
Information Collection Budget Figures, Fiscal Years 1980-1988
(in thousands of hours of reporting burden)
Fiscal Year       Base    Reduction   Additions   Net change
1980          1,477,000
1983          2,023,446   -143,386     12,636      -130,750
1984          1,989,230    -74,405     +8,787       -65,618
1985          1,894,071    -71,727    +12,792       -58,934
1986          1,741,920    -46,752    +16,670       -30,082
1987          1,881,434    -96,739    +30,643       -66,096(*)
1988          1,881,434   -106,264    +43,708       -62,556(**)
(*)OMB 1988 figures.
(**)OMB 1989 figures.
Sources: OMB, 1983, p. 8; OMB, 1984a, p. 20; 1985a, p. 22; OMB, 1986,
p. 23; OMB 1987, p. 25; OMB, 1988, p. 22; OMB, 1989b, p. 8.


Although OMB's early efforts to reduce the reporting burden met with success, reducing ICB was more difficult in later years for two reasons. First, more agency forms were added to the ICB process (GAO, 1989a, pp. 1, 12, 14). Second, new legislation added to the reporting burden (OMB 1986, cover letter; GAO 1989a, pp. 14-16, 18), as did judicial (in one case) and executive actions (GAO, 1989a, p. 16). Indeed, GAO's analysis showed "a 27 percent increase in reported burden hours (to 1.9 billion) between 1980 and 1987" (p. 1).

GAO attributed most of the changes "in reported burden between 1980 and 1987..." to these factors (GAO, 1989a, p. 10), which accounted for most of the ICB increase (p. 1) and some of the decrease (p. 12). Decreases in ICB were also due to forms that were were discontinued or had expired and not been renewed (p. 18), and to reductions of "ongoing collections" (p. 19). GAO's recalculation of reported burden (p. 12) showed a trend similar to that of OIRA's figures. Both showed a decline in reporting burden between FY 1984 and 1986, and an increase in FY 1987.

If OMB were serious about trying to reduce the reporting burden, one would expect voluntary forms to experience a greater reduction of reporting burden. OMB figures for 1984 and 1986 show cuts in ICB from reductions in voluntary reporting were relatively larger than cuts in other types of reporting (OMB, 1985a, p. 19; OMB, 1988, p. 17). GAO figures also show a disproportionate decrease in reporting burden for voluntary forms (GAO, 1989c, p. 104; also U.S. Congress House Committee on Science, Space, and Technology 1989, p. 34.)

Consequences

A comprehensive accounting of all the changes resulting from the Reagan administration's information policy is beyond the scope of this article. Instead, I shall provide a glimpse of some of the consequences of that policy and concerns it raised.

In 1984, the Baseline Data Corporation reported on the federal statistical system during the first part of the 1980s. Although it found it "difficult to compare the general status of the statistical programs to that of 1980 .... [,]" it pointed to some general trends that had emerged. First, "resource levels" remained below what they had been in 1980. Second, improvements in processing and collecting data had been made to adjust to reductions in budgets. However, "[i]n other cases," entire programs had been eliminated; frequency of data collection and production had been reduced; sample size had been reduced; scope of data collection had been reduced; and "fewer analyses of data collected..." were provided (U.S. Congress House Committee on Government Operations, 1984, p. CRS-6).

Especially hard hit were EIA, NCHS, and NCES. Data collected primarily for regulatory purposes were eliminated (EIA); statistical evaluation, analysis, and research were scaled back (NCES and EIA,); and programs were reduced in frequency or eliminated (NCHS, EIA, NCES) (U.S. Congress House Committee on Government Operations, 984, p. CRS-4).

Major developments in statistical programs included "the initiation of the Survey of Income and Program Participation ... [,] an "initiative to improve data available on service industries .... (p. CRS-3), and preparing "for the 1990 Decennial Census of Population and Housing" (p. CRS-4). For 1987, the Reagan administration recommended partial restoration of funds for BLS, BEA, and BOC, which had faced cuts "in part due to the Gramm-Rudman-Hollings provisions ...," although between 1985 and 1987 they would still face a decline "in real terms" (Joint Economic Committee, 1986, p. 17; testimony of Courtenay Slater).

Concern for the status of economic statistics was one reason why the Joint Economic Committee held a hearing in 1986. Senator Sarbanes (D-MD) referred to stories in Industry Week, the New York Times, and the Washington Post that expressed some anxiety over the quality and quantity of the statistics (Joint Economic Committee, 1986, p. 2). Sarbanes quoted Janet Norwood, BLS Commissioner, who said "[a]s both a producer and a consumer of federal statistics, I have found some of these [budget cuts] extremely painful. The cuts have eliminated or sharply reduced a number of very useful statistical series" (p. 3).

According to Elinor Chelimsky, Assistant Comptroller General for Program Evaluation and Methodology at GAO, GAO's review of OMB's forms review process indicated some agencies felt they were able to "get rid of data collections that were duplicative or otherwise not useful." However, other agencies "had stopped gathering information in some areas uniquely because of problems they had experienced with the OMB clearance process" (U.S. Congress House Committee on Science, Space, and Technology, 1989, p. 18). GAO's research showed "an unambiguous decrease of 10 percent since 1980 in the number of agency requests to OMB to collect data" (p. 18). As early as 1982, the quality and relevance of data relating to foreign trade, business inventories, capital investments, the consumer price index, and "the financial condition of manufacturing companies," had, according to Donald Woolley of Bankers Trust Co., "slipped in recent years as a result of previous budgetary limitations and, in certain instances, a lack of interest by the compiling agencies" (House Post Office and Civil Service, 1982, p. 44). Several other economic interests and governmental programs had been or would have been negatively affected by data reduction, delay, or elimination: lending institutions, hospital and travel industries, forecasting short-term sales, planning and market analysis, "scheduling by agricultural and equipment manufacturers..." (p. 47), sales, marketing. and media (p. 67), loss of data on air and water quality (pp. 88-90); programs related to federal assistance for ethnic and racial minorities (p. 37), "continued monitoring of desegregation in small rural or suburban [school) districts .... (p. 39), family living costs, wages, and collective bargaining[,] ... employer expenditures for fringe benefits[,] ...wage surveys[, and] ... the impact of inflation on workers ..." (p. 52); and difficulty in obtaining comparative state-level data relating to education (p. 70).

A survey of state statistical agencies in 1985 (Robinson and Stone, 1987, pp. 433, 436) showed that "70 percent the agencies indicated that they [would] be unable to compensate if federal statistical services [were] reduced substantially." While the survey was not a random sample of state statistical agencies, 207 such agencies were sent the survey in "an attempt ... to identify a reasonable variety of statistical agencies" (Robinson and Stone, 1987).

One observer suggests that the discontinuance of statistics in the 1980s dealing with unemployment rates in Los Angeles and New York, certain kinds of strikes, school busing, and other issues occurred because these statistics "were embarrassing to the administration in power at the time" (Maier, 1991, p. 194). Others claim the dissemination and collection of information by federal agencies has been restricted by OMB (Bass and Plocher, 1989, p. 413). They felt public access was limited by OMB and accused OMB of failing to improve the management of federal information; instead, OMB deferred "to private sector business interests" (p. 194). In short, had the Reagan administration been more successful in reducing the role of government in data acquisition, virtually every part of the American society would have lost information necessary to their functioning.

Conclusion

There have been important shifts in federal information policy since the Reagan administration. 1993 changes in OMB Circular A-130 broadened the definition of the kind of information which would be regulated from information disseminated, collected, processed, or disposed of "by" to "by or for" the federal government (Office of Federal Register, 1993, pp. 36069, 36070). Among other objectives, the revised A-130 requires federal agencies to carry out information resources management with "special focus on the information life cycle" (p. 36068). It now recognizes "that benefits to be derived from government information may not always be quantifiable..." (p. 36069), suggesting a greater role for government than pursued by the Reagan administration.

Reducing paperwork continues to be an important goal (Office of Federal Register, 1993, pp. 36071, 36072), even though PRA expired in 1989 (Council of Professional Associations on Federal Statistics, 1990, p.12).

Two bills relating to PRA had been introduced in the Senate in its 1993 session. One bill basically continued the thrust of its predecessors, with some changes (Senate Bill 681, 1993). The other was more reflective of the philosophy of the Reagan administration (Senate Bill 560, 1993).(10)

Some policy changes have added to and others have reduced the ICB. The Department of Treasury "conducted a comprehensive reassessment of its burden estimates.... These adjustments totaled approximately 3.4 billion additional hours, ..." and were reflected in the ICB for FY 1990 (OMB, 1990, p. 1) For FY 1991, "the implementation of new or revised environmental, food safety, immigration, and disabilities laws placed additional ... burdens on the public that were difficult to offset" (OMB 1992b, p. 11-3). The ICB increased by nearly 2.2 million hours between FY 1990-which had a base of almost 6.3 billion hours--and FY 1991 (p. 11-4). For FY 1992, the reporting burden was reduced by an estimated 4.5 million hours (p. II-7). The ICB for FY 1993 was projected to increase nearly 18.6 million (OMB 1992c, p. II-9).

The Supreme Court's 1990 decision in Dole v. Steelworkers that some of OSHA's information collection requirements were "not subject to OMB review under PRA" has led to a reduction in the ICB (OMB 1992b, p. II-5). At least five agencies or departments of the federal government "removed at least one information collection from OMB as a result of their interpretations [of the Court's decision]" (p. II-5) OMB expected that removal of forms from review under PRA would reduce reporting burden more than 150 million hours by FY 1992. OMB records the exemptions as adjustments rather than program changes (pp. II-5, II-6). However, adjustment figures may be underestimated, because some agencies will no longer submit requests for information collection to the OMB (p. 11-6); in essence, creating an off-budget ICB.

Budgetary changes indicate a greater commitment to federal statistical programs. Figures for FY 1993 show an increase in budget authority for those programs (the eight CESTAS listed in the grey box on page 435, and Agriculture's Economic Research Service, and Treasury's Statistics of Income Division) from $863 million (actual) in FY 1991 to $975 million in FY 1992 (enacted) and a proposed $1.17 billion in FY 1993 (OMB, 1992a, p. 1-315). Accomplishments listed for 1991 include: reinstated GNP estimates that had been discontinued in 1989; information on the communications industry were produced for the first time; improvement in some areas; and expansion in others P. 1-316).

I applaud efforts to improve the federal statistical system. Our inclination is to view information and statistical data as social goods, not as economic commodities--to use terms suggested by Detlefson (1984, p. 386). Following arguments made elsewhere (Morin 1999, pp. 854-857), I argue that, contrary to economic commodities, the value of data increases as its use increases. Statistical data have historical as well as contemporary value; consequently, their full worth cannot be adequately measured by market values. Private firms will provide statistical data only as long as it is profitable to do so, and profit is a short-term phenomenon. The discount rate of information, and long-term benefits of information, are virtually impossible for the market to measure (see the testimony of Minnesota's State Demographer in U.S. Congress House Committee on Government Operations, 1985a, p. 200).

Reliability and continuity of data may be more problematic if data collection were left to the private sector. Indeed, EIA was created in part because of the distrust of industry figures (Duncan, 1987, p. 410).

The questions of legitimacy, authority, and independence, of who defines "quality standards," whether private firms have the resources or incentive to match the scale at which data are collected by the government, and whether private firms could match the economy of scale achieved by the government (Sy and Robbin, 1990, p. 17; see also testimony in House Post Office and Civil Service, 1982, pp. 69, 70) lead us to believe that it would be dangerous to underestimate the importance of the role of government in data acquisition. Given that information is a social good, I believe it is better to err in collecting too much rather than too little data.

CESTAS and Their Data Responsibilities

Bureau of Census (BOC)--The U.S. Constitution requires that a census be taken every ten years. It was initially for the purpose of determining the numbers of Representatives to which each state was entitled, and for tax purposes (Article 1, Sections 2 and 9). Today, BOC collects data that "are utilized by the Congress, by the executive branch, and by the public generally in the development of economic and social programs" (Office of Federal Register 1989a, p. 149).

Bureau of Economic Analysis (BEA)--"is to provide a clear picture of the U.S. economy through the preparation, development and interpretation of the national income and product accounts, summarized by the gross national product; the wealth accounts, which show the business and other components of national wealth. the input-output accounts which trace the interrelationships among industrial markets;... the U.S. balance of payments accounts ..."; and it works with economic development forecasts (Office of Federal Register, 1989a, p. 151).

Bureau of Justice Statistics (BJS)--"is responsible for the collecting, analyzing and disseminating statistical data about crime, its perpetrators and victims,... prison and jail inmates, probation and parole, adjudication, processing offenders as they move through the criminal justice system, criminal justice expenditure and employment, ..." (Office of Federal Register, 1989a, pp. 397, 398).

Bureau of Labor Statistics (BLS)--"collects, processes, analyzes and disseminates data relating to employment, unemployment, and other characteristics of the labor force; prices and family expenditures; wages, other worker compensation, and industrial relations; productivity and technological change; and occupational safety and health" (Office of Federal Register, 1989a, p. 425).

Energy Information Administration (EIA)--"performs analyses of energy data to assist government and nongovernment users in understanding energy trends" (Office of Federal Register, 1989a, 287). EIA collects data on coal production and consumption, petroleum, natural gas, utility bills, etc. (Energy Information Administration, 1987).

National Agricultural Statistics Service (NASS)--"prepares estimates and reports on production, supply, price, and other items necessary for the orderly operation of ..." the economy of the nation's agriculture. It issues more than 300 reports every year (Office of Federal Register, 1989, pp. 136 and 137).

National Center for Education Statistics (NCES)--collects education data (House Education and Labor, 1988, p. 42), including data on vocational schools, secondary and post-secondary education (House Government Operations, 1985b, pp. CRS-85, CRS-86).

National Center for Health Statistics (NCHS)--Its data serve "as the basis for health research, health legislation, prevention and treatment, ..., and health insurance planning" (Senate Appropriations, 1988, p. 250; from a statement of James O. Mason, Director of the Centers for Disease Control, of which NCHS is a part).

Notes

The author would Like to thank Dean E. Mann, professor emeritus (UC Santa Barbara) for his editorial, organizational, 2-nd other suggestions. Thanks also to previous reviewers, to UC Santa Barbara for providing funds to support research which led to this article, for support provided by the Political Science Department at BYU during my stay as a visiting faculty, and to the Brookings Institution who provided space during a research stint in 1987. (1.) As this article was undergoing final revisions in the summer and fall of 1993, I came into contact with Mr. David Plocher, who provided a reference to a piece he co-authored in 1989 (Bass and Plocher, 1989). Bass and Plocher cover in that article the same issues as I do in this article; their assessment, though more strongly worded, is similar to mine. They also provide a more detailed discussion of OMB's role in regulatory review, records management, and telecommunications policy; and discuss its contrarian approach to privacy issues. They appear to be in agreement with my claim that information is more appropriately viewed as a social, not private, good (pp. 437 and 438). Finally, they discuss recommendations that they believe will improve federal information policy. (2.) OMB has published several reports that relate to its responsibilities in the areas of statistical policy, information collection budget, and managing information technology (see, for example, OMB, 1984b; 1984c; 1985b; 1985c; 1988; and 1989b). 1987 interviews with OMB, BEA, BOC, NCHS officials and others provided important information about the forms approval process, the information collection budget, and statistical policy more generally. A discussion of statistical policy and the ICB can also be found in Morin (1989, chapts. 1 and 6). Maier (1991) provides a discussion of the uses and abuses of government statistics (census, housing, health, education, crime, economy, wealth, labor, and business) and the politics of statistical. (3.) For example, there was a debate about whether some of the responsibilities of the National Technical Information Service should be privatized or contracted out (Eisenbeis, 1988; Hernon 1989, p. 55; Smith 1985, p. 49). Articles that discuss privatization and/or charging for government data (by levying user fees) or government information include: Andes (1988), Detlefson (1984), Duncan (1987), Goe and Kenney (1988), Kent (1989; see his endnotes for citations of other literature, pp. 130-131), Murdock and Goulding (1989), Owens (1986), and Smith (1985). Articles that look at privatization from other policy perspectives, in addition to the President's Commission on Privatization (1988, include Leighton (1988) and Stahl (1988). See also Shattuck (1988, p. 371). (4.) |The politics of information' covers a broad array of subjects: the role of government in collecting, disseminating or controlling data or other information (Alonso and Starr, 1987; Benshoof, 1988; Hayes, 1987; Kent, 1989; Yirby, and Harvell, 1989; Smith, 1985; Walsh, 1988); political, economic technological and other dimensions of information or statistical policy (Detlefson, 1984; Sanchez, 1989; Wilkinson, 1987; Wood, 1987); the international implications of data collection in foreign countries (Kelsey, 1988); and the rights of publishers (Landau, 1988; van Krevelen, 1987). (5.) Again, one must be careful about ascribing all of the impetus for reducing government's role in data collection to the Reagan administration. As the Commission on Federal Paperwork pointed out, "Beginning with the FY 1978 budget,...[OMB] incorporated a new requirement for agency reporting systems; that is, requests for new reporting systems must contain a review of the |practical utility' of the information to be collected' (Commission on Federal Paperwork, 1982a, p. 417).

Data not used were discouraged from being collected, even if the agency collecting the data was not responsible for the data not being used, and even if the data were necessary. It is also interesting to note that the commission endorsed |this new' |test' and [urged] the expansion of it's application beyond the reporting |context' (p. 417). (6.) The relevant language of the Paperwork Reduction Act is as follows: the term "collection of information" means the obtaining or soliciting of facts or opinions by an agency through the use of written report forms, application forms, schedules, questionnaires, reporting or recordkeeping requirements, or other similar methods [where ten or more respondents] other than agencies, instrumentalities, or employees of the United States [are asked to respond to identical questions or requirements, or when the information solicited from Federal agencies, employees or |instrumentalities' is] to be used for general statistical purposes" (Paperwork Reduction Act of 1980, p. 2813). (7.) This paragraph is based on 1987 interview with OMB officials; see Moe (1986) on OMB's role in clearing proposed legislation. (8.) 1987 interviews with OMB officials and others provided information useful to understanding the forms review process. Other useful information can be found in Rosenberg (1986, particularly pp. 207-209), Smith (1986), Griffith (1986, pp. 246, 248, 252), Morss and Rich (1980), Council of Professional Association on Federal Statistics Annual Reports 1985, 1986, 1988), and OMB (1985b, particularly pp. 1-3). See also House Governments Operations (1983, pp. 168 and 169). The 1989 GAO report has an excellent description of the forms review process and a lengthy analysis of how it worked during part of the 1980s (GAO 1989b, pp. 69-115). A report prepared for the Congressional Research Service by the Baseline Data Corporation has a somewhat critical discussion of the review process during the first four years of the Reagan administration (House Government Operations 1984, pp. 63-66). In addition, see Morin (1989, chap. 1, particularly Sect. DO.

OMB's Paperwork Docket library holds records of the forms submitted for approval. These records include comments on the forms from OMB officials and other interested parties, such as potential respondents. (9.) 1987 interviews with OMB officials and others provided information relevant to ICB, which is described in the first three paragraphs of this section. See also U.S. Congress House Committee on Government Operations (1983, pp. 166, 167) for a brief explanation of the ICB process and Commission on Federal Paperwork (1982b) for a discussion of the cost of government paperwork. For a short discussion of the difficulties of measuring reporting burden, see Commission on Federal Paperwork (1982a, p. 412). Forms in the OMB Paperwork Docket library can include comments on their ICB. (10.) Senate Bill 681 was intended as a reauthorization act. Among other goals, this bill sought to improve intergovernmental cooperation, encourage a focus on the information life cycle, facilitate interagency data sharing and public access, promote elimination of reporting burden, identify a class of respondents who were especially deserving of reporting reduction, and achieve greater congressional involvement in CESTA activity (Senate Bill 681, 1993).

A major goal of Senate Bill 560 was paperwork reduction. It's aims were to expand the definition of reporting burden, and reduce the reporting burden 5 percent a year for fiscal years 1994 through 1998. Other goals included: reduce duplication, ensure practical utility, write forms in plain English, and make forms compatible with the format in which respondents keep the information (Senate Bill 560, 1993).

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