A guide to the Paperwork Reduction Act

Burden hours and cost

One of the goals of the PRA is for the federal government to consider and account for the impact on the public when asking for information. This impact is called burden, and includes the value of both the time and the effort required to fulfill a collection along with the financial cost.

The PRA requires that agencies estimate burden to understand what is involved for the public to comply with a request.

Some common burden activities include:

• Reviewing instructions.
• Compiling materials necessary for collection.
• Acquiring, installing, and utilizing technology and systems.
• Adjusting existing ways to comply with previous instructions and requirements.
• Searching data sources.
• Completing and reviewing collected information.
• Compiling and sending information.

Overall, burden can seem intimidating, especially in a large collection. Our burden activity questions are a starting point to help you begin thinking about scope.

Avoiding excessive burden

Some examples of excessive burden include:

• Addressing more respondents than necessary.
• Asking questions that are not relevant or essential.
  • You must justify questions about personally sensitive matters like religious beliefs or political affiliation, or questions that may cause persons to incriminate themselves.
• Asking for a reporting frequency that is higher than necessary.
• Not considering an alternative approach to obtain the information.
• Requesting information in a different format than is usually maintained.

If your collection involves activities seen as excessive, you must justify them in the purpose and need sections of the collection in your supporting statement.

Burden activities

Many activities count as burden. These questions can help you to determine if a burden activity should be factored into your estimate. This is not a comprehensive list, but a starting point for you to begin thinking about the scope of burden in your collection.

Reviewing instructions

• How much time, effort, and cost will it take for respondents to understand what information the agency is asking for and how to collect it?

Compiling materials necessary for collection

• How much time, effort, and cost will it take for the respondents to locate, gather and compile necessary documentation required for the information collection?

Technology and systems

• What technology and systems do respondents need to gather, process, store, and send information?
• Is this new technology that needs to be bought?
• If it does not exist at all, what is the cost of development? Is there a cost associated with installation or with training? Are there one-time costs?
• Is there a cost to use the technology, like a subscription?

Adjusting existing methods

• If a previous collection has been updated or changed, how will the current methods need to be adjusted?

Training personnel

• Will the collection require staff, contractors, or other agents to undergo training to respond?
• How much time or money is needed to ensure they understand both program and policy context, and can respond to the collection?
• Will there be additional training for actual reporting and recordkeeping methods?

Searching data sources

• Are there public or private data sources that respondents can use to respond to the collection?
• What would be the cost of creating new data sources?

Completing and reviewing collected information

• How much time, money, and effort will it take to perform all tasks in the collection?
• Does the information also need to be certified for accuracy and reliability?

Sending and disclosing information

• What must be done to send the collected information to the federal agency requesting it?
• Does it need to be sent or disclosed to a third party, like other federal agencies or offices, state or local governments, other companies, or members of the public?

How to estimate burden

OMB has consistently held that measuring burden is "often difficult and imprecise in the absolute, but reliable and consistent measures of change are possible." These guidelines and resources are a good starting point for agencies to make the best estimates of burden for their collections.

Time (burden hours)

Estimates of burden hours need to include:

1. The number of respondents.
2. The frequency of response.
3. The total number of burden hours per year.

Base your burden hour estimates on consultation with a representative sample of potential respondents; do not make a special survey to make an estimate unless directed.

Burden hours may vary widely due to differences in activity, size, or complexity. If they do, include a frequency distribution of expected burden along with the factors that explain why.

To value and account for the full array of personnel required to plan, develop, prepare, and fulfill an information collection, burden hour estimates fall into four categories of labor:

1. Clerical and other unskilled workers
2. Skilled-labor, craft-labor, and other technical workers
3. Professionals and managers
4. Executives

This includes time spent by all employees, partners, and associates of the respondent. All wages need to be fully-loaded, meaning they reflect the full cost of labor, including benefits. The Bureau of Labor Statistics' wage data is a good resource to start with.

Financial costs and all other aspects of burden

Using market prices for time and effort, report burden costs that will be carried directly or indirectly by subordinates, associates, agents, or contractors for the respondent.

If you expect respondents to satisfy some part of a collection through outside consultants, contractors, legal and financial advisors, report the estimate for these services as a lump sum.

These types of burden need to be estimated in two separate categories:

• Non-recurring or capital cost: one-time investments to fulfill a collection request
• Recurring or annualized cost: ongoing costs, such as operating or maintaining a capital investment

Burden calculation

When submitting burden estimate to OIRA the agency should be prepared to include:

1. Estimated burden hours per respondent;
2. Estimated aggregate burden hours;
3. Estimated capital and other non-labor costs per respondent; and
4. Estimated aggregate capital and non-labor costs.