The gathering of information has become a major government agency preoccupation, thus it is not too surprising that checking on the questionnaires being sent out is also getting to be a bureaucratic art form.
Government being government, this responsibility has been split -- under the ever-wise direction of Congress -- because the General Accounting Office (GAO) and the Office of Management and Budget (OMB). There is a form of logic to it. GAO is an independent auditing arm of Congress, so it reviews the questionnaires of the independent regulatory agencies -- the Federal Trade Commission, Federal Communications Commission, Consumer Product Safety Commission, et al. OMB, an auditing, budgeting and do-all policy group run by the president, reviews the questionnaires proposed by executive branch agencies.
There is one major difference, however, in the authority granted to the two reviewing agencies. GAO, by law, can only recommend changes based on the burden the questionnaire imposes on the recipient, and in the area of duplication -- i.e., the question has already been asked or answers are available elsewhere.
GAO can't ask why the information is being sought. If the independent agency doesn't want to listen to GAO, the matter has to go to court (although nothing has ever gone that far). Also, GAO must act on a questionnaire within 45 days or the agency can go its merry way.
OMB is all-powerful. It can sit on a questionnaire it doesn't like, and the agency that produced it can't move. OMB also can get into the real question of whether the information being sought is really needed. An OMB official said the other day that of the last 2,000 questionnaires reviewed, 9 percent got turned down, primarily because what was being sought wasn't needed.
The Nov. 20 Federal Register contains a good illustration of this difference in approach. GAO reports receipt for clearance of a pair of Federal Trade Commission questionnaires designed to gather information from the auto leasing business (page 76798). The first, which the FTC says will take about two hours to complete, will go to 100 leasing compainies. The second will go to only 20 of those, but will require about 40 hours to fill out. The aim of the study is to gather information for the purpose of correcting apparent violations of the Consumer Leasing Act in the terminiation of car rental leases.
Is this a good way for the FTC to gather such information? That's not something GAO will deal with.
Twenty pages later in the register (page 76818), OMB lists a revision of a study proposed by the Department of Labor's Employment and Training Administration. It's a major study of households involved in 11 employment opportunity pilot projects testing various ways to see if employable people can be removed from the welfare rolls.
It's a complex, changing questionnaire and research program that will cost an estimated $8.6 million before it's completed, and OMB has been making changes in it for a couple of years. One major section of an earlier questionnaire was eliminated, an OMB official said, because "what they were seeking was interesting and important from an academic point of view, but not necessary or functional to this government program."
Labor has a partner and critic in OMB, which it must convince before its study goes out. In GAO, the FTC has only a nitpicker and a frustrated one at that.