The Information Collection Budget is required by the Paperwork Reduction Act

The White House Office of Management and Budget has this year issued catch-up editions of Information Collection Budget of the United States Government, a task in keeping with longstanding belated and reluctant bipartisan fufillment of compliance with the 1980 Paperwork Reduction Act and other regulatory oversight laws.

That compliance in part entails “minimiz[ing] the paperwork burden for individuals; small businesses; educational and nonprofit institutions; Federal contractors” and others.

Since 1999, the ICB has been published online. Usually, the calendar year boldly appearing on the cover signified a survey of the just-passed fiscal year.

That “clockwork” changed around 2016 such that by December 2020, a tardy 2018 ICB appeared, covering fiscal-year 2017.

This year, 2023, has brought a flurry of five laggard ICBs in two batches.

A composite Information Collection budget appeared in May, covering fiscal years 2018-2021 with those same corresponding dates printed on the cover.

But that still didn’t catch things up. That was accomplished with a July flourish, whereby the bland and traditional white-paper style ICB format was ditched for a glossier-looking report called Tackling the Time Tax: How the Federal Government Is Reducing Burdens to Accessing Critical Benefits and Services.

The traditional paperwork-hours grid we’ve seen for years does get presented to the public. But in the Biden administration it gets relegated to one of three separate appendices (”Appendix B: Paperwork Burden Accounting”).

The subtitle speaks volumes here. Not only are there no apologies for years of excructiatingly late reports, there is little sympathetic reporting on the varieties of red tape affecting business that largely spawned the Paperwork Reduction Act in the first place.

That observation isn’t to subtract from the fact that the PRA did address government-wide paperwork burdens. But the new emphasis for OMB is almost purely on lessening “varieties of administrative burdens that create barriers for individuals accessing public programs and services.” This reprsents a substantial shift in tone to which Congress needs to pay attention.

OMB “efforts to support innovation in small firms” did rate a mention, but the ICB is plainly no longer deployed primariliy as a “streamlining government” report from the standpoint of those having to obey its rules or else. Rather, it is being transformed to ease access to growing federal largesse and a consequently more powerful Washington. Indeed, OMB’s Tackling the Time Tax leads with the lament that, “every year more than $140 billion in government benefts that Congress has authorized goes unclaimed.”

Tackling the Time Tax showcases commitments to the likes of automatic eligibilities for questionable programs and partnering with “community-based organizations.” The writing had been on the wall in obsure proclamations and guidance like OMB’s April 2022 Memorandum M-22-10, “Improving Access to Public Benefits Programs Through the Paperwork Reduction Act,” and December 2022’s “Strategies for Reducing Administrative Burden in Public Benefit and Service Programs.”

These moves to expand and normalize dependency on federal programs (as opposed to, for example, emphasizing paperwork reductions to be enjoyed from restoring federal programs to the state authorities to which they properly belong) are in keeping with OMB’s simultaneous problematic rewrite of its Circular A-4 guidance on regulatory analysis. That project is replacing strict and ruthless cost-benefit assessments of agency regulations with the pursuit of net-benefits by the progressive left, providing unavoidable evidence that OMB no longer plays the appropriate watchdog role and congressional intervention is necessary.

Any beneficial hourly paperwork reductions we see now are less likely to come from ending or streamling programs, than from easing claims to an expanding inventory of government programs.

10.34 Billion Hours of Federal Paperwork in FY 2022

As the latest fiscal year 2022 edition of the federal Information Collection Budget of the United States Government portrays the state of play, 10.34 billion hours were required to complete mandatory paperwork from 40 departments, agencies and commissions. A table below depicts these.

The vast bulk, here 6.60 billion hours, is attributable to the Department of the Treasury, with the runner-up Department of Health and Human Services clocking in 1.65 billion hours. Past years’ cross-governmental paperwork-hour tallies appear below by fiscal year.

• 2015: 9.865 billion hours
• 2016: 11.442
• 2017: 11.529
• 2018: 11.357
• 2019: 10.998
• 2020: 11.618
• 2021: 9.974

One might compare 2022’s just-revealed 10.34 billion hours to the overall 7.2 billion hours clocked back in fiscal year 2000. Biden’s new report indicates an increase over fiscal year 2021’s 9.974 billion hours, despite renewed ease-of-access to larger government programs just discussed.

There’s nothing particularly counterintuitive about that, since more paper follows logically from more programs even if the ground-level paperwork is made “easier,” and there are certainly more programs given recent legislation like the Inflation and Infrastructure laws. Since the ICB appears to be resurrected to stay, albeit with is suspect change in thrust, we might get a clearer idea of trends when fiscal year 2023 arrives upon us in less than a week.

One might note that a small Trump slowdown in paperwork materialized between 2017 and 2019, perhaps given that administration’s range of regulatory liberalization moves such as the elimination of two rules for every significant rule added. There was a jump in 2020, but fiscal year 2021’s “low” count of 9.974 began during the Trump term.

Lifetime Equivalents

A billion here, a billion there, as they say. How might one visualize 10.34 billion hours of federal paperwork?

Here’s one way. An 80-year human lifespan amounts to 29,200 days, which translates into 700,800 hours (life is short; here’s an animation of this).

Looking at things this way, the 2022 ICB’s 10.34 billion hours of paperwork translates into the equivalent of 14,883 human lifetimes. On the bright side, one can see from the bullets above that this is an improvement over some priors years’ amounts of “dead tape.”

Not everyone lives 80 years, of course (the average is 76.4 years and unfortunately declining), and to that extent paperwork costs more “lives.” Surely, not many wish to spend more of our finite 700,000 hours on federal paperwork than absolutely necessary; yet one can’t escape feeling the bureaucracy sees much of this as a bargain.

For periodic real-time assessments for those so inclined, in addition to the formal Information Collection Budget, the OMB maintains an online landing page for “Government-Wide Totals for Active Information Collections.” As of today it stands at 10.5 billion “total annual hours” (similar to the Time Tax level) at a proclaimed $163.2 billion in “total annual cost.”

This appears to be OMB translating paper-shuffling and compliance into $15.50 per hour.

Historically the OMB has tended not to provide annual dollar-cost estimates for paperwork. But even back in the 2011 ICB it was noted that “if each hour [then “only” 8.783 billion] is valued at $20, the monetary equivalent would be $176 billion.” By comparison, the corporate income tax intake recently was $268 billion, so paperwork is a big dollar cost.

Back at the turn of the century (2001) OMB had pegged “Process/Paperwork” at up to $190 billion annually (over $250 billion in today’s dollars), and none can claim that the federal government is smaller today. Back then, paperwork was regarded as making up some 20 percent of overall regulatory costs, an observation having interesting implications for those who ponder them.

In any event, good luck finding a $15.50-per-hour compliance officers, a notion that appears to downplay the value of the public’s time even for those disinclined toward minimum-wage-hike enthusiasms.

A decade ago, this roundup of paperwork costs remarked upon the salaries of banking and environmental compliance for comparison’s sake. Today, the Bureau of Labor Statistics notes the following mean May 2022 hourly wages (the median is lower) for basic categories that one might regard as relevant in keeping up with complex federal paperwork. All exceed the $15.50 seemingly employed by OMB

• Human Resources Managers: $70.07.
• Accountants and auditors: $41.70.
• Compliance officers: $37.01

Assuming $40 an hour would mean over $413 billion in mere paper-shuffling costs at the new ICB’s 10.34 billion hours level. None of this is counting actual compliance with underlying rules and regulations; just the paper.

Health, finance and labor-related paperwork are likely to be driven higher by recent legislation like that mentioned. Just as unnecessary regulatory programs require scrutiny and rollback (as, for example, Sen. Rick Scott’s (R-Florida) “Unnecessary Agency Regulations Reduction Act” would require), critical analysis for federal paperwork is urgent. That task cannot be conducted by an OMB bent instead on increasing access to the larger federal government being ushered in by “Bidenomics” and the latter’s disdain for federalism and state, local and individual decision-making.

The very source of benefits, well-being and prosperity for which the federal government attempts to take credit in narratives like Tackling the Time Trap is the private productive sector, which in the final analysis, pays for it all, no matter what.

Policymakers should awaken to the many transformations at OMB, and this particular instance, restore the spirit and intent of the original Paperwork Reduction Act.