1. OMB should enable departments to conduct customer surveys. For voluntary customer surveys, the Office of Management and Budget will delegate its survey approval authority under the Paperwork Reduction Act to departments that are able to comply with the Act. A customer is defined to be a member of the public to whom the federal government supplies services or financial assistance directly and individually. A voluntary request would be clearly labeled as such when sent to the public and would exclude any requests where the information is required in order to maintain or obtain eligibility for a program or benefit. It is important that the requests be perceived as voluntary by recipients in order that the burden of supplying the information be a matter of personal choice. At this point, Action 1 is not intended to include surveys by regulators of regulated entities. The task of managing requests for information from these agencies to regulated entities so that the requests would be perceived as truly voluntary is a difficult one. Nonetheless, NPR believes that the regulatory agencies would benefit significantly from more public input. The following recommendation on focus groups addresses this need in part. However, NPR believes that more research is warranted to define conditions under which voluntary opinion surveys can be done by regulators. Departments taking responsibility for ICR approval in connection with Action 1 would be accepting the obligation to comply with the Paperwork Reduction Act in its entirety for surveys they approve; a delegation by the Director of OMB would not imply relief from any requirements of the Act itself. OIRA would retain the right to spot check ICRs. Under the Act, if OMB found Departments unable to meet their responsibilities, the Director of OMB could revoke a delegation.
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