OMB Delegate Voluntary Survey Approval Authority

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.