Shaping Smarter Regulations

Information Collection - Voluntary Survey Burdens

One of the questions posed as part of the Shaping Smarter Regulations campaign is concerned with information collection. While BLS collections are not mandatory, the Agency is required to include the estimated paperwork burdens of its various programs within the overall DOL paperwork budget. Unfortunately, the calculations presented in the BLS' ICR filings with OMB/OIRA do not address burden distribution. For example, many larger entities would be expected to recur in a PPS sample scheme, and this possibility, as well as the associated potential corrosive effects on response rates never receives consideration or scrutiny. There appears, as well, to be no consideration of cross-program burdens, such as an entity being selected for response to more than one BLS survey during overlapping time frames. It would seem some study of these burden distribution issues would be warranted to ensure overall efficiency of BLS resources is maintained and burden is optimally - and resonably - allocated among the reporting public.



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Idea No. 2