From: American Action Forum

A deeper examination of the supporting documentation behind such an estimate yields even more questions than answers. First, on the input side, there does not appear to be any insight gleaned from the public on the matter as no comments were filed on the entry during its approval stage. Second, the official reason given for the change in this ICR entry neglects to address the cost question at all, merely stating: “The change in burden is due to a change in the number of respondents from 14,185 in May 2014 to 14,398 in October 2014.” Considering the version of the ICR immediately prior to it had a cost estimate of zero, there seems to be nearly 42 billion reasons for greater clarity. Finally, looking to the “supporting statement” that lays out the agency’s calculations, one finds an estimate of only $113.6 million in costs – roughly 0.3 percent of the more public-facing estimate. The commensurate statement for this more recent edition sees only a $30 million increase in that figure. Simply put, there appears to have been no rhyme or reason for including $41.9 billion in projected costs. Assuming this was simply an error in perhaps data entry, it is still a sizable one.

Unfortunately, as egregious as this error was and as opaque as the process seems, this is hardly the first time it has been an issue. In 2013, AAF found an erroneous hour estimate that amounted to 5.2 million years of paperwork. We have also previously examined the discrepancy – often quite large – between the “official” estimate and that provided in the supporting documentation. The Government Accountability Office (GAO) has also recently found numerous examples of dissonance between these estimates. GAO includes 11 recommendations to various agencies to institute better vetting processes in this area.

Read Complete Article