Noel Dickover replied to the topic What Do You Think about OMB Soc Media and PRA Guidance? in the forum Forum Discussions 9 years, 7 months ago
Hi Chris, just for context, I spent more a couple of months studying the PRA (based on need, and more specifically, looking for loopholes to get around it) and came out with a number of recommendations to OMB that I submitted in a number of ways to them. You can see my comments here if interested:
But in short, no, they cannot ignore the PRA. But they can change the process by which its implemented. This is what I was hoping for. When we get caught up by truly silly propositions – such as the idea that making a common usability survey on a website takes six months and lots of paperwork to implement, there is clearly something fundamentally wrong. Partially, the problem certainly exists in statute, but more specifically it exists in OMB’s process for implementing the language.
If there was one line I’d change in Statute, it would be the reference to voluntary information collections, which is at Title 44, Chapter 35, Section 3506 (c)(1)(B)(iii)(IV), which in talking about the person receiving the collection of information states that, “whether responses to the collection of information are voluntary, required to obtain a benefit, or mandatory…”. If this were removed, most of the easier problems would go away. But this definitely requires an act of Congress.
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