The 2014 Federal Paperwork and Red Tape Roundup, Part 4: Independent Agency Paperwork Costs

A recent post here at OpenMarket noted the Annual Costs of Independent Agency Rulemakings and presented an annual cost placeholder of $6.14 billion annually stemming from compliance with rules issued since 2009. This vastly understates the overall impact of independent agencies given the number of agencies, the number of rules and simple lack of accountability.

Independent agencies are not subject to even the minimal cost disclosure that a few executive/cabinet agencies present in the Office of Management and Budget’s Annual Report to Congress on the Benefits and Costs of Federal Regulation.  

But we can supplement independent agencies costs with what we know of their paperwork burdens, as presented in the (sometimes) annual federal Information Collection Budget.

These independent agency paperwork burdens do not get accounted for in OMB’s annual benefits and costs roundup of executive agency rules, and include bureaus like the Securities and Exchange Commission with its 234 million reported hours of paperwork (Table 1, p. 9), and the Federal Communications Commission’s 82 million (Table 1, p. 9). Some of these hours, like contracting regulations and Social Security amount to costs of doing business with the government and administration of economic benefits like Social Security payments.

Be that as it may, as the link at Independent Agency Paperwork Burdens and the chart nearby shows, these hours add up to 610 million for agencies not headed by a cabinet secretary. At $35/hour (note I’m not using the $47 invoked in Part 3 with respect to tax/Treasury compliance), add an additional $21.3 billion in annual costs for independent agencies (beyond the $6.14 billion in annual compliance costs noted above).

So, leaving aside paperwork presumably accounted for in executive agency Regulatory Impact Analyses (more will be said about executive agency paperwork in the next installment of this Roundup series), a total cost placeholder for burdens associated primarily with taxation of $329 billion and independent agency paperwork of $21.3 billion amounts to $350 billion. This represents the baseline current, to-date cost of tax compliance and independent agency paperwork to which I will add future costs, while reserving the right to incorporate future information that convinces me to increase or decrease the base.

This figure is reflected in “Treasury/taxation paperwork costs” at the top of Principia Bureaucratica: The Total Annual Cost of Federal Regulation as well as dispersed among the respective independent agencies in that table. If better data appears on the regulatory paperwork costs of financial services, health care, consumer safety rules, I might adjust what I have now, but my figure is lower than other governmental ones that could have been employed here. 

Next time – Part 5: Executive Agency Paperwork Costs

Earlier Editions of A 2014 Paperwork and Red Tape Roundup

• Part 1: Big Bucks for Pencil Pushers (At CEI’s OpenMarket)
• Part 2: Billions of Dollars and 13,000 Lifetimes Annually (At CEI’s OpenMarket)
• Part 3: The Costs of Federal Tax Compliance (At Forbes.com)