In Parts 1 through 4 of The 2014 Federal Paperwork and Red Tape Roundup we compiled a basic picture of federal paperwork costs with respect to independent agencies and federal tax collection, as well as took a look at taxation’s deadweight costs.
Now we will briefly visit the executive departments, agencies and commissions to see what might be appraised about their paperwork.
For the most part, executive agency paperwork costs will have already been captured, at least as far as officialdom is concerned, in regulatory impact analyses and in OMB reporting on these agencies, whether the legacy estimates or the more detailed annual tallies. These all appear, as covered many times, in the Office of Management and Budget’s annual Report to Congress on the Benefits and Costs of Federal Regulations.
During the first years of the 2000s, OMB noted about $5 billion annually as the average amount of regulatory costs imposed annually. That has changed recently; last year’s executive agency costs acknowledged by OMB were only $3.5 billion, but the year before that they were $25 billion. Since fiscal year 2009 the lowest amount otherwise has been $12 billion.
It may or may not be true that paperwork costs are contained within most OMB estimates; probably not, as we’ll seen, and given the plethora of non-major rules that nonetheless generate paperwork. But I avoid possible double counting even when it understates cost. There are many other reasons regulatory costs are higher than what OMB reports on each year besides.
What I will do here however, is specify an excess of official paperwork cost estimates (to which I apply a $35 hourly rate) when paperwork hours-times-wage registers as greater than the costs of regulations about which OMB has otherwise informed us for a particular executive department or agency.
For reference, the total amount of annual executive agency paperwork costs, employing a $35/hour figure and using the latest OMB Information Collection Budget (precisely as above with respect to independent agency paperwork), is $313 billion. Removing the 800 pound gorilla of Treasury Department costs of $245 billion (largely taxation, treated separately earlier), we are left with $67 billion in executive agency paperwork costs. See the chart Executive Agency Paperwork Burdens for the detail.
These paperwork tallies are very useful to know. However, when compiling my separate tally of overall regulatory costs, I only “add” those amounts that exceed what OMB already discloses for a given executive department or agency in its annual Report to Congress. In the 2014 edition of Tip of the Costberg, for example, there were only four agencies for which such conditions held—yet the amount exceeding what OMB reported in its Report to Congress was $11.23 billion for those four.
Note that this “excess” amount is itself the equivalent of the magnitudes that OMB has been reporting over the past decade or so—effectively doubling actual executive agency costs that should be disclosed.
Later I’ll take a look at where paperwork estimates exceed what OMB reports for this newest data available and see where things stand.
Earlier Editions of A 2014 Paperwork and Red Tape Roundup