Nov 14, 2023Liked by Alexander Hertel-Fernandez, Don Moynihan
This is a good primer of the process. I have been responding to Federal Register notices lately telling them that they were inappropriate notices, and should have been exempted from the Paperwork Reduction Act under known exemptions and/or de minimus changes. I hope the desk officers take these comments to heart.
I don't think it's a remotely appropriate expectation that members of the public spend their own time suggesting random improvements to the USDA school lunch assistance program program. It is explicitly the responsibility of USDA to user test these forms with real users and make improvements well before ever publishing or using the form. This should be the actual role of OIRA in today's world, I believe: holding agencies accountable to reducing data collection and making forms as simple to use as possible, not expecting the public to do free random labor (which is not even allowed under the Anti Deficiency Act) making random suggestions to improve a form that may or may not be correct.
Nov 14, 2023Liked by Alexander Hertel-Fernandez, Don Moynihan
This is great and should be very helpful to people who want to make access and compliance easier. I especially liked the part about being patient; sometimes change takes time.
This is a good primer of the process. I have been responding to Federal Register notices lately telling them that they were inappropriate notices, and should have been exempted from the Paperwork Reduction Act under known exemptions and/or de minimus changes. I hope the desk officers take these comments to heart.
I don't think it's a remotely appropriate expectation that members of the public spend their own time suggesting random improvements to the USDA school lunch assistance program program. It is explicitly the responsibility of USDA to user test these forms with real users and make improvements well before ever publishing or using the form. This should be the actual role of OIRA in today's world, I believe: holding agencies accountable to reducing data collection and making forms as simple to use as possible, not expecting the public to do free random labor (which is not even allowed under the Anti Deficiency Act) making random suggestions to improve a form that may or may not be correct.
This is great and should be very helpful to people who want to make access and compliance easier. I especially liked the part about being patient; sometimes change takes time.