Commission on Federal Paperwork

Commission on Federal Paperwork
Name	Commission on Federal Paperwork
Formed	1975
Dissolved	1977
Jurisdiction	United States federal agencies
Headquarters	Washington, D.C.
Chief1 name	John J. Gibbons
Chief1 position	Chair

Contents

Commission on Federal Paperwork

The Commission on Federal Paperwork was a temporary advisory body created by Presidential directive to review paperwork burdens imposed by federal administrative entities such as U.S. Congress, Executive Office of the President, Office of Management and Budget, General Services Administration, and agencies including the Department of Health, Education, and Welfare and the Department of Agriculture. It reported during the administrations of Gerald Ford and Jimmy Carter and engaged with stakeholders including the American Bar Association, American Association of Retired Persons, U.S. Chamber of Commerce, National Association of Manufacturers, and the American Federation of Labor and Congress of Industrial Organizations. Its work intersected with statutory frameworks like the Paperwork Reduction Act and with oversight bodies such as the Congressional Budget Office and the Government Accountability Office.

History and Establishment

The Commission was established amid concerns raised by hearings in the United States Senate and the United States House of Representatives about the administrative costs of compliance with regulatory forms, testimonies before committees including the Senate Committee on Governmental Affairs and the House Committee on Government Operations, and advocacy from groups like the U.S. Small Business Administration, National Federation of Independent Business, and National Consumers League. Presidential directives referenced precedents such as the Hoover Commission and the Kennedy administration's efforts at administrative simplification, while legal context involved litigation in courts including the United States Court of Appeals for the District of Columbia Circuit and consultation with law schools like Harvard Law School and Yale Law School.

Mandated to evaluate reporting, recordkeeping, and information collection burdens imposed by agencies such as the Securities and Exchange Commission, Internal Revenue Service, Environmental Protection Agency, Federal Communications Commission, and Food and Drug Administration, the Commission aimed to recommend reductions in duplication and complexity. It sought to align agency practices with statutory requirements such as the Paperwork Reduction Act of 1980's antecedent principles, to coordinate with the Office of Information and Regulatory Affairs and to propose mechanisms akin to those used by the National Archives and Records Administration and the Library of Congress for information management. The Commission engaged experts from institutions including Brookings Institution, American Enterprise Institute, RAND Corporation, and universities like Stanford University and University of Chicago.

The panel comprised judges, scholars, and public figures drawn from sectors represented by institutions such as the American Civil Liberties Union, National Academy of Public Administration, Urban Institute, and various federal departments including the Department of Defense and the Department of Transportation. Leadership included figures with ties to the United States Court of Appeals for the Third Circuit and law firms with experience before the Supreme Court of the United States. The Commission established working groups mirroring task forces previously used by bodies like the Commission on Civil Rights and coordinating with advisory entities such as the Presidential Advisory Council on Executive Organization.

Major publications recommended streamlined forms, consolidation of duplicative data calls among agencies such as the Bureau of Labor Statistics and the Census Bureau, adoption of standardized identifiers similar to practices in the Social Security Administration, and pilot programs comparable to initiatives at the National Science Foundation and National Institutes of Health. The Commission's reports cited methodologies from the Federal Trade Commission, Federal Reserve Board, and academic studies from Columbia University, Princeton University, and Massachusetts Institute of Technology to justify cost-benefit analyses and regulatory impact assessments.

Some recommendations influenced subsequent rulemaking by agencies including the Environmental Protection Agency and the Securities and Exchange Commission, informed budgetary oversight by the Office of Management and Budget and the Congressional Research Service, and contributed to drafting legislation considered by the United States Senate Committee on the Judiciary and the House Committee on Oversight and Government Reform. The Commission's emphasis on information inventories paralleled efforts at the National Telecommunications and Information Administration and the Federal Emergency Management Agency to reduce redundant reporting, and its concepts were later reflected in administrative reforms credited to officials from the Carter administration and later Republican and Democratic administrations.

Critics from advocacy groups such as the Public Citizen and scholars at the Center for Auto Safety argued that recommendations risked weakening enforcement tools used by agencies including the Occupational Safety and Health Administration and the Consumer Product Safety Commission. Congressional critics on panels like the House Committee on Government Operations and commentators in outlets associated with The New York Times, The Washington Post, and The Wall Street Journal debated tradeoffs between paperwork reduction and public accountability, echoing concerns raised by think tanks such as the Heritage Foundation and Center for American Progress.

The Commission's work informed later statutes and administrative mechanisms, anticipating components of the Paperwork Reduction Act of 1980, influencing practices at the Office of Information and Regulatory Affairs and shaping academic curricula at institutions like Georgetown University Law Center and American University. Its legacy is discussed in historical analyses by scholars at Yale University, University of Michigan, and Duke University and has been cited in policy reviews by organizations including the Brookings Institution and the Mercatus Center.