Comments Due December 28, 2009

Send comments to oira_submission@omb.eop.gov

Analysis for SBCRR Subscribers

Sample Comment Letter:  Click here for Word document or here for Adobe Acrobat document.

Factoids:

 According to the NFIB Small Business Poll:

• The cost of paperwork for small business averages roughly $50 per hour.
• Tax-related = $72.24 per hour
• Financial = $62.16 per hour
• Licenses and permits = $47.96 per hour
• Govt. information requests = $43.50 per hour
• Customer/client information = $42.95 per hour
• Personnel = $40.75 per hour
• Purchases = $39.27 per hour
• Facilities/maintenance = $36.20 per hour
• Owners are much more likely to handle paperwork and record-keeping themselves, as opposed to the practice in larger firms that task the duties to employees.

According to the Office of Advocacy study on regulatory costs for small firms:

• The cost of tax compliance is 67 percent higher in small firms than the cost of large firms.
• Small businesses with fewer than 20 employees bear the largest burden of federal regulations.  The annual regulatory cost of $7,647 per employee is 45 percent higher than the cost per employee at firms with 500 or more employees.

Suggestions for Recommendations in Your Comments to OMB:

• IRS paperwork and record-keeping represents a significant portion of the burden imposed on small businesses.  There should be a federal mandate for the IRS to reduce their paperwork burden.
• A business owner should not have to submit the same information to the federal government more than once.  If it is not practicable for agencies to share information in order to relieve small businesses of filing multiple forms with the same information, than each agency should only receive information one time and be able to share the data amongst offices.
• Voluntary surveys should be subjected to the same scrutiny as mandatory information collection requirements.  When small businesses receive official requests from the federal government, they are not necessarily in a position to determine whether one form is less important than another.  Designating "voluntary surveys" as less onerous on small business is a not a true reflection of how small businesses react to paperwork and recordkeeping mandates.
• The burden associated with paperwork and recordkeeping are largely ignored by individual government offices that seek to impose new information collection requests, new reporting requirements, and additional lines of information in existing reporting requirements.  To cure the lack of sensitivity and promote transparency, uniform guidelines should require agencies to publish a "Paperwork Impact Analysis" with any proposed rule.  Such analysis, that would receive the benefit of public comment, should include: 
  1. the quantity of paperwork and recordkeeping that would reasonably be expected from the proposal; and
  2. the amount of time dedicated to paperwork and recordkeeping associated with regulatory compliance with the proposal; and
  3. the cost of compliance to meet the paperwork burden that would reasonably be expected from the proposal; and
  4. a consideration of alternatives that meet the underlying objectives of the proposal and would lessen the paperwork and recordkeeping burden on small entities.

Links to Important Documents:

• News article on OMB's Solicitation for Comments on the Paperwork Reduction Act:  Link here
• Federal Register Notice, Request for Comments on Improving the Paperwork Reduction Act:  Link here
• NFIB National Small Business Poll, Paperwork and Record-Keeping:  Link here
• Paperwork Reduction Act:  Link here
• SBA's Office of Advocacy, Research Report on the Impact of Regulatory Costs on Small Firms:  Link here

Analysis for SBCRR Subscribers

• SBCRR Sample Comment letter:  Click here for Word document or here for Adobe Acrobat document.