Statistics and the Paperwork Reduction Act: An FTC Case Study

Abstract

The Paperwork Reduction Act (PRA) requires that federal agencies obtain OMB approval before requesting most types of information from the public. Among other requirements, the PRA requires that agencies desiring to conduct surveys provide OMB with a variety of information about the study design to ensure that results will be high quality, objective, and methodologically consistent across agencies.Despite the large number of surveys conducted by federal agencies each year, most of these are little more than pilot studies on which the sponsoring agency cannot base regulatory, legislative, or policy decisions. A good example of this is the ongoing study by the Federal Trade Commission (FTC) of patent assertion entities (PAE). The FTC study may well contribute new data related to PAE activity, but, like other exploratory studies, there should be important limits on the use of the FTC’s findings and on the conclusions that may be drawn.