GAO Urges OMB to Modernize Burden Reduction Guidance for Federal Benefit Programs
In its April 2025 report titled “Administrative Burden: OMB Should Update Instructions to Help Agency Assessment Efforts” (GAO-25-107239), the U.S. Government Accountability Office (GAO) calls for the Office of Management and Budget (OMB) to revise its guidance to better support federal agencies in reducing administrative burdens associated with benefit programs. Despite longstanding efforts to improve access to federal assistance, eligible Americans continue to forgo more than $140 billion annually in unclaimed benefits, in part due to the excessive “time tax” and complexities involved in navigating federal aid systems. GAO’s investigation reveals that although the OMB issued Memorandum M-22-10 in 2022 to encourage burden reduction, agencies often fall short in fully implementing its recommendations.
GAO reviewed 51 major information collection requests (ICRs) submitted between April 2022 and April 2024 by nine agencies under the Chief Financial Officers Act. These ICRs were selected based on their significant impact—each estimated to impose at least 75,000 burden hours on the public. The findings show that agencies predominantly reported compliance costs—such as the time to fill out forms—but rarely accounted for other key burden elements like learning and psychological costs. Only two ICRs addressed learning burdens and just ten included psychological impacts, even though these are crucial to understanding the real barriers individuals face.
OMB guidance also encourages agencies to consider how burdens may disproportionately affect vulnerable populations, such as individuals with limited English proficiency or those in rural areas. However, only one ICR explicitly addressed how certain groups might be adversely impacted. Moreover, just 17 of the 51 ICRs demonstrated external consultation beyond the mandatory Federal Register notice-and-comment process, missing an opportunity to enhance their burden assessments with real user feedback.
One of the primary reasons for this incomplete implementation is the disconnect between OMB’s guidance and the formal instructions agencies must follow when submitting ICRs. GAO found that these instructions do not explicitly require agencies to report on learning or psychological costs, nor to identify affected subgroups or detail the outcomes of public consultations. As a result, agencies focus primarily on securing OMB approval rather than engaging in a thorough burden analysis. Officials from the Departments of Agriculture, Veterans Affairs, and the Social Security Administration admitted this gap leads to inconsistent application of burden reduction strategies, despite having internal tools and customer experience offices dedicated to improving service delivery.
GAO praises the use of the generic clearance process, which allows agencies to expedite customer feedback collection and reduce burdens more responsively. Agencies like SSA, VA, and USDA have employed this process effectively to study and improve digital service delivery. Nonetheless, GAO concludes that systemic change will only come when OMB aligns its submission instructions with the full scope of its burden reduction guidance. Without such alignment, federal agencies will continue to miss critical opportunities to streamline access to public benefits and reduce economic insecurity for millions of Americans.
This report was authored by Yvonne D. Jones, Director of Strategic Issues at the GAO. The full text is available at https://www.gao.gov/products/GAO-25-107239. Disclaimer: This blog post summarizes a GAO report and is not guaranteed to be accurate. It is not intended to provide legal advice.