Overview
Title
Submission for OMB Review; Comment Request
Agencies
ELI5 AI
The Department of Agriculture wants to know if a form people use to say they've been treated unfairly is really needed and if filling it out takes too much time. They are asking people to share their thoughts about this by March 29, 2021.
Summary AI
The Department of Agriculture has submitted a request to the Office of Management and Budget (OMB) for review of an information collection requirement under the Paperwork Reduction Act of 1995. They are asking for public comments by March 29, 2021, on whether the information is necessary and if the burden of collecting it can be minimized. This requirement involves the USDA Program Discrimination Complaint Form, used by individuals who believe they have faced discrimination in a USDA program. The collected information helps the USDA Office of the Assistant Secretary for Civil Rights address such complaints, and respondents are typically USDA customers who report annually.
Keywords AI
Sources
AnalysisAI
The document in question is a notice from the Department of Agriculture, seeking public comments on a proposed information collection as part of their adherence to the Paperwork Reduction Act of 1995. The primary focus of this collection is the USDA Program Discrimination Complaint Form, which aims to gather data from individuals who believe they have encountered discrimination within a USDA program.
General Summary
This notice formally communicates that the Department of Agriculture plans to collect information via a complaint form dedicated to addressing discrimination claims within USDA programs. By submitting this requirement to the Office of Management and Budget (OMB), the USDA is looking to ensure the process is efficient and effective while seeking public commentary on its necessity and potential improvements. Such feedback is critical as it helps refine practices, ensuring that they truly serve their intended purpose and do so with as little burden on respondents as possible.
Significant Issues or Concerns
One major concern with the document is the lack of clarity regarding the ultimate objectives of the information collection. It merely mentions data collection without specifying how this data will impact or improve USDA programs. Furthermore, the formal language employed throughout may not be easily understandable to the average reader, potentially obscuring the document's intentions and limiting effective public engagement.
Another point of potential confusion lies in the representation of the "Total Burden Hours," equating it directly to the number of respondents. This could imply that each person spends exactly one hour on this task annually, which may oversimplify the situation and not accurately reflect the true diversity of respondent experiences.
Additionally, the document does not give any indication of possible consequences or next steps for respondents who file complaints. Such information would be crucial for individuals considering filing a complaint and seeking resolution.
Impact on the Public
Broadly speaking, this document calls for public involvement in assessing the necessity and efficiency of a bureaucratic process — a task that serves the greater good by promoting transparency and seeking to minimize the time and resources individuals must expend. Members of the general public, especially those involved in USDA programs, may be directly affected as their contributions could shape future policies and practices.
Impact on Specific Stakeholders
USDA customers and individuals who might find themselves filing a discrimination complaint are most directly affected by this document. For individuals who believe they have been wronged, the form provides a channel through which they can seek justice or remediation within USDA programs. However, the document's lack of detail regarding the post-submission process, and potential burdens imposed by filing, may serve as barriers, discouraging participation.
Potentially positive impacts include the prospect of a more streamlined and user-friendly complaint process based on public feedback, which could lead to quicker resolutions and less dissatisfaction among complainants. Still, more explicit information about technological measures to minimize respondent burdens could reassure stakeholders that their input is genuinely valued and will be managed efficiently.
Overall, while the initiative has the potential to improve USDA's handling of discrimination complaints, clarity and accessibility remain critical elements requiring further attention in order to facilitate meaningful public engagement and ultimately, program improvement.
Issues
• The document does not provide an explicit action or purpose for the information collection requirement, making it difficult to understand the ultimate goal or impact of the data collection.
• The complexity and formality of the language used, such as 'validity of the methodology and assumptions used,' may be challenging for a general audience to understand.
• The document requests comments regarding the necessity and utility of the information collection but does not provide specific examples or contexts in which the collected data will be used, potentially leading to ambiguity.
• The description of the 'Total Burden Hours' as equal to 'Number of Respondents' suggests that each respondent spends exactly 1 hour annually, which could oversimplify or misrepresent the variety of possible respondent experiences.
• There is no information provided about the potential consequences for respondents who believe they have been discriminated against and wish to file a complaint, which could be an important consideration for individuals weighing whether to participate.
• The document does not mention any specific measures or technologies that will be used to minimize the burden on respondents, especially given modern expectations for electronic or automated processes.