How to estimate burden

OMB has consistently held that measuring burden is “often difficult and imprecise in the absolute, but reliable and consistent measures of change are possible.” These guidelines and resources are a good starting point for agencies to make the best estimates of burden for their collections.

Time (burden hours)

Estimates of burden hours need to include:

1. The number of respondents.
2. The frequency of response.
3. The total number of burden hours per year.

Base your burden hour estimates on consultation with a representative sample of potential respondents; do not make a special survey to make an estimate unless directed.

Burden hours may vary widely due to differences in activity, size, or complexity. If they do, include a frequency distribution of expected burden along with the factors that explain why.

To value and account for the full array of personnel required to plan, develop, prepare, and fulfill an information collection, burden hour estimates fall into four categories of labor:

1. Clerical and other unskilled workers
2. Skilled-labor, craft-labor, and other technical workers
3. Professionals and managers
4. Executives

This includes time spent by all employees, partners, and associates of the respondent. All wages need to be fully-loaded, meaning they reflect the full cost of labor, including benefits. The Bureau of Labor Statistics’ wage data is a good resource to start with.

Financial costs and all other aspects of burden

Using market prices for time and effort, report burden costs that will be carried directly or indirectly by subordinates, associates, agents, or contractors for the respondent.

If you expect respondents to satisfy some part of a collection through outside consultants, contractors, legal and financial advisors, report the estimate for these services as a lump sum.

These types of burden need to be estimated in two separate categories:

• Non-recurring or capital cost: one-time investments to fulfill a collection request
• Recurring or annualized cost: ongoing costs, such as operating or maintaining a capital investment

Burden calculation

When submitting burden estimate to OIRA the agency should be prepared to include:

1. Estimated burden hours per respondent;
2. Estimated aggregate burden hours;
3. Estimated capital and other non-labor costs per respondent; and
4. Estimated aggregate capital and non-labor costs.