The President's website to promote health care reform, www.healthreform.gov, collects Personally Identifiable Information (PII) without explaining why or what it will be used for, in violation of the Paperwork Reduction Act (PRA).
In two Freedom of Information Act (FOIA) requests, the government states that it has no records of anyone even discussing Information Collection Requests for any part of www.healthreform.gov as required by the Paperwork Reduction Act. Both the Department of Health and Human Services (HHS) (PDF), who manages the website, as well as the Office of Management and Budget (OMB) (PDF), who administers the PRA, have no records for anything involving www.healthreform.gov.
Under the PRA, collection of "general comments" is allowed without approval, as well as information "necessary for self-identification" such as name and email or mailing address. Anything other than that requires an Information Collection Request which is published in the Federal Register, then OMB will issue a control number for the form, which indicates it was properly generated and approved. The forms at www.healthreform.gov have no OMB control numbers.
Normally FOIA requests that result in no records provide a very simple response that says just that. But the response from HHS goes a step further. HHS claims, "as only general comments were to be received, no Paperwork Reduction Act documentation was created because clearance was not required." This is partially true, but it does not address the "support" form at all which ONLY collects PII such as name, address, email, and even phone number. Thats all, no field for "general comments" or anything else, unless your comment is "I support health reform this year."
Since this request was filed, the "support" form was removed from the website, the original page can still be found as part of my FOIA package (PDF). As to why this page was removed, I'll leave that to speculation.
In two Freedom of Information Act (FOIA) requests, the government states that it has no records of anyone even discussing Information Collection Requests for any part of www.healthreform.gov as required by the Paperwork Reduction Act. Both the Department of Health and Human Services (HHS) (PDF), who manages the website, as well as the Office of Management and Budget (OMB) (PDF), who administers the PRA, have no records for anything involving www.healthreform.gov.
Under the PRA, collection of "general comments" is allowed without approval, as well as information "necessary for self-identification" such as name and email or mailing address. Anything other than that requires an Information Collection Request which is published in the Federal Register, then OMB will issue a control number for the form, which indicates it was properly generated and approved. The forms at www.healthreform.gov have no OMB control numbers.
Normally FOIA requests that result in no records provide a very simple response that says just that. But the response from HHS goes a step further. HHS claims, "as only general comments were to be received, no Paperwork Reduction Act documentation was created because clearance was not required." This is partially true, but it does not address the "support" form at all which ONLY collects PII such as name, address, email, and even phone number. Thats all, no field for "general comments" or anything else, unless your comment is "I support health reform this year."
Since this request was filed, the "support" form was removed from the website, the original page can still be found as part of my FOIA package (PDF). As to why this page was removed, I'll leave that to speculation.
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