DOGE is missing a trillion dollars a year in regulatory costs – Watts Up With That?

From CFACT

By David Wojick

The infamously glorious Department of Government Efficiency (DOGE) is scouring the federal government and finding many billions of dollars’ worth of stuff to cut. Their total claimed savings to date are $180 billion, with just under $30 billion of that in regulatory costs.

See here.

Looking at their big ticket list, I see they have missed a potentially huge source of regulatory costs. The likely reason is because it is a truly obscure critter, but I helped build it, so here it is.

It is called the Federal Information Collection Budget (ICB). Sounds like nothing, but it is the estimated sum total of all the information-related work that American people do because of federal regulations. Keeping records and doing your taxes, for example. This is not about filling out forms; it is about all information activities required by a federal regulation.

This work is called regulatory “burden,” and it sure is that. It is estimated by every federal agency, for every regulation they have or propose, in two forms — hours and dollars. Few people know the federal government actually tracks in a general way all this free work people are required to do for them.

The tracking is done by OMB’s Office of Information and Regulatory Affairs (OIRA), which I helped set up back in 1980 under the new Paperwork Reduction Act. Each regulatory requirement gets a separate OMB control number, which is printed on every form.

The estimated numbers are huge, but they are also ridiculously low to the point of fraud. First, here are the official estimates, which are certainly big enough for DOGE to take a whack at.

Government-Wide Totals for Active Information Collections

ACTIVE OMB CONTROL NOS.

10,704 – call it 11,000 for a round number

TOTAL ANNUAL RESPONSES

136,143,659,968 – call it 136 billion

TOTAL ANNUAL HOURS

11,529,625,471 – call it 11.5 billion

TOTAL ANNUAL COST

$203,090,046,782 – call it $200 billion

So 11,000 regulatory requirements require 136 billion responses a year, taking 11.5 billion hours and costing 200 billion dollars. Surely some of this is wasting the American people’s valuable time, so DOGE should look into it.

Given a reported annual cost of over $200 billion, DOGE ought to easily match their $30 billion in regulatory cost savings to date. That is just a 15% cut.

But the numbers are really much bigger; in fact, these official numbers are ridiculously small. Taking 11.5 billion hours to do 136 billion responses gives an average response time of 0.085 hours, or just 5 minutes.

In the 11,000 cases, there might be one or two that only take 5 minutes, although I cannot imagine one. We are not talking about simply filling out a form. This is about everything involved in dealing with the form (or record keeping) over time.

The cases I am familiar with typically take hours; some take days. For example, for the business meal’s deduction, you have to make and keep a detailed record of each meal, which over a year can add up to a lot of time.

Let’s say the average response work is just half an hour, or five times the OIRA figure. That already puts the annual cost over a trillion dollars. If the average is an hour, then two trillion dollars. These are enormous numbers, which are not being revealed.

Note too that if the cost is just the hours of work, then the average wage is $17.39 an hour. The national average wage is reportedly $36.24, or roughly double what the agencies are using. If the cost includes capital costs, then the agency wage rate is even smaller.

I do not know how much DOGE looks into cooking the books to hide regulatory costs, but that is clearly what is going on here. The agency burden estimates are preposterously low, hiding the huge burden cost of their regulations.

These fraudulent agency estimates of regulatory burden on the American people are government-wide, so Congress should be looking hard at them.

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