If we have fewer federal workers, we'd better choose what's most important for them to do. A law that keeps us locked into nineties era paperwork should be first on the chopping block.
I think the Truman administration had it half right: have protocols. The other half, allow agencies to test their forms and then it’s up to the (probably with an audit function).
Love these non-edit forms! I would add that I was thwarted several times in my Federal carrier by PRA bureaucracy so I’m way sympathetic to the criticism.
For what it’s worth, the vast majority of forms on private websites don’t go through user research. You just put them up, and you check metrics like what % of people complete this form, and what % of data has an error in it, and if you see problems there you change the form.
I really don’t know what it would take to make government forms operate this way.
It would start with rolling back the PRA, and continue with staffing agencies with people who know to instrument and follow the performance of their sites, and empowering them to make the changes that data indicates.
Thank you for a good post. I'm pretty familiar with all of this have spent a good part of my working life doing regulatory work in the biopharma industry (and a stint working on biotech food and industrial products). I'm of the generation that had to deal with the daily paper Federal Register and would laugh the day that the Government's semi-annual regulatory agenda was published. It usually was two volumes and maybe 400 pages or so. Part of the reason for the dismal state of affairs is what I call "cover your ass" syndrome. If the hapless Federal regulator goes through and checks all the right boxes and moves something up the chain, they can feel safe. I never counted, but suspect n the course of my career I helped in the drafting of about 200 comments to various agency rulemaking efforts.
Maybe a lot of readers here do not remember Congressman John Dingell and his compatriot on the House Energy and Commerce Committee, Henry Waxman. Nobody wanted to be called up, sworn in, and have to testify about something that had gone awry. Dingell always had a group of dogged investigators rummaging through Agency regulatory decision-making.
FDA managed to move away from rulemaking and began drafting and putting out Guidance documents which "reflected the Agency's best thinking" on an issue of importance. Sure, these were not "regulatory" documents as proscribed in the Code of Federal Regulations but .....you needed a good reason not to follow the Guidance. When I was running the regulatory group at PhRMA in the late 1990s through the aughts, we would have regular meetings with various drug review divisions to share collective ideas on scientific issues.
I guess I would fall into the category of an industry sock puppet master of the FDA were I still working today. It is all too sad to see.
I think the Truman administration had it half right: have protocols. The other half, allow agencies to test their forms and then it’s up to the (probably with an audit function).
Love these non-edit forms! I would add that I was thwarted several times in my Federal carrier by PRA bureaucracy so I’m way sympathetic to the criticism.
For what it’s worth, the vast majority of forms on private websites don’t go through user research. You just put them up, and you check metrics like what % of people complete this form, and what % of data has an error in it, and if you see problems there you change the form.
I really don’t know what it would take to make government forms operate this way.
It would start with rolling back the PRA, and continue with staffing agencies with people who know to instrument and follow the performance of their sites, and empowering them to make the changes that data indicates.
Thank you for a good post. I'm pretty familiar with all of this have spent a good part of my working life doing regulatory work in the biopharma industry (and a stint working on biotech food and industrial products). I'm of the generation that had to deal with the daily paper Federal Register and would laugh the day that the Government's semi-annual regulatory agenda was published. It usually was two volumes and maybe 400 pages or so. Part of the reason for the dismal state of affairs is what I call "cover your ass" syndrome. If the hapless Federal regulator goes through and checks all the right boxes and moves something up the chain, they can feel safe. I never counted, but suspect n the course of my career I helped in the drafting of about 200 comments to various agency rulemaking efforts.
Maybe a lot of readers here do not remember Congressman John Dingell and his compatriot on the House Energy and Commerce Committee, Henry Waxman. Nobody wanted to be called up, sworn in, and have to testify about something that had gone awry. Dingell always had a group of dogged investigators rummaging through Agency regulatory decision-making.
FDA managed to move away from rulemaking and began drafting and putting out Guidance documents which "reflected the Agency's best thinking" on an issue of importance. Sure, these were not "regulatory" documents as proscribed in the Code of Federal Regulations but .....you needed a good reason not to follow the Guidance. When I was running the regulatory group at PhRMA in the late 1990s through the aughts, we would have regular meetings with various drug review divisions to share collective ideas on scientific issues.
I guess I would fall into the category of an industry sock puppet master of the FDA were I still working today. It is all too sad to see.