Burden reduction efforts using human-centered design can easily connect to broader management techniques such as performance management, Lean, Six Sigma, and Agile, which favor collaborative teams in consultation with stakeholders and customers, using iterative processes of mission-based improvement, rapid feedback loops that convert insights into actions, which in turn depends upon engaged and empowered teams and leadership. These shared philosophical goals are often contrasted with more traditional bureaucratic approaches, which are presented as cut off from client feedback, lacking institutionalized routines to collect and use data, and overly cautious about engaging in change. While those critiques can sometimes veer into stereotypes, they are echoed by those trying to make changes in government. In the absence of market-based competition and the presence of many structural constraints, public organizations need management tools that can better embed change processes.
An important consideration in soliciting information to improve the public experience is representativeness and participation. These components are interrelated and iterative. For example, deep expertise is created through institutional knowledge gleaned from experience, extended engagement with stakeholders, and strong internal agency teams that can share this knowledge. Deep knowledge includes learning from the agency workers interacting with the public daily and building channels to learn from the public.
Public comments, focus groups, and surveys provide ways of gaining input, but they sometimes do not represent the public using the services. A representative approach would deliberately look for those not being heard. This need not be burdensome. Careful sampling can mean drawing on smaller samples, employing either quantitative or qualitative methods, to understand their experiences.
1. Consultation With Stakeholders
Consultation allows agencies to hear from underrepresented communities and better understand where burdens can be reduced. Where agencies have institutionalized consultation processes, valuable information is exchanged, leading to burden reduction. Consultation can occur in various ways; some of the most promising are exemplified below.
A key to the success of CX efforts at the Department of Veterans Affairs (VA) has been the engagement of stakeholders. Veteran service organizations (VSOs) regularly meet with the Secretary and staff. This allows them to identify client concerns. VSOs also work directly with clients. They may take claims and provide counseling, conditional on training and accreditation, giving them direct experience with the administrative process. They have come to see CX efforts as a way to ensure their members’ voices are heard.
It is worth noting that VA is fortunate and unusual in some respects that make CX efforts more likely to succeed . It directly serves clients, unlike many government agencies, and those clients are viewed as deserving of government support by both parties. It also experiences less ambiguity about its core goals than other agencies, though politicians may still disagree about how to get there, with some favoring greater privatization of services. Further, it has an active group of stakeholders who share the basic mission of serving veterans, are in direct contact with both veterans and VA, and can advocate for veteran concerns. Human-centered design and customer experience efforts resonate with those stakeholders because their purpose is to represent the voices of veterans.
Stakeholder engagement can also occur through a proxy-like system through established working groups like the White House Legal Aid Interagency Roundtable. This group, housed in the Department of Justice’s (DOJ’s) Office of Access to Justice, convenes agency representatives, including the Legal Services Corporation, to, among other things, “improve coordination among Federal programs, so that programs are more efficient and produce better outcomes by including, where appropriate, legal services among the range of supportive services provided.” Through this group, the Legal Services Corporation can identify burdens experienced by underrepresented and vulnerable communities coming to legal aid services for assistance navigating benefits programs. Agencies consult with the advocacy community directly as well. “For example, DOL regularly convenes Claimant Advocate listening sessions,” typically legal service lawyers, to identify burdens claimants face.
2. Direct Observation, Focus Groups
To understand how to reduce burdens, one must be able to identify them. In some agencies, the barriers people face trying to access benefits or services are easily identifiable. In cases where they are not, direct observation of clients engaging with processes or listening sessions with users can be informative. Such data can feed into human-centered design and journey mapping processes.
For example, Department of Homeland Security (DHS) staff were asked to examine processes to identify whether each step was necessary . Did information still need to be collected? Were there alternative sources of information? The Biden Administration has institutionalized this sort of journey mapping with their focus on nine key life experiences as a frame for understanding burden reduction. One life experience, recovering from a disaster, exemplifies how journey mapping can lead to tangible reductions in burdens. In this case, DHS was able to collaborate with other agencies—the Small Business Administration, the Department of Housing and Urban Development (HUD), the Department of Agriculture (USDA), and the Department of Health and Human Services (HHS)—to
clarify and simplify the experience of applying for Federal disaster assistance programs. Currently, survivors must navigate and apply for each relief program separately. These processes can be confusing, and survivors are unclear about the different kinds of assistance [which] they may be eligible for and how to apply [for them]; once they do, they must keep track of multiple processes and communication channels and often enter the same data multiple times.
This process led to concrete reforms, such as flexibility in requirements for assistance to streamline and speed up benefits. Examples included expanding the types of documents that can prove home ownership, waiving proof of homeownership for repeat disaster survivors, and expanding application times.
3. Client Surveys
One means of collecting data on user experience is via client surveys. Such surveys can serve different purposes. They can be used to examine the value of interventions designed to reduce burdens, identify problematic processes or offices, or track long-term trends. For example, each quarter, VA “surveys approximately 257,000 [v]eterans with recent interactions . . . with claims, appeals, health care, memorials[,] and other services to rate their overall trust in VA.” The office also provides resources and training to other VA employees, such as human-centered design. One person we interviewed, who had worked in claims, discussed how the survey data was illuminating. “We were like ‘wow, this is great!’ as a way to infuse the perspective of the veteran, as opposed to ‘we will decide for the veterans what is best for them, and we will decide bureaucratically what is best for us.’”
4. Public Comment
Agencies have also relied upon public comments on published notices to understand the public’s view. This can also be a valuable tool for burden identification and reduction. DHS has successfully turned to public comment to gain insight into burden reduction. For example, the U.S. Citizenship and Immigration Services (USCIS) published a request for public input specifically related to burdens felt by the public. The agency then prioritized going through the comments as a crowd-sourcing tool. Such processes can easily become make-work, but DHS created a process of reviewing comments to identify possible actions . In the wake of these comments, USCIS published policy alerts that addressed immediate burdens, such as updating language on forms related to allowing an automatic extension of twenty-four months beyond the expiration of a permanent resident card. This flexibility reduced the number of forms needed for particular permanent residents seeking naturalization. DHS estimated that dozens of agency actions flowed from responding to public comments .
5. Complaint Portals
A less interactive form of learning from the public that provides additional information toward identifying and reducing burdens is through an accessible complaint portal. In order for a complaint portal to generate burden reduction, it must be structured so that the information from the public flows to the CX office. The Consumer Financial Protection Bureau offers an example: using a
collection of personal stories by consumers dealing with credit, debt collection, student loans, and other financial matters is a particularly effective use of complaint processes and education. These stories are published online and used to guide data collection and enforcement priorities at the agency. The complaint architecture is designed well from an access to justice perspective, but, as with all agency structures, its effectiveness depends on leadership and culture at the agency to learn from it.
These tools can be further refined by mapping a person’s journey with a complaint. For example, HUD is currently studying the experience of a prospective tenant going through the portal to file a complaint. The CX team at HUD is mapping this out with the goal of making the complaint process less burdensome for the public .
6. Exploit Worker Knowledge
To learn how the public experiences accessing benefits and services, agencies should also exploit worker knowledge about those processes. Staff working with the public will have deep knowledge about complex frictions that will be less apparent to nonspecialists. Such expertise in both the policy and the organizations in which it is implemented is needed. Journey mapping, in particular, will not work without individuals who are deeply knowledgeable about the policy and its current implementation. In some cases, journey mapping is less functional, in part because agency staff already know both the journey and the pain points. They are more likely to share that knowledge under conditions where (a) identifying and reducing administrative burdens are framed as a salient agency goal and (b) routines exist where their knowledge is sought.
B. Capacity: Have a Devoted Customer Experience Team
Agencies that have enacted some of the most systematic burden reduction reforms have made CX teams, which coordinate efforts to improve customer experiences within agencies, a critical capacity component. The teams play a few key roles. First, because it is their primary mission or the entire focus of their work, they provide a stable and consistent source of effort and attention to continue burden reduction efforts in the agency. Second, they coordinate efforts across groups within the agency to tackle burdens, as described below. In short, they are the driving organizing force that facilitates team building. One fundamental rule, however, is that the CX team must have deep policy and agency knowledge, as well as sufficient authority within the agency to succeed at the mission.
VA provides an excellent example of why creating a specific team devoted to customer experience matters. In 2014, VA was rocked by a scandal that became front-page news and led to the resignation of its Secretary and the resignation or reassignment of fourteen of the seventeen top agency leaders. VA hospital staff had been falsifying wait lists to make it appear that patients were seen more quickly than they really were. In the years that followed, trust in the agency rebounded, from about 55% to almost 80% in 2022. In doing so, it became a leader in CX skills years before more systematic efforts were in place in other agencies or the CX EO. Using its experience integrating CX principles into a large organization, VA has developed outstanding resources for others in government doing the same, such as The CX Cookbook.
After the VA hospital scandal, the new VA Secretary, Bob McDonald, saw the lack of a mechanism to channel the voice of customers as a blind spot that needed to be corrected. In response to the scandal, McDonald created a Customer Experience Institute, which offered a systematic means to understand customer experience. Each quarter, VA “surveys approximately 257,000 [v]eterans with recent interactions . . . with claims, appeals, health care, memorials[,] and other services to rate their overall trust in VA.” Ultimately, McDonald helped institutionalize customer experience improvement efforts by giving these officials resources and ensuring they had the authority and permission structure to experiment, innovate, and coordinate across the agency.
The VA experience points to two key requirements for an effective CX team. First, members need to be experts on the agency’s policy, benefits, and services, and have a deep understanding of the agency itself. VA has made an early start on CX efforts and has the largest CX team in government, with hundreds of members. It has emphasized the need for service-specific expertise to use CX skills best:
Understanding government, its constraints, its levers, is critical to understanding how to implement any new initiative, including CX. Career public servants are experts with this distinct skill set, and through their experience, they know how to navigate through the government environment to execute, scale, and sustain . . . . Understanding the particular agency’s culture is also key, as every organization is different. Identifying what is important to the agency, how initiatives receive prioritization in terms of leadership visibility, funding, etc., how one makes CX relevant to agency mission and strategy, and knowing how to tie CX to anything that is important in the agency’s culture and operations enables the organization to clearly see how CX fits in.
The second requirement of an effective CX team is that they need senior staff members with authority and leverage to ensure the team is taken seriously, within and outside of the agency. Having a team of CX workers within an agency is critical to implementing more systematic reforms. The CX team does a lot of the team coordination, keeping track of what different groups are doing, and can facilitate to ensure everyone is moving forward. Some agencies that have been most active regarding burden reduction, such as HHS, USDA, and VA, all have CX teams that can provide the capacity to guide the agency toward implementing these reforms. Key to their success is the leadership of the CX team and the support and resources they enjoy from agency leaders.
C. Collaboration: Build Collaborative Teams Dedicated to Burden Reduction
Having a dedicated CX team is crucial to reducing burdens, but engaging in any sort of change will inevitably require many parts of an agency to work together, including those whose work is being affected, senior policymakers, and General Counsels. Reducing administrative burdens, like many wicked problems, requires nontraditional combinations of actors to coordinate with each other. However, agency staff within different departments are often siloed from others. As one OMB official noted: “There is a cultural thing in the government about not going outside of your lane, and this is about crossing lan es.”
Collaboration requires officials to perform tasks outside of their normal hierarchy. It, therefore, requires extra effort and coordination, including leadership prioritization.
1. Connect CX Teams to Other Parts of the Agency
How agencies are structured internally has a significant impact on burden reduction efforts. In the wake of the CX EO, more agencies have created offices or roles to manage customer experience. There can be issues with budgets and appropriations that can be handled better if these offices are staffed properly. One emerging best practice is to have senior career staff and a partner political appointee champion the people and the work in these offices.
2. Include General Counsels and OIRA Desk Officers in Working Teams
Burden reduction efforts will often involve new ways of doing things and create requests about what powers the agency actually has to implement burden reduction. This, in turn, requires the involvement of Offices of General Counsel. If General Counsel (GC) officials are involved in burden reduction teams, particularly from the start, they are more likely to understand the purpose and benefit of burden reduction efforts and can help facilitate ways to achieve them . If they are the last actor in the process to be consulted, it is more likely that they will veto a change, in part because they have not been able to provide advice throughout the process that could prevent roadblocks .
We also heard from agencies that sometimes the disagreements are between Program Counsel and GC . In one case, the dynamic was described like this: “Our counsels do [not] always agree, but the pattern is the Program Counsel thinking about statutes directly connected to the action, GCs thinking more about government-wide statutes and might mandate a different interpretation.”
Agencies also have case officers responsible for the implementation of the PRA. As with GC, there is often a pattern of desk officers taking a procedural approach to their role, ensuring that they follow guidance but do not look for onerous or unnecessary friction . OMB has issued guidance on flexibilities with PRA, and ACUS has recommended that agencies increase training on these statutory flexibilities. In one agency, we learned of variations among desk officers when denying requests for nonsubstantive revisions under the PRA . Another issue is how long it takes to receive approvals under the PRA. At one agency, we learned of placeholders almost a year out for PRA renewals . Bringing desk officers more actively into burden reduction teams could help agencies systemize solutions to these challenges.
D. Simplifying: Increase Access by Simplifying Processes and Providing Support
Agencies also employ strategies to reduce administrative burdens, such as simplifying processes. Tactics include limiting the number of steps in processes, reducing the number and length of forms, limiting documentation requirements, and expanding language access.
The U.S. Postal Service (USPS) provides an excellent example of how to provide robust customer support and how other agencies can specifically partner with USPS to expand their own customer support. USPS’s one-stop address change is one particular example. Members of the public can change addresses, forward mail, or temporarily stop mail by filling out a short form at a post office or online. It takes only a few moments. The USPS process is notably easier and faster than changing an address with many private companies, such as a cellular telephone provider. But USPS has also partnered with other federal agencies to provide on-the-ground support . Post offices are nearly everywhere, the public always knows how to find them, and the public generally views them favorably. It has already partnered with the Department of State to ease access to passports. It has also more recently been a site for individuals to provide in-person support for those trying to obtain identity verification for Login.gov.
USDA, particularly in its administration of SNAP, has been actively simplifying processes and reducing burdens since the mid-to-late-2000s. Prior to the 1996 welfare reform bill, those enrolled in Aid to Families with Dependent Children (AFDC) nearly automatically received SNAP, which substantially decreased the burden on recipients and increased access to SNAP. When SNAP was delinked from AFDC after the 1996 welfare reform, the fraction of people eligible for benefits who actually received them plummeted. Consequently, USDA engaged in a decades-long process of gradually simplifying processes, ranging from simplified income reporting and less complicated applications to reducing in-person interview requirements and expanding periods between recertification. The result has been an increase in participation from a low of 54% of eligible individuals in 2001 to over 80% of eligible individuals today. USDA simplification efforts have also been in place to help farmers. To increase access to its loan program application program, USDA converted a ten-form, twenty-nine-page application process into a single thirteen-page document while also launching a Loan Assistance Tool to help farmers determine eligibility and complete the process.
Beyond merely simplifying processes, agencies have long offered multiple types of support and assistance with navigating processes. Assistance can range from partnering with legal aid organizations and codifying programs to accredit nonlawyer representatives to providing other forms of agency support through ombuds, public advocates, and navigator programs. Some agencies, like the IRS, help support and collaborate with organizations that help low-income taxpayers, who are eligible for benefits that exceed their tax liability, file taxes so that they can access these benefits, particularly the EITC. We discuss the current state of expanding representation in Part V.
We want to note some recent successes in burden reduction related to the pandemic. The pandemic was an era of intense experimentation where governments sought to maintain the supply of benefits. In some cases, those flexibilities improved access and are worth maintaining. For example, in-person requirements may tangibly reduce access. One study found that Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) participation during the pandemic was 14% lower in “Offline Electronic Benefits Transfer (EBT)” states, where beneficiaries had to reload their EBT cards in person, as compared to “Online EBT” states, where beneficiaries could reload their cards remotely.
Similarly, creating alternatives to “wet” signatures, such as digital or telephone signatures, would eliminate access barriers. The Western Center on Law and Poverty said in a comment:
The expanded use of telephonic signature technology by benefits-granting agencies during the pandemic has been enormously helpful. The logistical challenges of getting wet signatures cause[] unnecessary delays and unfair denials/terminations. Requiring wet signatures on documents burdens applicants and beneficiaries who are unhoused, elderly, and/or have disabilities. These applicants go into an agency office to sign documents, which can be very difficult for those with mobility issues. Applicants and recipients who must wait to receive and return documents by mail, experience problems with timely submissions due to slow mail delivery, and those who do not have a fixed address are disadvantaged.
The federal waiver system for programs allows such experimentation, and it has been used in the past to generate insights about how to reduce burdens in programs such as Medicaid. For example, Oregon will use a waiver to pilot a continuous enrollment program for children under six years old, reducing the burden of re-enrolling annually. This is critical because large fractions of beneficiaries who are still eligible lose coverage during re-enrollment for procedural reasons, such as missing paperwork or documentation. Waivers can also create additional complexity for the public. For example, Medicaid waiver programs have become a central way for states to fund and deliver long-term care. Their temporary nature, the amount of variation and application for benefits across and within states, and funding constraints all actually increase burdens for eligible individuals.
E. Critical Data Tools: Sharing Data
Effectively sharing data across federal agencies and between federal and state agencies is one of the strongest potential tools to reduce burdens. Because of conditionality, or the need to demonstrate one is eligible for benefits and services, as well as the quantity, agencies need information about the individual to ensure eligibility. Having sufficient information allows agencies to ease access significantly. This can allow for (1) better outreach so that individuals know they are eligible; (2) reduction in forms and documentation requirements; and (3) automatic enrollment under some conditions.
The Chief Data Officer Council’s Data Sharing Working Group issued a report highlighting the need to expedite data-sharing agreements. Similar to our findings, the Working Group explained that data-sharing agreements are slowed by “a myriad of complex legal, oversight, policy and compliance regimes that often conflict” and that “[e]ducation of agency leadership across the federal government is needed on the value of data and the importance of sharing for cross-agency mission enablement.” Moreover, the working group found that “an agency’s aversion to risk, especially concerning the interpretation of statute supporting data-sharing, leads to a historical posture of inaction.”
For many agencies, data-sharing practices are primarily governed by the Computer Matching and Privacy Protection Act. Some agencies have other specific statutory guidelines regarding data-sharing. There are foundational legal questions that must be addressed with any data-sharing possibility, including: which agency is sharing the data, which agency is using the data, what are the parameters of the data being shared, and what is the purpose for which the data are being shared. Each of these questions will have statutory guidance that must be interpreted and adhered to, and minor edits to data-sharing design at an early stage in the process can open up possibilities. A critical step here requires the program and legal staff to collaborate closely to understand how data-sharing furthers program administration, including articulating burden reduction benefits. It is critical to note that in addition to reducing burdens, effective data-sharing can also significantly reduce fraud, abuse, and general errors in distributing benefits and services.
The model of such a system is SSA’s Old Age Insurance (OAI) benefits, which is based on a shared data model with the IRS. Individual beneficiaries do not have to provide earnings or almost any other information. The administrative system—set up when the program was implemented in the 1930s—ensures that employers provide these data and that SSA keeps track of it based on a shared data model with the IRS. The result is a system with low administrative costs (1%, compared to 9% for a program like SNAP), very little error, and low burdens for beneficiaries. Shared data between the IRS and SSA is integral to OAI benefits’ relatively low burdens and administrative costs.
More recent efforts have also been made to reduce burdens with better data-sharing. A GAO report found that former students entitled to student loan forgiveness due to disability status often lost the benefit due to paperwork. A striking 98% who lost the benefit did so not because they were ineligible but because they failed to provide an annual income verification form. As a result, the Department of Education used data-matching with SSA to verify eligibility status, automatically discharging debt for some 323,000 borrowers.
Another example features SSA data-sharing with states. SSA has data exchange agreements with all fifty states. In some states, an agreement between USDA, SSA, and the state allows for a joint application between Supplemental Security Income (SSI) and SNAP (the Combined Application Project (CAP)). In short, SSI eligibility is more restrictive than SNAP eligibility, so it can serve as a “passport” for SNAP eligibility. This has been shown to significantly reduce burdens and increase eligible individuals’ access to SNAP benefits.
There are, however, problems with the existing CAP program. First, only seventeen states participate. And even among those states that participate, it is sometimes limited to narrow populations or has lower SNAP benefits. In December 2022, SSA and the USDA were going to work more closely to reduce burdens and improve their data-sharing. In part, establishing and expanding such agreements is reported to be very labor intensive, requiring months of negotiation between SSA, USDA, the state, and vendors of data management systems. The labor-intensive nature of these agreements slows the spread of a useful data-sharing arrangement.
Further, there is limited information on the actual outcomes associated with the CAP or broader ways that SSA and USDA work together to improve access to SNAP for SSI beneficiaries. Indeed, a recent letter from twelve U.S. Senators asked SSA and USDA to document data, such as the number of SNAP applications received by SSA offices and the number of SNAP applications transferred to state offices, both by CAP and non-CAP states. This kind of data collection and reporting is critical to understanding how effectively this collaboration is working to reduce burdens and increase benefit access.
In sum, while there are excellent existing models of data-sharing for burden reduction, significant improvements are needed to maximize burden reduction.
V. Developing Innovative Practices to Identify and Reduce Burdens
This section details newer innovations agencies have employed in recent years, many of which are a response to the series of recent EOs to improve people’s interactions with government, including improving benefit and service delivery. This rapidly developing regulatory structure represents a change in agencies’ worldviews. Burden reduction requires new thinking about data. It also requires silo-busting: expanding trust and collaboration among experts with different skill sets, all interconnected with burden. Amid a flurry of new management tools, unfamiliar territory, and lots of information, agencies are innovating in successful ways while still encountering remaining and new challenges. The goal of this section is to illustrate more recent best practices, as well as how they can be further developed and expanded.
A. Organizational Culture, Including Building Appropriate Capacity, Which Focuses on Burden Reduction
In this section, we detail particular actions that agencies have taken to actively create a culture focused on burden reduction. This provides additional insight into what factors might encourage an organizational culture that prioritizes burden reduction.
1. Role of Leadership
a. White House Leadership/Prioritization Through EOs
The impact of the Biden Administration’s EOs on equity and customer experience cannot be overstated. Agencies already focused on burden reduction, such as VA, leveraged these orders to further build on their existing activities, while other agencies that had more limited attention to customer experiences, such as DHS, significantly ramped up their activities.
The White House also plays a leadership role in more direct ways. For example, they have been seeding coordination, either via visible White House leadership or less visible actors, such as within OMB. For example, OMB budget examiners are credited with pushing data-sharing collaborations that facilitated burden reductions in access to SNAP—via the partnership between SSA and USDA—and student loan forgiveness for those with disabilities—via a partnership between SSA and the Department of Education—as discussed above.
Another key support service facilitated by the central leadership within the Executive Branch is the Office of Evaluation Sciences (OES). OES collaborates with agencies across the federal government to enable evidence-based research on interventions, including those intended to reduce burdens .
Finally, the creation of the U.S. Digital Service (USDS) and 18F (an office within GSA that helps agencies build or buy digital services) have been critical to the broader effort across the federal government to improve customer experiences and reduce administrative burdens. USDS partners with nearly all of the agencies named in the EO on customer experience. They help bring a crucial part of capacity building agencies need to implement burden reduction efforts.
b. Prioritization from Agency Leadership
Agency leadership prioritizing burden reduction is a key element to effective reduction efforts. Agency leadership at VA was critical to building a culture and institutionalizing processes and procedures to improve customer experience after the 2015 hospital waiting scandal. The new VA Secretary, Bob McDonald, would hand out his personal phone number and email to veterans and encourage them to contact him, symbolizing to agency employees the leadership commitment to hearing from clients and solving their problems. Such actions reflect a model of transformational leadership, where leaders use their position to articulate and commit to a meaningful and motivating vision. The aftermath of the waiting list scandal could have been imposing new requirements and checks as a defensive measure. McDonald exploited the failure to change the ethos and operation of VA. One VA official we spoke with said: “The burning platform was there, but we also had leadership from McDonald. A Secretary-level endorsement is critical. It w[ill not] do the work for you, but it is essential .”
More recent attention has been paid to burden reduction on the part of leadership at DHS. Agency staff repeatedly noted that Secretary Mayorkas’s focus on burden reduction made their efforts substantially easier. For example, officials at DHS point to the Secretary prioritizing the need to make things simpler and easier for people as to why burden reduction has become a key part of their regulatory review agenda. This was described as a shift toward holistically defining burden reduction throughout the agency, with a goal of reducing burdens by twenty million hours across different sub-agencies. The target was a tangible way to communicate the leadership priority across DHS. By June 1, 2023, DHS reported exceeding its goal, reducing the burden hours by twenty-one million. A phrase used to describe the burden reduction goals at DHS was to make government interactions “less humiliating” for people . That sort of humanizing of burden reduction goals can be a powerful motivator for agency staff.
More specifically, leaders can help by increasing the salience of customer experience efforts, linking them to mission and organizational culture, and allocating resources (including their time) to burden reduction efforts. Another recent example of this kind of leadership is at HHS. As Andrea Palm, Deputy Secretary of HHS, noted, the agency is putting “the people that we serve at the center of what we do.” She explicitly noted both cross-departmental and intergovernmental collaboration to reduce burdens. “For example, HHS and other agencies, like USDA and the Department of Labor, are critically thinking about how to serve families who may have needs that fall under multiple agencies’ jurisdiction or programs.” As she noted, “[s]o how we think about the customer experience is an opportunity for us at HHS to lift up, to put people at the center, and to wrap service around them instead of requiring people to come to programs and interface with individual programs.”
We heard a similar shift in approach from the Taxpayer Experience Office at the IRS . There, interviewees spoke of the more holistic focus on the entirety of the taxpayer experience beyond merely communicating filing instructions . Echoing this shift in view, the National Taxpayer Advocate recommended that the IRS adapt its mission statement to specifically recognize its role as a benefits-provider:
By explicitly stating the IRS’s benefits administration role as a separate agency mission in the context of service and non-coercive compliance, the IRS would be required to align its procedures, goals, and measures with those of other agencies serving similar situations. That would in turn build taxpayer trust and confidence, leading to improved compliance and an environment that reflects the essential dignity of all taxpayers.
2. Codifying Burden Reduction
OMB is currently working on ways to ensure that burden reduction is encoded into agency regulations. The proposed Circular A-4 includes a section on “Improving Government Operations and Service Delivery” that states,
Regulations are necessary for the day-to-day functioning of government and can also help promote a government that operates more smoothly, is more transparent, and delivers public services more efficiently. For example, a regulation may further effective government operations by setting performance criteria that government must follow. Regulations can also help government deliver services to more individuals at lower cost, such as by reducing administrative burdens or by simplifying public-facing or internal processes.
VA provides a robust example of why this kind of encoding matters for agency culture. It is perhaps the most notable agency for creating a culture focused on burden reduction and broadly improving how veterans experience their encounters with the agency. It partially did this by explicitly connecting burden reduction efforts to its organizational culture. VA cultural values are codified in law as Integrity, Commitment, Advocacy, Respect, and Excellence (I CARE). These values put veterans at the organization’s center and emphasize the need to continue agency learning to serve veterans better. This made it easy to connect customer experience principles to the core values. VA would also codify customer experience principles alongside these values. These include:
(a) Ease. VA will make access to VA care, benefits, and memorial services smooth and easy.
(b) Effectiveness. VA will deliver care, benefits, and memorial services to the customer’s satisfaction.
(c) Emotion. VA will deliver care, benefits, and memorial services in a manner that makes customers feel honored and valued in their interactions with VA. VA will use customer experience data and insights in strategy development and decision-making to ensure that the voice of veterans, servicemembers, their families, caregivers, and survivors inform how VA delivers care, benefits, and memorial services.
One notable aspect of these principles is that they focus on access to services, not just positive experiences for those using them. They also use a word not commonly seen in government documents—“emotion”—to convey that the psychological experience of the service is a key aspect of serving clients. VA officials we spoke with emphasized that people are drawn into the government to help others . Reducing burdens and improving client experiences offers a chance to directly and measurably help the public and serve as a basis for recruiting the next generations of public servants showing, “You can be a badass in government .”
Even within VA, the connection to the mission varies across staff . Nurses and physicians have direct interactions with the clients they serve, but back-office workers such as claim examiners do not . The work of those employees can still significantly affect client experiences, but it requires extra work to draw those connections.
3. Building Learning Routines and a Sense of Ownership Overburden Reduction
As with any new reform effort, long-term success depends upon institutionalization. Here, burden reduction efforts could look at performance management efforts in government. To some extent, reformers have done so by, for example, connecting customer experience goals with GPRA Modernization Act strategic planning and performance reporting goals in Circular A-11. There are other lessons from the performance management practices. One such practice was to identify goal leaders who were publicly responsible for reporting progress on specific reporting goals, whose names and pictures are presented alongside the goal on the federal Performance.gov website.
Another strategy has been to ensure that data is used by mandating quarterly reviews of progress made on key views . Federal employees involved in such reviews were more likely to report using performance data to make substantive decisions relative to those who were not.
One incentive structure that shapes cultural attitudes is that agencies face significant pressure to minimize spending. This can pit burden reduction efforts and spending reduction efforts at odds with each other. Burden reduction efforts will sometimes require costs, such as hiring new CX staff or consulting help. The public enjoys the benefits but does not reduce the bottom line. By contrast, efforts to reduce spending can work oppositely. Asking the public to provide more information in administrative processes does not cost the administrator anything, even as it imposes negative externalities on the public. A former Presidential Innovation Fellow, Angelo Frigo, put it this way:
If an agency can increase program integrity by asking the public for more information or requiring more evidence—burdens go up. When CX leaders try to get their agencies to reduce burdens but that requires an increase in spending or a reduction in integrity—even if slight—it almost always loses.
Of course, in many cases, burden reduction for the public, such as automating benefit renewals and relying on administrative data, actually reduces administrative overhead on average. For example, a caseworker will spend less time accessing administrative data to verify income than helping a beneficiary provide that information and documentation. There may be upfront costs, however, to achieve these savings.
B. Collaboration: Cross Department and Cross Governmental Collaboration
1. Collaboration Across Federal Agencies
We described in Part IV how agencies, such as VA, have been effectively building collaborations across units within the agency to reduce burdens. But one key part of the new EO, which is focused on “Life Experiences,” requires cross-agency collaboration. These experiences—including retiring or facing a financial shock—require that people seek services and benefits across multiple agencies, which can be confusing and require duplicative and sometimes unnecessary efforts. For example, one might be required to provide income documentation multiple times or fill out somewhat different forms, but ultimately, they provide the same information. Agencies need to collaborate to reduce these onerous processes.
Collaboration can include information sharing on burden reduction methods, program design that connects certain functions across multiple agencies, expanded use of data match agreements, and ongoing communication channels. The broader lesson is the need for cross-agency working groups to reduce burdens, including actors from the who know the specifics of the case and the broader burden reduction agenda.
An example highlighting many of these collaborative tools is how VA has worked closely with the Department of Defense (DOD), facilitating the handoff between the end of military service and accessing veterans’ benefits. This includes data-sharing, document exchange, and process simplification. This outcome benefited from a joint executive committee that works together to find pain points. The Health Artifact and Image Management Solution (HAIMS) system facilitates document sharing, and the two agencies are working on an electronic health record exchange. Officials from both agencies meet quarterly and are supported by OMB . The process can be slow. Developing a single health assessment that both DOD and VA would accept . Such efforts improve access and reduce overpayments, such as individuals claiming multiple benefits when they are only allowed to claim one.
Such efforts depend upon good faith and trust from all sides. If one side thinks the other is slow rolling, they are more likely to withdraw effort and invest it elsewhere. One interviewee noted: “It’s like building the St. Louis Arch. You gotta build to meet in the middle.” Another noted that having an inexperienced counterpart unfamiliar with the complexities of the systems they sought to integrate was enough to stall progress . Third parties, such as OMB, may also be required to step in. In a couple of instances, OMB budget examiners provided the impetus for pushing coordination .
More recently, HHS has been collaborating with Food and Nutrition Services within USDA to streamline access to both SNAP and Medicaid, each administered by separate agencies but serving similar populations. This collaboration reflects a response to the CX EO, with USDA specifically issuing a new regulation to facilitate this kind of cross-agency collaboration. In 2022, HHS also used categorical eligibility to reduce burdens for families with lower income seeking Early Start and Head Start services. It instructed providers to provide automatic eligibility for SNAP and Temporary Assistance for Needy Families (TANF) recipients rather than require an extra enrollment process, which had been viewed as discouraging take-up.
There is significant potential to continue building on existing collaboration and build new collaboration. For example, in some cases, programs exist and have relatively low utilization because of limited collaboration. The Achieving a Better Life Experience (ABLE) program is an example. It provides tax sheltered savings accounts for families who have a member with a disability. The program ensures that disabled beneficiaries with more than the $2,000 asset cap for programs like Supplemental Security Income can accrue some savings and not lose access to these critical benefits. The simplest solution would be to increase asset limits, which the government has not changed in decades, or do away with them since only a small number of families have significant assets.
ABLE provides a complex way to work around the asset limits. However, it remains underutilized because of the learning costs posed by a new program. Eligible individuals do not know about the program or how to utilize it. One way to address this would be for the IRS and SSA to work together to reduce those learning costs by contacting eligible families and explaining the program and their eligibility. Such a step has proven to be an effective tool for increasing take-up for the EITC, which is administered by the IRS. SSA has data that could help identify potentially eligible individuals. Though SSA does advertise ABLE accounts in its field offices, far more collaboration and outreach are required for that outreach to be effective. The SSA, however, sees the program as an IRS program and does not see improving take-up as its responsibility . The result is that only families with a good understanding of the tax system will likely be aware of ABLE accounts.
2. Federalism: Collaborating Across Levels of Government
One of the reasons for high levels of burden in public programs is federalism. Most federal social welfare policies, with key exceptions like Medicare and Social Security, are administered by the states, and the design of those benefits, such as who is eligible and what conditions people must meet to receive those benefits, is also significantly driven by state choices. The significant variation—in both benefit design and administration—adds complexity, making those programs more burdensome for people to access. Programs can gain layers of additional requirements as states or local governments customize them. Other levels of government may also lack the capacity to fix burdens.
Consequently, significant coordination between the federal government, states, and sometimes counties or other localities is required to reduce burdens. Federal directives to identify and mitigate burdens already exist through the revised PRA guidance and the CX EOs. These apply to any program that receives federal funding regardless of who administers the program. But there is limited awareness of these changes, especially at lower levels of government, and more active coordination efforts are needed. We highlight some recent examples of how federal agencies coordinate with states to reduce burdens.
One of the most notable failures in benefit delivery occurred during the pandemic when millions of people tried to access unemployment insurance (UI) benefits but were met, in many states, with endless burdens and barriers. A benefit intended to protect people when they became unemployed was effectively inaccessible to many of those eligible. UI is a prototypical example of how significant state variation in both benefit design and administration can lead to highly burdensome experiences for the public.
A host of issues were identified with state UI systems, ranging from understaffing to outdated technologies, which helped drive some of the problems people faced at the start of the pandemic. And because UI comprises fifty-three different benefit systems, there is no single administrative solution that the federal government can employ to improve UI.
ARPA included resources that allowed DOL to send teams, called Tiger Teams, to consult with states, examining technology operations and process flows to improve benefit delivery systems. Their goal is to
work with states to identify ways to enhance their existing efforts and make actionable recommendations, along with allocated grant funding, for states to make near-term impacts within the pillars of Equity & Accessibility, Timeliness & Backlog, and Fraud Prevention & Detection. In addition, the Tiger Teams work across the national UI system to identify promising practices and develop tools and resources for the states.
DOL has worked with thirty-six states up to May 2023.
A key change from the federal government in employing these teams was a shift from only focusing on benefits errors and state compliance with federal rules to an additional focus on problem-solving to ensure improved benefit delivery. Before ARPA, the focus had been almost exclusively on fraud and error prevention. DOL did not have the operational resources to provide the kinds of assistance included in ARPA.
Critically, DOL created entirely different teams for enforcement activities versus these new assistance activities. Tiger Teams emphasize organizational learning rather than focusing on blame for prior errors. Furthermore, they provided state governments, especially those with more limited capacity, additional expertise and necessary support for improving their systems. The basic programmatic model is that the teams work closely with states to understand their strengths and weaknesses and, in that context, develop a set of recommendations. The states can then access grants and awards to implement these recommendations.
Moving forward, without the capacity to provide problem-solving help and improve state services, the relationship will revert back to compliance.
3. Standardizing Processes for Burden Reduction
Whether it is collaboration across federal departments or departments across levels of government, one key way to improve people’s experiences, given the complexity of federalist programs like UI, is to standardize eligibility tools when possible. We discuss a range of methods to address this below.
a. Identity Verification
An essential tool needed across almost any program is identity verification. While a seemingly simple task, in practice, it is complicated and can serve as a substantial barrier to services and benefits. Identity verification is also critical to prevent programmatic fraud, a significant UI problem during the pandemic. One way to meet both goals—reduce fraud and simplify access to services—is to create a single identity verification tool that can be used across any federal or state program.
One such tool is Login.gov, an identity verification tool created by GSA. This tool was extended to state governments under the Intergovernmental Cooperation Act. The value proposition of Login.gov is intuitive. Rather than creating a separate account and password for every government service, a single one becomes the gateway for all. Users do not have to hunt for multiple passwords or renew credentials if they cannot find them. Other countries, such as Denmark, have models where all primary government services run through a single account. In the aggregate, a digital option reduces friction in accessing public services. There have been controversies around Login.gov, in part because it does not include biometric verification. The GSA chose not to add this feature because of compelling evidence indicating that biometric tools are prone to bias, particularly against Black, Brown, and Native individuals, leading to inaccuracies in identification.
However, the benefits of employing Login.gov are much higher than any costs associated with not having the biometric tools. Having both federal and state agencies employ a wide array of differing identity tools creates enormous burden and confusion. Further, if states employ other tools, private entities do not have the same obligation to pay attention to equity concerns as does the federal government.
One risk associated with any digital identification is exclusion if nondigital users have no other options. This is another area where Login.gov has a substantial advantage. Login.gov allows users to go to post offices to verify their identity if they do not wish to do it online.
The actual value of Login.gov to users has not been estimated. This should be relatively easy for GSA to do by estimating the time value of logins across the number of users by the number of accounts used. While the PRA mandates that the government track the amount of time users spend on interactions, it should also look for examples to quantify time savings, such as those offered by Login.gov.
b. Standardizing Definitions for Eligibility Processes
One key source of burden is varying definitions of particular eligibility components, such as income. For example, different agencies can count income differently, such as including or excluding specific components (e.g., child care or health care costs) or whether it is based on weekly or monthly income. To the extent this varies across agencies, and even within agencies across programs, it creates confusion and complexity for beneficiaries, and it also reduces the ability to coordinate to reduce burdens. For agencies to work at synchronizing these kinds of definitions, GCs must be involved in systematically reviewing statutes to see where they have and do not have flexibility.
One example of success in this domain was through regulations related to the Housing Opportunity Through Modernization Act of 2016 (HOTMA). HUD regulations implementing HOTMA aim to allow more flexibility with data-sharing through upgraded definitions of income and other eligibility criteria. Through its work to integrate overlapping programs, HUD is streamlining eligibility determinations for specific rental assistance programs.
Specifically, the new rules will: [o]nly require each adult household member to sign a consent form one time, instead of annually[;] [e]nable PHAs [Public Housing Agencies]/owners to use income determinations made under other federal benefit programs, which will eliminate redundant work[;] [s]implify income deductions and allow families to self-certify assets up to $50,000[;] [and r]educe the frequency of interim income recertifications.
c. Common Forms and Shared Platforms
The extent to which agencies have shared platforms can also reduce burdens for the public. If all agencies, for example, employ the same identity verification platform, this substantially reduces learning and compliance costs for the public. Another example is the use of Healthcare.gov, a single-entry portal that determines whether one is eligible for subsidies to provide private health insurance and whether or not one is eligible for Medicaid. Statutory guidelines also allow for it to assess eligibility for programs like SNAP. Indeed, some state exchanges allow for applications for SNAP within their state-run health care exchanges. A previous ACUS recommendation noted that more common forms between agencies could also lessen PRA clearance hurdles.
C. Building Capacity: Providing Assistance with Accredited Representatives and Ombuds
Legal aid organizations have deep experience and understanding of the challenges that historically underserved people face in accessing government services and benefits. And indeed, legal aid organizations provided comments in response to the Request for Information from ACUS as part of this project’s research strategy. These comments focused mainly on Social Security and SSI benefits, with some overlap with SNAP, TANF, and Medicaid benefits. A few legal services organizations also focused on taxpayer programs and unemployment insurance.
The comments received from legal services providers provide insight into the nature of challenges experienced by members of the public when attempting to access these vital benefits. These challenges can be sorted into the following buckets: communication barriers, technological barriers, burdensome procedures, and substantive hurdles.
Many commenters expressed frustration at extremely long wait times and failure to receive return phone calls after leaving messages. Mail and fax communications are often lost. Even when mail is a viable option, many people lack reliable mailing addresses and thus can miss communications or deadlines. Internet options vary and can create more burdens regarding account creation and identity verification procedures. There were also repeated themes that plain language and language access are not being used throughout systems, particularly where there are federal and state partnerships. Finally, comments highlighted the need for uniformity of policy and accountability across field offices.
Additionally, legal aid providers were especially attuned to the differences between navigating these processes with and without representation. Burdens exist in both situations, but the cumulative burdens experienced without legal representation can be overwhelming to the point of forgoing benefits rightly entitled. In other cases, errors exacerbated through lack of assistance can result in benefits being wrongly denied.
Specific examples of the challenges added by lack of representation include inaccessibility to claimants’ files, confusion about various forms and their purposes, and missing evidence in the first instance, which can cause an incomplete record that follows a claimant throughout the application process and any subsequent appeals. Disability benefits determinations have long suffered from problems with consistency and accuracy. Recent studies have shown that legal representation at these initial benefits eligibility decision stages produces better outcomes for people who need these benefits. A 2022 study by the National Bureau of Economic Research concluded that “legal representation in the initial stage leads to earlier disability awards to individuals who would otherwise be awarded benefits only on appeal. Furthermore, by securing earlier awards and discouraging unsupported appeals, representation reduces total case processing time by nearly one year.”
However, there are not enough lawyers to assist people with accessing government services and benefits. Due to geography, income, or other restrictions and challenges, people may not have access to free or reduced-cost legal services. There are opportunities to expand available representation beyond the traditional lawyer model. For example, VA has an accredited representative program. The agency accredits VSO representatives to assist with benefits applications free of charge. DOJ has a similar accreditation program for expanding access to representation in immigration matters at USCIS, such as visa applications and Deferred Action for Childhood Arrivals (DACA) applications.
Advocate ombuds in agencies can provide a similar service. According to a 2016 ACUS Report describing the duties of advocate ombuds: “Unlike other ombuds, the advocate ombuds is authorized, or required, to listen to individuals or groups found to be aggrieved. Due to the unique role, this ombuds must have a basic understanding of the nature and role of advocacy, and of legal statutes or regulations.” Ombuds play various roles related to identifying and reducing burdens, as explained by survey results described in the ACUS report:
Ombuds were seen as providing value in assisting visitors to navigate a confusing government bureaucracy, and providing a bridge between concerns of individuals and offices of the government. Particularly noted was the value of the ombuds in providing a voice, and options for understanding and resolution, for populations that would otherwise be ignored or have limited options. Ombuds were credited in helping both internal and external visitors to receive guidance on information and resources, ‘next steps’ they might pursue, and coaching suggestions on conflict resolution strategies. Furthermore, ombuds who were interviewed believe they add value by ‘humanizing’ the federal government and helping others ‘to find their own voice and resolve their own issues.’
Even statutory notification expansions can increase access to representation and reduce administrative burdens felt by underrepresented populations. For example, the Taxpayer First Act specifically authorizes the Secretary of the Treasury to notify taxpayers about Low Income Taxpayer Clinics’ geographic region.
D. Critical Analytic Tools: Rethinking Cost-Benefit Analysis and Requirements
Current agency cost-benefit analyses do not typically incorporate the cost of burdens. According to GAO, agencies “did not consistently address key costs and benefits needed to assess the value of their computer matching programs,” including administrative benefits. And OMB guidance on cost-benefit analysis regarding computer matching programs is extremely general and outdated.
