Paperwork Reduction Research Articles

Counting regulations and measuring regulatory impact: a call for nuance

The effect of regulation on virtually every aspect of the lives of US citizens has led to an understandable impulse to measure this total impact. It has led to various attempts to count the total number of regulations and regulatory requirements, and to total the costs and benefits of regulation. And these counting mechanisms have played prominent roles in discussions over statutory changes designed to reform the process by which we write regulations. However, counting regulations in a meaningful way and measuring their cumulative economic impact is an astonishingly difficult task. For this reason, there have been a wide variety of methods that scholars and advocates have employed in the effort to do so. This article is an attempt to catalog the most prominent methods of counting regulations and measuring regulatory impact in the United States, describe their strengths and weaknesses, and suggest alternative approaches to attack this important question. We suggest both using large language models and detailed analysis of Paperwork Reduction Act data and, at the opposite extreme, doing more qualitative work on the consequences of regulation on individuals, firms, and industries.

THE USE OF ARTIFICIAL INTELLIGENCE IN LAW ENFORCEMENT ACTIVITY

The article presents the results of a study on the use of artificial intelligence in the field of law enforcement, such as facial recognition, crime forecasting, reduction of paperwork, intelligent exchange of knowledge about incidents, assistance in investigating crimes using artificial intelligence algorithms, as well as increasing the efficiency of training and education of law enforcement officers in various organs of the State. At the same time, artificial intelligence in its use in law enforcement activities also carries risks similar to a double-edged sword. Risks in this regard include biased decision-making, privacy concerns, over-reliance on technology, the potential for misinterpretation, security vulnerabilities, job displacement, accountability, and transparency, the potential for abuse, erosion of trust, and legal and ethical implications. Ethical and legal considerations in the synergy of AI and law enforcement have been highlighted, focusing on aspects like bias and discrimination, privacy concerns, accountability and transparency, informed consent. In conclusion, it is noted that although the promise of AI in law enforcement is promising, the risks associated with it require careful consideration, regulation, and oversight.

Blockchain in supply chain management: A review of efficiency, transparency, and innovation

As global supply chains become increasingly complex, traditional systems face challenges in ensuring efficiency, transparency, and innovation. Block chain technology has emerged as a transformative force in addressing these issues, offering a decentralized and secure framework for supply chain management. This paper presents a comprehensive review of the impact of block chain on supply chains, focusing on its potential to enhance efficiency, transparency, and foster innovation. The efficiency gains facilitated by block chain in supply chain management are examined through the elimination of intermediaries, reduction of paperwork, and real-time visibility into the entire process. These improvements result in streamlined operations, reduced costs, and enhanced responsiveness to market dynamics. Moreover, block chain’s decentralized nature ensures data integrity, mitigating the risk of fraud and errors in the supply chain. Transparency is a critical aspect of modern supply chains, and block chain provides an immutable and transparent ledger that enables end-to-end visibility. The technology ensures traceability and accountability, allowing stakeholders to access real-time information about the origin, movement, and status of products. This transparency not only enhances trust among supply chain participants but also facilitates compliance with regulatory requirements. The role of block chain in fostering innovation within supply chains is explored, emphasizing its potential to enable new business models, collaborative ecosystems, and the integration of emerging technologies such as the Internet of Things (IoT) and Artificial Intelligence (AI). The paper highlights case studies and pilot projects where block chain has been successfully applied to drive innovation in supply chain processes. Challenges and considerations related to the implementation of block chain in supply chain management are also discussed, including interoperability, scalability, and regulatory issues. The paper concludes by outlining future research directions and emphasizing the need for industry-wide collaboration to unlock the full potential of block chain in revolutionizing supply chain management. Overall, this review contributes to the understanding of how block chain can serve as a catalyst for efficiency, transparency, and innovation in contemporary supply chains

Letter of PTAAARMIGAN (Patent and Trademark Attorneys, Agents, and Applicants for Restoration and Maintenance of Integrity in Government) to OMB/OIRA re Paperwork Reduction Act violations of DOCX rule (Sep. 5, 2024)

Letter of PTAAARMIGAN (Patent and Trademark Attorneys, Agents, and Applicants for Restoration and Maintenance of Integrity in Government) to OMB/OIRA re Paperwork Reduction Act violations of DOCX rule (Sep. 5, 2024)

Benefits, barriers, and facilitators of using speech recognition technology in nursing documentation and reporting: A cross-sectional study.

Nursing reports are necessary for clinical communication and provide an accurate reflection of nursing assessments, care provided, changes in clinical status, and patient-related information to support the multidisciplinary team to provide individualized care. Nurses always face challenges in recording and documenting nursing reports. Speech recognition systems (SRS), as one of the documentation technologies, can play a potential role in recording medical reports. Therefore, this study seeks to identify the barriers, benefits, and facilitators of utilizing speech recognition technology in nursing reports. This cross-sectional was conducted through a researcher-made questionnaire in 2022. Invitations were sent to 200 ICU nurses working in the three educational hospitals of Imam Reza (AS), Qaem and Imam Zaman in Mashhad city (Iran), 125 of whom accepted our invitation. Finally, 73 nurses included the study based on inclusion and exclusion criteria. Data analysis was performed using SPSS 22.0. According to the nurses, "paperwork reduction" (3.96, ±1.96), "performance improvement" (3.96, ±0.93), and "cost reduction" (3.95, ±1.07) were the most common benefits of using the SRS. "Lack of specialized, technical, and experienced staff to teach nurses how to work with speech recognition systems" (3.59, ±1.18), "insufficient training of nurses" (3.59, ±1.11), and "need to edit and control quality and correct documents" (3.59, ±1.03) were the most common barriers to using SRS. As well as "ability to fully review documentation processes" (3.62, ±1.13), "creation of integrated data in record documentation" (3.58, ±1.15), "possibility of error correction for nurses" (3.51, ±1.16) were the most common facilitators. There was no significant relationship between nurses'demographic information and the benefits, barriers, and facilitators. By providing information on the benefits, barriers, and facilitators of using this technology, hospital managers, nursing managers, and information technology managers of healthcare centers can make more informed decisions in selecting and implementing SRSfor nursing report documentation. This will help to avoid potential challenges that may reduce the efficiency, effectiveness, and productivity of the systems.

КОНЦЕПТУАЛЬНІ ОСНОВИ ЦИФРОВІЗАЦІЇ МЕНЕДЖМЕНТУ ПЕРСОНАЛУ

Digitalization is more than just a trend in HR management. All labor related processes are changing, putting forward new demands and expectations for modern personnel management. Digitalization transforms the traditional business model. Organizations implement a digital approach, develop and implement innovations in personnel management to remain competitive in business. Modern conditions encourage organizations to develop employee-oriented HR practices with the support of digital technologies to achieve the best results and maintain competitiveness in the market. The purpose of the article is to analyze the theoretical aspects of digitalization, its impact on personnel management processes, and to determine the most effective HRM system on the domestic market. The theoretical foundations of the digitalization for personnel management processes were analyzed and their influence was determined. Advantages and disadvantages of implementing software as a digitalization tool are considered. Among the advantages are: the search and selection of personnel, monitoring of performance, management of salaries and bonuses, as well as personnel training. The criteria for the review of HRM systems were: data security, interface convenience, cost, Self and Performance management, adaptability on different devices, availability of analytics, OKR and recruiting module, polls in the system. The popular domestic HRM systems were analyzed: BambooHR, Zoho People, Personio, Hurma System, Sage HR. It was concluded that the Ukrainian Hurma System is the most effective, because if it is evaluated according to the criteria mentioned above, it has OKR, unified HR and recruiting, also it lets create a survey in the system. Therefore, when implementing digitalization, the company receives the following advantages: flexibility, economy and efficiency; cost reduction; improved security; accuracy in data analysis; reduction of paper work; better communication; improved quality of work. Among the disadvantages are: lack of trust in digital data; lack of knowledge about how to effectively use technology; in some cases, loss of subjectivity.

217 THE USE OF SIILO MESSAGING APP BETWEEN HOSPITAL-BASED FRAILTY INTERVENTION THERAPY TEAM AND COMMUNITY-BASED EMERGENCY DEPARTMENT IN THE HOME TEAM

Abstract Background Effective communication is an important component of any healthcare system. There is frequent communication of patient care and information between the EDITH (Emergency Department In The Home) and the FIT (Frailty Intervention Therapy) teams, which are based across two sites. Traditionally handovers between therapists were completed via email/ fax. Siilo is a secure medical messaging app designed to facilitate instant communication of patient information between healthcare professionals in a confidential manner. Methods A 3-month pilot of the Siilo app was commenced in August 2021 to improve the flow of information between teams, facilitate timely decision making and improve patient care. A questionnaire to rate speed, efficiency, accuracy, accessibility and confidentiality on a 4point scale was completed by all therapy staff members. Qualitative questions regarding positive and negative aspects, and future suggestions were included. Results Pre-pilot the median time from EDITH assessment to receipt of handover was 20 hours. During the pilot, median time to handover was 1 hour. Speed, efficiency and accessibility of communication between teams received a median rating of 2 (“average”) pre-pilot, increasing to 4 (“excellent”) during the pilot. Accuracy and confidentiality received a median rating of 3 (“good”) pre-pilot, improving to a median rating of 4 (“excellent”). 100% of respondents reported Siilo had a positive impact on decision making and on patient care.Qualitative themes included; earlier acute care discharge planning; ease of use and reduction in paperwork. Suggestions to further improve communication between the services were made and will be explored at a later date. Conclusion A significant reduction in time from assessment to handover improved the flow of communication between the teams, reduced duplication of assessments and improved patient care for older patients. Confidentiality and accuracy were maintained over this period. The use of the app will be continued and suggestions to further improve the integration between the services will be implemented.

Stakeholder, Sponsor, and Child Care Provider Perspectives on Barriers and Facilitators to Child Care Center Participation in the Child and Adult Care Food Program (CACFP)

ObjectivesThe Child and Adult Care Food Program (CACFP) is a federally-regulated, state-administered program that reimburses early care and education (ECE) programs for serving nutritional meals to low-income children. CACFP participation is voluntary and varies among states. This study explored barriers and facilitators of ECE participation in CACFP, and identified strategies to promote participation by eligible programs. MethodsA mixed-methods study of 4 states with varying levels of ECE participation in CACFP. Stakeholders from 22 CACFP-associated agencies, representatives of 17 sponsor organizations, and 40 center-based ECE program directors were interviewed; 100 ECE directors completed surveys. In total, 66% of the ECE programs were in CACFP. ResultsKey barriers to CACFP participation included cumbersome enrollment and reimbursement paperwork, strict eligibility requirements, concerns about non-compliance penalties, strict meal patterns, low-reimbursement levels, and lack of on-site cooking facilities. Facilitators identified by participants were the outreach and technical assistance provided by stakeholders and sponsors, paperwork organizational systems established by sponsors, and trainings and nutrition education provided by stakeholders and sponsors. From the surveys, directors reported it was helpful that CACFP covered the cost of food (87%), served healthy meals (78%), provided meals to at-risk children (49%), kept tuition low (38%), and helped them serve a variety of foods (26%). Nearly all directors agreed that CACFP was “very important/important” to their program (94%), and would recommend CACFP to others (94%). Suggested strategies to promote CACFP participation focused on paperwork reduction, modification to eligibility requirements, increased reimbursement rate, leniency with unintentional non-compliance errors, and outreach/provision of additional technical assistance to ECE programs. ConclusionsCACFP confers critical nutritional benefits, but key barriers can impact program participation. Policy changes are needed at the federal and/or state levels to address these barriers. Funding SourcesHealthy Eating Research, a national program of the Robert Wood Johnson Foundation (RWJF); and the School of Public Health at Indiana University Bloomington.

Blockchain in Healthcare Today Best Article Award 2020

The award was announced during the ConV2X 2021 conference, themed “Blueprint for a New Digital Health Era,” broadcast November 9-11, 2021. The winning article is titled: "The Last Mile: DSCSA Solution Through Blockchain Technology: Drug Tracking, Tracing, and Verification at the Last Mile of the Pharmaceutical Supply Chain with BRUINchain," by lead author William Chien (PharmD, MBA) and fellow authors from UCLA Health and LedgerDomain. The article is located at https://doi.org/10.30953/bhty.v3.134. The groundbreaking article was part of the FDA’s Pilot Project Program for the Drug Supply Chain Security Act (DSCSA), and centered on a healthcare center pharmacy operating solely on commercial off-the-shelf (COTS) technology. It presented the highest number of BHTY 2020 reader engagements, with the most downloads and views. The study demonstrated a 100% success rate across scanning, expiration detection, and counterfeit detection; and paperwork reduction from approximately 1 hour to less than a minute. Projecting out to 4.2 billion prescriptions being dispensed each year in the United States, the study found that distributed ledger technologies (such as blockchain) would not only save $183 million in annual labor costs, but also avert bad or fraudulent transactions, reduce the need for safety stock, and enhance the detection and removal of potentially dangerous drugs from the drug supply chain to protect U.S. consumers.

A BPM-based framework for the impact assessment of blockchain to the midstream LNG supply chain

PurposeThe current study addresses how blockchain can deal with the challenges that the midstream liquefied natural gas (LNG) supply chain poses combined from a management standpoint. Such challenges are: the volume of transactions, communication hurdles and the lack of contemporary management tools. The paper proposes a comprehensive framework to assess the impact of blockchain implementation in the midstream LNG supply chain in order to tackle those barriers.Design/methodology/approachThe basis of the research is the business process modelling (BPM), through which entities, roles, tasks, resources and transactions can be modelled and simulated. The modelling of the midstream LNG supply chain, via BPM, is based on guidelines of the Society of International Gas Tanker and Terminal Operators (SIGGTO) and common industry business models. A quantitative analysis is employed to support the motivation and the potential impact of blockchain implementation. The methodology is used to identify (1) inefficiencies related to large volume of transactions between stakeholders and (2) critical areas of an LNG shipping company, where blockchain can be implemented.FindingsProcess repeatability, numerous shared documentation forms, excessive paperwork and communication imbroglios are mapped from the modelling section. Up to 327 processes are repeated during a typical vessel voyage, and up to 122 shared documentation forms are exchanged. Excessive paperwork and communication imbroglios are tracked through, which correspond to 25 severe errors as detected. By implementing the methodology, stakeholders can quantify the possible impact of blockchain on the operational performance of each stakeholder's operations separately and the supply chain as a whole in terms of real-time monitoring, transparency and paperwork reduction, time and cost savings.Research limitations/implicationsThe research has certain limitations deriving from its conceptual nature. The business processes' modelling is based on standard procedures described in the guidelines by SIGGTO and may need further adjustment for specific use cases. A structured case study has not been realisable as corporate data for an LNG shipping company regarding processes and other commercial sensitive information are required.Practical implicationsPotential practitioners may exploit the proposed framework as a low cost and seamless tool to evaluate how blockchain could disrupt their operations. Thus, the blockchain implementation's improvements or weaknesses can be pinpointed, and enabling the interested stakeholder of the LNG supply chain with specific feedback, it can guide them towards informed decisions on their operations.Originality/valueThe research has a novel approach as it combines the creation of practical management framework, with a comprehensive visualization of the midstream LNG supply chain. Thus, the reader can identify in which parts of the midstream LNG supply chain can blockchain be implemented, and what impact it could have in terms of supply chain operations.

Напрями вдосконалення системи управління державними фінансами країни

The article analyzes the system of public finance management of the country, identifies a number of existing problems and outlines areas for further improvement and development. Emphasis is placed on the need to apply best practices in public finance management, in particular the introduction of a new instrument for coordinating fiscal and economic policy, called the European Semester, a tool for monitoring compliance with fiscal rules, similar to the German debt brake, and appropriate regulatory measures as well as the application of program-target budgeting method. It is expedient to create in Ukraine a tool similar to the European Semester in order to strengthen monitoring of the formation and implementation of fiscal, budgetary, economic policy of the state, promote broad public involvement and other stakeholders in 7collectivediscussion of budget requests, plans, concepts, socio-economic development strategies, carrying out structural economic reforms. The authors focus on the existing system of public finance management of the country, which requires an integrated approach, taking into account all components as a holistic mechanism of the system. It is emphasized that digitalization of the entire system and reduction of paperwork to zero will improve its manageability. In reforming the public financial management system, it is necessary to determine the unique role of each institution, which operates within a single mechanism and affects the effectiveness of its work, including those that assess its condition and ensure the reliability of the system, stimulate effective levers and tools finances. This will increase the efficiency of the distribution of budget expenditures, ensure the rational use of budget funds, sustainable dynamics of socio-economic development of the country, increase the welfare of citizens. Keywords: budget, budget funds, budget expenditures, public finance management system, socio-economic development of the country.

P120 Developing “My quality of life” programme based on ICHOM Standard Set for IBD: 1-year results

Abstract Background Inflammatory bowel diseases (IBD) are chronic relapsing diseases of unknown etiology, usually beginning at a young age. Although life expectancy of IBD patients is near to the mean of healthy population, IBD has a significantly negative impact on patients’ quality of life. Recent research has evidenced that a poorer quality of life can contribute to relapse or worsening of IBD symptoms, reduce treatment adherence and lead to poorer outcomes. The Ezkerraldea-Enkarterri-Cruces Healthcare Organization in Spain has made a firm commitment to adopt the Value-Based Health Care (VBHC) model, which advocates for the incorporation of patient-perceived quality of life variables to the items we normally assess. The IBD Unit, in pursuit of adhering to the VBHC corporate programme, has launched on a process to analyze our health care delivery system and improve the effectiveness of our Performance Improvement Plan based on patients’ experience. Objectives: - To identify and systemize the incorporation of perceived quality of life variables - To reorient medical care towards what really matters to patients Methods We have built a multi-disciplinary team comprised of healthcare professionals involved in IBD management (Figure 1). Patients form the core of the team’s meetings, helping in the development of User Experience (Figure 2) and Empathy Maps (Figure 3) by using Design Thinking strategies. After the detection of the obstacles faced by patients, we outlined a Process Map (Figure 4), where we critically analyzed the route followed by patients in our health-care system before reaching the IBD Unit. Subsequently, a specific route was outlined considering the set proposed for the disease by the ICHOM consortium as a reference framework. Questionnaires and surveys were designed using patient information across different areas of care, in order to guarantee the correct functioning of the route. Results We obtained a list of 14 improvement proposals which are currently at different levels of evaluation. In our first year, we have been able to implement important modifications which include: - A specific remote consultation for IBD patients - Fast track pathways - Nutritional guidelines to assure compliance - Shortening waiting lists - Reduction in patient bureaucracy and paperwork - Virtual monitorization of patients with asymptomatic disease Conclusion - VHBC implementation implies a transformation of the organization - User Experience tools add a different perspective to the route design, focusing on what really matters to patients and improving their quality of life - This change of perspective is important, especially in chronic diseases, so that patients feel less lonely with their disease and better outcomes can be obtained

Hand Character Recognition Systems: A Review

“Handwritten Char. Recognition”, is also known as “HCR”. It is a dynamic and developing area which has seen substantial improvements due to the use of in various areas. One of the exciting fields of machine learning and artificial intelligence is text detection. Numerous methods and techniques are used to classify characters. However, the techniques for translating textual content from a paper document into a machine-readable form were defined as preliminary studies and paperwork. The character recognition system may be a critical factor in establishing a paperless world by digitizing existing paper documents in the coming days. Numerous researches have been conducted in this field, but as handwriting styles differ from each human, it remained an active area of research. The biggest challenge is to obtain the highest possible character recognition accuracy rate, which will inevitably lead to a reduction in manual paperwork. The aim's to enhance handwriting text recognition s/w with a better accuracy, which makes it perfect, reducing the complexity of its space-time. Several papers have implemented a new diagonal-based feature extraction method, which generates a high precision rate than traditional feature extraction methods. This project aims at designing an expert system for HCR (English) using Neural Network. Using the Artificial Neural Network approach, this can effectively recognize a specific character of type format. This paper shows an overview of the field of recognition of Handwritten Text.

Автоматизация базы данных запасных частей и агрегатов лесозаготовительной техники

For reduction of paperwork and time for information retrieval, an electronic resource was created for an enterprise providing maintenance and repair for forestry equipment. A brief description of the facility is given, its capabilities are shown and recommendations for further improvement are proposed.

Big data driven supply chain design and applications for blockchain: An action research using case study approach

Blockchain appears to still be nascent in its growth and a relatively untapped asset. This research investigates the need of blockchain in Industry 4.0 environment from Big Data perspective in supply chain management. The research method used in this study involves a combination of an Action Research method and Case Study research. More specifically, the action research method was applied in two industry case studies that implemented and tested the designed architecture in a global logistics environment. Case Study A examined the blockchain application in cross-border cargo movements whereas Case Study B investigated the application in a liquid chemical logistics company serving to petroleum industries. Our research analysis has identified that the Case A subject had disconnected systems and services for blockchain wherein the big data interactions had failed (failure case). Whereas in Case B, the company has achieved nearly 25% increase in revenue through its customer service after the blockchain implementation and thereby reduction in paperwork and carbon emissions (success case). This research contributes to the advancement of the body of knowledge to big data and blockchain by identifying key implementation guideline and issues for blockchain in supply chain management. Further, action-based research coupled with a case study approach has been used to evaluate the application aspects of the architecture's scalability and functionality of bigdata and blockchain in supply chain management.

Identifying Best Practices in Pharmacy Experience: An Analysis of Military Treatment Facilities With the Highest Pharmacy Patient Experience Scores.

Pharmacy patient experience within military treatment facilities (MTFs) is a significant indicator of healthcare quality, as hospital admissions correlate with medication use (Budnitz etal., 2006) and pharmacists have a unique opportunity to influence patients' health (Dalton & Byrne, 2017). To improve patient care across the military health system (MHS), we investigated best practices within MTF pharmacies with the highest patient experience scores. Researchers performed semi-structured telephone interviews with pharmacists, pharmacy technicians, and patient experience officers from three of the highest ranked MTF pharmacies according to outpatient satisfaction survey results to glean "best practice" approaches to patient care. Researchers utilized the Gioia approach as a guiding theory for qualitative analysis of the interview data, and the study was excluded from a requirement to obtain institutional review board approval due to the number of respondents in accordance with the Paperwork Reduction Act of 1980 guidelines. Interview participants from highly rated pharmacies emphasized the importance of communication among and between staff and patients, staff engagement and morale, and supportive leadership at their facilities for creating a positive patient experience and clinical environment. These findings provide valuable insights to improve public health in military-connected populations through improved patient care practices in pharmacies across the MHS. Initiatives aimed at improving health care for pharmacy patients should prioritize improved communication and structural support for team members to create patient-friendly environments, which enables pharmacists and technicians to connect with patients and positively impact health outcomes. Limitations include lack of comparison data for lower performing pharmacies; future research will explore practices at lower ranking pharmacies to provide insights into communication practices, environments, and staff relationships impacting patient experience scores as well as the role patient demographics (e.g., retirees vs. active duty) and characteristics including facility size play in potential improvements.

91 Patent and Trademark Practitioners, Comment letter to PTO, Control Numbers 0651-0035 60-day notice, Representative and Address Provisions (Mar. 12, 2021)

91 patent and trademark practitioners to comment on the PTO’s burden estimates for Representative and Address Provisions, and to recommend various steps the PTO can take to minimize burden as required by the Paperwork Reduction Act, 44 U.S.C. § 3506(c)(2)(A)(iv); 5 C.F.R. § 1320.5(d). The signatories are members of several email listserv groups, and subscribers to several organizational blogs. The signatories taken together have filed many thousands of patent and trademark applications at the PTO during the past ten years. The Paperwork Reduction Act requires the PTO to establish “objective” estimates of burden, and to use comment periods like this one to solicit recommendations to “reduce[ ] to the extent practicable and appropriate the burden on persons” who file papers at the agency. 44 U.S.C. § 3506(c)(3)(C). The time estimates in the notice are entirely implausible, off by a factor of 10 to 30. They are not “objectively supported” as required by law. We offer corrected estimates, and recommendations that could reduce burden by about $100 to $150 million per year.

85 Patent Practitioners, Comment letter to OMB, Control Number 0651-0012 30-day notice, <i>Admission to Practice and Roster of Registered Patent Attorneys and Agents Admitted to Practice Before the PTO</i> (Mar. 28, 2021)

OMB should approve PTO's request for Control Number 0651-0012, subject to terms of clearance that approve only status quo ante collections of information. In August and October of 2020, the PTO issued two new collections of information without statutory procedure: one by guidance, one by a new regulation dropped into a final rule without an NPRM, neither with any of the antecedent procedure required by the Paperwork Reduction Act (PRA), OIRA’s Information Collection regulations, or Executive Order 12866. The new regulation and proposed guidance document propose that the PTO intends to (1) collect information regarding continuing legal education for patent practitioners, in the form of (2) a required biennial practitioner registration statement. The information gathering burden of these two collections of information is currently in full effect, even though first submission to the agency won’t be required until March 1, 2022, and even though the PTO’s Supporting Statement admits the PTO has no clearance. OIRA should disallow these new collections of information. These collections are already creating substantial annual paperwork burden. We observe that the PTO’s Supporting Statement estimates the burden for these collections to be only $1.6 million, but as demonstrated herein and in 60-day and rulemaking comments, this number is far too low. Estimates of burden range from $120 to $150 million annually. None of the three relevant Federal Register notices proposed burden estimates, and none requested comment as required by 44 U.S.C. § 3506(c)(2)(A).

95 Intellectual Property Practitioners, Comment letter to OMB, Control Number 0651-0032, Initial Patent Applications, update re PTO computer systems failure of Mar 6-8, 2021 (Mar. 12, 2021)

95 users of the Patent and Trademark Office’s computer systems alert OIRA to new facts that arose earlier this week, on March 6-8, 2021. These new facts give further impetus to comments on this ICR in the November 60-day comment period and the December 30-day comment period. This letter does two things: (a) adds further facts that must be considered in this ICR, to urge that PTO’s request for approval for DOCX filing should not be approved; and (b) invokes OIRA’s authority under 44 U.S.C. § 3504, § 3506(c)(3)(J), § 3506(h)(3), 5 C.F.R. § 1320.8(d)(1)(iv), to assist the PTO in implementation of appropriate information technology. Recent issues with the PTO’s electronic filing system suggest that the PTO may lack ability to objectively evaluate its own technological decisions, is vastly underestimating burden on the public, and is almost certainly overestimating savings to itself. Many of the problems stem from inappropriate technology. Fifteen years ago, when it was developing the current electronic filing system for patent applications, the PTO made an incredibly poor design decision. The PTO included an extra, unnecessary step in its processing of documents that users submit electronically: the PTO throws out some of the information that users submit. But the PTO needs this information in every application. So the PTO’s computers first throw out the information, and then recompute and reconstruct the information. Notably, analogous computer systems at all other leading patent offices worldwide and all U.S. federal courts work by not throwing out the information—the PTO is an outlier. The PTO is developing a replacement system, now in beta test. The PTO could have simply eliminated the “throwing out” step. Instead, the PTO now proposes to add another unnecessary step. The new step makes the filing process far more unreliable for the public. We agree with the Boundy and Forrest estimates submitted during the 60-day comment period, that the additional burden will be about $200 million per year, because users will have to error check the PTO’s processing before hitting “submit.” As any engineer knows, adding a new failure-prone component to “compensate” for an old failure-prone component never compensates; it increases the likelihood of error. Likewise, adding human error is only a good idea as a way to compensate for computer error if the PTO single-mindedly considers only its own costs, and ignores burden on the public and the requirements of the Paperwork Reduction Act—as the PTO quite pointedly did in its NPRM and final rule.

E tumau le fa'avae ae fesuia'i faiga

E tumau le fa'avae ae fesuia'i faiga