The ICR White Paper: Proposed Options for Demonstrating Program Rigor and Streamlining the ICR Process


Angela Helman, Industrial Economics Incorporated


Traditionally, OMB has favored the use of experimental designs (randomized control trials) for information collections supporting performance measurement and program evaluation of EPA programs. However, methodological problems often arise when applying experimental designs to EPA programs, especially smaller programs and non-regulatory programs. These methodological problems include infeasibility of random assignment, difficulty in establishing baseline conditions, sample bias, multiple confounding factors, and the inability to capture spillover effects. These methodological problems, combined with delays in obtaining clearance for information collection (ICR clearance), have led to unintended consequences including reducing the availability of measurement and evaluation findings to inform policy-making at EPA. This white paper explores options for demonstrating program effectiveness and streamlining the ICR process. We look forward to discussing options with fellow evaluators and gaining feedback.

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