Conformity in the face of ambiguity: A bureaucratic dilemma

TLDR: In this article, the review and approval by the U.S. Office of Management and Budget (OMB) of government's plans to collect information from persons or entities outside it is discussed.

Abstract: One of the central problems in the analysis of bureaucracy involves the occasions in which the formal rules of the system fail to provide adequate guidance. Bureaucrats must then attempt not only to decide whether or not to follow the applicable rules, but also to determine, individually and collectively, which rules apply in which situations. How can bureaucrats establish their conformity to the rules of the system in the face of such ambiguity? This paper addresses this question through the analysis of a specific bureaucratic process in the federal government in the United States: the review and approval by the U.S. Office of Management and Budget (OMB) of government's plans to collect information from persons or entities outside it. Specifically, the paper provides an overview of federal information collection policy, a description of the process through which this policy is exercised, an analysis of the kinds of argument marshalled among the participating bureaucrats to determine the utility of particular information collections, and examples of the process at both its simplest and most complex. As shall be seen in the concluding section, the consideration of this process militates for a view of bureaucratic behavior that straddles the divide between administrative and ethnomethodological approaches to the subject. This last point, however, suggests the need for a brief review of the approach taken to the subject prior to the description of the review process itself.