All- I have been tasked by the FIRM council to draft a reply to OMB in regards to the Government Paperwork Elimination Act (GPEA). To view the actual GPEA, go to http://www.fws.gov/laws/G-PEA.html To view the OMB letter that we are responding to, go to http://www.whitehouse.gov/OMB/fedreg/gpea.html

I need your help. Please read my draft below. If you have any comments you can post them directly to this discusion forum. This reply is from all of us so make your voice heard! Thanks. ----------------------------------------------------------------- June 3, 1999 In reply to: Government Paperwork Elimination Act Office of Management and Budget Information Policy and Technology Branch Office of Information and Regulatory Affairs Office of Management and Budget Room 10236 New Executive Office Building Washington, D.C. 20503 Attention: Peter Weiss Dear Office of Management and Budget, OMB proposed implementation of the GPEA This reply is a compilation of comments received from the Federal Information and Records Managers Council (FIRM). I would first like to tell you more about our organization. The purpose of FIRM is to improve the efficiency and effectiveness of Information and Records Managers functions in all agencies by providing a forum for sharing knowledge, resources, and methodologies for the implementation and evaluation of systems and practices. Objectives of the FIRM Council include: A. Providing leadership to the FIRM Community as it creates partnerships with archivists, librarians, program staff, technical staff, the information industry, professional associations, and other information management professionals to: 1. manage the life cycle of federal information, and 2. protect the nation's documentary heritage.

B. Providing advice and assistance to the National Archives and Records Administration (NARA); the Office of Management and Budget; the Government Accounting Office; the Office of Personnel Management; the National Institute for Standards and Technology; the General Services Administration; and other federal entities charged with oversight of information and records management.

C. Providing a forum to advance professional knowledge and techniques through educational programs, workshops, seminars, and by sharing experiences, approaches, and information related to the records management profession.

Our comments to your package are below:

7 Where will the funding come from to allow agencies to procure, install and customize electronic record keeping software by October 2003? For large agencies like the Department of Defense, this could be over a billion dollars if it will be installed on everyone's desktop computer. Is Congress planning to add additional funds for the purpose of this Act? 7 To our knowledge, there is not a federal government wide standard in place for digital signatures. Can we assume that one will be in place by October 2003 that all agencies can subscribe to? 7 How does the GPEA tie into e-FOIA? The GPEA does not acknowledge e-FOIA. We feel the implementation of GPEA needs to incorporate e-FOIA's requirements. 7 OMB needs to seriously consider consulting the National Archives and Records Administration as well as the Commerce Department to implement GPEA. 7 It is always good to include a risk assessment when determining which technology is approved. Glad to see that language in the GPEA. 7 The biggest obstacles to the government going paperless are its employees. This is a new way of doing business and will require a total mind shift of all employees. What training measures will the GPEA deploy to facilitate a smooth transaction? If nothing is in place, it will take much longer than October 2003 to complete this mission. Where does it talk about training in the GPEA? 7 Although there is proven customer and citizen acceptance of PIN's this is no way to ensure security of electronic information. Again, we have to change the mind-set of the people. 7 Most ERMS gives you security features that ensure that no one is able to alter a transaction/document/record once it has been received by the agency. 7 The Summary of the procedures and Checklist was well done. Should be a good framework for agencies. However, it is critical that agencies realize that due to the GPEA they might have to change their internal processes and they need to begin looking at that in conjunction with the electronic filing and digital signatures. Sincerely, Carol Brock, Chairperson FIRM Council

-- Anonymous, June 10, 1999

Answers

Charley, Some observations we have follow:

Mayn of our public use forms are used less than 1000 times per year. The Act requires OMB to ensure that Executive agencies provide for the option of the electronic maintenance, submission, or disclosure of information "when practicable" as a substitute for paper commencing October 21, 2003. Thus, the Act seems to provide OMB some flexibility. Maybe OMB could set a threshold in the regulation based on form usage and allow agencies to decide if low use forms should be subject to electronic submission. Agencies would evaluate these forms from the perspective that electronic submission makes good business sense and results in a burden reduction for the public.

The regulation mentions several important Acts agency's need to draw and feed from (Part I, Section 2.b) but does not refer to the Federal Records Act and ensuing requirements. Methods used to preserve electronic records for future need is of great concern to many parties including the legal, audit and investigative communities. Records retention and archiving requirements will need to be considered when designing and implementing electronic forms.

-- Anonymous, June 14, 1999