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Date:         Wed, 29 Jul 1992 12:31:38 GMT
From:         Duncan Aldrich <duncan@equinox.unr.edu>
Subject:      FOMB Circular A-130

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From LISTSERV@PSUVM.PSU.EDU  Wed Jul 29 12:14:13 1992
Message-Id: <9207291914.AA05879@equinox.unr.edu>
Date:      Wed, 29 Jul 1992 15:12:17 EDT
From: Joe Ryan <JORYAN@SUVM.acs.syr.edu>
To: Government Documents List <GOVDOC-L@psuvm.BITNET>

Please post if appropriate.
Thanks in advance!


SUMMARY RECOMMENDATIONS ON PROPOSED OMB CIRCULAR A-130 REVISIONS

>From Discussions Held at the Seminar on Proposed Circular A-130
Strategic Information Resources Management
in the Public Sector Series (SIRM)
Arlington VA
June 10, 1992

Reported By:

Joe Ryan <joryan@suvm.acs.syr.edu>
Charles R. McClure <cmcclure@suvm.acs.syr.edu>
School of Information Studies
Syracuse University
Syracuse, NY  13244-4100


Introduction

   The following summarizes key policy issues and
recommendations from discussions on the Office of Management and
Budget's (OMB) proposed Circular A-130 revisions at a briefing
session sponsored by Syracuse University's SIRM series.
Participants were primarily senior government officials, Federal
librarians, and information policy makers.

   After a half day briefing session on A-130 issues
participants were assigned to groups of 7-10 individuals.  Some
effort was made to limit members from the same agency to one per
group.   Group members were  asked to identify five key issues and
policy recommendations concerning the proposed A-130 revisions.

   The list below is a compilation of the resulting small group
reports and subsequent discussion.  The list reports participants'
comments; no assessment of those comments has been done by the
compilers. A copy of this summary has been sent to the Office of
Management and Budget, Office of Information and Regulatory
Affairs for their consideration and attention.


Key Issues

o  Any Circular should be issued with a sensitivity to, and
awareness of existing and proposed legislation, circulars, and
other regulations.

o  Of the issues to be addressed in Phase II of the OMB Circular
A-130 revisions to be issued this winter proposed changes in cost
recovery  and accounting,  other financial issues, and computer
security were of most immediate concern to workshop participants.

o  Guidelines are needed to resolve the conflicting demands of
agency information dissemination: cost recovery needs of agency
provider; disenfranchisement of citizenry who cannot afford to
pay; potential for marketplace environment among Federal agencies;
prioritizing dissemination demands v. the agency's "true" (or at
least traditional) mission; does dissemination requirements exceed
scope of agency's mission?

o  Policy statements should be flexible and transitional in
nature. Electronic information collection and dissemination is
likely to revolutionize the IRM practices addressed in Circular A-
130.  Some feel that it may be too early to do any more than lay
out broad guidelines.  Others strongly feel the need for specific
guidance now.  Many feel the need for A-130 to address how
agencies should move older information technologies out as new,
electronic means were acquired.  All agreed developments in this
area needed to be watched.

o  What is the agency's role in information dissemination of the
Internet/NREN? Who pays for the Internet/NREN involvement, and
What are appropriate agency roles and responsibilities in the
national network?

o  Should there be policy guidance on the re-packaging and
copyrighting of Federal (not copyrighted) information by State and
Foreign governments?  Should international access to governmental
information be the same as domestic access?

o  To what degree are the archival requirements for agencies
similar to or different than dissemination requirements?

o  Who is the Federal IRM community, who serves as advocates for
IRM managers in the agency, and how are key terms related to IRM
being defined?  There is inadequate information on these points in
the revised Circular.

o  To what degree does Circular A-130 fully address the issues and
policies covered in the Circulars, A-3 and A-114, that it
rescinds?

o  There are too many competing and often-times conflicting
information processing and dissemination standards, more specific
language is needed to sort out what standards are to be used in
what situations.


Recommendations


o  The revised Circular  needs to capture the attention of top
agency officials, in addition to relevant agency middle managers;
someone needs to be held responsible for implementing the policy.

o  Define key terms better and standardize their use among the
circulars (at least).   Identify players and boundaries.

o  Resolve conflicts between existing legislation, regulation, and
policy.  Mentioned hot spots include: Brooks Act, A-130, NARA,
GSA, JCP, FAR.  Key concepts (IRM, oversight, information,
recorded information, value-added) need to be better defined and
related to each other.

o  Promote Depository Library access to agency's electronic
holdings. There was sentiment in written comments for free access
by depositories to agency electronic information be it available
from the agency, GPO or NTIS,  or from private re-sellers.

o  The Circular should devise a mechanism to provide direct public
access to agency databases.

o  Spell out both the electronic and the paper records management
responsibilities that agencies have. A consensus among records
managers present was the need for more specific guidance in the
records management area.  Also mentioned was the need to
strengthen the tenuous relationship between agency FOIA and
records management personnel.

o  Treat all policy regarding information products and their
dissemination in the same Circular, no matter the format.

o  Promote user need studies before, during, and after the
introduction of a new information product and service.  Pay
particular attention to users who do not have adequate access to
new information technologies or choose not to use them.

o  Provide more guidance in cost recovery.  What are acceptable
principles as well as specific practices?  For example, the
Circular should define what is a dissemination cost (and what is
not), clarify the distinction between cost v. price and how to
figure it.  Agencies do not want to have OMB second-guessing them
when they determine user fees.

o  Promote and adopt interconnectivity and interoperability
standards.  There are too many competing and different standards.

o  Discuss the role of contractors and outsourcing particularly
regarding copyright, intellectual property, costing, and access
issues.

o  Develop a mechanism so that fees collected for information
products and services produced by an agency remain in that agency.

o  More clearly delineate the roles of the principal, government-
wide information policy, monitoring, and dissemination agencies
including: OMB, NARA, GSA, GAO, GPO, and NTIS.   Specifically
mentioned was the need to spell out GPO's role in information
reproduction, distribution, and sales (Title 44, USC), especially
in an electronic environment.

o  Integrate, codify, and disseminate existing government
information laws, policies, regulations and standards including
OMB, FIPS, CALS, ISO/OSI, and user interface standards.  The
objective being to enable agencies to be able to go to a single
source to determine existing rules.

o  Integrate OMB policies in this area such as A-3, A-27, A-76, A-
114 and A-130.  In addition, resolve conflicting standards where
they exist.    OMB should consider the creation of an OMB
sanctioned approval process, formalizing the work of existing
interagency working groups and standards makers.

o  The Circular should make clear that public data may also
include the software to access that data.  In addition the
Circular should address the responsibility of agencies to provide
human (help desk) assistance to users accessing agency produced
public data.

o  The Circular should provide more specific language describing
inventory/locator systems, how the agency is to develop locators,
what information content should be contained in the locators, and
how the locator should be made available to the public.

o  The Circular should address the need for continuing education
and training for information professionals in government
particularly in the areas of applications of new information
technologies.  Where possible, incentives should be provided to
both the individuals and the agencies.

o  Attention should be given to mechanisms to ensure that agency
data disseminated to the public are complete, accurate, and
current.

o  The enforcement techniques for the proposed guidelines in OMB
Circular A-130 was conspicuous by its absence.  One suggestion was
to make agency heads responsible for A-130 compliance. Some urged
OMB to use its powers of the purse.  There was a general consensus
that enforcement procedures were lax and should be strengthened.

o  Clarify and prioritize the centrality of information
dissemination to an agency's "true" mission.  Is dissemination in
addition to, high priority, in lieu of, existing agency mandates
(or the existing methods of carrying them out)?  Do all agencies
have a dissemination role?

o  Match A-130's policy guidelines with the agency's "business"
plan and better coordinate OMB's budget process by facilitating
the agency's ability to carry out the guidelines in Circular A-
130.

o  Add explicit reference to the Internet/NREN as a means for
disseminating agency information, encourage agencies to use the
Internet/NREN for dissemination activities and meeting user
information needs, and better define agency roles and
responsibilities in the use of the Internet/NREN.

o  The circular should explicitly address the equity of access
issue -- the degree to which agencies are responsible for
maintaining a "level playing field" in insuring equal access to
electronic information.


ADDITIONAL COMMENTS

   Comments on the proposed A-130 revisions will be accepted
until August 27, 1992.  Comments by post should be addressed to:
Information Policy Branch, Office of Information and Regulatory
Affairs, Office of Management and Budget, Room 3235 New Executive
Office Building, Washington, D.C. 20503.  Electronic comments may
be sent via electronic mail to: <omba130@nist.gov>.  Comments sent
by post or electronically will be included as part of the official
record.
Comments: Gated by NETNEWS@AUVM.AMERICAN.EDU