Information Management: The Challenges of Managing Electronic Records
Published: 2010-06-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Federal agencies are increasingly using electronic means to create, exchange, and store information, and in doing so, they frequently create federal records: that is, information, in whatever form, that documents government functions, activities, decisions, and other important transactions. As the volume of electronic information grows, so does the challenge of managing electronic records. Both federal agency heads and the National Archives and Records Administration (NARA) have responsibilities for managing federal records. As requested, after providing some context about records management in the federal government and the roles of federal agencies and NARA, this testimony describes the challenges of electronic records management and potential means of addressing these challenges. In preparing this testimony, GAO relied primarily on its previous work, supplemented by analysis of publicly available documents.
section_title: What GAO Found
paragraphs: Under the Federal Records Act, agencies are to manage the creation, maintenance, use, and disposition of records in order to achieve adequate and proper documentation of the policies and transactions of the federal government and effective and economical management of agency operations. If records are poorly managed, individuals might lose access to benefits for which they are entitled, the government could be exposed to legal liabilities, and records of historical interest could be lost forever. NARA is responsible, among other things, for providing records management guidance, assistance, and oversight. However, as GAO has previously reported, records management has received low priority within the federal government. Prior reports have identified persistent weaknesses in federal records management, including a lack of policies and training. GAO's most recent report, in 2008, found weaknesses in e-mail management at the four agencies reviewed due in part to insufficient oversight and training. This year, NARA published the results of its first annual agency records management self-assessment survey, indicating that almost 80 percent of agencies were at moderate to high risk of improper disposition of records. Electronic records are challenging to manage, especially as electronic information is being created in volumes that pose a significant technical challenge to the ability to organize and make it accessible. Further, electronic records range in complexity from simple text files to highly complex formats with embedded computational formulas and dynamic content, and new formats continue to be created. Finally, in a decentralized environment, it is difficult to ensure that records are properly identified and managed by end users on individual desktops (the "user challenge"). E-mail is particularly problematic, because it combines all these challenges and is ubiquitous. Technology alone cannot solve the problem without commitment from agencies. Electronic recordkeeping systems can be challenging to implement and can require considerable resources for planning and implementation, including establishing a sound records management program as a basis. In addition, the "user problem" is not yet solved, particularly for e-mail messages. Further, automation will not solve the problem of lack of priority, which is of long standing. However, several developments may lead to increased senior-level attention to records management: NARA's use of public ratings as a spur to agency management, growing recognition of risks entailed in poor information and records management, the requirements and emphasis of the recent Open Government Directive, and the influence of congressional oversight. Senior management commitment, if followed through with effective implementation, could improve the governmentwide management of electronic and other records.

section_title: Letter
paragraphs: I appreciate the opportunity to discuss critical issues surrounding  electronic records management in the federal government. As you  are aware, federal agencies are increasingly using electronic means  to create, exchange, and store information, and in doing so, they  frequently create federal records. According to the Federal Records  Act, federal records are information in whatever form that  documents government functions, activities, decisions, and other  important transactions, and such records must be managed and  preserved in accordance with the act. As the volume of  electronically stored information grows, so does the challenge of  managing electronic records.
As requested, after providing some context about records  management in the federal government and the roles of federal  agencies and the National Archives and Records Administration  (NARA), my statement will focus on describing the challenges of  electronic records management and potential means of addressing  these challenges.
My comments today are based primarily on our previous work, all of  which was conducted in accordance with generally accepted  government auditing standards, supplemented by analysis of  information contained in publicly available documents, following  appropriate GAO quality assurance processes.
subsections: section_title: Background
paragraphs: The federal government collects, generates, and uses large amounts  of information in electronic form, from enormous geographic  databases to individual e-mails. Much of that information can  constitute official federal records, and agencies must have ways to  manage such records.
subsections: section_title: Federal Agencies and NARA Have Responsibilities for Federal Records Management
paragraphs: Under the Federal Records Act, each federal agency is required to  make and preserve records that (1) document the organization,  functions, policies, decisions, procedures, and essential transactions  of the agency and (2) provide the information necessary to protect  the legal and financial rights of the government and of persons  directly affected by the agency’s activities. If these records are not  effectively managed, individuals might lose access to benefits for  which they are entitled, the government could be exposed to legal  liabilities, and historical records of vital interest could be lost  forever. In addition, agencies with poorly managed records risk  increased costs when attempting to search their records in response  to Freedom of Information Act requests or litigation-related  discovery actions. Finally, without effective management of the  documentation of government actions, the ability of the people to  hold the government accountable is jeopardized.
Effective records management is also an important tool for efficient  government operation. Without adequate and readily accessible  documentation, agencies may not have access to important  operational information to make decisions and carry out their  missions.
Accordingly, to ensure that they have appropriate recordkeeping  systems with which to manage and preserve their records, agencies  are required to develop records management programs.  These  programs are intended, among other things, to provide for accurate  and complete documentation of the policies and transactions of  each federal agency, to control the quality and quantity of records  they produce, and to provide for judicious preservation and disposal  of federal records.
Among the activities of a records management program are  identifying records and sources of records and providing records  management guidance, including agency-specific recordkeeping  practices that establish what records need to be created in order to  conduct agency business.
Under the Federal Records Act and the regulations issued by NARA,  records must be effectively managed throughout their life cycle,  which includes records creation or receipt, maintenance and use,  and disposition. Agencies create records to meet the business needs  and legal responsibilities of federal programs and (to the extent  known) the needs of internal and external stakeholders who may  make secondary use of the records. To maintain and use the  records created, agencies are to establish internal recordkeeping  requirements for maintaining records, consistently apply these  requirements, and establish systems that allow them to find records  that they need. Disposition involves transferring records of  permanent, historical value to NARA for archiving and destroying all  other records that are no longer needed for agency operations.
One key records management process is scheduling, the means by  which NARA and agencies identify federal records and determine  time frames for disposition. Creating records schedules involves  identifying and inventorying records, appraising their value,  determining whether they are temporary or permanent, and  determining how long records should be kept before they are  destroyed or turned over to NARA for archiving. For example, one  general records schedule permits civilian agencies to destroy case  files for merit promotions (2 years after the personnel action is  completed, or after an audit by the Office of Personnel Management,  whichever is sooner). No record may be destroyed or permanently  transferred to NARA unless it has been scheduled, so the schedule is  of critical importance. Without schedules, agencies would have no  clear criteria for when to dispose of records and, to avoid disposing  of them unlawfully, would have to maintain them indefinitely.
Scheduling records, electronic or otherwise, requires agencies to  invest time and resources to analyze the information that an agency  receives, produces, and uses to fulfill its mission. Such an analysis  allows an agency to set up processes and structures to associate  records with schedules and other information (metadata) to help it  find and use records during their useful lives and dispose of those  no longer needed.
Records schedules are based on content and are media-neutral; that  is, electronic records are classified on the same basis—by content— as physical records. In addition, agencies are to compile inventories  of their information systems, after which the agency is required to  develop a schedule for the electronic records maintained in those  systems.
NARA also has responsibilities related to scheduling records. NARA  works with agencies to help schedule records, and it must approve  all agency records schedules. It also develops and maintains general  records schedules covering records common to several or all  agencies. According to NARA, records covered by general records  schedules make up about a third of all federal records. For the other  two thirds, NARA and the agencies must agree upon agency-specific  records schedules.
Under the Federal Records Act, NARA is given general oversight  responsibilities for records management as well as general  responsibilities for archiving—the preservation in the National  Archives of the United States of permanent records documenting  the activities of the government. Of the total number of federal  records, less than 3 percent are permanent. (However, under the act  and other statutes, some of the responsibilities for oversight over  federal records management are divided across several agencies.  Under the Federal Records Act, NARA shares a number of records  management responsibilities and authorities with the General  Services Administration (GSA). The Office of Management and  Budget (OMB) also has records management oversight  responsibilities under the Paperwork Reduction Act and the E- Government Act.)
For records management, NARA is responsible for issuing guidance;  working with agencies to implement effective controls over the  creation, maintenance, and use of records in the conduct of agency  business; providing oversight of agencies’ records management  programs; approving the disposition (destruction or preservation) of  records; and providing storage facilities for agency records. The act  also gives NARA the responsibility for conducting inspections or  surveys of agency records and records management programs.
section_title: Federal Records Management Has Been Given Low Priority and Has Had Persistent Weaknesses
paragraphs: Historically, despite the requirements of the Federal Records Act,  records management has received low priority within the federal  government. As early as 1981, in a report entitled Federal Records  Management: A History of Neglect, we stated that “persistent  records management shortcomings” had been attributed to causes  that included “lack of commitment by top management, emphasis  on agency missions, and the low priority of records management.”  Almost 30 years later, the priority problem has remained remarkably  persistent.
For instance, a 2001 study prepared for NARA by SRA International,  Inc., on perceptions in the federal government with respect to  records management, concluded that recordkeeping and records  management in general receive low priority, as evidenced by lack of  staff or budget resources, absence of up-to-date policies and  procedures, lack of training, and lack of accountability. This  assessment also concluded that although agencies were creating  and maintaining records appropriately, most electronic records  remained unscheduled, and records of historical value were not  being identified and provided to NARA for archiving.
In 2002, drawing on the 2001 study, we reported that the low priority  given to records management programs was a factor in program  weaknesses. We noted that records management is generally  considered a “support” activity. Because support functions are  typically the most dispensable in agencies, resources for and focus  on these functions are often limited.
In 2008, we reported on weaknesses in federal e-mail management  at four agencies. The four agencies reviewed generally managed e- mail records through paper-based processes, rather than using  electronic recordkeeping. (A transition to electronic recordkeeping  was under way at one of the four agencies, and two had long-term  plans to use electronic recordkeeping.) We attributed weaknesses in  agency e-mail management (such as senior officials not conforming  to regulations) to factors including insufficient training and  oversight regarding recordkeeping practices (as well as the  onerousness of handling large volumes of e-mail)—similar to the  effects of low priority described by SRA. Accordingly, we  recommended that agencies with weaknesses in oversight, policies,  and practices develop and apply oversight practices, such as  reviews and monitoring of records management training and  practices, that would be adequate to ensure that policies were  effective and that staff were adequately trained and were  implementing policies appropriately.
Further evidence of the persistence of the priority issue was  provided in 2008, when NARA surveyed federal senior managers  about their perception of records management. According to the  survey, only 64 percent of managers saw records management as a  useful tool for mitigating risk.
In April 2010, NARA released a report on its first annual records  management self-assessment, which analyzed responses to a survey  sent in September 2009 to 245 federal cabinet-level agencies, agency  components, and independent agencies. According to NARA, the  survey results showed that almost 80 percent of agencies were at  moderate to high risk of improper disposition of records. For  example, the survey found that not all agencies had appropriate  policies in place for handling e-mail, and that only a little over half  of the responding agencies had training in place for high-level  executives and political appointees on how to manage e-mail; this is  consistent with the finding in our 2008 report on e-mail practices  regarding insufficient training and oversight regarding  recordkeeping practices. NARA rated almost half of the responding  agencies (105 of 221) as high risk in the area of e-mail.
NARA’s survey also indicated, among other things, that a large  proportion of agencies have not scheduled existing systems that  contain electronic records. In December 2005, NARA issued a  bulletin requiring agencies to have NARA-approved records  schedules for all records in existing electronic information systems  by September 30, 2009. 27 percent of agencies responding to NARA’s  September 2009 agency self-assessment survey indicated that fewer  than half of their electronic systems were scheduled. Such large  numbers of unscheduled systems are a problem for agencies  because their records cannot legally be disposed of, with the  consequences for increased cost and risk mentioned earlier.
NARA concluded that the varying levels of agency compliance with  its records management regulations and policies have implications  for the government’s effectiveness and efficiency in conducting its  business, protecting citizens’ rights, assuring government  accountability, and preserving our national history.
section_title: Our Previous Reports Have Recommended Strengthening NARA’s Oversight Approach
paragraphs: The Federal Records Act gave NARA responsibility for oversight of  agency records management programs by, among other functions,  making it responsible for conducting inspections or surveys of  agencies’ records and records management programs and practices;  conducting records management studies; and reporting the results  of these activities to the Congress and OMB.
We have made recommendations to NARA in previous reports that  were aimed at improving NARA’s insight into the state of federal  records management as a basis for determining where its attention  is most needed. In 1999, in reporting on the substantial challenge of  managing and preserving electronic records in an era of rapidly  changing technology, we noted that NARA did not have  governmentwide data on the electronic records management  capabilities and programs of all federal agencies. Accordingly, we  recommended that NARA conduct a governmentwide survey of  these programs and use the information as input to its efforts to  reengineer its business processes. However, instead of doing a  governmentwide baseline assessment survey as we recommended,  NARA planned to obtain information from a limited sample of  agencies, stating that it would evaluate the need for such a survey  later.
In 2002, we reported that because NARA did not perform systematic  inspections of agency records management, it did not have  comprehensive information on implementation issues and areas  where guidance needed strengthening. We noted that in 2000,  NARA had suspended agency evaluations (inspections) because it  considered that these reached only a few agencies, were often  perceived negatively, and resulted in a list of records management  problems that agencies then had to resolve on their own. However,  we concluded that the new approach that NARA initiated (targeted  assistance) did not provide systematic and comprehensive  information for assessing progress over time. (Only agencies  requesting assistance were evaluated, and the scope and focus of  the assistance were determined not by NARA but by the requesting  agency.) Accordingly, we recommended that it develop a strategy  for conducting systematic inspections of agency records  management programs to (1) periodically assess agency progress in  improving records management programs and (2) evaluate the  efficacy of NARA’s governmentwide guidance.
In response to our recommendations, NARA devised a strategy for a  comprehensive approach to improving agency records management  that included inspections and identification of risks and priorities.  Subsequently, it also developed an implementation plan that  included undertaking agency inspections based on a risk-based  model, government studies, or media reports.
In 2008, we reported that under its oversight strategy, NARA had  performed or sponsored six records management studies in the  previous 5 years, but it had not conducted any inspections since  2000, because it used inspections only to address cases of the  highest risk, and no recent cases met its criteria. In addition,  NARA’s reporting to the Congress and OMB did not consistently  provide evaluations of responses by federal agencies to its  recommendations, as required, or details on records management  problems or recommended practices that were discovered as a  result of inspections, studies, or targeted assistance projects.
Accordingly, we recommended that NARA develop and implement  an oversight approach that provides adequate assurance that  agencies are following NARA guidance, including both regular  assessments of agency records and records management programs  and reporting on these assessments. NARA agreed with our  recommendations and devised a strategy that included annual self- assessment surveys, inspections, and reporting. It has now begun  implementing that strategy, having released the results of its first  governmentwide self-assessment survey, as mentioned earlier.
section_title: Managing Records in Electronic Form Presents Major Challenges
paragraphs: As we have previously reported, electronic records pose major  management challenges: their volume, their complexity, and the  increasingly decentralized environment in which they are created. E- mail epitomizes the challenge, as it is not only voluminous and  complex, but also ubiquitous.  ●  Huge volumes of electronic information are being created.
Electronic information is increasingly being created in volumes that  pose a significant technical challenge to our ability to organize it and  make it accessible. An example of this growth is provided by the  difference between the digital records of the George W. Bush  administration and that of the Clinton administration: NARA has  reported that the Bush administration transferred 77 terabytes of  data to the Archives on leaving office, which was about 35 times the  amount of data transferred by the Clinton administration. Another  example is the Department of Energy’s National Energy Research  Scientific Computing Center, which said that, as of January 2009, it  had over 3.9 petabytes of data (that is, about 4,000,000,000,000,000  bytes) in over 66 million files and that the volume of data in storage  doubles almost every year.  ●  Electronic records are complex.
Electronic records have evolved from simple text-based files to  complex digital objects that may contain embedded images (still and  moving), sounds, hyperlinks, or spreadsheets with computational  formulas. Some portions of electronic records, such as the content  of dynamic Web pages, are created on the fly from databases and  exist only during the viewing session. Others, such as e-mail, may  contain multiple attachments, and they may be threaded (that is,  related e-mail messages are linked into send–reply chains). They  may depend heavily on context. For example, to understand the  significance of an e-mail, we may need to know not only the identity  but the position in the agency of the sender and recipients. (Was it  sent by an executive or a low-level employee?) In addition, new  technologies, such as blogs, wikis, tweets, and social media,  continue to emerge, posing new challenges to records managers.   ●  Identification and classification of electronic records are difficult  in a decentralized computing environment.
The challenge of managing electronic records significantly increases  with the decentralization of the computing environment. In the  centralized environment of a mainframe computer, it is  comparatively simple to identify, assess, and manage electronic  records. However, in the decentralized environment of agencies’  office automation systems, every user can create electronic files of  generally unstructured data that may be formal records and thus  should be managed. Documents can be created on individuals’  desktop computers and stored on local hard drives. E-mail can come  from outside the agency. In cases like these, the agency generally  depends on the individual to identify the document or the e-mail as a  record, and, through placing it in a recordkeeping system, associate  it with its appropriate schedule, make it searchable and retrievable,  and preserve it until it is due for disposal.
As we reported in 2008, e-mail is especially problematic. E-mail  embodies several major challenges to records management:  ●  It is unstructured data, and it can be about anything, or about  several subjects in the same message, making it difficult to classify  by content.   ●  There is a very large volume of it: one study estimates that a typical  corporate user sends or receives around 110 messages a day.  Further, there may be many copies of the same e-mail, which can  increase storage requirements or require a means of determining  which copy to keep. Keeping large numbers of messages potentially  increases the time, effort, and expense needed to search for  information in response to a business need or an outside inquiry,  such as a Freedom of Information Act request.  ●  It is complex: e-mail records may have multiple attachments in a  variety of formats, they may include formatting that is important for  meaning, and they include information about senders, recipients,  and time of sending. Recordkeeping systems must be able to capture  all this information and must maintain the association between the  e-mail and its attachment(s).  ●  Its relevance depends on context. It may be part of a message thread  that is necessary to understand its content, or it may discuss other  documents or issues that are not well identified. An e-mail that says  “I agree. Let’s do it” may be about a major decision or about going to  lunch next week.  ●  It may not be obvious who is responsible for identifying an e-mail as  a record and at what point. NARA regulations require that both  senders and recipients may be responsible for identifying records.  However, an e-mail may have multiple recipients and be forwarded  to still other recipients.
section_title: Agency Commitment Is a Prerequisite for Addressing the Electronic Records Challenge
paragraphs: As NARA has pointed out, the decision to move to electronic  recordkeeping is inevitable, but as we and NARA have previously  reported, implementing such systems requires that agencies commit  the necessary resources for planning and implementation, including  establishing a sound records management program as a basis.  Further, automation will not, at least at the current state of the  technology, solve the “end user problem”—relying on individual  users to make sound record decisions. Nor will automation solve the  problem of lack of priority, which, as our previous work has shown,  is of long standing. However, several developments could lead to  increased senior-level attention to records management: NARA’s use  of public ratings as a spur to agency management, growing  recognition of risks entailed in poor information and records  management, the requirements and emphasis of the recent Open  Government Directive, and the influence of congressional oversight.  Senior management commitment, if followed through with effective  implementation, could improve the governmentwide management of  electronic and other records.
subsections: section_title: Electronic Recordkeeping Systems Are Challenging to Implement and Will Not Yet Solve the End User Problem
paragraphs: Moving to electronic recordkeeping is not a simple or easy process.  Agencies must balance the potential benefits against the costs of  redesigning business processes and investing in technology. Our  previous work has shown that such investments, like any  information technology investment, require careful planning in the  context of the specific agency’s circumstances, in addition to well- managed implementation.
In 2007, a NARA study team examined the experiences of five  federal agencies (including itself) with electronic records  management applications, with a particular emphasis on how these  organizations used these applications to manage e-mail. Among the  major conclusions was that although the functionality of the  software product itself is important, other factors are also crucial,  such as agency culture and the quality of the records management  program in place. With regard to e-mail in particular, the survey  concluded that for some agencies, the volume of e-mail messages  created and received may be too overwhelming to be managed at  the desktop by thousands of employees across many sites using a  records management application alone. A follow-up study in 2008  added that although a records management application offers  compliant electronic recordkeeping, “it can be expensive to acquire,  time consuming to prepare for and implement, requires user  intervention to file records, and can be costly over the long haul for  data migration and system upgrades.” NARA found that in most  instances agencies had to work to overcome user resistance to using  the system.
This user challenge has led records management experts to believe  that end users cannot be relied on to manage e-mail records, or  indeed any other types of records. A recent Gartner study concluded  that user-driven classification of records, especially e-mail, has  failed and will continue to fail; a study by the Association for  Information and Image Management (AIIM) stated “it is simply not  plausible to expect all creators of records to perform accurate,  manual declaration and classification.” According to Gartner,  “What enterprises really need (and want) is a mechanism that  automatically classifies messages by records management type …  without user intervention.” At the time of writing (August 2007),  Gartner described such technology as “in its infancy,” but expected  it to mature rapidly because of high demand.
This technology, automated records classification (sometimes called  “autocategorization”), might help address the user problem. (The Air  Force is currently working with autocategorization projects.)  However, like other information technology, it requires resources  for setup and maintenance to be effective, and it is not simple to  implement. Further, according to AIIM, autocategorization might  not work for an agency’s particular documents or file plan, and  might not be sufficiently accurate or cost effective.
Some proposals have been made to simplify the e-mail problem.  Gartner recommends treating e-mail as a separate issue from  general records management, perhaps by putting all e-mail in a  single category of temporary records with a uniform retention  period. Similarly, the Director of Litigation in NARA’s Office of  General Counsel has suggested keeping all e-mail created by key  senior officials (with some additional designations by agency  components) as permanent and treating all the rest as temporary.  Both proposals would make managing e-mail simpler, but could  increase the risk that significant information will not be preserved.
section_title: Recent Developments Could Help Spur More Action on Information and Records Management
paragraphs: Raising the priority of records management has been and continues  to be an uphill battle. As we have reported, government needs to  prioritize the use of resources, and records management has not  been a high priority. Further, records management can also be time-  and resource-consuming and technically difficult to implement.
NARA can influence this situation by providing effective guidance  and assistance to agencies, as well as through its oversight and  reporting activities. With its recently initiated annual self- assessment survey, NARA is responding to our earlier  recommendations on oversight by beginning an effort to develop a  comprehensive view of the state of federal records management as a  basis for determining where its attention is most needed. Reporting  the results of the survey, with scores for individual agencies and  components, to the Congress, OMB, and the public is one way to  help bring the records management issue to the attention of senior  agency management.
Another factor that could help raise awareness of the value of  records management is the growing recognition of the risks of weak  electronic records and information management, as a result of fear  of potentially large costs to organizations that have to produce  electronically stored information to respond to litigation, as well as  well-publicized incidents of lost records, including e-mail. This  recognition of risk is coupled with increased awareness of the value  of organizations’ information assets; according to AIIM, the field of  enterprise content management (which includes records  management) has been accepted, driven by the need to control the  content chaos that pervades local drives, file shares, email systems,  and legacy document stores. As a result, according to an AIIM  survey, the highest current priorities for ECM activity are electronic  records management and managing e-mails as records.
Further, recent Open Government initiatives, which emphasize the  importance of making information available to the public for  transparency and accountability, could be an additional impetus to  addressing electronic records management. OMB’s Open  Government Directive makes a direct link between open  government and records management by requiring that each  agency’s Open Government Plan include a link to a publicly  available Web site that shows how the agency is meeting its existing  records management requirements. More generally, the directive  urges agencies to use modern technology to disseminate useful  information. According to an Administration official, records  management plays a crucial role in open government by ensuring  accountability through proper documentation of government  actions. Increased attention to information and records  management could provide another spur encouraging agencies to  devote resources to managing their electronic records more  effectively.
Finally, the priority that agencies give to addressing weaknesses  may be increased by hearings such as this, which show that the  Congress recognizes the importance of good records management  for the efficient, effective, and accountable operations of  government.
In summary, federal records management has been given low  priority for many years. However, the explosion of electronic  information and records is an increasing risk to agencies, and could  even become a drag on agencies’ ability to perform their missions if  not brought under control.
Raising visibility, as NARA is doing by publishing the results of its  self-assessment survey, can raise the perception among senior  agency officials of the importance of records management. Also  significant is the push for Open Government, which, by heightening  the importance of agencies’ providing information to the public,  makes information a more central part of their missions and could  help highlight the actual importance to agencies of actively  managing their information. Strong indications from the Congress  that records management needs more attention could also raise the  priority among agency management.
Mr. Chairman, this completes my prepared statement. I would be  pleased to respond to any questions you or other Members of the  Subcommittee may have at this time.
section_title: Contact and Acknowledgments
paragraphs: If you should have questions about this testimony, please contact  me at (202) 512-6304 or melvinv@gao.gov. Other major contributors  include Barbara Collier, Lee McCracken, J. Michael Resser, and  Glenn Spiegel.
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