USDA Electronic Filing: Progress Made, But Central Leadership and Comprehensive Implementation Plan Needed
Published: 2001-02-28T00:00:00

Fast Facts:

Highlights:
section_title: What GAO Found
paragraphs: The Department of Agriculture (USDA) has made progress in implementing the Freedom to E-File Act and has partially met the act's initial deadlines for providing agricultural producers with access to forms via the Internet and submitting required reports on initial e-file activities and plans to Congress. However, implementing full e-filing capabilities for all its farm service customers by the deadlines set by the act poses a far more complex and difficult challenge. Critical to the success of any such initiative is the necessary authority and responsibility to manage it across different departmental entities. Yet no single official has been so designated. Also, a comprehensive implementation plan--one that addresses both the Government Paperwork Elimination Act (GPEA), the Freedom to E-File Act requirements, and Office of Management and Budget's (OMB) implementation guidelines--is critical to help USDA achieve a more consistent approach in its entire e-government transformation.

section_title: Letter
paragraphs: On June 20, 2000, the President signed the Freedom to E-File Act  (P.L. 106-222), requiring the Department of Agriculture (USDA) to establish  an electronic filing and retrieval system enabling farmers and other  agricultural producers to access and file paperwork electronically with the  department. Provisions of the act set forth separate implementation  requirements and deadlines for USDA’s county-based agencies (CBA)—the  Farm Service Agency (FSA), the Natural Resources Conservation Service  (NRCS), and the Rural Development (RD) mission areas—and for USDA’s  Risk Management Agency (RMA). At your request, we reviewed measures  being taken by USDA to implement the act and briefed your office on the  results of our work on November 15, 2000. The briefing slides are included  in appendix I.
This report provides a high-level summary of the information presented at  that briefing and includes the results of additional follow-up work we  conducted at USDA through December 31, 2000. It also presents  recommendations we are making to USDA to help ensure that e-file  mandates are met.
subsections: section_title: Background
paragraphs: USDA’s CBAs provide services such as farm loans and conservation  assistance along with rural and economic development help. Under the E- File Act, these agencies were required to establish an electronic filing and  retrieval system enabling farmers and other agricultural producers to  access departmental forms, such as farm loan applications, via the Internet  by December 18, 2000. Along with the December 18 deadline for  establishing the forms-retrieval system, the Secretary of Agriculture was  also to report to Congress by that date on progress made in implementing  the act. The law further mandated that by June 20, 2002, agricultural  producers be able to file paperwork electronically with USDA if they  choose to do so.
RMA administers the federal crop insurance program, which helps protect  producers against losses due to drought, flooding, and other unavoidable  causes. By December 1, 2000, it was to submit to Congress a plan for  enabling producers to obtain forms and information, such as crop  insurance applications and production and yield reports, over the Internet.  Implementation of the plan is to be completed by December 1, 2001.
In addition to addressing the mandates of the Freedom to E-File Act, USDA  is—like other agencies—preparing to implement plans in accordance with  the GPEA.
section_title: Departmental Actions to Address the E-File Act
paragraphs: To develop and implement USDA’s e-file capabilities, on August 30, 2000,  the Secretary of Agriculture issued a memorandum to the undersecretaries  of the affected agencies and assigned them and mission area leaders with  collective responsibility. The Secretary’s memorandum also required that  one shared plan be developed and implemented to meet E-File Act  requirements. The Secretary gave the Office of Chief Information Officer  (OCIO) the role of coordinating and facilitating e-file implementation  planning and required that the plan be submitted to OCIO no later than  September 30, 2000.
In response to the Secretary’s directive, the undersecretaries transmitted a  “Mission Area Report on Freedom to E-File Legislation” to OCIO on  October 17, 2000. While providing general information, it lacked specifics  on activities and milestones, dependencies among USDA activities, and  needed resources. It also did not assign a senior-level official with overall  accountability for managing and ensuring the implementing disparate e-file  activities.
section_title: CBAs Actions to Address E-File Requirements
paragraphs: To address their e-file requirements, the CBAs had two separate  interagency teams working together to meet the act’s December 18, 2000,  deadline—one consolidating and developing electronic forms and the other  building a technical infrastructure for expanding Internet use. For example,  the CBAs purchased an on-line common forms software tool for creating  electronic forms, selected forms to post on the Web, and designed and  begun implementing a common Internet Web site. At the time of our  November briefing, the CBAs still needed to obtain OMB approval for each  electronic form, complete testing of the Web page, train county-based field  staff in the new e-file procedures, publicize the department’s e-file services,  and notify the public on how to use them.
The CBAs progress in meeting the E-File Act’s December 18 deadline was  discussed in a report to Congress signed by the Secretary of Agriculture on  December 22, 2000. Our review found that, by the December 18 deadline,  the CBAs had successfully established a common Internet Web site,  obtained OMB approval for 52 FSA and NRCS forms, and placed them on  the Internet. However, none of the 100-plus RD forms that the CBAs  expected to have deployed on the Web site by the deadline were available.  According to USDA documentation, OMB had not approved these forms  because some forms appeared to be for the department’s internal use, did  not have clear and user-friendly instructions, or did not include forms  instructions that conformed to the format standard established by OMB  and the agencies. As of December 31, 2000, RD had not resubmitted any of  its forms for OMB review.
A marketing brochure, being developed by the CBAs to promote public  awareness of the e-file effort, was still in production at the end of  December 2000, and the CBAs had decided not to issue any press releases  publicizing the new e-file Web site. In addition, because the CBAs decided  that training needs for service center employees were minimal at this phase  of the project, informational directives on the new program were provided  to employees in lieu of giving them training.
Fully meeting all remaining e-file mandates to successfully establish  effective and secure electronic filing capabilities by June 2002 poses far  more complex and difficult tasks for USDA, such as reengineering business  processes and establishing reliable and secure methods of transmitting and  storing all electronic records. Moreover, since the E-File Act requires USDA  to continue providing services through non electronic means as well, the  department will also face increased workload demands supporting dual  service delivery functions—one electronic and one paper-based. At the end  of our review in December 2000, USDA did not have a detailed plan for how  it would implement these actions and had not identified how much funding  or what staff resources would be required to carry out them out.
section_title: RMA Actions to Address E-File Requirements
paragraphs: In response to the E-File Act, RMA began work on the required December  1, 2000, plan for allowing agricultural producers the option of obtaining,  over the Internet from approved insurance providers, all forms and other  information, and filing all paperwork required for participation  electronically. RMA’s initial efforts focused on establishing and distributing  guidelines and policies for crop insurance providers to follow in meeting  their e-file responsibilities. By the time of our November briefing, RMA had  issued its final e-file guidelines.
RMA met the December 1, 2000, deadline for submitting a plan to Congress.  This plan outlines the process the agency will use to ensure that insurance  providers comply with the act’s e-file requirements. Specifically, insurance  providers must follow RMA’s issued guidelines and submit a completed e-business plan to RMA for approval no later than April 1, 2001. RMA said it  expects full implementation, as the act requires, by December 1, 2001.
section_title: Conclusions
paragraphs: USDA has made progress and has partially met initial E-File Act deadlines  for providing agricultural producers with access to forms via the Internet  and submitting required reports on initial e-file activities and plans to  Congress. However, implementing full e-filing capabilities for all its farm  service customers by the deadlines set by the act poses a far more complex  and difficult challenge. A component critical to the success of any such  initiative is the necessary authority and responsibility to manage it across  different departmental entities, yet no single official has been so  designated. Also, a comprehensive implementation plan—one that  addresses both GPEA, the Freedom to E-File Act requirements, and OMB’s  implementation guidelines—is critical to help the department achieve a  more consistent approach in its entire e-government transformation.
section_title: Recommendations for Executive Action
paragraphs: To ensure that USDA fully meets its E-File Act mandates, we recommend  that the Secretary of Agriculture  assign a senior-level official with overall responsibility, authority, and  accountability for managing and carrying out implementation for both  CBAs and RMA E-File Act requirements;   direct the assigned official to work with RD and OMB to expedite  resubmission and approval of all appropriate RD forms and ensure that  these forms are made available over the Internet as soon as possible;  and  direct the assigned official, in cooperation with the undersecretaries for  Farm and Foreign Agricultural Service, Natural Resources and  Environment, and Rural Development, and the OCIO, to develop and  document a comprehensive plan for implementing all E-File Act  requirements.
In developing the department’s comprehensive plan, we further  recommend that the Secretary of Agriculture direct the assigned senior  official to document and track all critical activities and milestones,  dependencies among major activities, and resources needed to complete  these efforts. In addition, the plan should clearly  describe all project tasks, their priorities, and time frames and  milestones for their completion;  assign task responsibilities to staff and show critical dependencies   identify required staff/budget resources for completing the plan; and   document contingency actions planned to address unforeseen work  delays or problems.
We also recommend that the Secretary direct the assigned senior official to  include both e-file and GPEA requirements in the department’s  comprehensive plan to help better coordinate actions across USDA  agencies and apply a consistent approach for addressing all mandated  requirements and deadlines during USDA’s e-file government  transformation.
Finally, we recommend that the Secretary hold the senior official  accountable for carrying out the comprehensive plan and require that this  official provide quarterly reports to the Secretary describing the results of  USDA’s efforts to implement each of these actions and all e-file  requirements.
On November 8, 2000, we provided a copy of our briefing materials, which  were used in preparing this report, to USDA’s CIO, deputy CIO, and officials  representing USDA’s CBAs and RMA. These officials generally agreed with  our briefing. They stated that providing more focused leadership and  having a comprehensive implementation plan for the e-file effort would  increase the department’s overall chances of success with fully  implementing the Freedom to E-File Act. In its December 22, 2000,  progress report to Congress, and consistent with our recommendations,  USDA said that it plans to begin an effort to develop comprehensive project  plans for enhanced services that meet the 2-year requirements of the  Freedom to E-File Act and GPEA in January 2001.
section_title: Agency Comments and Our Evaluation
paragraphs: On February 13, 2001, USDA’s Acting CIO provided written comments on a  draft of this report. USDA’s comments are summarized below and  reproduced in appendix II.
USDA said that it fully supports the spirit and intent, as well as the legal  mandates, of the e-file act. USDA agreed that it had problems meeting the  act’s initial December 18, 2000, deadline for deploying electronic forms on  the Internet and that significant challenges remain to fully implement the  act. USDA also stated that successful implementation of the act will require  continued funding, along with understanding and support of the USDA’s  programs or “owners” of the business being transformed.
USDA agreed with our recommendation for making RD forms available on  the Internet as soon as possible. The department also agreed that  comprehensive plans must be developed for implementing the Freedom to  E-File Act and GPEA to help better coordinate across agencies and apply a  consistent approach for addressing USDA’s e-transformation. However, the  department stopped short of describing the extent to which its  comprehensive plan will include all the detailed steps we recommended or  what the department’s time frame is for completing it.
Moreover, it was unclear from USDA’s response whether the department  planned to implement our recommendation for assigning a senior-level  official with overall e-file responsibility, authority, and accountability for  managing and carrying out implementation of the E-File Act requirements.  With respect to our last recommendation for providing the Secretary  quarterly reports on implementation results, USDA stated that OCIO will  continue to ensure that the Secretary is fully informed on the department’s  progress in meeting the E-File Act requirements. However, the department  did not specify when and how progress will be reported to the Secretary  nor did it describe how accountability for results will be ensured. We  continue to believe that having a senior-level official vested with sufficient  accountability and authority is important to the success of USDA’s e-file  implementation efforts.
section_title: Objective, Scope, and Methodology
paragraphs: As requested, our objective was to review measures being taken by the  department to implement the provisions of the Freedom to E-File Act. In  carrying out our work, we obtained and reviewed USDA and contractor  documents and discussed actions planned or under way with department  officials handling implementation of the act and assessed progress made.  On November 15, 2000, we briefed your staff on the results of our review up  to that point. Our work on the briefing was performed from August through  October 2000. We performed follow-up work to update USDA’s progress  implementing the act through December 31, 2000. The results of all of our  work are summarized in this report. We conducted our review at USDA  headquarters in Washington, D.C., and at key agency offices involved in e- file activities in Fort Collins, Colorado, and Kansas City, Missouri. Our  work was done in accordance with generally accepted government auditing  standards.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from its  date. At that time, we will send copies to Representative Eva Clayton,  Ranking Minority Member, Subcommittee on Department Operations,  Oversight, Nutrition, and Forestry, House Committee on Agriculture;  Senator Richard Lugar, Chairman, and Senator Tom Harkin, Ranking  Member, Senate Committee on Agriculture, Nutrition, and Forestry;  Representative Larry Combest, Chairman, and Representative Charles  Stenholm, Ranking Minority Member, House Committee on Agriculture;  Representative Tom Davis, Chairman, Representative Jo Ann Davis, Vice  Chairwoman, and Representative Jim Turner, Ranking Minority Member,  Subcommittee on Technology and Procurement Policy, House Committee  on Government Reform; and Representative Stephen Horn, Chairman,  Representative Ron Lewis, Vice Chairman, and Representative Janice  Schakowski, Ranking Minority Member, Subcommittee on Government  Efficiency, Financial Management and Intergovernmental Relations, House  Committee on Government Reform. We will also send copies to the  Honorable Ann M. Veneman, Secretary of Agriculture; the Honorable  Mitchell E. Daniels, Jr., Director, Office of Management and Budget; and  other interested parties. Copies will also be made available to others upon  request.
Should you have any questions on matters discussed in this report, please  contact me at (202) 512-6257 or Stephen A. Schwartz, Senior Assistant  Director, at (202) 512-6213. We can also be reached by e-mail at  mcclured@gao.gov and schwartzs@gao.gov, respectively.
section_title: Briefing on USDA Freedom to E-File
subsections: section_title: Purpose
subsections: section_title: • Brief Requester on USDA’s Efforts to Implement Electronic
section_title: Background
subsections: section_title: Freedom to E-File (P.L. 106-222, June 20, 2000)
subsections: section_title: Requires the Farm Service Agency (FSA), Natural Resources
paragraphs: Conservation Service (NRCS), and Rural Development (RD) mission area--hereafter referred to collectively as County- based Agencies (CBAs), and the Risk Management Agency (RMA) to establish an electronic filing and retrieval system enabling farmers and others to file paperwork electronically.
Provides separate requirements for the CBAs and RMA.
section_title: Background (cont’d.)
subsections: section_title: Major E-File Act provisions CBAs* Not later than December 18, 2000, the Secretary shall establish
paragraphs: an Internet-based system enabling agricultural producers to access all forms and shall submit to Congress a report that describes the progress made.
Not later than June 20, 2002, the system shall be expanded to enable producers to access and file all forms and, at the option of the Secretary, selected records and information.
section_title: Background (cont’d.)
subsections: section_title: Major E-File Act provisions RMA* Not later than December 1, 2000, RMA should submit to
paragraphs: Congress a plan to allow agricultural producers the option of obtaining, over the Internet from approved insurance providers, all forms and other information and filing all paperwork required for participation electronically.
Not later than December 1, 2001, RMA should complete implementation of the plan. *RMA administers the federal crop insurance program, under which insurance policies are sold and serviced by private companies to help protect agricultural producers against crop losses due to drought, flooding, and other unavoidable causes.
section_title: Background (cont’d.)
subsections: section_title: Government Paperwork Elimination Act of 1998 (GPEA, P.L.
paragraphs: 105-277, October 28, 1998)* requires that by 2003, federal agencies provide the public, where practicable, the option of submitting, maintaining, or disclosing information--such as employment records, tax forms, and loan applications-- electronically, instead of on paper.
On the basis of guidance issued by the Office of Management and Budget (OMB), agencies are preparing plans for implementing GPEA, including the use of electronic signatures. *P.L. No. 105-277, Div.C, tit XVII.
section_title: Objective, Scope, and Methodology
subsections: section_title: Objective
subsections: section_title: Obtained and reviewed USDA documents, including internal
section_title: Departmental Actions to Address E-File Requirements
subsections: section_title: On August 30, 2000, 2 months after enactment of the Freedom to
paragraphs: E-File Act, the Secretary issued a memorandum to the undersecretaries for the affected agencies, requiring that  one shared plan be developed and implemented to meet E- File Act requirements and the plan be submitted to Office of Chief Information Officer (OCIO) no later than September 30, 2000.
section_title: Consistent with USDA’s current organizational structure, the
paragraphs: Secretary assigned the undersecretaries and mission area leaders with collective responsibility for developing and implementing e-file activities and gave OCIO the role of coordinating/facilitating e-file implementation planning.
section_title: Departmental Actions to Address E-File Requirements (cont’d.)
paragraphs: In response to the Secretary’s memorandum, the undersecretaries approved and transmitted the “Mission Area Report on Freedom to E-File Legislation” to the CIO on October 17, 2000.
The report, which included two separate sections covering the CBAs and RMA, provides general information on USDA activities to address e-file requirements. establish and define all major activities and milestones, dependencies among activities, and resources necessary to complete them or  assign a senior-level official with overall responsibility and accountability for managing and implementing all the separate e-file activities.
section_title: CBAs Actions to Address E-File Requirements
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
subsections: section_title: Specifically, as of October 31, 2000, CBAs had
paragraphs: purchased an on-line common forms software tool for  selected a total of 219 forms (57 from FSA, 6 from NRCS, and 156 from RD) to post on the Web (USDA believes customers can complete these on their own with assistance only from form completion instructions),  coordinated with OMB to develop a user-friendly format and are working to obtain OMB approval for each new electronic form, and  designed and is implementing a common Internet Web site that can utilize a single Internet address to provide user access with common search and retrieval functions for all available forms.
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
subsections: section_title: However, USDA officials told us that considerable work remains
paragraphs: to be done to meet the December 18 deadline.  For example,  CBAs still need to obtain final OMB approval for each of the  contractor testing of the Web page design, which is not addressed in the October 17 report, was scheduled to be completed December 15, the last workday before the deadline, and  some key technical staff who were implementing web farm hardware, software, and security had other full-time duties and had no replacements should they be assigned elsewhere.
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
paragraphs: plans still needed to be established to train county-based field office staff in the new e-filing procedures and in providing customer assistance and  publicizing USDA’s new e-file services and notifying the public on how to use them still needed to be done.
USDA officials working on these activities believe that these tasks can be accomplished by the December 18 deadline.
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
paragraphs: establishing full e-government services across a broad range of USDA  building in solutions that also address GPEA and OMB requirements. reengineering numerous existing programs and systems,  using multiple electronic submission processes to accommodate various categories of agency customers,  designing and investing in technology to securely connect service center agencies to customers and to USDA’s national network,  developing software to move and utilize data collected from customers to appropriate serving locations, and training employees in new roles, responsibilities, and technologies.
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
subsections: section_title: Adding further to the challenge is the need to accommodate
paragraphs: workload increases.
E-File Act requires USDA to continue providing services in the traditional way to customers who choose not to use the Internet.
CBAs must therefore support dual service delivery functions--one electronic and one paper-based.
section_title: Moreover, USDA officials told us the department had not yet
paragraphs: identified how much funding and staff resources will be needed to fully implement the act.
The E-File Act provides that the Secretary is to reserve, from applicable accounts of the CBAs, not more than $3 million for fiscal year 2001 and $2 million for each subsequent fiscal year.
Decisions on use of these accounts and funding are still pending.
section_title: CBAs Actions to Address E-File Requirements (cont’d.)
subsections: section_title: According to USDA’s October mission area report, detailed
paragraphs: planning on how USDA will carry out the tasks needed to meet the June 20, 2002, deadline for implementing full electronic filing capabilities will not begin until January 2001.
section_title: RMA Actions to Address E-File Requirements
paragraphs: In response to the E-File Act, RMA is working on a December 1, 2000, plan for allowing agricultural producers the option of obtaining, over the Internet from approved insurance providers, all forms and other information and filing all paperwork required for participation electronically. *These were issued in final on November 1, 2000.
section_title: RMA Actions to Address E-File Requirements (cont’d.)
subsections: section_title: According to USDA’s October mission area report, insurance
paragraphs: the location and type of data made available  where paperwork can be filed and  responsibilities of the applicable parties.
RMA said it approved plans from two participating insurance providers on September 26, 2000, enabling them to market and service federal crop insurance programs over the Internet.
section_title: Observations
subsections: section_title: USDA has made progress beginning to implement the E-
paragraphs: File Act, and the CBAs’ and RMA’s October 17 report, done in response to the Secretary’s request for a shared e-file plan, generally discusses their actions.
However, several steps essential to the overall success of USDA’s e-file initiative remain to be done.
Specifically, USDA has not assigned a senior-level official with overall responsibility, authority, and accountability for managing and implementing all the separate activities to ensure that critical tasks are completed on time and within budget and that all federal mandates are met.
section_title: Observations (cont’d.)
paragraphs: USDA has also not yet developed and documented a comprehensive e-file implementation plan.  Having such a plan is important to  define the milestones for all major activities, dependencies and critical tasks among these activities, and resources required to complete them;  help identify priorities as to which activities must be completed first and where milestone and resource shifts may be made to ensure that the most critical activities are completed on time, within budget, and, more important, are successful; and  address OMB and GPEA requirements by coordinating actions across mission areas and applying a more consistent approach during USDA’s e-government transformation.
section_title: Suggested Actions
paragraphs: To ensure that USDA fully meets its E-File Act mandates, the  assign a senior-level official with overall responsibility, authority, and accountability for managing and carrying out implementation of all E-File Act requirements and  direct that the assigned senior-level official, in cooperation with the undersecretaries for Farm and Foreign Agricultural Service, Natural Resources and Environment, and Rural Development, and the CIO, develop and document a comprehensive plan for implementing all E-File Act requirements.
section_title: Suggested Actions (cont’d.)
subsections: section_title: At a minimum, the comprehensive plan should document and track all critical activities and milestones, dependencies among major activities, and resources needed to complete them. The plan also should clearly
paragraphs: describe all project tasks, their priority, and time frames and milestones for their completion;  assign task responsibilities to staff and show critical dependencies identify required staff/budget resources for completing the plan; and  document contingency actions planned to address unforeseen work delays or problems.
In addition, the comprehensive plan should cover both e-file and GPEA requirements to help better coordinate actions across USDA agencies and apply a consistent approach for addressing all mandated requirements and deadlines during USDA’s e- government transformation.
section_title: Suggested Actions (cont’d.)
subsections: section_title: Finally, the Secretary should hold the senior official accountable for carrying out the plan and require that this official provide quarterly reports to the Secretary describing the results of USDA’s efforts to implement each of these actions and all e-file requirements.
section_title: Comments From the Department of Agriculture
subsections: section_title: Ordering Information
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