FOIA established a legal right of access to government information on the basis of the principles of openness and accountability in government. Prior to passage of the act in 1966, the government required an individual or entity to demonstrate a “need to know” before being granted the right to examine a federal record. FOIA established a “right to know” standard, under which an individual or entity could receive access to information held by a federal agency without demonstrating a need or reason. The “right to know” standard shifted the burden of proof from the individual or entity to the government agency holding the information and required the agency to provide proper justification when denying a request for access. Any person, with a few exceptions, can file a FOIA request, including foreign nationals, corporations, and organizations. For example, a foreign national can request his or her alien file, and a commercial requester, which can include data brokers that file a request on behalf of others, may request, among other things, a copy of a government contract or grant proposal. In response, the agency holding the desired record is required to provide it to the requester (unless the record falls within a permitted exemption). Generally, FOIA allows agencies to collect a fee for searching and duplicating records in connection with responding to a request. Apart from providing access to records in response to a request, FOIA also requires agencies to disclose certain information by publication in the Federal Register or electronically (e.g., on the Internet), or by making it available in a physical or electronic reading room. While FOIA has helped improve public access to government information and has been a positive step toward providing more openness in government, a March 12, 2007, House committee report accompanying the OPEN Government Act pointed out that agencies receive hundreds of thousands of FOIA requests a year, which has led to slow response times, increased backlogs, and costly and time-consuming litigation between requesters and the government. As such, according to the report, FOIA requesters have argued that they would benefit from having access to an ombudsman to provide guidance before, or as an alternative to, litigation. To help address the concerns surrounding FOIA implementation, the OPEN Government Act,NARA to: among other things, established OGIS within review policies and procedures that agencies have developed to administer FOIA; review agency compliance with FOIA requirements; recommend policy changes to Congress and the President to improve the administration of FOIA; and offer mediation services to resolve disputes between individuals or entities making FOIA requests and agencies as an non-exclusive alternative to litigation. OGIS was established within NARA, on September 8, 2009. The office operated directly under the Archivist of the United States until March 7, 2011, when it was moved to Agency Services, which operates under the authority of the agency’s Chief Operating Officer. According to its charter, the mission of Agency Services is to lead NARA’s efforts in servicing the ongoing records management needs of federal agencies and to represent the public’s interest in the accountability and transparency of these records. OGIS is one of five supporting offices under Agency Services, as shown on the organization chart in figure 1. Headquartered in Washington, D.C., OGIS is led by a director who reports to the Executive of Agency Services. As of August 2013, the Director was aided by a deputy director, an attorney advisor, two management and program analysts, and a staff assistant—for a total of six full-time employees. In addition to OGIS, other federal agencies also have responsibility for the oversight and administration of FOIA. Specifically, since it was established 30 years ago, the Office of Information Policy within the Department of Justice (Justice) has been responsible for overseeing the administration of FOIA by encouraging compliance, overseeing agencies’ implementation of the OPEN Government Act, and issuing policy guidance. As such, the office prepares a comprehensive guide that addresses various aspects of the act; conducts a variety of FOIA-related training programs for personnel across the government; and uses attorneys to serve as counselors that provide FOIA information, advice, and guidance to government staff and the public regarding implementation of the act. In addition, Justice represents federal agencies in lawsuits brought by FOIA requesters. According to Justice, as of fiscal year 2012, a total of 99 federal agencies had responsibility for implementing FOIA. These agencies process requests, publish related regulations, and submit annual reports through the heads of their agencies to the Attorney General that include statistics on their FOIA processing. Further, the OPEN Government Act gave agency chief FOIA officers responsibility for ensuring agencywide compliance by monitoring implementation throughout the agency; recommending changes in policies, practices, staffing, and funding; and reviewing and reporting to agency heads and to Justice on the agency’s performance in implementing FOIA. (These reports are referred to as chief FOIA officer reports and are in addition to the annual reports that agencies also submit to Justice.) Over the past 6 years, we have issued several reports on federal agencies’ implementation of FOIA, including their progress in improving FOIA processing and backlog reduction. GAO, Freedom of Information Act: Additional Actions Can Strengthen Agency Efforts to Improve Management, GAO-12-828 (Washington, D.C.: July 2012). example, using a single tracking system and providing requesters with the ability to track the status of their requests online. We recommended that the agencies improve the management of their FOIA programs by ensuring that actions were taken to reduce backlogs and the use of exemptions, improve FOIA libraries, and implement technology. Officials from the four agencies agreed or generally agreed with the recommendations. OGIS has engaged in several activities that, according to its officials, were intended to respond to the OPEN Government Act requirement that it review federal agencies’ FOIA policies, procedures, and compliance. Specifically, OGIS has engaged in tasks such as making suggestions for improving the clarity and readability of agencies’ proposed FOIA regulations and notices and offering general observations regarding agencies’ correspondence. For example, in 2010 and 2011, the office reviewed the Federal Register to identify when agencies had submitted FOIA regulations for public comment and then offered responses to the requests for comments on the proposed regulations. In this regard, OGIS offered comments on improving the contents of regulations that had been proposed by 18 agencies. Among the suggestions that it offered to one or more of these agencies were that they: provide requesters with an estimated amount of fees, including a breakdown of the fees for the time staff devote to searching, reviewing, and/or duplicating records for a FOIA request; add a statement to clarify the difference between a third-party request made under FOIA and a first-party request made under the Privacy Act; notify requesters in writing when their requests have been referred to another agency, and include the part of the request that has been referred and the name of the FOIA contact in that agency; and recognize the important statutory role of the FOIA Public Liaison in reducing delays, increasing transparency, and understanding the status of requests. In addition, as part of its actions taken to review policies and procedures, in 2011 and 2012 the office responded to agencies’ requests in the Federal Register for public comments on Privacy Act system of records notices. The office commented on six such requests during these 2 years. For example, the office suggested that agencies include model language in their system of records notices that would allow OGIS to share information with the affected agency as a permitted disclosure under the Privacy Act. According to the officials, without the model language, OGIS would be required to obtain written consent from each requester prior to being able to access their records when mediating a dispute. Further, through various means (for example, FOIA roundtable meetings, website, and blog) in 2012 and 2013, OGIS invited agencies to submit FOIA correspondence, such as acknowledgment and close-out letters, for its review. According to OGIS, one agency responded to these invitations and the office, in turn, made suggestions aimed at improving the clarity and readability of the agency’s correspondence. Specifically, OGIS provided comments to the National Geospatial Intelligence Agency on a template for its close-out letter that clarified the legal requirements to protect from disclosure, information on the location of classified military systems personnel, and information on contractor proposals. Beyond this activity, the office offered Dispute Resolution Skills training to agencies, including the Departments of State, Homeland Security, and Health and Human Services, and, as part of the training, provided instruction on improving agency correspondence to requesters. Nevertheless, while OGIS has engaged in these specific activities, none was a proactive, comprehensive evaluation of federal agencies’ FOIA policies and procedures. Moreover, the office has not conducted any reviews of agencies’ compliance with FOIA. Rather, the office has generally worked in an ad hoc, reactive manner to respond to Federal Register proposals put forth by agencies or to seek opportunities to comment or provide training on correspondence and documentation other than FOIA policies and procedures. Furthermore, the activities that it has undertaken have been limited to engaging with only a small fraction of the 99 federal agencies that, according to Justice, have responsibility for implementing FOIA. Similarly, while the office reported that it has reviewed agencies’ annual FOIA reports and Chief FOIA Officer reports from Justice’s Office of Information Policy website to identify best practices on improving FOIA processing, and has made general observations about agencies’ policies, procedures, and compliance with FOIA through the office’s mediation case work, these actions were not undertaken as part of a specific review of agencies’ compliance with FOIA, as required by the OPEN Government Act. A key factor contributing to the absence of proactive and comprehensive reviews of federal agencies’ FOIA policies, procedures, and compliance by OGIS is that the office has not established a structured methodology for conducting such reviews. Our work has determined that developing a methodology is critical to conducting quality, credible, and useful reviews.