ArchiveTitle: NPR Recommendations Affecting Services to Children and Families
Author: National Partnership for Reinventing Government
(formerly National Performance Review)
National Performance Review
Recommendations Affecting Services
To Children and Families
Principles of the National Performance Review
We will invent a government that puts people first, by:
Cutting Unnecessary Spending
Serving It's Customers
Empowering Its Employees
Helping Communities to Solve Their Own Problems
Here's how. We will:
Create a clear sense of mission
Steer more, row less
Delegate authority and responsibility
Replace regulations with incentives
Develop budgets based on outcomes
Expose Federal operations to competition
Search for market, not administrative solutions
Measure our success by customer satisfaction
The principles laid out above underpin all of the recommendations to
reinvent government developed by the National Performance Review
(NPR). In developing recommendations, the NPR looked internally at
each of the 25 largest agencies as well as across the Federal system
at 13 functions that are critical to making government work better
and cost less. Many recommendations within each of these areas
affect services to children and families. Those NPR recommendations
that affect -- both directly and indirectly -- services to children
and families are summarized below, and are categorized by the NPR
agency and system reports which accompany the September 1993 NPR
summary report, "From Red Tape to Results: Making Government Work
Better and Cost Less". More detail can be found on each of these
recommendations in the accompanying reports.
These recommendations have been compiled here to serve as a tool for
stimulating cross-cutting actions and efforts to collaborate and
coordinate the hundreds of Federal programs serving children and
families. Some of these recommendations directly improve children
and family programs. Others improve all government services and
operations, including those to children and families. Explanatory
notes (in italics) follow those recommendations where the
relationship to children and family programs may not be entirely
With at least 340 children and families programs administered by 11
different Federal agencies, it is imperative in our efforts to
improve the delivery of service to the customers of this country that
we look across departments and agencies as well as at our fundamental
operation of governmental systems.
While this compilation lists the relevant recommendations made in
the NPR reports, many additional efforts are underway all across
government. As communities and governments at all levels strive to
implement these efforts and to improve services to children and
families, the NPR principles can serve as a guide.Major
Recommendations by Agency
There are eleven federal agencies predominately responsible for
providing or funding services to children and families. The relevant
recommendations from the NPR reports covering these agencies are
Improving service delivery requires partnership at all levels,
intergovernmentally as well as internally within the Federal
government. Efforts to strengthen services within each agency
impacts services to that agency's customers, as well as services
provided or funded by other agencies that serve the same customers.
In order to keep this customer in focus, we must recognize these
interconnections from the customer's perspective and work to better
coordinate our efforts. Many of the systems' recommendations
(summarized below following the specific agency recommendations) are
aimed at improving inter-agency coordination.
Department of Agriculture
USDA05 Administer the Employment and Training Requirements for
Food Stamp Recipients More Effectively and Efficiently
Redirect funds from an ineffective training program for food stamp
recipients and allow them to participate in programs with proven
USDA06 Encourage Better Food Package Management Practices and
Facilitate Multi-State Contracts for Infant Food and Formula Cost
Containment in the WIC program
The recommendation encourages increased competition among infant
formula vendors and manufacturers of other items in the USDA's
Special Supplemental Food Program for Women, Infants and Children
(WIC). Savings accrue to program.
USDA07 Deliver Food Stamp Benefits Via Electronic Benefits
Transfer to Improve Service to Customers While Remaining Cost
Use electronic technology to distribute food stamp benefits,
thereby improving service and reducing the need for current paper
Federal Emergency Management Agency
FEMA01 Shift Emphasis to Preparing for and Responding to the
Consequences of All Disasters
FEMA's early focus was on preparedness for nuclear war. The
current world situation and recent natural disasters highlight the
need for FEMA to continue to shift its resources to respond to all
FEMA02 Develop a More Anticipatory and Customer-Driven Response to
These recommendations should make FEMA respond faster and more
effectively to catastrophic disasters.
Department of Transportation
DOT11 Improve Intermodal Transportation Policy Coordination and
DOT should institute a strategic planning process to promulgate
national, integrated transportation policies. Transportation policy
affects families by, for example, isolating the poor from jobs and
services if strategic, community-wide planning is not conducted.
Department of Commerce
DOC01 Reinvent Federal Economic and Regional Development Efforts
Improve coordination of federal economic development efforts with
the goals of eliminating duplication and better directing federal
resources to improve business conditions and provide jobs.
DOC07 Provide EDA Public Works Loan Guarantees for Infrastructure
This recommendation would provide the Economic Development
Administration with authority to use part of its funding as a
reserve for loan guarantees for various public economic development
DOC09 Expand the Electronic Availability of Census Data
To increase access to and use of census data, the Census Bureau
should create a computerized census information center. This data
can help inform policy, implementation, and evaluation of all
government programs and can provide critical information to all
levels of government and the local communities in developing
DOC14 Build a Business and Economic Information Node for the
To assist in the distribution of government information to private
citizens, Commerce should build a business and economic information
node to the "information highway."
Department of Education
ED01 Redesign Chapter 1 of Elementary and Secondary Education Act
Recommendations focus education funds on the neediest students and
simplify requirements on schools receiving federal education aid.
Existing funds are redirected.
ED02 Reduce the Number of Programs the Department of Education
Eliminate or consolidate more than 40 existing education grant
programs and free up funds for use in other educational programs.
ED03 Consolidate the Eisenhower Math and Science Education
Program with Chapter 2
NPR proposes combining this teacher training program, which is
largely consumed with short-term training, with other Education
programs to create a new program with a more coherent national focus
on teacher training and professional development.
ED08 Create a Single Point of Contact for Program and Grant
Education should create an electronic system that can be used by
students, parents, researchers and administrators to learn about
department programs, funding opportunities, best practices and other
ED12 Develop a Strategy for Technical Assistance and Information
Education should develop a strategy for its $290 million technical
assistance efforts designed to promote the National Education Goals
Department of Health and Human Services
HHS01 Promote Effective, Integrated Service Delivery for Customers
by Increasing Collaborative Efforts
These recommendations outline a number of steps needed to better
integrate and deliver social services to communities and families.
HHS02 Reengineer the HHS Process for Issuing Regulations
HHS should improve the timeliness and quality of regulations issued
and should involve stakeholders in the development of regulations.
HHS06 Improve Social Security Administration Disability Claims
Processing to Better Serve People with Disabilities and Safeguard
Trust Fund Assets
SSA should apply resources and management tools needed to reduce
backlogs and to avoid paying benefits to individuals who are no
HHS11 Redesign SSA Service Delivery and Make Better Use of
Technology to Provide Improved Access and Services to Customers
SSA's organizational structure needs to be updated to reflect
changing customer needs and to take full advantage of emerging
HHS13 Review the Field and Regional Office Structure of the HHS
and Develop a Plan for Shifting Resources to Match Workload Demands
The review should emphasize customer service, results and increased
Department of Housing and Urban Development
HUD01 Reinvent Public Housing
HUD should create pilot programs to devolve greater authority over
housing funds to sound local agencies. It should create
demonstrations of mixed-income public housing with portable
subsidies. HUD should also streamline public housing rules and take
other steps to improve public housing management.
HUD02 Improve Multi-Family Asset Management and Disposition
HUD should use public-private partnerships to manage and sell HUD-
held loans and real estate for non-subsidized housing projects.
Congress should reduce restrictions on HUD sale of multi-family
properties, including use of portable subsidies for tenants when the
Secretary determines that to be best for tenant needs.
HUD03 Improve Single-Family Asset Management and Disposition
HUD should use a combination of early assistance to borrowers
having financial difficulties, contract loan servicing, contract
mortgage assistance programs and public-private partnerships to
streamline and improve management of HUD- assigned single-family
HUD04 Create an Assisted-Housing/Rent Subsidy Demonstration
HUD should be authorized to experiment in negotiated restructuring
of privately owned assisted-housing projects to improve management,
promote mixed-income housing and save taxpayer funds.
HUD05 Establish a New Housing Production Program
HUD should stimulate housing production through FHA risk-sharing
arrangements with housing finance agencies, stimulate a secondary
market for multi-family properties, improve access to FHA insurance
for first-time home buyers, provide special FHA programs to
revitalize neighborhoods and improve FHA management.
HUD06 Streamline HUD Field Operations
HUD should streamline its Washington, regional and field office
structure and consolidate and reduce its size over time.
HUD08 Reduce Section 8 Contract Rent Payments
HUD should modify its process to reduce unjustified increases in
annual payments to Section 8 projects.
HUD09 Consolidate Section 8 Certificates and Vouchers
This recommendation would consolidate two overlapping projects to
HUD10 Reduce Operating Subsidies for Vacancies
This recommendation would encourage public housing agencies to make
better use of their assets by reducing subsidies paid for
unjustifiably vacant units.
Department of Justice
DOJ01 Improve the Coordination and Structure of Federal Law
NPR recommends the designation of the Attorney General as the
Director of Law Enforcement to coordinate federal law enforcement
efforts to improve public safety. It also recommends changes in the
alignment of federal law enforcement responsibilities.
DOJ02 Improve Border Management
Federal border management should be significantly improved. NPR
recommends a series of actions to be taken by Customs and INS to
make these improvements. Border states' budgets and workload are
severely impacted by government services to undocumented aliens. In
addition, INS's efficiency and effectiveness in verifying INS status
impacts the Aid to Families with Dependent Children program's
ability to determine eligibilty for it's applicants.
DOJ03 Redirect and Better Coordinate Resources Dedicated to
Interdiction of Drugs
This recommendation outlines changes that can be made to better
coordinate federal programs directed at the air interdiction of
DOJ05 Improve the Bureau of Prisons Education, Job Training,
and Financial Responsibilities Programs
NPR makes a series of recommendations for improving prison
education, training, and inmate financial responsibility policies.
DOJ08 Reinvent the Immigration and Naturalization Service's
NPR recommends a number of changes in INS organization and
management processes to provide an improved management structure and
a strategic vision for the agency.
Department of Labor
DOL01 Enhance Reemployment Programs for Occupationally Disabled
These recommendations would help occupationally disabled federal
employees return to productive careers by expanding DOL's return-to-
work program. This saves money by reducing long-term benefit costs
to the government.
DOL02 Develop a Single Comprehensive Worker Adjustment Strategy
Improve services to the unemployed--and those at risk of
dislocation--and make better use of resources available for
assistance by developing a new worker adjustment strategy.
DOL08 Create One-Stop Centers for Career Management
Establishing one-stop centers for career management would create a
customer- driven work force system, empowering Americans to make
informed career choices and providing the means to achieve those
DOL11 Open the Civilian Conservation Centers to Private and Public
A long-term reduction in costs is possible through expanded
competition for contracts to operate Job Corps Civilian Conservation
DOL19 Transfer the Veterans' Employment and Training Service
to the Employment and Training Administration
The DOL can improve service delivery to veterans and save money by
consolidating administration of this function.
DOL21 Change the Focus of the Unemployment Insurance Benefits
Quality Control Program to Improve Performance
Re-examining the present mix of systems to shift the focus of this
program from error measurement to a constructive use of the results
would allow DOL to improve benefit payment quality and more
effectively achieve the program's goals.
Small Business Administration
SBA02 Improve Assistance to Minority Small Businesses
This proposal recommends a complete review of all federal minority
business assistance programs and the establishment of a Small
Disadvantaged Business Set-Aside program for civilian agencies to
provide increased opportunities for minority small business.
SBA03 Reinvent the U.S. Small Business Administration's Credit
Identify ways to improve SBA's credit programs to make SBA more
responsive to those industries with the potential for creating a
higher number of jobs, those involved in international trade, and
those providing critical technologies. It will also enable the
agency to operate more efficiently.
SBA04 Examine Federal Guidelines for Small Business Lending
The federal government should examine the guidelines bank
regulators set for small business lending by financial institutions
to ensure that capital is available without undue barriers while
maintaining the integrity of the financial institutions.
SBA05 Manage the Microloan Program to Increase Loans for Small
Allowing SBA to guarantee loans made by banks to nonprofit
intermediaries, who could, in turn, make small loans to low-income
individuals, women, minorities and other small businesses unable to
obtain credit through traditional lending sources would increase
private sector participation and lessen administrative burdens
linked to direct government lending.
SBA06 Establish User Fees for Small Business Development Center
Authorize Small Business Development Centers to charge a nominal
fee for their services to reduce federal outlays and require the
direct beneficiaries of the assistance to pay a share of the cost.
Department of Veterans Affairs
DVA02 Modernize Benefits Claims Processing
Modernization of the VA benefits claims processing system will
improve the quality of service and save taxpayer dollars over time.
DVA04 Streamline Benefits Claims Processing
VA should examine the usefulness of a New York Regional Office
approach to benefits claims processing that promises to streamline
the process. It should also examine regional staffing.
DVA10 Serve Veterans and Their Families as Customers
This recommendation outlines several approaches for VA to improve
its focus on veterans and their families as customers.
DVA12 Improve Business Practices through Electronic Commerce
VA should expand its use of electronic media to reduce paperwork
and save money. It should seek to make greater use of electronic
funds transfer of compensation and pension benefits.
DVA15 Restructure the Veterans Affairs' Health Care System
VA should re-examine its role and delivery structure after the
issuance of the report of the President's National Health Care
Reform Task Force and take actions to restructure the VA health care
Major Recommendations Affecting Governmental Systems
Systems improvements impact the way government does business in
literally every area, including services to children and families,
which are greatly enhanced when we are able to: strengthen
intergovernmental partnerships; reinvent support services;
streamline management control; transform organizational structures;
implement mission-driven, results-oriented budgeting; improve
customer service; improve financial management; reinvent human
resource management; reinvent Federal procurement; reengineer
through the use of information technology; focus on program design;
and, improve regulatory systems.
Improvements in each of these areas are especially relevant in the
11 Federal agencies charged with administering programs to children
and families. These systems improvements will free up resources and
provide a clearer sense of organizational mission and objectives as
we measure and improve our performance in serving families.
Strengthening the Partnership in Intergovernmental Service Delivery
FSL01 Improve the Delivery of Federal Domestic Grant Programs
Create flexibility and encourage innovation by designing a bottom-
up solution to the problem of grant proliferation and its
accompanying red tape. Also, support proposals for Federal-State
Flexibility Grants. Establish a Cabinet-level Enterprise Board to
oversee initiatives in community improvement.
FSL02 Reduce Red Tape through Regulatory and Mandate Relief
Issue an Executive Order addressing the problems of unfunded
federal mandates and regulatory relief and authorize Cabinet
Secretaries and agency heads to obtain selective relief from
regulations or mandates in programs they oversee.
FSL03 Simplify Reimbursement Procedures for Administrative Costs
of Federal Grant Disbursement
Modify OMB Circular A-87, "Cost Principles for State and Local
Governments," to provide states and localities with a fixed fee-for-
service option in lieu of costly reimbursement procedures covering
administrative costs. Time and funds saved by reducing accounting
and allocative burdens can be recaptured and refocused on achieving
FSL05 Simplify Administration by Modifying the Common Grant Rules
on Small Purchases
Modify OMB Circular A-102, "Grants and Cooperative Agreements to
State and Local Governments", to increase the dollar threshold for
small purchases by local governments from $25,000 to $100,000. This
modification would allow local governments to use relatively simple
procurement methods (e.g., obtaining price or rate quotations over
the phone from an adequate number of vendors) rather than formally
advertise and solicit sealed public bids for purchases up to
$100,000 for services, supplies, or other property. This will speed
the procurement process and thus speed services to customers when, for
example, a grantee wants to procure one small van to transport the
FSL06 Strengthen the Intergovernmental Partnership
Reinvent the Advisory Commission on Intergovernmental Affairs
(ACIR) and charge it with the responsibility for continuous
improvement in federal, state and local partnership and
intergovernmental service delivery. Direct the ACIR to identify
opportunities to improve intergovernmental service delivery and
develop a set of benchmarks.
Reinventing Support Services
SUP02 Assure Public Access to Federal Information
Give the executive branch agencies responsibility for distributing
printed federal information to depository libraries. Require
agencies to inventory the federal information they hold and make it
accessible to the public.
Streamlining Management Control
SMC03 Change the Focus of the Inspectors General
Change the focus of the Inspectors General from compliance auditing
to evaluating management control systems. In addition, recast the
IG's method of operation to be more collaborative and less
adversarial. As the IG's and others in government change their
focus from compliance with process to collaborative management for
results, all government programs will improve.
SMC04 Increase the Effectiveness of Offices of General Counsel
Define clearly the clients of agency General Counsel offices as
agency line managers. Train staff attorneys to understand the
cultural changes they will need to undertake to operate in an
environment where program results are important. Develop
performance measures and "feedback loops" to ensure close
cooperation with line managers. As the culture of government in
every office focuses more on cooperation to achieve results, all
government programs will improve.
SMC05 Improve the Effectiveness of the General Accounting Office
Through Increased Customer Feedback
Improve GAO's documentation of best practices and the use of
feedback loops on its performance.
SMC07 Reduce Internal Regulations by More than 50 Percent
Direct department secretaries and agency heads to reduce by a least
50 percent the number of internal regulations and the number of
pages of regulations within three years. These actions will help
eliminate unnecessary procedural delays many agencies face in
serving their customers.
SMC08 Expand the Use of Waivers to Encourage Innovation
Establish a process for obtaining waivers from federal regulations
and identifying those regulations for which this process should
apply. Regulatory barriers that prevent front line innovation to
improve services will be reduced.
Transforming Organizational Structures
ORG05 Sponsor Three or More Cross-Departmental Initiatives
Addressing Common Issues or Customers
The President's Management Council should identify and sponsor
three or more cross-departmental initiatives in areas such as
illegal immigration, debt collection, and the problems of the
ORG06 Identify and Change Legislative Barriers to Cross-
As cross-organizational collaborations become an integral part of
government operations, barriers to ready collaboration and funding
should be removed. Cross-organizational cooperation can be a very
effective tool to improving program results and meeting the needs of
Mission-Driven, Results-Oriented Budgeting
BGT01 Develop Performance Agreements with Senior Political
Leadership that Reflect Organizational and Policy Goals
The President should develop performance agreements with agency
heads. Agency heads should also use performance agreements within
their agency to forge an effective team committed to achieving
organizational goals and objectives. Performance agreements are one
tool to set a common mission, prioritize organizational goals, and
focus on achieving results.
BGT02 Effectively Implement the Government Performance and Results
Act of 1993
Accelerate planning and measurement efforts to improve performance
in every federal program and agency. Designate as pilots under the
act several multi-agency efforts that have related programs and
function. Develop common measures and data collection efforts for
cross-cutting issues. Clarify the goals and objectives of federal
programs. Incorporate performance objectives and results as key
elements in budget and management reviews.
BGT03 Empower Managers to Perform
Restructure appropriations accounts to reduce overitemization and
to align them with programs. Ensure that direct operating costs can
be identified. Reduce overly detailed restrictions and earmarks in
appropriations and report language. Simplify the apportionment
process. Reduce the excessive administrative subdivision of funds in
financial operating plans. These actions will allow front line
managers, those closest to the service delivery level, more
flexibility in using funds to best meet program objectives.
Improving Customer Services
ICS01 Create Customer-driven Programs in All Departments and
Agencies that Provide Services Directly to the Public
Establish an overall policy for quality of federal services
delivered to the public and initiate customer service programs in
all agencies that provide services directly to the public.
ICS02 Customer Service Performance Standards--Internal Revenue
As part of its participation in the NPR, the Internal Revenue
Service is publishing customer service performance standards. To
speed the delivery of taxpayer refunds, the Secretary of the
Treasury should delegate disbursing authority to IRS in 1993 and
future tax seasons. IRS serves the same customers as several other
Federal programs. With the expansion of the Earned Income Tax
Credit (EITC), IRS's responsiveness to it's customers becomes even
more relevant to Federal programs such as Aid to Families with
Dependent Children and Food Stamps. The effective disbursement of
these EITC payments could prevent the need for families to seek
assistance in these other Federal programs.
ICS03 Customer Service Performance Standards--Social
As part of its participation in the NPR, the Social Security
Administration is publishing customer service performance standards.
SSA will also obtain customer opinions on all the goals and
objectives of their strategic plan, using that input to revise the
goals and objectives as needed, set priorities, and establish
ICS05 Streamline Ways to Collect Customer Satisfaction and Other
Information from the Public
For voluntary information collection requests directed at
customers, OMB will delegate authority to approve such requests if
departments certify that they will fully comply with Paperwork
Reduction Act requirements. OMB will also clarify rules on the use
of focus groups and streamline renewals of previously approved
Improving Financial Management
FM04 Increase the Use of Technology to Streamline Financial
Use electronic funds transfer to pay and reimburse expenses for all
federal employees, to handle all interagency payments, to make
payments to state and local governments, and to pay for purchases
from the private sector. Similarly, all payments to individuals
should be done electronically.
Reinventing Human Resource Management
HRM03 Authorize Agencies to Develop Programs for Improvement of
Individual and Organizational Performance
Authorize agencies to design their own performance management
programs which define and measure success based on each agency's
unique needs. In departments charged with serving children and
families, human resource tools which reinforce a clear sense of
mission, performance goals, and expected results will help to
improve outcomes of all programs.
HRM04 Authorize Agencies to Develop Incentive Award and Bonus
Systems to Improve Individual and Organizational Performance
Authorize agencies to develop their own incentive award and bonus
systems. Encourage agencies to establish productivity gainsharing
programs to support their reinvention and change efforts. These
actions are among the human resource tools which can be used to
improve government performance in all programs.
HRM06 Clearly Define the Objective of Training as the Improvement
of Individual and Organizational Performance; Make Training More
Reduce restrictions on training to allow managers to focus on
organizational mission and to take advantage of the available
HRM07 Enhance Programs to Provide Family-Friendly Workplaces
Implement family-friendly workplace practices (flex-time,
flexiplace, job sharing, telecommuting) while ensuring
accountability for customer service. Provide telecommunications and
administrative support necessary for employees participating in
flexiplace and telecommuting work arrangements. Expand the
authority to establish and fund dependent care programs. Allow
employees to use sick leave to care for dependents. Allow employees
who leave and then re-enter federal service to be given credit for
prior sick leave balances.
Reinventing Federal Procurement
PROC07 Enhance Programs for Small Business and Small Disadvantaged
Repeal statutory limitations on subcontracting and substitute
regulatory limitations to provide greater flexibility. Authorize
civilian agencies to establish small disadvantaged business set-
asides. These actions will affect economic development in
PROC10 Ensure Customer Focus in Procurement
Revise Procurement Management Reviews to incorporate NPR principles
such as "focusing on results" for the line managers.
Reengineer Through the Use of Information Technology
IT01 Provide Clear, Strong Leadership to Integrate Information
Technology into the Business of Government
Create a Government Information Technology Services working group
to develop a strategic vision for the use of government information
technology and to implement NPR's information technology
recommendations. A major focus of this group is the application of
technology to improve governmental services to citizens.
IT02 Implement Nationwide, Integrated Electronic Benefit Transfer
Design an integrated implementation plan for the use of electronic
benefit transfer for programs such as Food Stamps and for direct
payments to individuals without bank accounts.
IT03 Develop Integrated Electronic Access to Government
Information and Service
Use information technology initiatives to improve customer service
by creating a one-stop "800" calling service, integrated one-stop
service "kiosks," and a government-wide electronic bulletin board
IT04 Establish a National Law Enforcement/Public Safety Network
Establish a national law enforcement/public safety data network for
use by federal, state, and local law enforcement officials.
IT09 Establish an Information Infrastructure
Develop a Government Information Infrastructure to use government
information resources effectively and support electronic government
applications. Consolidate and modernize government data processing
centers. These actions will speed government service and provide
information to improve government service.
IT10 Develop Systems and Mechanisms to Ensure Privacy and Security
Establish a Privacy Protection Board. Establish uniform privacy
protection practices and generally acceptable implementation methods
for these practices. Develop a digital signature standard for
sensitive, unclassified data by January 1994. In children and
family programs, confidentiality concerns have impeded some past
efforts for interagency and interdisciplinary collaboration.
DES01 Activate Program Design as a Formal Discipline
The President's Management Council should commission the
development of a handbook to help federal managers understand the
strengths and weaknesses of various forms of program design, which
will lead to improvements in the outcomes of government programs.
DES02 Establish Pilot Program Design Capabilities in One or Two
Test the usefulness of the program design handbook and the value of
program design as a useful discipline.
DES03 Encourage the Strengthening of Program Design in the
The President's Management Council should work with congressional
support agencies to help them strengthen their program design
DES04 Commission Program Design Courses
Develop training courses for managers and policymakers on various
program design approaches to improve government programs.
Improving Regulatory Systems
REG01 Create an Interagency Regulatory Coordinating Group
Create an interagency Regulatory Coordinating Group to share
information and coordinate approaches to regulatory issues. These
actions will help to improve the design and outcomes of all federal
REG04 Enhance Public Awareness and Participation
Use information technology and other techniques to increase
opportunities for early, frequent and interactive public
participation during the rulemaking process and to increase program