The Department of the Interior (DOI) is a large, complex organization with 10 bureaus and over 76,000 employees working in hundreds of locations across the United States. In order to efficiently manage this organization, DOI needs to streamline and modernize its support systems, including telecommunications, procurement, financial management, paperwork control, and the rulemaking process.
To transmit information, directives, and messages, DOI's bureaus have historically maintained and operated independent communications networks. Non- standard telecommunications practices prevent effective cross-bureau communications. The independent networks that exist within DOI have parallel services (particularly for dedicated circuits) which are costly and often underutilized.
Well-coordinated electronic communications technology can assist in disseminating and maintaining rules and regulations, transmitting mail, and producing technical reports. This technology can also help people manage their time more effectively and encourage sharing of information. Enhanced communication between people and organizations, standard procedures for electronic data interchange, and easier citizen access to federal electronic data will help move DOI onto the Information Highway. Without the ability to effectively communicate electronically, the department will be hindered in carrying out its mission. Some possible communication strategies include:
--sharing circuits on high density routes between heavy-use areas;
--connecting local area networks within buildings or campus environments to a wide-area network;
--sharing video teleconferencing facilities to reduce travel; and
--improving phone communication through capabilities such as voice mail and conferencing to speed contacts and reduce administrative work hours.
While DOI's telecommunications can be improved by greater consolidation, current procurement practices in the department are over-regulated and inefficient and need simplification. DOI's procurement process is governed by a bewildering array of government-wide rules. To complicate matters, bureaus are authorized to issue additional internal regulations. As a result, bureaus have established additional rules at their own discretion which typically exceed the federal guidelines in restrictiveness and stringency, requiring more documentation, review, and approvals. Each layer of self-imposed regulation adds confusion to the process and decreases management's ability to exercise judgment and common sense.
Internal, self-imposed regulations confuse the procurement process even further, adding delays, increasing overhead costs, constraining common sense, and rendering government action more vulnerable to formal protest. To extricate itself from the inefficiency of current procurement regulations, DOI must eliminate as many self-imposed rules as possible and provide a reliable means to review outdated or contradictory regulations.
Facilitating effective procurement depends not only on deregulating the process itself but also on ensuring that it relates smoothly to other management tasks. Financial systems are inextricably tied to procurement since all federal acquisitions have a fiscal dimension. At present, DOI has not placed sufficient priority on guaranteeing that its financial and acquisition systems will be compatible.
Seven of the 10 bureaus in DOI use the Federal Financial System (FFS), gaining vast benefits from its ability to automate activities that were previously manual, duplicative, and labor-intensive. DOI also has begun planning for an Electronic Acquisition System (IDEAS), which will transform the procurement process with modern technology. If IDEAS could interface with FFS, field managers would gain substantial efficiencies: instead of transferring acquisitions documents onto the financial system by hand, the link would be computerized. This advantage, which would free employees and reduce paperwork, will materialize only if the department makes the FFS interface an integral requirement of IDEAS development.
FFS operating software resides on two mainframe computers which process in excess of three million invoice payments annually. Despite the advantages of FFS, a payment process initiated at a field office still takes a minimum of three weeks from start to finish. The system still requires too much handling of documents and duplicative data entry.
Substantial cost and efficiency savings could be gained by moving the FFS software to smaller computer platforms, such as minicomputers which currently operate in many of the seven participating bureaus. Staffing levels for Administrative Service Centers' mainframe computer operations are higher than levels required to operate the software on smaller, easier to manage, less expensive systems. Because the current trend is to move financial systems away from large mainframe computers, a newer version has been created that can operate on a file server in a local area network environment.
FFS could be further enhanced by expanding remote access and data entry capabilities through implementation of the Department of the Treasury's Vendor Express Program (Electronic Payment System) and Electronic Certification System. This change would allow the originating office to enter invoice payments directly into FFS, which would automatically edit all payment transactions and notify the Treasury electronically to prepare a check for mailing. This enhancement would reduce document handling, eliminate errors, and accelerate payment to the customers.
Further efficiencies can be gained by treating DOI as one entity when paying central operating costs, such as rent, workers' compensation, unemployment compensation, and other costs of health units and learning centers. Needless and costly steps are currently required to bill each bureau separately for a prorated share of these costs.
One common suggestion among DOI employees is the need to reduce the amount of paperwork and review involved in even the seemingly simplest process. The clearance process for general correspondence within the department is extremely complex and unwieldy. DOI should review its correspondence system to ensure that only directly affected program offices have the opportunity to review policy; legal, legislative, and budgetary information; and commitments that are communicated to correspondents. This review should be efficient and timely, eliminating unnecessary steps, streamlining operations to avoid delay, and reducing the number of reviewers.
At the departmental level, written guidelines are not sufficiently detailed to ensure correspondence will be prepared in a consistent manner from one bureau to the next. Existing guidelines are incomplete, outdated, and scattered among a variety of sources, often resulting in confusion among correspondence preparers as to what is required.
The regulatory process is a related paperwork processing activity that could be better managed. DOI issues approximately 250 to 330 regulations, or rulemakings, each year. This includes both proposed and final rules. In recent years, however, rulemaking has become increasingly complex and time-consuming, which results in poorer service to the public.
Several problems have been identified at the initial stage of the departmental regulatory process. These problems include a lack of logical, well-communicated workflow and priority assignment of rules on the part of various levels of regulation reviewers. The rulemaking process must be well-understood by all bureaus, and deadlines must be met for rulemaking to proceed effectively.
In addition to the internal formulation of rules, DOI needs to streamline procedures for using the semiannual rulemaking agenda. The Regulatory Flexibility Act and Executive Order 12291 requires the development of a semiannual agenda to:
--alert the public to upcoming regulations and to reduce the burdens of existing and future regulations;
--increase agency accountability for regulatory actions;
--provide for presidential oversight of the regulatory process;
--minimize duplication and conflict of regulations; and
--ensure well-reasoned regulations.
In practice, DOI misuses this tool, ignoring its intended purpose and using it as a place to list every conceivable rule that the department might publish. When used in this manner, the agenda provides little information on actual departmental priorities. Use of the agenda can be vastly improved.
There must also be a clear and well-defined process for developing regulations and obtaining approval for their release. In many cases, rulemakings have been delayed because:
--interested bureaus become involved late in the process, forcing reconsideration of issues previously resolved;
--confusion exists over which bureaus must approve rulemakings before they are released; and
--deadlines for completion of various phases of the rulemaking process either do not exist or are not enforced.
1. DOI should implement standard practices for electronic communications and an agencywide data network strategy with the following steps:
--agree upon a conceptual framework identifying networks, common data bases (e.g., payroll), and a network architecture;
--establish ways to share data across bureaus;
--require data centers to use compatible communications software;
--require bureaus to optimize communications capacity (e.g., T-1 circuit bandwidth and video- conferencing room time);
--shift to Government Open Systems' Interconnection Profiles;
--standardize imaging systems across the department for transmission of financial data, land records, rules and regulations, library material, and basic review documents to reduce paperwork in the workplace; and
--standardize telephone system capability across bureaus to provide timesaving components and to improve quality of direct communication.
2. DOI should ensure that its data network initiatives all tie into a departmental data network.
DOI data network initiatives are the Secretary's electronic mail project, Local Area Network Administrator's Group, and the Data Networking Task Group. In addition there are a number of bureau initiatives which provide further capability for an agencywide network. These include:
--the National Park Service (NPS) ParkNet Telecommunications Network;
--U.S. Fish and Wildlife Wetlands Mapping program;
--Bureau of Land Management's (BLM) Automated Land and Mineral Records System;
--Office of Surface Mining Technical Information Processing System;
--Minerals Management Service's (MMS) Technical Information Management Program;
--U.S. Geological Survey's (USGS) Advanced Cartographic Systems program;
--Bureau of Mines Minerals Availability System; and
--use of Geographic Information Systems by Bureau of Indian Affairs, NPS, BLM, MMS, and USGS.
3. DOI should establish a council to review all internal, self-imposed procurement regulations, eliminate as many of them as possible, evaluate any requests by individual departmental agencies/bureaus to retain specific rules, and determine the advisability of rescinding the authority of agencies/bureaus to issue restrictive supplements to federal acquisition guidelines.
To expedite the council's work, all of DOI's existing internal regulations should expire at the end of fiscal year 1994. In addition, the department should work with Office of Management and Budget, the General Accounting Office, and the Office of the Inspector General to ensure that these organizations do not encourage self-imposed rules in their circulars or audit reports.
4. To guarantee the compatibility of its financial and acquisition systems, DOI should make FFS interface capacity a top priority in the development of DOI's Electronic Acquisition System.
5. DOI should develop and implement a strategic plan for making the FFS readily available to field users through alternative system environments such as mini- computers and local area networks.
6. DOI should expand the remote access and data entry capabilities of FFS users to certify payments and streamline payment processing by implementing Treasury's Vendor Express Program (Electronic Payment System) and Electronic Certification System.
Implementation of the Treasury systems will result in direct wiring of payments to employees and outside customers and electronic certification of payments, eliminating preparation of hard-copy payment schedules and reentering of data into Treasury's on- line payment system.
7. DOI should streamline the processing of bills by establishing a separate appropriation account within the department to pay common costs rather than issuing separate billings to each bureau.
A single appropriation account would simplify the administrative process and result in a more timely recording of charges.
8. DOI should take measures to revise existing correspondence guidelines and reduce excessive and unnecessary review of correspondence.
This should include defining the purpose and scope of policy and legal clearance and delegating signatory authority to the lowest appropriate organizational level.
9. DOI should use its semiannual regulatory agenda to establish dates for formulation and publication of rules that can be achieved within agency resource constraints.
These dates should be commitments that are kept by the bureau developing the rule. The agenda should reflect major priorities and concerns requiring interagency coordination.
10. DOI should identify all parties that may be interested in a rulemaking and involve them early in the process.
DOI's Office of Regulatory Affairs has developed a flow chart of the steps and timeframes involved in the regulatory review and approval process and a regulatory alert system to provide departmentwide notice of all intended rulemakings. DOI should use this system to identify interested parties and encourage them to participate in the process during the initial stages of regulatory development.
Streamlining these management functions should generate some immediate dollar savings in procurement and financial management and vastly increase confidence in the department's administrative processes. Removing unnecessary obstacles should play an integral role in shaping a more flexible DOI for the coming century.
Implementation of a departmentwide telecommunications network will result in management efficiency improvements throughout the department. A telecommunications network will reduce time delays in reviews, enable information to more easily reach its target audience, and expedite information sharing. Aggressively reducing acquisition regulations, both federal and self-imposed, would decrease data entry errors, increase the quality of purchases, quicken payment to vendors, and free substantial work hours by eliminating manual, labor-intensive tasks.
Streamlining management support functions at DOI will free up resources for other needed services. Implementing these recommendations should lead to more efficient use of the department's resources and could yield long-term cost savings of over $25 million.
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