The Rule-Making Process

The FCC just changed its rules on regulating the Internet--they're going to treat it as a public utility.  A post at Vox takes them to task for being slow and untransparent in their rule-making process.  While the process for regulatory commissions like the FCC is a bit different than for agencies like FSA, I have to agree that everyone could gain by revising their process to take account of the Internet.  It's a forlorn hope, however--things don't change fast, particularly when you've got lawyers involved.

The Challenges of On-Line Versus Bricks: Banking and FSA

Had an experience the other day which IMHO shows the hurdles FSA and other agencies face when they try to combine bricks and mortar offices with online service.

The situation: dealing with my bank, with which my wife and I have several accounts, savings, checking, brokerage, IRAs, etc., basically operating under an umbrella which they call the PMA. They're the result of a history which started back in 1968 when I set up an account in DC in a bank which has been merged and remerged and remerged, and as my wife and I made decisions about savings and investments and consolidating accounts.

Anyhow, we have a branch office near our home, but we mostly do our banking online.

Though I haven't seen an organization chart for the bank, I deduce that they have a unit responsible for their branches,  a unit responsible for PMAs, a unit responsible for their brokerage accounts and IRA accounts, and a unit responsible for online banking. So we go in the branch to get a safe deposit box and straighten out a situation with the 1099 for 2015 taxes (I won't go into detail on that, because it's an embarrassing story--recalling the old lesson for software: when all else fails, read the manual.)

So the banker with whom we talked couldn't resolve our problem, so she made a call to the PMA help desk unit. We talked with the PMA person, without success, because she needed to talk to the online banking person.  At that point we decided to go back home and work the phones from there. I called the online banking help, who couldn't resolve it, and wanted to talk to the PMA people.  About that point I realized that it was my screw-up so I said thank you and hung up.

What's my bottom line:  in the old days dad would take the egg check and milk check to the bank, deposit them, get cash.  He knew the tellers and the bankers because it was a locally owned bank.  I'd imagine the general operations were very similar to those of the ASCS county office back in the 60's or before.  But as banking got more complicated, with different lines of business,, and more automated, that's changed, as witness my frustrating day.  More complexity means less mastery by the teller/clerk--even though the person is likely more educated, specialization means less total comprehension.

And the effect of the specialization/automation online operation is to create a frustration trap for customers and operators: 90 or 99 percent of the time it's a routine operation which goes smoothly, but the minority of the cases become much more problematic simply because there's a lack of centralized knowledge. [added--The point with my bank is the interaction among their various silos/units; the point with FSA would be the same.  The fiscal silo and the conservation silo and the payments silo all look separate to the Washington bureaucrat; they're one thing to the producer in the field.]

How successful has FSA been in moving its producers into online program servicing?  I don't know.  But organizing and educating to make that process work will be very challenging.

The Big Advantage Government Has in Hiring

The big advantage government has over private industry in hiring is the possibility of work being important, in serving the society.  Sure, Google engineers can aim to do no evil, programmers could aim to make information free, but there's always the suspicion that what you're doing is enriching Larry Ellison. 

What's the trigger for this bit of euphoria: the sun peeking through the clouds and this post on the US Digital Service.  Get the salt shaker.

5 Minutes to Pay Your Taxes?

That was the claim in a newspaper article this week.  Trying a short-cut search brought up this article in The Economist, which has a more reasonable estimate:

Estonia’s approach makes life efficient: taxes take less than an hour to file, and refunds are paid within 48 hours. By law, the state may not ask for any piece of information more than once, people have the right to know what data are held on them and all government databases must be compatible, a system known as the X-road. In all, the Estonian state offers 600 e-services to its citizens and 2,400 to businesses.

 As a bureaucrat I love the idea.  The reality for the US though is we're always going to trade efficiency for what we see as privacy and freedom.

Paperless Government

The Post has an article describing the efforts of the paper industry to lobby against "paperless government", like the requirement that every recipient of government money go to direct deposit.  Apparently paper companies are feeling the impact of IT on their bottom line and so argue that every citizen should have the right to get paper instead of electrons.

I've written before I think that part of the sales pitch for the IBM System/36 was the "paperless office".  That didn't happen.  But a lesson for us:  change can come slower than its enthusiasts promise, but it can come. 

Reader Ratings

I have a lot of RSS feeds--used to use Google Reader for them but with its demise have now switched to Feedly.

For each feed, Feedly has a metric it labels "readers". I'm not sure what it means, but I suspect it's the number of Feedly users who have subscribed to the feed.  In my case the number is about 1 percent of my usual daily page views.  While it's possible some people, like nerds and geeks, are more likely to use an RSS feed than others, which would skew the results, the Feedly figure is one way to compare different sites. 

I'll perhaps update this listing as I get more energy.

Extension: 18
USDA 3
Grist 7K
Flowing Data 33K
Grasping REality (Brad DeLong) 1K
USA gov 187
FSA  43

Slate Blogs  4K
The Agenda  861
The Way of Improvement 164
USA gov  187
USDA FSA  43
Gov exec  551
Rural information center 5

More Administrative Procedure Act Weeds

I mentioned an amendment to the farm bill from House Judiciary, requiring compliance with the Administrative Procedure Act.

Today I followed up an a USDA notice in the Federal Register, not something I usually do, and found they're withdrawing a 1971 statement on APA compliance.

The U.S. Department of Agriculture (USDA) is proposing to rescind the Statement of Policy titled “Public Participation in Rule Making,” published in the Federal Register on July 24, 1971 (36 FR 13804) that requires agencies in USDA to follow the Administrative Procedure Act's (APA) notice-and-comment rulemaking procedures even in situations where the APA does not require it. The Statement of Policy implemented a 1969 recommendation by the Administrative Conference of the United States (ACUS), which urged Congress to amend the APA to remove the exemption from the notice-and-comment requirement for rulemakings relating to “public property, loans, grants, benefits, or contracts,” adding that agencies should follow the notice-and-comment procedures pending amendment of the APA.

They've several justifications for withdrawal: loan programs are governed by OMB rules, some notices of proposed rulemaking don't attract significant comments, Congress never adopted the 1969 recommendation of the ACUS, information on rules is much more readily available in today's environment than it was in 1971. 

I know the Dems revived the ACUS. I wonder what they've done, if anything, to bring the rulemaking/public participation process into the 21st century.

Al's Back Reinventing Government

Government Executive reports Al Gore will speak at a 20th anniversary event of his "Reinventing Government".   Though I voted for the guy, 3 times actually, I didn't and don't think much of his initiative. Why?

• one big thing was government procurement credit cards.  A fine idea, except someone forgot to include oversight functions to catch fraud, abuse, and screwups.  Those had to be added later, after news reports which gave bureaucrats a bad name.
• another big thing was flattening the bureaucracy, reducing the number of layers. I'd like to see a GAO analysis comparing now with 20 years ago.  My bet is there's been no real change.
• a small thing--getting rid of agricultural programs.  As I remember, he got the honey loan program and the wool/mohair incentive programs.  Last I checked, Congress had replaced both. 

More generally, I thought he was too conservative in his approach, just adopting a few ideas which might be good, but didn't really reinvent government

High Prices at GPO

I've been looking at the history of Washington, DC in the 1800's for a couple different reasons.  One is a writing project I may post about later.  Anyhow, I'd like to see this book on the Army Corps of Engineer involvement with DC.  I've read a bio of Gen. Montgomery Meigs, who engineered the dC water system, bridges, etc. in the 1850's-60's, and was quartermaster general in the Civil War.  Also read Liberty's Cap (I think that's the right title), which deals with the process by which the Capitol Building was given its final dome in the same period.  So I've got some idea of what might be involved, but this would be interesting.

Look at the price, though: $61.00.  I don't understand it at all. Why doesn't the GPO use print on demand?  Looking at Amazon, it appears a number of outfits have scanned old books, and are now selling them as print on demand books for amounts in the range of $15-20.

Praise for USA.gov

One of my hobbyhorses is more transparency on websites (excluding my own), particularly government ones.  We as a community don't know what works and what doesn't unless we see some metrics.  And if we don't know, we can't improve.

In light of that, I'd like to note usa.gov has a post of its most posts, pages, links.  I wish more gov sites would do the same.

USDA Performance Measures

Forgive my asking,but aren't we now in FY13, nearing the end of the first quarter?  Having nothing better to do, I was trolling through the performance.gov site for USDA.  

When I copy the data over, I lose the formatting but these relate to MIDAS and OCE, and they seem to be a tad out of date. Tsk, tsk.

Initial Operating Capability (IOC) Deployment

IOC Release 1 acquisition and detailed planning will occur in FY11 Q3-Q4. Releases will follow SAP ASAP methodology (project prep, blueprint, realization, final prep and go live). Less

2011-07-01

2012-09-30

$119098

% of Field Offices with WAN Acceleration Monthly % 80 -- 2012-02-28 % of Field Office with centralized file services Monthly % 55 -- 2012-02-28 % of Field Office on centralized backup Monthly % 55 -- 2012-02-28 % of infrastructure components out of life cycle (goal is to refresh prior to out of life cycle so l More.. Monthly % 55 -- 2012-02-28 % End Users Satisfied with OCE-related IT Infrastructure Components Monthly % 55 -- 2012-02-28 % of Field Offices with Telephone systems upgraded Monthly % 75 -- 2012-02-28

The question is, is anybody looking at the measures?

USDA Improving?

From an FCW piece on the mandate for departments to establish a structure for "digital governance".

The Agriculture Department, for example, has been improving and standardizing the look and feel of all the department’s websites by hosting monthly webmaster meetings. The Labor Department is building a knowledge management program that integrates data from its 25 agencies and call centers, including answers to the most frequently asked questions, with the aim of building a cohesive customer experience.

Thanksgiving has made me cynical: how is "digital governance" different from "e-government" which was in turn different from  "IT management" which was in turn different from "ADP operations"?

Harvard Disappoints

Harvard recognizing for 2012  100+ innovations in government.  It's disappointing because probably half of the listings have no url.  Come on, get real.

FSA and Twitter Following

FSA is in the list of the 50 most followed Federal agencies. 

But it's included under USDA, which rates 19th out of 50. 

Query: why does USDA have both the @usda and @usdagov tags? And where are the other USDA agencies (Forest Service makes it on its own, no. 47) like NRCS?

NRCS IT Type

Federal Computer Week Government Executive profiles the whippersnapper who now heads up NRCS IT.

It's fine, but it sounds as if NRCS only got a website when she came aboard, which is wrong.

I've never been very impressed with their website, and it appears it's been revised now, which may be the project which failed twice before.  I do see they have a my.nrcs.usda.gov site.  I'm not clear whether farmers can get services on the website--probably.

I'm not sure what is meant by saying the website is accessible to both external and internal user base. Maybe they're saying the NRCS intranet is accessible through the home page?

Finally in my nitpicking is the claim NRCS is the second biggest USDA agency.  Not sure that's correct, if you add together FSA's federal and county employees, but then NRCS could add in their district employees as well. [Updated to correct error]

Posting Feedback on Government Sites

I think government websites should post their metrics online.  Usa.gov takes the first step towards that--a journey of a 1000 miles begins with one step.

I suppose I'm being a little hypocritical, since I don't give my own stats.

What Difference Does a Person Make

This FCW post reports the Obama administration has 22 "rockstar innovators" coming in to help transform the government.  I wish them luck, I really do. 

But...

There's always a but. My guess is only 5-10 percent of them will have the desired impact.  They may know software and they may know people, but they probably don't know government. 

Point number one: in 90 days they're dead meat if Obama doesn't win reelection. There may be one or two who know someone in Romney's camp with sufficient pull to stay on, assuming they want to but that's all.  And everyone in the bureaucracy knows they're dead meat if Obama's polls continue to fall, so how much cooperation will they get?

Point number two: to be effective the innovator needs to hook up with someone in the bureaucracy who has some clout and is open minded about sharing credit with the innovator.  After all the innovator isn't the secretary's person, he's the president's; he's from the Innovator initiative and he's here to help. ("He" because there appear to be only 2 women in the list.) 

Point number three: during the next 90 days the bureaucracy is going to move slowly simply because of the impending election.  It takes a unique blend of chutzpah and dedication to push full steam ahead on something when it's much more interesting to spend the day checking realclearpolitics and hashing over Obama's chances in Florida or Ohio.

My bottomline--one or two of the innovators may land in the right place where their skills and personality fits with someone already there, and together they may make significant changes.  That's better than not having any changes in the next 6 months, but it's not a silver bullet.

Identity Proofing

From Regulations 

Identity proofing can be accomplished for 
customers in two ways: (1) By visiting a local registration authority 
at a USDA Service Center, or (2) through a new on-line identity 
proofing service. The new on-line identity proofing service will 
provide registrants with a more efficient mechanism to have their 
identity proofed. The on-line identity proofing requires responses to 
at least four randomly selected identity questions that are verified by 
a third party identity proofing service in an automated interface. Once 
an account is activated, customers may use the associated user ID and 
password that they created to access USDA resources that are protected 
by eAuth.

 Estimate of Burden: Public reporting burden for this collection of 
information is estimated to take eight (8) minutes to complete the self 
registration process for a Level 1 Access account. A Level 2 Access 
account registration is estimated to be completed in one hour 40 
minutes when travelling to a USDA Service Center to visit a local 
registration authority (expected to be approximately 30% of the 
registrants), or 50 minutes when using the on-line identity proofing 
service (expected to be approximately 70% of the registrants).
    Respondents: Individual USDA Customers.
    Estimated Number of Respondents: 114,841 Level 1 and 14,860 Level 2 
for an estimated total of 129,701 respondents.
    Estimated Number of Responses per Respondent: 1.
    Estimated Total Annual Burden on Respondents: 31,077 hours. 

This is from USDA's Information Collection Notice.    Some comments:  I assume USDA/OCIO will do the same sort of thing as Treasury has done with their Treasury Direct customers: ask things like what the customer's address, phone number, date of birth, years in house, etc. etc. are--that's the "third party identity proofing service" referred to.  The theory is that such data is publicly available and has been collected by the credit rating people, and other entities, so if I give answers which match that set of data, I must be me.  It makes sense to me.

I wonder how OCIO came up with the time estimates in the document.  When I did this sort of thing with Treasury it was more like 5 minutes than 50--maybe the third party service they use is less efficient than the Treasury's?  I'm assuming, perhaps wrongly, the identity proofing is only for Level 2, seems like bureaucratic overkill to require it for Level 1.

 I'm most fascinated though by the estimated number of respondents. Only 15K Level 2's, which are the people who want to do real business with FSA* online??  Elsewhere I've noted, I think, the big plans USDA/FSA has for moving to online business; I think this figure is inconsistent with those plans being successful.  Trying to construe them as favorably as possible, if I had been writing this document I would have used only the new FSA customers I anticipated over the period of the collection.  I'd assume there's some period OMB says to use for this, though usually you're talking about an annual collection, not an open-ended one.  

Finally I wonder if USDA/OCIO has run this process through a user review, as pushed by Prof. Sunstein.  If the good professor had been bureaucratically sharp, he would have changed the OMB guidance for these documents to specify the extent they were tested with users.

* I don't know that other USDA agencies use the e-Auth process.

Filling Out Forms: Deferred Action

Wrote recently about Cass Sunstein and the OMB form approval process.  Today is the first day people can apply for "deferred action for childhood arrivals".  From the website:

Over the past three years, this Administration has undertaken an unprecedented effort to transform the immigration enforcement system into one that focuses on public safety, border security and the integrity of the immigration system. As the Department of Homeland Security (DHS) continues to focus its enforcement resources on the removal of individuals who pose a danger to national security or a risk to public safety, including individuals convicted of crimes with particular emphasis on violent criminals, felons, and repeat offenders, DHS will exercise prosecutorial discretion as appropriate to ensure that enforcement resources are not expended on low priority cases, such as individuals who came to the United States as children and meet other key guidelines.  Individuals who demonstrate that they meet the guidelines below may request consideration of deferred action for childhood arrivals for a period of two years, subject to renewal, and may be eligible for employment authorization.

Here's the application.  Note it can be filled in online, which is good, and it has an OMB clearance.  I suspect it was put together in a hurry.  I wonder about the software backing it up.  Apparently the process means: fill out online and print the form, mail the completed forms to a "lockbox" facility with the fee.  The forms are scanned to pick up the data.

A couple of nits: some of the entry blocks are blue shaded, some aren't.  The drop-down lists of state abbreviations includes "AA" and "AE", which points up the error of not including state name.  I also question whether the language on the site is clear English, but then they're anticipating criticism.

More seriously--I see we're still imposing our name structure on the rest of the world (first, middle, last; which doesn't work well for some of the other cultures in the world).

Returning to my previous post: this example both fits and doesn't fit.  It is a case of a new program which requires a new information collection.  But since it's the President's own priority and a key to a reelection, I'm sure Prof. Sunstein cleared it personally through OMB.  And since it's still using a hybrid process to collect data (i.e. print completed form then scan) it's an example of how backward even the Obama administration's effort at egovernment are.

Cass Sunstein and Catch-22

Cass Sunstein is leaving as head of regulatory review for the Obama administration, but before he's out the door he's pushing the idea of making government forms simpler, by testing them through focus groups or similar processes.  That's fine and dandy, but...

What's my but?  

Most government information collections (forms) are well-established, but some are new. The memo which Sunstein's post links to, further links to earlier guidance, including a detailed Q&A put out by the Bush administration.  There we learn that you need to have OMB approval before using focus groups over 9 people in total.  So if I've got a new program which requires a new data collection and a new form, I've got to get OMB approval twice: first of the draft form, second, after I've run the draft through my focus groups of the final form.  It would make more sense to give blanket approval of focus groups without this Catch-22.  Matter of fact, changing the guidance for OMB approval of information collections to require focus group (or equivalent) testing in the documentation would be good.

But I've got another but.

Sunstein's initiative shows how stuck in the past OMB is.  He should have been leading a transition from paper-based collections to Web-based collections.  He didn't.