Freedom of Information: AIIM's GovSIG GOTS What It Takes to Satisfy - Part 2
Special to the NCC-AIIM newsletter, The Capitol Image
By Owen Ambur, February 3, 1999
[Back to Part 1]

In an article entitled "Document-enabling the call center ... revisited" in the January 1999 edition of KMWorld (pp. 28 & 29), Bruce Silver highlighted a contemporary example of the need for effective knowledge management, which is to say "records management." He notes one of the forces driving "call centers" and workflow/document technology vendors together: "The rapid growth of Web-based marketing and sales - the E-commerce phenomenon - is generating a flood of E-mail customer service requests that many companies have simply no resources to handle."

As an aside, it's is worth noting that E-mail is a stage of immaturity through which we must pass on our way to the business-quality processing of information. However, Bruce's comment is directly attributable to government agencies as well as commercial enterprises, not only with respect to E-mail but also telephone calls.

With reference to phone calls, the Vice President's Blue Pages initiative and the X.500 directory standard are especially noteworthy. The essence of the VP's initiative is to list government functions by commonly understood functional terms, rather than the traditional bureaucratic office nomenclatures that may or may not mean anything to the public. It is incumbent upon public servants to offer their services in the language of the people, rather than to expect the public to wend its way through a Byzantine hierarchical labyrinth of bureaucratic office "brand" names. (Does it make sense that public agencies are expected to pay to "advertise" their phone numbers in the telco directories, but private citizens are required to pay not to advertise theirs?)

Moreover, the very same well-recognized, "generic" terms used to simplify the identification of the appropriate phone numbers can and should also be used to direct citizens to the exact information (public records, i.e., documents) they desire. In fact, as in any supply chain, the objective should be to eliminate from the process as many needless steps as possible. Government should not be in the business, nor should taxpayers be forced to pay for needless conversation. AIIM's GovSIG can do the taxpayers a big favor by building into the DMA standard the ability to classify and query records by the X.500 Blue Pages functional terms.

Testifying on behalf of Microsoft in the government's antitrust litigation, Professor Richard Schmalensee of MIT made the following assertion: "The user uses what they need to do their job. Nobody needs 10,000 applications." [The Washington Post, January 15, 1999, E3.]

Amen! And how many software applications do people generally need to process business-quality records? Could it be two, and only two?

When Rich Noffsinger of Microsoft appeared before NCC AIIM, he said: "Document management is a true horizontal; it cuts across all business lines." EDMS/ERMS software is the single application required to manage all business-quality records that are logically unstructured as a class. (Individual record types may be highly structured but, for purposes of records management, the same metadata elements as well as the same software programming logic may be applied to all records of all types.)

For highly structured data, the single application required is E-forms software. Subject to appropriate access controls, a single E-forms client should be able to write data to any standards-compliant database and a single EDMS client should be able to manage any record - both locally as well as in any document repository, worldwide.

The wisdom of JetForm's recently announced strategy to offer free "citizen's licensing" for FormFlow99 remains to be seen in terms of market share and profitability. However, relative to the public interest as well as the interests of Federal agencies with respect to GPEA, it is dead on the mark. No citizen should be expected or forced to pay anything simply for the privilege of filling out a form or filing a document with their Government.

(Hint: The DMA vendors should follow JetForm's lead and step up to the plate with free citizen's licenses for the submission of documents to government agencies. Individuals, businesses, and organizations who get a taste of the empowerment that EDMS/ERMS technology provides may find it addictive, something with which they cannot live without in their own operations. If and when they do, brand recognition may be important even if the products are based upon an international standard.)

Kudos to JetForm too for their participation in the Workflow Management Coalition (WfMC). If the WfMC incorporates the international X.500 White (and Blue) Pages standard for directory services, we'll really be in business - the business of processing and providing access to business-quality information in a business-like way, worldwide. (The White Pages comprise person metadata, while the Blue Pages catalog government functions.)

Speaking of operating in a business-like way, USDA's Agricultural Marketing Service (AMS) has established a best practice with respect to the vital role of government in the process of rulemaking. Apart from electing the President and their representatives in Congress, serving in the military, and paying their taxes, perhaps the single most important way that citizens participate in government is in commenting on proposed regulations. AMS empowered citizens to file their comments on the proposed National Organic Program (NOP) rules directly in a (KeyFile) EDMS over the Internet. In addition to avoiding the needless inefficiencies and complexities associated with E-mail, AMS's approach also enabled citizens to self-classify their comments for purposes of analysis and record-keeping, thereby reliving the taxpayers from having to pay public employees from having to perform that function. (Notably, like JetForm, KeyFile is also a member of the WfMC.) The DMA ought to challenge Office of Management and Budget and/or the CIO Council to join in a partnership to pilot an Internet-based, governmentwide and nationwide regulatory notice and comment EDMS/ERMS. (Suggested name: RegNot.)

In the past, government "home-grown," often mainframe-based, applications have been derisively called GOTS (government off-the-shelf). Implicit in the interpretation placed upon the acronym is the thought that applications developed "by the government and for the government" invariably fall far short of the usability and functionality of similar applications developed and used in the commercial sector. Indeed, many, if not most IT applications developed by government are relative, if not complete failures. Director Raines didn't specify COTS for no reason. His aim was to save the American taxpayer from being forced to relive the mistakes of the past. However, it is time to change the meaning of the term. Indeed, GOTS is exactly what government agencies need, provided the term is defined as follows:

To a degree, AIIM's vendor members already offer such applications and, at the technical level, the requirements are largely the same as for commercial customers. The components simply have not been effectively segmented and marketed. Too much technical support and specialized programming are required. By failing to coalesce more rapidly on the necessary standards and then offering proven components that comply with those standards, vendors have been their own worst enemy. However, there is plenty of blame to go around.

When contacted in 1995, a sales representative for Saros (now part of FileNet) indicated their focus was on large private corporations because the Feds were (are?) "too hard to market to." (That fact was also reflected in the placement of Saros' sales force. The nearest contact for the Washington area was located in Atlanta, Georgia.) Not only was (is?) it too difficult to get anyone to make a decision in Federal agencies, but even if they did (do?), they were (are?) not in a position to make a commitment for more than a very narrow segment of the bureaucracy.

"Hard to market to" means added expense, which in turn means risk of unprofitability in a highly competitive commercial marketplace. (A number of the EDMS/ERMS vendors have recently opened DC-area marketing operations, but PC DOCS probably deserves credit for making the greatest concerted effort over the long haul.) Worse yet, from the standpoint of the public interest, the fact that public agencies are "hard to market to" means that the taxpayers get the old double-whammy. Not only do they end up paying more than they should for the EDMS/ERMSs that are acquired by enlightened public officials, but they also end up with incomplete and inaccessible records in every other public office and agency.

It is somewhat ironic that ignorance is no excuse under the law as it applies to a private citizen, but public agencies routinely invoke it with respect to the right of the public to have full access to the public record. Somehow agency leaders feel justified in not documenting, managing, and making available public records of actions they have taken and information their employees have possessed. In fact, simply being unable readily to produce a record is taken as a valid excuse for not supplying it under FOIA. No justification has been required as to whether the agency should have been able to produce the records, and what steps they have taken to ensure that they will be able to do so. The simple fact that they are unable to do so, for whatever reason, has been taken as an acceptable defense. In effect, their first mistake is taken as justification for the second.

That loophole was narrowed significantly, if not closed, by E-FOIA, which requires that any record created on or after November 1, 1996, must be made available in electronic form upon request. However, as always, accountability and enforcement remain open questions in the Federal bureaucracy. Sadly, it may take the risk of a law suit for many agencies recognize their obligation. On the other hand, AIIM GOTS what it takes to help begin to change the equation that routinely leads public servants to the wrong answer with respect to the stewardship of the public record. Working with and through AIIM's GovSIG, NCC-AIIM can facilitate that change.

In the closing chapter of her book, Ms. Vos Savant says, "One of the biggest weaknesses of majority rule is that the majority may be wrong." It is perfectly reasonable, she notes, for any individual to "accept political rhetoric at face value rather than going through the laborious research required to verify it." (p. 166) And it doesn't take a genius to understand that her assertion is all-the-more true to the degree that officials are permitted to deny the right of the public to a clear, open, and readily accessible public record.

It is not as if "democracy as we know it" depends upon AIIM's GovSIG - although it does depend upon each of us, as individual citizens. Indeed, Ms. Vos Savant references the concept of "satisficing, in which people settle for a satisfactory level of winning rather than searching for an ideal or optimal solution." (p. 194) As we pass into the third millennium, no doubt, democracy will continue to muddle through in our nation as it has for the past two "centennia". However, leadership is not about the past. It's about shaping the future. As President Kennedy said, "I dream of things that never were and ask why not."

Are we up to the challenge? Does AIIM really GOTS what it takes to satisfy the actual needs of public agencies as they relate to the true interests of the public? Or am I only dreaming?


Owen is a personal member of AIIM and a masters candidate an the University of Maryland University College. He worked on Capitol Hill for 14 years (8 in the House and 6 in the Senate) and was Congressional liaison for the U.S. Fish and Wildlife Service for 7 years. Currently, he is on assignment to redraft the agency's records management policies. His personal home page is at http://www.erols.com/ambur and he may be contacted at ambur@erols.com.