AGENCY POLICY ON RESPONDING TO EXTERNAL REPORTING REQUIREMENTS

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP83B00823R000100140001-1
• Release Decision: RIPPUB
• Original Classification: U
• Document Page Count: 9
• Document Creation Date: December 9, 2016
• Document Release Date: April 3, 2000
• Sequence Number: 1
• Publication Date: February 28, 1974
• Content Type: MF

`ENCF
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WII 100140001-1
.ptp; pop: xe tive Officer to the Deputy Director
for Management a d Services
&en Policy on. Responding to External
Reporting Requirements
DWI = 74-0630
. 1. We have reviewed the Comptroller's ne ora d ,
subject as above, dated 13 reb ary 1974 to the Secretary,
CIA Management Committee d have the following cor eats
a. The Office of Security is responsible for
preparing eleven (11) safety reports, each year, to
the Department of Labor (9 quarterly and 3 annual
reports). An annual report is also prepared for the
Federal Fire Council. Moreover, we submit input for
such reports as the DCI Annual Report to the Presi-
dent's Foreign, lntelli once ?c viso ?oardd and the
General Counsel's report to the Attorney General
covering an inventory of wire-tapping and electronic
eavesdropping equipment in our possession in the
United States.
Approved t12~0~/9l~91L'~`Ii l
We believe that the Co troller's recon-
nen tions set forth in paragraphs 6 and 7 of his
memoranda are reasonable in that they would assist
other Federal agencies in the perfortance of their
responsibilities in this field and, at the sane time
protect classified information involving sources
and methods and other 'sensitive matters.
2. Please advise if we can be of further assistance
in this matter.
John P. Blak
~ACtiUg Director of Security
Approve
DID A!
6,2002/05/01 . CIA RDPO 00100140001-1
 Approved F/,051~`:~IA-FZDAB
b1 00140001-1
SUBJECT: Agency Policy on Responding to External
Reporting Requirements
distribution:
Ori 4 1 - Also
1 - AD/Security
PPR File
PPB Chrono
OS/PpBE
; a;-1 STATINTL
28 ebrua y .e 4
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Approved For 3Q2/05/01 CIA-RDP83E~0R~ 0140001-1
 MEMORANDUM FOR: Secretary, CIA Management Committee
SUBJECT: Agency Policy on Responding to External
Reporting Requi rements
1. Executive Order 11717 directed the transfer of certain
functions from the Office of Management and Budget (OMB) to the
Administrator of General Services and to the Secretary of Commerce.
These functions include formulating, prescribing, and assuring
compliance with Government wide policies in the area of financial
management systems improvement, procurement and contracting,
real and personal property management, development and improve-
ment of management techniques and systems, transportation procurement
and management, and.automated data processing management. The
transfer of Government-wide management policy responsibilities
for these functions, with attendant reporting requirements, from
OMB to the General Services Administration (GSA) and to Commerce
suggests the need to establish a formal Agency policy on responding
to all external reporting requirements. It is suggested that this.
issue be placed on the Agenda for consideration by the CIA Management
Committee.
2. The Agency receives numerous requests from other Federal
agencies for reports on a wide variety of personnel, administrative,
and management matters. Examples include reports on occupational
accidents, EEO, real estate holdings, financial management improvement
efforts, transportation management, silver recovery, etc. As a general
.rule, administrative reporting requirements levied by other Federal .
agencies are received by or referred to the CIA component primarily
concerned. However, there appears to be little uniformity with
respect to compliance, except in the case of OMB-levied requirements.
Historically, we have responded to OMB management reporting
requirements directly to the International Affairs Division (with
 Approved el~efi's '1M&4_: A*t~P$.' B F~ J01400D)-1
whom the Agency maintains continuing liaison on all budgetary and
related matters) rather than to OMB's Assistant Director for Management
and Organization as prescribed in most cases by OMB circulars.
3. Particularly with the transfer of certain management
policy responsibilities from OMB to GSA, we are faced with a prolifera-
tion of reporting requirements levied by GSA. Evidence of this
trend is present' in the early issuances of the new GSA series of
Federal Management Circulaws (FMC) which are concerned with
questions on real property, auditing practices, energy conservation,
etc. ' Offering to provide requested data to OMB as in the past
would not seem appropriate since such would not serve GSA's purposes,
but we may need to question whether it is appropriate to give
GSA certain management-type data which previously was provided
to OMB. While some reporting requirements probably will call for
innocuous data which we could provide on an unclassified basis.
without difficulty, others no doubt will request information we
might prefer not to provide for security, operational, or other reasons.
The promulgation of a formal Agency policy on all external reporting
requirements would serve as a basis not only for establishing our
relationship with GSA on its FMC series without relying on ad
hoc responses seeking exceptions when non-compliance is judged
to be justified, but also. for handling reporting requirements of other
Federal agencies.
4. As noted rn Paragraph 2 above, we have responded to
most OMB requirements directly to that Office. However, in some
instances, OMB instructions were for reports to be submitted to
other agencies. For example, OMB Circular No. A-2 (concerned
with utilization, disposition, and acquisition of Federal real property)
called for a report to GSA, with concurrent copies to OMB (FMC
73-5 replaced A-2 and continues the reporting requirement to GSA) .
Since the Agency submitted the required report in 1972 and 1973,
we have a precedent in our relationship with GSA which obviously
must be considered in dealing with reporting requirements levied
by future FMC's. For other than OMB-originated reporting requirements,
past practice in the Agency has varied somewhat. In response
to requirements levied by some agencies (e.g., the Civil Service
Commission), compliance has been the exception rather than the
rule. Requests from certain other agencies (e.g., Department of
Labor, Treasury, GAO), although less numerous, have more frequently
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 11 ~Affproved For
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been responded to by the Agency. We have been unable to identify
a formal policy on which current practice is based, but it seems
reasonable to assume that, had we been challenged, the Director's
special authority, security grounds, or the protection of sensitive
intelligence sources and methods would have been our justification
for non-compliance. In those.cases where the Agency has complied
with external reporting requirements levied by other Federal agencies,
our response has with minor exceptions been unclassified. In
one or two cases, our offer to comply on a classified basis has
been rejected with the statement that such a response would not
serve the purpose intended and therefore we need not respond.
5. As a practical matter, the de facto but not specifically
articulated Agency policy has been to respond to most external
reporting requirements when such can be done on an unclassified
and meaningful basis. However, some requirements have been
simply ignored. In questionable cases involving the propriety
of responding to a specific requirement, or where it seemed desirable
to respond on a classified basis, the matter has been referred to
a senior officer for decision. It seems appropriate that our informal
policy be made explicit and formally stated in a manner to conform,
insofar as possible, with the practice of other Federal agencies.
If such a policy were to be adopted, we would expect certain exceptions,
as follows: (a) requirements levied by OMB, with which our reporting
relationship must remain unique, (b) requirements levied by Congress,
which in all cases would be referred to and handled by OLC, and
(c) requirements which can only be satisfied on a classified basis
where compliance would be in the best interest of the Agency. In
the latter cases, the question of compliance would be referred to
the DDM&S or to the DCI, as appropriate, for decision.
6. It is recommended that:
It be Agency policy to comply with external reporting
requirements levied by other Federal agencies for administra-
tive and management information in all instances where a
meaningful unclassified response can be prepared, subject
only to the exceptions noted in Paragraph S. above involving
OMB, Congress, and certain classified responses.
Approved For ' (]q/?,p5 b
CIA-RDP83B00$a)t00(:140001-1
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 Approve
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7. In the instant case of the FMC's, and assuming approval
of the above-recommended policy, we believe it would be prudent
to advise the Administrator of General Services of our intent to
comply to the extent possible with GSA-levied reporting requirements
and to Inform him of our past practice in reporting management
information to OMB. Accordingly,, it is recommended that:
The Comptroller prepare a coordinated. letter to this
effect to the Administrator for the DCI's signature.
JOHN D. IAMS
Comptroller
Distribution:
Orig - Secty/MC
1-DCI
1 - DDCI
1-DDI
- DDM&S
1-DDO
1-DDS&T
1 - Gen Counsel
1 - IG
1 - Comptroller
1 - ES/CIA
1-ER
DD/M&S Distribution:
1 - D/JCS
1 - D/Log
,Y - D/Sec
1 - D/Fin
1 - D/Pers
1 - DD/M$S Subject
Appr
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.
. STATI NT
 Pee apil'i S N W LL CHE K LA ICATION O TOM
UNCLASSIFIED CONFIDENTIAL SECRET
OFFICIAL ROUTING SLIP
TO
NAME AND ADDRESS
DATE
INITIALS
I
Director of Security
4E60Hs
2
3
4
5
6
ACTION
DIRECT REPLY
PREPARE REPLY
APPROVAL
DISPATCH
RECOMMENDATION
COMMENT
FILE
RETURN
CONCURRENCE
INFORMATION
SIGNATURE
Remarks :
The attached proposal has been submitted to
the Management Committee for consideration. If
you have any comments, please submit them as soon
as possible. We don't know when it will appear on
the agenda.
RHW
FOLD HERE TO RETURN TO SENDER
FROM: NAME. ADDRESS AND PHONE NO.
DATE
Acting Executive Officer to the DD/M$S
7
e old
FORM NO. 237 Use previous editions
1-67 I
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F1 R *RAZ002/O5/O 1
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CIA-RDP8nO0ea N 1t000I -1
11
SECRET
ROUTING AND RECORD SHEET
SUBJECT: (Optional)
Agency Policy on Responding to External
Reporting Requirements
FROM:
EXTENSION
NO
.
Acting Chief
Plans, Programs Branch
5311
DATE
28 February 1974
TO: (Officer designation, room number, and
building)
DATE
OFFICER'S
COMMENTS (Number each comment to show from whom
RECEIVED
FORWARDED
INITIALS
to whom. Draw a line across column after each comment.)
1.
C/PP&AD
DEADLINE: Noon, 1 March 1974
2.
DD/P&M
74
3.
AD/Security
4.
DD/Security
MAR
5.
6.
7.
AC/PPB
8.
9.
10.
11.
12.
13.
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15.
^ SECRET ^ CONFIDENTIAL ? USE O LY ^ UNCLASSIFIED