DEAR MR. MCNICHOLAS,

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP85-00988R000400180001-9
• Release Decision: RIFPUB
• Original Classification: K
• Document Page Count: 4
• Document Creation Date: December 15, 2016
• Document Release Date: October 1, 2003
• Sequence Number: 1
• Publication Date: March 4, 1980
• Content Type: LETTER

Mr. John P. McNicholas
Acting Deputy Assistant foz
Information Policy
New Executive Office Building
Room 9002
Washington, DC 20503
Dear bir. McNichalas,
P.ttaehed are Interagency Committee for ADP comments o~
Rouse Resolution No. 6410.
Due to the short response time available by your offi~ve,
the full Interagency Committee did not have an oppartunity to
respond. However, the Executive Board of YAC consisting or
regresentatives from fiEW, SUD, Dt~D, DOE, Congress, Treasury,
and Agriculture did revie~a HR 6410 and their coordinated
cotn~nents appear below.
IAC fully supports this effort to reduce paperwork in the
Federal Government. We note that the burden placed on the OMB
and the agencies to execute this Bill will be great, but with
proper planning and the effective use of ADP the burden will be
considerably alleviated. IACJADP will be pleased to tend
support where possible in this area.
We do have some major concerns with the sectiona of the
Bill that deal with ADP and Telecommunications. If these co.i-
cerns are accommodated then we can fully support alI aspects of
the Bill. IAC supports the basic tenets of these sections i:l
having the.OMB more involved in a policy and oversight role in
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regard to the effective and efficient use of AD? by Fe~3era1
agencies, We believe that determined pursuit of -the objectives
by C7MB of this Bill could aid agencies in acquiring ADP faster,
reduce the obsolescensQ problem, and lead to better planning
and more effective use of this resource by agencies. an
addition, the added emphasis on control of standards and their
utility in obtaining competition as well as transportability ref
ADP systems is again fully supported by SAC.
We have three concerns with the details in implementing the
sections of the Bill dealing with ADP and Telecommunications.
The first is the basic relationships between the OMB, GSA,
and the agencies. The 8111 can be interpreted as placing GSA
in a control, directive, and reviex position essentially at the
OMB level in addition to their normal procurement and acquir~i-
tion responsibilities. To equip GSA to perform these roles
would be an additional overhead in the Federal bureaucracy that
would be a redundant one and contrary to the President?s
policy to reduce overhead in the Federal bureaucracy. More
important, if our interFretation holds, is that conflict will
arise between the agencies who have the ultimate responsibility
far execution of programs and GSA which interfaces in one
segment of the process. On occasion, conflict will exist
between an agencies mission responsibility and GSA's procure-
ment responsibility. fihe need is to establish a smooth Bup?-
p?rtive managerent flow from the definition of need, through
the requirement determination, acquisition, implementation, a~.d
operation. OM3 is properly pieced to insure that flow and
presently has the authority by the Brooks Hill to adjudicate
differences between agencies and the GSA to ultimately decide
the best course of action the Government should take. OMB,
therefore, should remain separate, indepenaent and above the
agencies and GSA to properly execute its adjudiction rol?. We
recagniae that QMB has not been active in this regard in the
past, but House Resolution 6410 clearly directs and emphasizes
execution by OMB. Specifically, G5A should not be a party to
the responsibility to devtlop 5-year plans for the Government.
This is clearly the agency's responsibility, GSA should,
however, b~?the recipient of the agency plans and provide ty
requirements contracts or other means the capabilities to
assist the agencies in execution of their plans. Further, Goa
should not directly influence the budget process which is again
properly constituted as an agency and OMB responsibility. OMB
can and should receive input from GSA on agency actions
pertaining to ADP and Telecommunications which may at OM.g
discretion influence the budget process.
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Quz Second concern is with the possible interpretation of
the' review function detailed in AOUSQ Resolution 641i?. St may
he construed that OMS will direct internal auditors and may use
one agencies auditors to investigate another agency. Ageneit
internal auditors and inspector generals are more independent.
than ever in our history and perform a needed function for
senior managment of an agency to investigate internal problems
and take eorreetive action. The agency staff is much more
familiar with potential internal problems, and agencies eur-
rently have the capability to investigate and correct problems
before they get out of hand, do serious damage, or bring
discredit to the Federal government. Direct contr?1 of
internal audit functions by central agencies will take away at
at a minimum dilute the capability of agency heads to correct
their own problems,
Our third concern deals with the senior official
responsible for execution of this Bill at the ~~gency level. We
agree with insuring that a senior official be designated ar_ a
high Level to he responsible to assure the tenets of this IIill
,are executed, but disagree with the legal requirement foy that
same individual to necessarily be responsible for the acquisi-
tion and control of ADP and Teleco::..2~unications. This sh4u~.d be
at the agencies discretion. Moat organizaticna vest procure-
ment authority in procurement and acquisition a;parts. Tv
force the same individual to be rasp?nsible far all the myriad
aspects of this Bill to include acquisition of At3P res~aurces
^aay disturb an effective r~anageu~nt relationship xithin agen-
cies that exists today.
We believe the intent of the Bill as it pertains to 1~I3P
and Telecommunications; to have aMB responsible for g~oliog
pertaining to the res~uire:~ent, acquisition, and use cif the
information technology resource and to be an t+ctive and force-
ful player in this regard is worthy. We also believe the
Bill's intention for GSA to have a direct role in support flf
UMB's responsibility to be proper.
However, the specific wording of the 9!11. Leads tQ
different interpretations which is the cause of pus concez?nw
Prover rewording will correct theses areas o~ concerts.
Specific suggestions are attac5ed.
The Interagency Committee an ALP sPPPreciates tie
opportunity to be a participant and hopefully has provided
constructive advice fa supporting the desire of the Congress to
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reY~.eve the paperwork burden on the American public and to wort
effectively and efficiently use the vast ADP resourc+~ of t~je
Federal Government. _
I`nterageney Committee on
Automatic Data Processing
c~Ae/ADp)
1 Attachment
Recommended Changes
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