WAIVER OF GSA REGULATIONS GOVERNING WORD PROCESSING EQUIPMENT

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP84B00890R000500030075-0
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 9
• Document Creation Date: December 19, 2016
• Document Release Date: November 21, 2006
• Sequence Number: 75
• Publication Date: March 3, 1981
• Content Type: MF

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5 MAR
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M,-MORVCDF Pages 2 thru
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C PAN tt ; FOR: Deputy Director for Administration
'Bruce T. Johnson
Director of Data processing
T. C ~? n Waiver of C1-4% Regulations Governinei
t^'ordd Processing Ecuipmont
Leh/A. Registry
1. Attached is a staff study, coordinated with the Office
of Logistics, which addresses the problem created for us because
CSA regulations fail to treat word processing equipment (VPE) as
an intearal part of APP and particularly office automation
systems. Because of the relationship of ,',PE procurement with the
procurement of other A?DPE, under our delegation , of procurement
authority (DPA) I have provided some information about the IPA
Fr'd our success in employing it. I believe it will. give you what
you need to pr_epare for discussion of this subject with the new
P"dr inistrator of the GSA.
?. The staff study is longer than I had hoped, but the
subject is a technical one and difficult to summarize. Since
your time is limited you may wish to concentrate on the section,
I lave highlighted, Sections I (Problem.), III (Discussion,
C
AA'~~aracfraphs A' and F and. ` ~:,:i) , IV (Conclusions), and V
(Mecomrmendations) .
3. You may have concluded from our introductory discussion
of ODD that I felt we had some fundamental problems with 3DPF
procurement in general. k,"y' intention vs'as to acquaint you with
the ways in which the procurement process impinges on our
operation, and indeed we are forced to invest considerable effort
in support of p :rocurement. As the staff study shows, however, I
consicjer the requirement for competitive procurement to be
reasonable and I believe our delegation of procurement authority
from GSA serves our purposes extremely well. It is only in the
area of word processing- where some changes are needed.
4. Preparation of a formal request for waiver (or
"deviation," as it is called) to permit CIA to proceed with its
word processing/off ice automation program unhindered by GSA
regulations will recuire additional time. The staff study was
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the first step, outlining the basis for the case to be made to
GSA in making the request. Unless instructed otherwise as a
result of your discussions at GSA, I will collaborate with
OL/Procurement and the Office of General Counsel in the
preparation of the formal request.
/s/ Deuce T..''~"~' snn
Attachment: a/s
I Information Handling Systems Architect STAT
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l lww
WORD PROCESSING AS AN INTEGRAL PART OF AN
OFFICE AUTOMATION PROGRAM
I. Problem: As defined and managed by the National Archives and
Records Services Administration (NARS) for the General Services
Administration (GSA), word processors are treated as nothing more
than expensive production typewriters, to be justified only when
volume production requirements can be cited. Thus acquisition of
equipment for purposes of office automation, with its emphasis on
information management instead of records management is severely
inhibited, and valuable manpower that could be addressing the
challenges and opportunities of office automation must be invested
instead in volumetric studies of the ways in which word pro-
cessors are to be used in offices requesting installations.
II. Facts Bearing on the Problem:
A. In April 1979 GSA, citing technological advancement which
made it "increasingly difficult to differentiate between WPE [word
processing equipment] and ADPE," redefined all WPE as ADPE and
subjected WPE to the procurement regulations which implement the
Brooks Act.
B. The redefinition of WPE did not remove it from the purview
of NARS, and regulations governing its acquisition and use remain
in the Records Management (FPMR 101-11) section of the FPMR's, just
after Vital Records and Forms and preceding Reports Management., and
Aidiovisual Records.
C. Acquisition of automatic data processing equipment
(ADPE) for the Federal Government is governed by the Brooks Act, PL
89-306, 40 U.S.C. 759. The Act authorizes and directs the
Administrator of the GSA "to coordinate and provide for the
ecomonic and efficient purchase, lease and maintenance of automatic
data processing equipment by Federal agencies." It permits him
to delegate authority to other federal agencies to acquire and
operate ADPE when "necessary for the economy and efficiency of
operation, or when such action is essential to national defense or
national security." It stipulates, however, that the Administrator
is not to "interfere with, or attempt to control in any way," the
use made of ADPE. The Act also gives the Secretary of Commerce
certain authorities regarding the establishment of uniform Federal
ADP standards. The language of the Brooks Act gives it preeminence
over other inconsistent provisions of law, so CIA cannot employ the
extraordinary authorities of the DCI to avoid application of GSA's
implementing regulations, except insofar as the Administrator
grants a waiver.
D. In December 1973 GSA issued to CIA a delegation of
Procurement authority (DPA) for "the lease, purchase and/or
maintenance of ADPE and related items." The DPA prescribed,
however, that the Agency must follow all applicable procurement
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regulations and it cited a number of specific Federal Property
Management Regulations (FPMR's) which were to be followed. It also
provided for an annual review of procurement actions. In an
amendment dated 29 September 1978 GSA added ADP services to the DPA
and updated the references to various applicable regulations.
The DPA carries the stipulation that it can be voided for "failure
to operate within the established limitations."
E. GSA's regulations, supplemented by instructions and
circulars from OMB (e.g. Circular A-71 on Responsibilities
for the Administration and Management of ADP Activities), establish
comprehensive rules governing the acquisition of ADPE. Prime among
the requirements is the need to demonstrate a maximum reliance on
competition to ensure the advantages of lower costs and to give as
many vendors as possible access to the Federal market. In their
broad interpretation of the Brooks Act GSA has had the consistent
and active support of Congressman Brooks, who has made himself the
watchdog of ADPE procurement and use in the Federal establishment.
F. CIA and the Intelligence Community have supported the
concept of competitive procurement. In NFIB 74.2/25, 8 November
1977 on NFIP Procurement Policy, the then DCI stated that "all
procurement, whether by formal advertising, or by negotiation,
within the limitations of statutory responsibilities to protect
sensitive intelligence sources and methods, should be made on a
competitive basis to the maximum practical extent." In HN 45-191,
31 May 1978, on CIA Procurement Policy, the then DDCI reiterated
this NFIP policy and stressed the need for thorough justification
wherever sole-source procurement is proposed.
G. In December 1980 the so-called Paperwork Reduction Act of
1980 (P.L. 95-511) was passed. Among its purposes was "to ensure
that automatic data processing and telecommunications technologies
are acquired and used by the Federal Government in a manner which
improves service delivery and program management, increases produc-
tivity, reduces waste and...the information processing burden..."
Because the Act would give additional oversight authorities to the
Director of OMB, ADPE and telecommunications equipment used for
military or intelligence activities were excluded. During
legislative debate on the bill, however, Senator Jackson found the
opportunity to assert that "to the maximum degree feasible...
competitively bid procedures would continue to be employed in the
acquisition of...ADP equipment used in support roles for military
and intelligence activities," and Congressman Brooks, in accepting
the proposed exclusion amendment, asserted that "existing statutes
[e.g. the Brooks Act] covering these activities are not affected by
this amendment." Thus the Paperwork Reduction Act became at once a
form of reinforcement for the application of GSA regulations to
CIA's ADPE procurement, and a source of new guidance regarding the
ways in which WPE, as a subset of ADPE, could be used "to improve
the effectiveness of the use and dissemination of data in the
operation of Federal programs..."
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Now
H. In the CIA report of October 1980 to the National Academy
of Public Administration (NAPA) in support of NAPA's in-depth
review of GSA, the Agency used the delegation of ADPE,procurement
authority as the model for the kind of shift in responsibilities
needed if other services essential to CIA were to be at all
adequate.
A. Word processing aside, the procurement of ADPE under the
Agency's DPA is working extremely well. At a time when critics of
GSA (such as the General Accounting Office and the Federal Data
Processing Reorganization Study) are pointing out that it can (and
usually does) take from 2 to 6 years to procure new computer
systems through GSA,?`CIA is issuing Requests for Proposal (RFP's)
and bringing in CPU's other peripheral hardware, and various ADP
services in a fashion that is the envy of other Federal ADP
managers who come to us for advice. Our last CPU, for example,
took 74 days from issuance of RFP to award. The current pro-
curement of our 3033 MP, interrupted by the equipment moratorium,
could have been completed in 102 days (71 from the date of the last
RFP amendment). ODP and OL/Procurement work closely and in harmony
to obtain the equipment and services needed to keep CIA's data
processing establishment equipped with the latest technology. Our
management of these processes under the DPA is audited periodically
but not disruptively by GSA, which has consistently found our
procedures to be legal and proper. Given continuing Congressional
concern over maintenance of a competitive approach to ADPE
procurement, such audit reports represent an excellent defense,
against any charges by critics of CIA that we high-handedly ignore
the FPMR's and the will of Congress. In a time of strong sentiment
for checks and balances on Federal authority, the relationship
represented by our DPA can be perceived as clearly advantageous to
CIA.
Nor does the subordination of the ADPE procurement process to
another agency's delegation inhibit our ability to protect sen-
sitive sources and methods information. We have been supported in
our insistence that the routine publicity attending most Federal
procurement cannot be provided, and the language of the DPA, which
says that the limitations imposed must be followed "within the
bounds of security," has provided the necessary latitude for our
procurement officers to adapt their procedures to meet the needs of
security.
One additional factor should be cited. Competition has not
infrequently brought real savings. Care must be taken to ensure
that we do not take on long-term, hidden systems maintenance costs
when we accept a "bargain" proposal, but as we have grown more
sophisticated in our use of this procurement tool, we have been
able to avoid most such pitfalls. For a combination of security
and system stability reasons we have insisted on limiting the
number of vendors with whom we deal, and OL/Procurement has
supported us in this regard.
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B. Turning to word processing, it is possible to see how the
requirement to follow GSA regulations can become burdensome when
those regulations are out of step with the technological facts of
life. In the ADPE world generally, our commitment to follow the
FPMR's does not inhibit us technologically. The regulations push
us constantly toward competition and require careful documentation
when security or technical reasons call for sole source
procurement, but the GSA review does not speak to the ways in which
we use ADP. As noted above, the Brooks Act prohibits such
involvement. In the area of word processing, however, the pattern
was set when WPE was considered exclusively as a records management
phenomenon. To quote the recent NAPA report on GSA: "Within ADTS
[the Automated Data and Telecommunication Service of GSA], the
management of ADP and telecommunictions have been carried out as
separate functions. Little considerat'jon has been given to the
emerging technological merger of these two fields. Moreover,
responsibility for the management of word processing equipment and
technologies is not housed in ADTS, but rather in NARS. Thus, at a
time when the technologies underlying the ADP, telecommunciations
and office and records management are becoming virtually
indistinguishable parts of common information system technology,
management responsibilities are fragmented among a variety of
relatively independent elements within GSA, resulting in
unnecessary duplications, inefficiencies, and lack of a coordinated
approach."
C. The NARS approach to WPE is illustrated dramatically in
the January 1979 GSA Bulletin FPMR B-86 on "Use of word processing
equipment," which used a cost comparison of WPE with electric
typewriters as a basis for imposing cost-effectiveness determinants
for the justification of acquisitions of WPE. No reference is made
to the increasing concern for the effective capture of keystrokes
as an essential first step in the automation of office functions.
In the February 1980 Bulletin (FPMR A-75) which enunciated the
reclassification of WPE as ADPE, GSA saw fit to require that the
determination of need for WPE was to be governed by the rules set
forth in the Archives and Records subchapter of the FPMR's. Those
rules speak of ensuring "that an objective need for increased
efficiency and effectiveness has been established and that all
reasonable alternatives...have been considered," among those
alternatives being typing training, work simplification and
increased use of dictation equipment (FPMR 101-11.9).
D. GSA Bulletin FPMR A-75 announced the formation of a GSA
task force to review "necessary FPMR revisions regarding the
application of WPE to office automation consistent with management
and acquisition provisions for ADPE...as an information technology
resource." The target date for issuance was 31 December 1980, but
we have not seen any results.
E. The approach taken by the vendors of WPE has, until
recently, encouraged narrow views of the significance of this
technology. Emphasis has been on the secretary's efficient
manipulation of textual material; systems integration has only
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recently become a significant part of the sales pitches as new
networking capabilities have come into vogue.
F. In CIA the link between word processing and ADP is close
and growing closer. One of the most popular forms of word
processing has been and continues to be the SCRIPT facility under
our interactive VM system. We have built text processing
capabilities into our new standard terminal and plan a software
package for the terminal to provide basic word processing
capability. As newer generation VDU word processors have come into
use we have collaborated with NFAC to create effective links
between their interim standard (NBI) word processor installations
and ODP's computers, and thence to OL's Electronic Text Editing and
Compositing System (ETECS).
G. In 1979 we undertook to transfer responsibilities for WPE
from OIS to ODP, coincidentally matching GSA's redefinition of WPE
at about the same time. No additional resources were made
available when the transfer took place, and the Agency demand for
word processing equipment has expanded to the point where 4 ODP
man-years are required to effectively manage this program.
(Previously, one-half man-year was committed by OIS.) Another
significant factor is the time committed by the organizations
requesting these devices. The primary reason for this manpower
commitment rests in satisfying the GSA regulations already
mentioned, which demand documentation of the cost effectiveness and
requirements for each word processing device installed. GSA's
intent with these regulations was to slow down the government's
resource commitment to WP devices. In the Agency's case, this view
is short sighted because it views WPE only in the typing function
and not in its potential to increase overall organizational
productivity through efficient transfer of information. As noted
earlier, the whole concept of office automation stresses the early
capture of keystrokes in electronic form. Should the GSA
documentation requirements be lifted from the Agency, the ODP
resources now committed to this activity could be redirected to
other more meaningful areas related to office automation. For
example, investigations could begin in ways to link word -
processing, electronic mail, and Agency registry system.
H. The Paperwork Reduction Act requires each agency to
designate a senior official to oversee its major information
systems and ensure their effective coordination. (As noted, CIA's
ADPE was excluded from the Act, but OGC is currently reviewing the
other provisions to determine how they affect CIA.) With
establishment of the position of Information Systems Architect, CIA
has already begun to address the coordination problem which was one
of the Act's targets. The development of SAFE, while not the only
sign by any means; is perhaps the most dramatic piece of evidence
that CIA has attempted to do one of the things the Act calls for,
that is, promote the use of ADP to improve effectiveness in the use
of data. Now that we have in place an official whose task it is to
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ensure information systems compatibility, we would seem to be in an
excellent position to urge GSA to take the redefinitiop of WPE the
final logical step, to let it be treated as an integral part of
larger ADP-based information systems.
I. The Federal Procurement Regulations (FPR's) provide for
what are termed "deviations," which may be authorized by the GSA
Administrator or his designee. Requests must be in writing and
must describe the nature of the deviation and the reasons for it.
A. The procurement of ADPE, excluding WPE, is effectively,
efficiently and securely carried out in CIA under the terms of the
GSA's delegation of procurement authority. The restrictions under
which we operate are those laid down in principle by Congress, and
although not without burden, keep our procurement program in line
with prevailing convictions about what is "right" for the country's
economy.
B. The management of word processing equipment is inap-
propriately divorced from the rest of ADPE by GSA and the FPMR's,
thus inhibiting efforts to move systematically in the direction of
greater automation in our information handling systems.
C. CIA has the structure, the expertise and the organiza-
tional discipline to develop effective office automation programs.
D. General relief from the limitations on procurement of WPE
(FPMR 101-11.9) for those agencies with effective controls over the
growth of ADP systems would release resources for development of
forward-looking information management systems. If general relief
is not feasible at this time, a specific waiver for CIA would
permit us to get on with the task.
A. That the DDA call the problem of word processing
management as described above to the attention of the newly-
appointed Administrator of GSA;
B. That the Administrator be urged to reposition WPE manage-
ment under FPMR 101-35; and,
C. That the Administrator specifically grant CIA authority to
treat WPE as falling exclusively within the existing delegation of
procurement authority to this Agency for ADP and without reference
to FPMR 101-11.9.
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