OMB issues draft electronic guidelines

The Office of Management and Budget set the stage for moving the federal government further into the Digital Age when it released this month proposed procedures for how agencies should interact with the public electronically.

OMB issued the guidelines March 5 to help agencies comply with the Government Paperwork Elimination Act (GPEA), saying the administration's ultimate goal is to make government services and documents more accessible.

GPEA requires agencies to have in place by October 2003 systems that provide the public with the option of submitting government forms electronically whenever possible as a substitute for paper.

OMB officials could not be reached for comment. But last month, at a seminar about GPEA, Peter Weiss, a senior policy analyst at OMB's Office of Information and Regulatory Affairs, said the guidelines are "what every federal manager needs to know to get started" deploying electronic commerce.

Signed by President Clinton in October, GPEA gives OMB and the Commerce Department's National Telecommunications and Information Administration 18 months to develop procedures that agencies should follow to deploy electronic technologies.

According to the law, electronic authentication methods, such as electronic signatures, should be used to verify the identity of the sender and to check whether the electronic content has been altered in any way. The law also requires systems that enable online submission of forms to guarantee privacy. The systems also must ensure that the form information cannot be changed without authorization and that the form is available when needed.

When crafting the bill, lawmakers also tried to head off court challenges by expressly saying that electronic records and the electronic signatures that validate them must be accepted as legal documents.

OMB's guidelines call on agencies to weigh the risks of various technologies and select the one most appropriate for the form or document being transmitted. The different security approaches that agencies can consider include personal identification numbers or passwords, and digitized signatures or biometrics, such as a fingerprint or retinal scan.

Lynne Boyd, senior vice president at JetForm Corp., an electronic forms company in Ottawa, said the guidelines give agencies a road map for complying with GPEA.

For example, the OMB guidelines clarify that the law applies not only to government forms that have more than 50,000 respondents. Initially, some people thought GPEA applied only to forms of that volume, Boyd said, but the law applies to all forms the public has to fill out and submit to the federal government. Forms that have more than 50,000 respondents must provide more than one kind of electronic signature technology, he said. The Small Business Administration, the Social Security Administration and the Education Department are agencies that have forms with that volume of respondents, Boyd said.

The guidelines also provide a pragmatic explanation of what agencies should consider as they look at the various technologies. "I would point to the definition of different kinds of signature technology and [the] checklist for risk assessment - when to use which kind of technology" - as being especially helpful, he said.

Agencies will have to consider the relationships between parties, such as frequent business partners or the public, when choosing technology and will need to consider if the document will be recalled if it is contested, Boyd said.

Ed Burke, managing partner in the government strategy division at Andersen Consulting, said that as agencies embark on electronic document and electronic signature implementations, they should look at their in-house transactions and the interactions they have with other agencies and constituents.

"They need to re-examine the processes and the way they deal with customers," Burke said. "If you are going to redesign forms for electronic media, it gives you an opportunity to rethink the exchange, rethink the whole interaction with your customers or constituents."

OMB also stresses that agencies should strive to make sure whatever technology they select is compatible with standards for electronic signatures already used outside government. They also should avoid favoring one technology over another and make sure the solution they select includes storage, according to the guidelines.

Several agencies are testing online submission of forms and documents.

OMB will accept comments on the guidelines through July 5 and expects various organizations that may have experience with e-commerce - including the American Bar Association, banks and Internet companies - to make suggestions. The final guidelines will be issued next year.