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    Federal Agency: "Library of Congress"

    3 publications with a total of 30 open recommendations
    Director: Daniel Bertoni
    Phone: (202) 512-7215

    4 open recommendations
    Recommendation: To ensure that it provides all eligible populations access to its services and that its eligibility requirements are consistent with currently accepted practices, the Library of Congress should re-examine and potentially revise its requirement that medical doctors must certify eligibility for the NLS program for those with a reading disability caused by organic dysfunction.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress indicated that the National Library Service for the Blind and Physically Handicapped (NLS) has contracted for a study of how eligibility based on reading disability should be certified. This study will look at medical advances in the diagnosis of reading disabilities, the NLS authorizing statute, and the potential impact of a regulatory change on the program. The expected completion date is December 2017. To close this recommendation, the Library of Congress must demonstrate that this study has been completed and that NLS has determined whether a change in its requirements is warranted.
    Recommendation: To ensure funds are directed to the most cost-effective outreach efforts, NLS should evaluate the effectiveness of its outreach efforts, including the extent to which different outreach efforts have resulted in new users.

    Agency: Library of Congress: National Library Service for the Blind and Physically Handicapped
    Status: Open

    Comments: The Library of Congress indicated that the National Library Service for the Blind and Physically Handicapped (NLS) has begun revising the program application form so that it captures information on how applicants were referred to the program. NLS expects to have all libraries nationwide using this revised application by sometime in 2018. In addition, the Library of Congress indicated that NLS has contracted for a multi-year, multi-media advertising campaign. This effort will assess the effectiveness of different approaches by connecting direct responses to ads with verified program enrollment. The campaign is expected to be fully underway by January 2018. To close this recommendation, the Library of Congress will need to demonstrate that NLS has fully implemented one or more of its planned new approaches for evaluating outreach.
    Recommendation: To help it determine the most cost-effective approach for its next audio player, NLS should comprehensively assess the alternatives of designing its own specialized audio player versus providing commercially available players to its users.

    Agency: Library of Congress: National Library Service for the Blind and Physically Handicapped
    Status: Open

    Comments: The Library of Congress indicated that the National Library Service for the Blind and Physically Handicapped (NLS) has contracted for a study of the different commercially available audio players for their usability, life-cycle costs, maintenance needs, and durability. The study is expected to be completed by December 2017, and will guide NLS in its decision about how to develop its next generation of audio players. To close this recommendation as implemented, the Library of Congress will have to demonstrate that this study has been conducted and that NLS has considered its findings in making a decision about its next generation audio player.
    Recommendation: To help it determine whether to supplement its collection of human-narrated audio materials with text-to-speech materials, NLS should thoroughly assess the text-to-speech option versus continuing to provide only human-narrated materials.

    Agency: Library of Congress: National Library Service for the Blind and Physically Handicapped
    Status: Open

    Comments: The Library of Congress indicated that the National Library Service for the Blind and Physically Handicapped (NLS) has developed a library of 100 text-to-speech (synthetic speech) talking books. In September 2017, NLS will begin a 3-month pilot in which a group of NLS users try out these talking books and provide input to NLS. Also, NLS will require that its next generation of audio players have the capacity to play synthetic speech talking books, and the study it has contracted of commercially available players will consider this requirement among other factors. To close this recommendation as implemented, NLS needs to demonstrate that it has completed its text-to-speech pilot and has decided on an approach going forward with regards to expanding this program.
    Director: Joel Willemssen
    Phone: (202) 512-6253

    2 open recommendations
    Recommendation: To help ensure that the Copyright Office makes improvements to its current IT environment, the Librarian of Congress should direct the Register of Copyrights to, for current and proposed initiatives to improve the IT environment at the Copyright Office, develop plans including investment proposals that identify the business problem, a proposed solution, the expected benefits, how the solution aligns with the Library's strategic plan, an initial 3-year cost estimate, and expected funding sources, and bring those to the Library's IT Steering Committee for review, as required by Library policy.

    Agency: Library of Congress
    Status: Open

    Comments: In commenting on our draft report, the Copyright Office neither agreed nor disagreed with our recommendation. Subsequently, the Copyright Office has begun to take steps to address this recommendation. For example, in November 2015 Copyright submitted to the Library's IT Steering Committee plans for three new fiscal year 2017 IT initiatives aimed at improving current systems, such as technical upgrades to the electronic (eCO) registration system. For each initiative, the office developed plans that identified the business problems, proposed solutions, expected benefits, alignment with the Library's strategic plan, initial 3-year cost estimates, and expected funding sources. In November 2016, the Librarian of Congress directed all top-level IT staff in the Library's various service units, including the Copyright CIO, to be detailed to the Library's OCIO. Subsequently, in April 2017 Library and Copyright Office officials stated that the Copyright Office, in coordination with the Library OCIO, will develop IT investment proposals for fiscal year 2018, including proposals for modernizing the Copyright Office's IT systems. We will continue to evaluate the Copyright Office's efforts to address our recommendation.
    Recommendation: To help ensure that the Copyright Office makes improvements to its current IT environment, the Librarian of Congress should direct the Register of Copyrights to develop an IT strategic plan that includes the office's prioritized IT goals, measures, and timelines, and is aligned with the Library's ongoing strategic planning efforts.

    Agency: Library of Congress
    Status: Open

    Comments: In commenting on our draft report, the Copyright Office neither agreed nor disagreed with our recommendation. In November 2016, the Librarian of Congress directed all top-level IT staff in the Library's various service units, including the Copyright Chief Information Officer (CIO), to be detailed to the Library's Office of the CIO. In light of this organizational realignment, in May 2017 the Library's Office of the CIO and the Copyright Office stated that they will be working in coordination to address our recommendation. We will continue to evaluate the Library and Copyright's efforts to address our recommendation.
    Director: Joel C. Willemssen
    Phone: (202) 512-6253

    24 open recommendations
    Recommendation: To provide strategic direction for the Library's use of its IT resources, the Librarian of Congress should establish a time frame for developing a complete and reliable enterprise architecture that accurately captures the Library's current IT environment, describes its target environment, and outlines a strategy for transitioning from one to the other, and develop the architecture within the established time frame.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to address, this recommendation. For example, according to Library officials, they have developed a schedule and processes for creating an architecture that describes the current and target environments. The Library plans to complete the steps necessary to implement this recommendation by September 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide strategic direction for the Library's use of its IT resources, the Librarian of Congress should establish a time frame for implementing a Library-wide assessment of IT human capital needs and complete the assessment within the established time frame. This assessment should, at a minimum, analyze any gaps between current skills and future needs, and include a strategy for closing any identified gaps.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in July 2016 the Library engaged the Office of Personnel Management (OPM) to develop and conduct a skills assessment of the Library's IT workforce. According to Library officials, OPM led a focus group with IT specialists to review and revise competency and skill lists for IT positions. Those officials also stated that OPM plans to administer a gap analysis survey by June 2017. Upon completion of OPM's assessment, the Library plans to develop a strategy for closing any identified gaps. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should establish and implement a process for linking IT strategic planning, enterprise architecture, and IT investment management.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, the Library developed a template for IT investment proposals that calls for investment managers to provide information on how the investments align with the Library's IT strategic plan and enterprise architecture. Additionally, in February 2017, the Library provided us with IT investment proposals for 19 fiscal year 2017 investments. To the Library's credit, the proposals describe how many of the investments align with the IT strategic plan and enterprise architecture. However, we also identified instances where the alignment with the IT strategic plan and enterprise architecture was not included in the proposals or was not clearly defined. In a written response, the Library stated that the inconsistencies were attributable to manual processes for collecting the information and that it is working to make improvements to these processes for the fiscal year 2018 investments. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should establish and implement policies and procedures for reselecting investments that are already operational.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives relating to IT investment management, to include reselecting investments that are already operational. Additionally, in October 2016 the Librarian approved the Library's fiscal year 2017 IT investment plan, which describes $145 million in planned IT spending on systems across the Library that are both operational and in development. The Library plans to complete the steps necessary to implement this recommendation by September 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should establish and implement policies and procedures for ensuring that investment selection decisions have an impact on decisions to fund investments.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives relating to IT investment management, to include ensuring that investment selection decisions have an impact on decisions to fund investments. The Library plans to complete the steps necessary to implement this recommendation by September 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should ensure that appropriate governance bodies review all investments that meet defined criteria.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives relating to IT investment management, to include ensuring that appropriate governance bodies review all investments that meet defined criteria. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should require investments in development to submit complete investment data (i.e., cost and schedule variances and risk management data) in quarterly reports submitted to the ITSC.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives relating to IT investment management, to include requiring investments in development to submit complete investment data in quarterly reports submitted to the Information Technology Steering Committee. Additionally, officials stated that the Library has begun to require IT investments to submit quarterly reports with complete investment data, including cost and schedule variances and risk management data. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should fully establish and implement policies for developing a comprehensive inventory of IT assets.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. The Library is revising its asset management policy to improve its process for developing and maintaining its inventory of IT assets. Additionally, the Library's Office of the CIO has engaged a contractor to perform a full inventory of IT assets by September 2017. The Library plans to complete the steps necessary to implement this recommendation by September 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To provide a framework for effective IT investment management and ensure that the Library has accurate information to support its decisions, the Librarian should fully establish and implement policies and procedures consistent with the key practices on portfolio management, including (1) defining the portfolio criteria, (2) creating the portfolio, and (3) evaluating the portfolio.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives relating to IT investment management, to include key practices on portfolio management. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To effectively plan and manage its acquisitions of IT systems and increase the likelihood of delivering promised system capabilities on time and within budget, the Librarian should complete and implement an organization-wide policy for risk management that includes key practices as discussed in this report, and within the time frame the Library established for doing so.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, it is drafting several policies and directives to relating to IT investment management, to include requiring investments to identify and review risks. Additionally, in February 2017, the Library provided us with risk management information for 19 fiscal year 2017 investments. To its credit, the Library generally identified, documented, evaluated, and categorized risks for each of the 19 investments. However, the Library did not always document the context and consequences of occurrence for all risks and did not describe mitigation plans for all risks. In a written response, the Library noted that it will improve the guidance for risk management, providing examples that should ultimately elicit more useful information for the IT Steering Committee to make decisions or take action when necessary. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To effectively plan and manage its acquisitions of IT systems and increase the likelihood of delivering promised system capabilities on time and within budget, the Librarian should establish and implement an organization-wide policy for requirements development that includes key practices as discussed in this report.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in January 2017 the Library established a Project Management Office within the Office of the Chief Information Officer and tasked the office with communicating and enforcing Library requirements for project management and systems development. Additionally, according to the Library, it is working to give the Project Management Office the authority to establish organization-wide policy for requirements development. Further, the Project Management Office is drafting detailed guidance for the Library on requirements development. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To effectively plan and manage its acquisitions of IT systems and increase the likelihood of delivering promised system capabilities on time and within budget, the Librarian should establish and implement an organization-wide policy for developing cost estimates that includes key practices as discussed in this report.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in January 2017 the Library established a Project Management Office within the Office of the Chief Information Officer and tasked the office with communicating and enforcing Library requirements for project management and systems development. Additionally, according to the Library, it is working to give the OCIO's Project Management Office the authority to establish organization-wide policy for cost estimating. Further, the Project Management Office is drafting detailed guidance for the Library on cost estimating. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To effectively plan and manage its acquisitions of IT systems and increase the likelihood of delivering promised system capabilities on time and within budget, the Librarian should establish a time frame for finalizing and implementing an organization-wide policy for developing and maintaining project schedules that includes key practices as discussed in this report, and finalize and implement the policy within the established time frame.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in January 2017 the Library established a Project Management Office within the Office of the Chief Information Officer (OCIO) and tasked the office with communicating and enforcing Library requirements for project management and systems development. Additionally, according to the Library, it is working to give the OCIO's Project Management Office the authority to establish organization-wide policy for developing and maintaining project schedules. Further, the Project Management Office is drafting detailed guidance for the Library on developing and maintaining project schedules. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should revise information security policy to require system security plans to describe common controls, and implement the policy.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, the Information Technology Security Group reviewed all system security plans to ensure that they are complete. After the completion of this review, in December 2016 the Library provided us with system security plans for nine key systems. To its credit, the plans describe many of the common controls (i.e., where a system relies on controls established for another system) on which the systems relied. However, we also identified instances where the plans included conflicting information about whether certain controls are being implemented by the system, are inherited from another system, or are not being implemented. In a written response, the Library noted that it has requested additional funding to hire information system security officers in order to improve the Library's management of information security, including information security planning. The Library plans to complete the steps necessary to implement this recommendation by September 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should ensure that all system security plans are complete, including descriptions of how security controls are implemented and justifications for why controls are not applied.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, the Library's Information Technology Security Group reviewed all system security plans to ensure that they are complete. After completing this review, in December 2016 the Library provided us with system security plans for nine key systems. Each of the plans generally includes descriptions of how security controls are implemented and justifications for why controls are not applied. However, we also identified instances where the plans included conflicting information about whether certain controls are being implemented. In a written response, the Library noted that it has requested additional funding to hire information system security officers in order to improve the Library's management of information security, including information security planning. The Library plans to complete the steps necessary to implement this recommendation by September 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should conduct comprehensive and effective security testing for all systems within the time frames called for by Library policy, to include assessing security controls that are inherited from the Library's information security program.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, according to the Library, in August 2015 the Library began monthly security testing and vulnerability scans for servers, networks, and workstations. Additionally, in November 2015 the Library finalized guidance for its continuous monitoring program, which includes the establishment of ongoing security controls assessments for each system. The Library began to implement this guidance in fiscal year 2016 and plans to complete the steps necessary to implement this recommendation by June 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should ensure that remedial action plans for identified security weaknesses are consistently documented, tracked, and completed in a timely manner.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in March 2017, the Library provided us with remedial action plans for key Library systems. The Library has generally documented and tracked remedial action plans for these key systems and has completed many. However, we also identified instances of remedial actions that, as of April 2017, had yet to be completed and were past their expected completion date. In a written response, the Library explained that it followed the Library's process for managing these actions and extended the time frames for all but three remedial actions. Further, in May 2017 the Library provided additional information regarding its process for extending timeframes for remedial actions. We are reviewing this information to determine the extent to which the Library followed its process.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should finalize and implement guidance on continuous monitoring to ensure that officials are informed when making authorization decisions about the risks associated with the operations of the Library's systems.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in October 2015 the Library finalized its guidance on security assessment and authorization, which requires authorizing officials to review the security status of information systems on an ongoing basis to determine whether the risk of operating the system remains acceptable. The Library began to implement this guidance in fiscal year 2016 and plans to complete the steps necessary to implement this recommendation by June 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should develop contingency plans for all systems that address key elements.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in December 2016 the Library finalized an IT system contingency planning template that generally addresses key elements of National Institute of Standards and Technology guidance. Additionally, in April 2017 the Library required that contingency plans be established for all systems by September 2017. The Library plans to complete the steps necessary to implement this recommendation by December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should establish and implement a process for comprehensively identifying and tracking whether all personnel with access to Library systems have taken required security and privacy training.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. According to Library officials, the Office of the Chief Information Officer is developing a process to track user accounts, including contractors and volunteers, on Library systems to ensure completion of required annual IT Security Training. The Library plans to complete the steps necessary to implement this recommendation in December 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To better protect IT systems and reduce the risk that the information they contain will be compromised, the Librarian should establish a time frame for finalizing and implementing the Library's standard contract sections for information security and privacy requirements, and finalize and implement the requirements within that time frame.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. In April and September 2016 the Library provided us with IT contracts that included some, but not all, of the standard contract sections required by Library policy. In February 2017, the Library provided us with newly awarded IT contracts, each of which included the required information security and privacy sections. Further, according to the Library, it plans to incorporate its required information security and privacy provisions into its existing contracts for IT services as the Library exercises options for these contracts. The Library plans to complete the steps necessary to implement this recommendation in June 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To help ensure that services provided by ITS meet the needs of the Library's service units, the Librarian should finalize and implement a Library-wide policy for developing service-level agreements that (1) includes service-level targets for agreements with individual service units and (2) covers services in a way that best meets the need of both ITS and its customers, including individual service units.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, in September 2016 the Library's Office of the Chief Information Officer (OCIO) finalized a new service catalog that captures its IT services. The catalog identifies 21 categories of IT services that are available to Office of the CIO customers (e.g., data network management, IT service desk, and website support) and describes applicable service-level targets relating to availability, fulfillment, and response. Additionally, between May 2016 and May 2017, the Office of the CIO executed memorandums of understanding with the six main Library units. Each memorandum establishes roles and responsibilities for specialized applications and services that the Office of the CIO provides to those units. Further, according to Library officials, the Library intends to write and promulgate a regulation on IT service management. The Library plans to complete the steps necessary to implement this recommendation by September 2017. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: To help ensure that services provided by ITS meet the needs of the Library's service units, the Librarian should document and execute a plan for improving customer satisfaction with ITS services that includes prioritized improvement projects and associated resource requirements, schedules, and measurable goals and outcomes.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, the Office of the Chief Information Officer has begun drafting a customer satisfaction improvement plan. The Library expects this plan to be finalized by December 2017. The Library plans to complete the steps necessary to implement this recommendation by September 2018. We will continue to evaluate the Library's progress in implementing this recommendation.
    Recommendation: In addition, to help ensure an efficient and effective allocation of the agency's IT resources, the Librarian should conduct a review of the Library's IT portfolio to identify duplicative or overlapping activities and investments, including those identified in our report, and assess the costs and benefits of consolidating identified IT activities and investments.

    Agency: Library of Congress
    Status: Open

    Comments: The Library of Congress generally agreed with, and has begun to take steps to implement, this recommendation. Specifically, the Library is drafting several policies and directives relating to IT investment management, to include reviewing the Library's IT portfolio to identify duplicative or overlapping activities and investments. The Library plans to complete the steps necessary to implement this recommendation in June 2017. We will continue to evaluate the Library's progress in implementing this recommendation.