THE DEPUTY LIBRARIAN OF CONGRESS WASHINGTON, D.C. 20540 April 26, 1996 Dear Mr. Gadsby: The Library appreciates the opportunity to review and comment on the draft Management Review of the Library of Congress prepared for GAO by BoozáAllen & Hamilton Inc. In addition to the Library's comments herein, we have separately forwarded to the Assistant Comptroller General our comments on the Financial Statement Audit for the Library of Congress for Fiscal Year 1995. Overall the report's findings and conclusions mirror the assessment that led to the Library's 1996 Management Improvement Plan (MIP-96), developed prior to receiving BoozAllen's management review. The Library agrees with the report's recommendation that it must capitalize on its strengths -- chiefly its incomparable collections and unique workforce which acquires, catalogs, secures, preserves, provides research access and generates analysis for the Congress front those collections. The Library must, therefore, extend and improve the program planning and execution processes begun with its 1992 Strategic Plan. The Library recognizes that it has not developed fully integrated work processes and supporting systems and that its planning and delivery of support functions needs improvement. We are already tackling these issues and will utilize the report's data and findings to good effect. The update of the 1992-2000 Strategic Plan is an essential component of the Library's internal management improvement process. The Library began the management improvement process in 1995 and the Plan has since been formally adopted by the Library's Executive Committee. It is being revised to reflect many of the recommendations and findings included in the BoozáAllen report. The Library will now begin formulating the Library's 1997-2004 Strategic Plan. The key objectives of MIP-96 are the improvement of management/employee relations and management techniques; strengthened accountability throughout the Library; improved efficiency and responsiveness of support functions; and enhanced security for people, facilities, collections and data systems. The Library questions the methodology used in arriving at some of the report's findings. Throughout the report, data gathered from small focus groups are offered as "benchmarks" for study or emulation by the Library in critical areas. There is no indication that these benchmarks have been subjected to the same in-depth analysis as the Library's systems and processes to which they are compared. The BoozáAllen management review addressed the Library's mission as articulated in Dr. Billington's October 1995 Statement of Mission and Strategic Priorities. While it is clear that the review recognized the Library's unique stature and rich history, the report questions the Library's mission to serve the Congress and the American people with a sustained universal collection of knowledge and creativity. The Library disagrees with the BoozáAllen assessment of its mission in the strongest possible terms. We will comment in detail on the Library's mission to the Joint Committee on the Library on May 7, 1996. The remainder of the report addresses management processes, organizational structure infrastructure, and human resource management. The report consistently challenges the Library's functional structure and processes. We will be evaluating the broader application of process management as a key objective of MIP-96. A particular focus will be on improving customer satisfaction and improving key areas such as collections and facilities management. Although not noted in the report, the Library had successfully piloted a number of process management improvements prior to the BoozáAllen review. The Library's advances in whole book cataloging have met with praise throughout the library community and its efforts in Exchange and Gift have drastically reduced and refined the Library's incoming workload. These are, in fact, but two examples illustrative of our movement from functional to process management. With regard to the Library's organizational structure, the position of Deputy Librarian has already been announced as the Library's Chief Operating Officer and a search is underway. We will take the report's other organizational recommendations under advisement. We strongly agree with the report's conclusions that the Copyright Office and CRS should remain part of the Library. The report recommends that the Library strategically link its human, information, and facilities resources to fulfilling its mission objectives. We cannot agree more. Critical decisions lie ahead about the future of the Library's computer legacy systems, but the Library is no different from virtually any other major entity -- federal or private -- in needing to manage its transition from a main frame to a client server environment. We will need to refocus our technology infrastructure to accomplish this, a process which is underway. The report does not recognize strongly enough the Library's cutting edge efforts in harnessing technology to create the digital Library of the 21st century. The National Digital Library Program, THOMAS, and the Copyright Office Electronic Registration, Recordation and Deposit System (CORDS; for which we are partnered with the Defense Advanced Research Projects Agency) all demonstrate national leadership by the Library -- leadership not acknowledged in other parts of the report. The report recognizes the impact of the Cook class action suit on our human resources operations. The Court approved the Cook class action settlement on September 22, 1995. Final approval awaits a court decision regarding appeals from five individuals brought forward after the settlement was approved. The report notes the Library's compliance with the Cook settlement as it relates to the competitive selection process. We agree that the Library's lengthy competitive selection process hampers efficient and effective recruitment but affirm and underscore the report's finding that some needed changes are constrained by the Cook Settlement Agreement. Management will pursue the report's recommendation of a labor relations pilot. The establishment of an internal university, barely mentioned in the report, will significantly buttress the Library's training initiatives, but critical resources are needed to achieve the levels recommended by the report on a per employee basis. The report suggests that the Library has ignored the implications of its aging workforce and the prospect of an ever larger group of retiring experts. We have been well aware of and vocal about this problem before the Congress for some time but it is impossible to solve such a problem without resources for new hires. All areas of human resource management will be addressed as we continue MIP-96. With regard to collections security, we concur with the report's finding that the Library's security challenge is unique. The Library's collections acquire value only through their use. Dr. Billington took the single most effective step to secure the Library's collections when he closed the stacks in 1992. At that time, he also directed each area of the Library to assess and act on its particular collections security needs. The five-year effort that has followed addressed many aspects of securing the Library's collections in a comprehensive manner. As we indicated in November 1995 testimony, critical data from the Computer Science Corporation studies, due to be reported on June 7, 1996, will enable the Library to proceed with risk assessment and overall formulation of a complete policy. The Library will also be recruiting a Library Security Officer with appropriate credentials. Library officials regularly confer with major libraries and research institutions regarding collections security. The report confirms that the development of protective standards has not been a high priority for the library community. The Library has appropriate responsibility in place for its computer security and will codify its existing procedures for disaster recovery into a written plan. We appreciate all the work that has been done by BoozáAllen & Hamilton for GAO and we look forward to hearing your comments at the hearing on May 7th. Sincerely, Thomas P. Carney / / Acting Deputy Librarian Mr. J. William Gadsby Director, Government Business Operations Issues U. S. General Accounting Office Washington, DC 20548 cc:: Dr. James H. Billington