Copyright Office Needs To Develop Plans that Address Technical and Organizational Challenges
GAO-15-338: Published: Mar 31, 2015. Publicly Released: Mar 31, 2015.
What GAO Found
The Copyright Office has a legal mission supporting the creative industries that significantly contribute to the United States economy and relies heavily on information technology (IT) to carry out this mission. For example, by law, the office must be able to receive and examine copyright registration applications, collect and maintain deposited copies of copyrighted works, and maintain records of the transfer of copyright ownership. To meet these mission requirements, the office relies on several IT systems, as well as the infrastructure managed by the Library of Congress's central IT office. However, GAO and others have identified challenges with this environment. For example, comments solicited by the Copyright Office from external users have described limitations in the performance and usability of the office's electronic copyright registration system, and the Copyright Office has expressed concerns about the integrity of the files stored in the Library's servers. Organizationally, responsibility for managing the office's IT environment is shared between the Copyright Office's Office of the Chief Information Officer (CIO) and the Library's central IT office. The Library has serious weaknesses in its IT management, which have hindered the ability of the Library and the Copyright Office to meet mission requirements. For example, the Library has not had a permanent CIO in over 2 years.
The Copyright Office requested over $7 million in fiscal years 2015 and 2016 to address four key challenges: (1) reengineer recordation—one of the office's key business processes—to include developing an online filing capability; (2) develop a secure digital repository for its electronic materials (e.g., books and music); (3) develop a software application development environment; and (4) establish a data management team, to include developing data standards. The office has also published a report that summarizes stakeholder comments on the current IT environment and makes several recommendations to improve this environment.
However, the office has not adequately justified these proposed investments. Specifically, it has not identified the business needs they are intended to meet, expected costs, or how they align with the agency's strategic plan, as called for by Library IT investment management policy. The office also did not present the investments to the Library's IT investment review board, which was established to select investments for funding that meet defined criteria and ensure that such investments are not duplicative of existing investments or activities performed within the Library. Copyright officials stated that these initiatives were in early stages and the office was not yet in a position to develop this information. However, without identifying key costs and benefits of proposed initiatives and presenting this information to the Library-wide investment review board, decision makers at the Library and the Copyright Office do not have the assurance that the selected investments support the organization's goals and do not duplicate existing activities. In addition, the office does not have an IT strategic plan, and officials described difficulties in developing such a plan given that the Library has not yet developed one. As noted in a recent GAO review of the Library's IT management, the Library has recently committed to developing an updated IT strategic plan, and it will be important for the Copyright Office's own strategic planning to be aligned with this effort.
Why GAO Did This Study
The mission of the Copyright Office, a service unit within the Library of Congress, is to promote creativity by administering and sustaining a national copyright system. As part of this mission, the Copyright Office registers about 500,000 creative works a year for copyright and records documentation related to copyright transfer and sale. In recent years, the Register of Copyrights has discussed the need for a modernized Copyright Office, to include upgrades to the current IT environment.
The Senate Appropriations Committee report accompanying the 2015 legislative branch appropriations bill required GAO to review the Copyright Office's current IT environment and plans for the future. This report (1) describes the legal, technical, and organizational aspects of the Copyright Office's current IT environment, and (2) describes and evaluates the Copyright Office's plans for modernization. To carry out its work, GAO reviewed Library policies and related best practices, comments by stakeholders, IT funding requests, and other relevant documentation, and interviewed key Library and Copyright Office officials.
What GAO Recommends
GAO recommends that the Copyright Office (1) develop key information to support proposed initiatives for improving its IT environment and submit them to the Library's IT investment review board for review, and (2) develop an IT strategic plan that is aligned with the Library's strategic planning efforts. The office neither agreed nor disagreed. GAO continues to believe its recommendations are warranted.
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Recommendations for Executive Action
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 March 2018 the Copyright Office, in coordination with the Library OCIO, developed investment proposals for fiscal year 2018, to include proposals for modernizing the Copyright Office's IT systems. We are reviewing the investment documentation to ensure that the Copyright Office continues to submit its proposals for new initiatives consistent with the Library's investment review process.
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 Affected: Library of Congress
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. In September 2017, the Library's Office of the CIO and Copyright Office began developing a Copyright IT modernization program management plan. According to the Library, this plan will include prioritized IT goals, measures, and timelines which are aligned with the Library's ongoing strategic planning efforts. The Library plans to complete a first draft of the Copyright IT modernization program management plan in January 2018. We will continue to evaluate the Library and Copyright'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 Affected: Library of Congress