Challenges to Utilizing Open Government


Implementation Challenges

There are both internal and external challenges to successfully implementing open government within the Department. The following diagram illustrates HUD's main areas of focus in regards to the challenges it faces:

HUD's Internal and External Challenges

Collaboration with External Partners
Due to the crosscutting nature of many of HUD's open government activities, its relationships with its external partners are of vital importance. From other Federal Agencies to community-based non-profits, HUD will utilize a framework that is mindful of each group's own priorities and goals.

The ultimate goal of this incentive structure is the long-term institutionalization of the external partnerships that facilitate open government. HUD understands that its partners are a diverse group of individuals and organizations, and that it will need to have a flexible and adaptive framework for engaging them on a sustainable basis.

Collection of Necessary Data
HUD realizes that there are datasets vital to the success of its new initiatives that are either available internally within the Department or in the possession of its partner organizations. HUD will work continuously in order to standardize its own internal data collection methods, and to create flexible, adaptive, and sustainable mechanisms for sharing vital data with other Agencies and organizations.

Empowering and Providing Support to its Employees
HUD is dedicated to institutionalizing the cultural changes necessary for the successful implementation of this Open Government Plan. A significant challenge to this goal is empowering managers at all levels to absorb and utilize open government concepts in their daily and strategic business activities. Their subordinates must be able to, for example, identify archaic or inefficient policies, and then be encouraged to elevate them to the relevant stakeholders within the Department.

Indentifying Long-Term Funding Streams
HUD understands that the key to the long-term success of open government is the identification of sustainable long-term funding streams. The Department will work diligently with both its internal stakeholders and its external partners to formulate a clear understanding on the budget expenditures that are necessary to fund open government activities.

Policy Management

HUD's implementation of open government will require policy changes in areas ranging from the use of social media to data quality and security. Due to the rapid evolution of technology, HUD will establish a continuous review process in order to keep its policies and available tools up to date. The following lists HUD's main areas of focus in regards to policy management:

Open government must include people with disabilities. Federal law requires that programs and resources provide comparable access and equivalent communications to people with disabilities, including alternative methods and formats, unless it would be an undue burden on the agency.

To acquire services in support of this initiative, HUD must follow policies identified in the Federal Acquisition Regulation (FAR).

Web pages or any other open government related activities or processes must not publicly release sensitive information. Due to the nature of open government, it will be impossible to vet all data as not containing any sensitive information, especially when information from multiple agencies is combined. As is the case with, HUD will retain the right to redact any previously published data or processes if such a situation occurs. In such cases, HUD will convene a privacy working group to investigate how the compromise happened, and in the case of inter-Agency compromises, establish necessary partnerships with other Agencies to convene a ‘lessons learned summit.'

Data Quality
Due to HUD's reliance on data for many of its missions, HUD has an extensive data quality policy. In order to release data in a timely manner, HUD will investigate the necessary governance and policy changes that must be made in order to ensure the public has the most accurate and up-to-date information. Data standards will still comply with all Federal laws and regulations as consistent with the Data Quality Act.

Employee Behavior/Ethics
Due to the direct contact that many HUD employees have with the public, standards and guidelines must be set in regard to the professional behavior that they must maintain, including in on-line venues.

Enterprise Architecture
Enterprise architecture will play a key role in developing the necessary plans to align open government efforts with modernization roadmaps and setting realistic timelines to implementation.

Open government solutions, especially technology-based ones, will place an increased load on HUD's Information Technology (IT) infrastructure. HUD's OCIO will investigate necessary policy changes and IT infrastructure investments to ensure the Department will have the necessary resources to launch new open government solutions.

Information Collection
HUD currently has an extensive information collection operation and mandate due to its interaction with many groups outside of the Federal government. The Department will closely monitor the Office of Management and Budget's (OMB) efforts to modify the Paperwork Reduction Act exemption process to align with 21st century delivery mediums. It will also investigate its own avenues to obtain necessary PRA exemptions in order to reduce time to implementation for open government solutions.

Intellectual Property
Due to the two-way feedback mechanism of open government, intellectual property issues may become a significant impediment to HUD's open government solutions. It will work closely with its Office of General Counsel in order to establish relevant policies that anticipate the kinds of issues that may arise from the novel ways in which it will receive information, suggestions, and ideas from the public. Additionally, HUD will identify best practices from across the Federal government in this realm and seek to establish and participate in inter-Agency working groups to develop unified policies across cross-functional domains to reduce systemic risk in intellectual property issues across the Federal government.

Open Formats
HUD will utilize open formats that are platform independent, machine readable, and made available to the public without restrictions that would impede the re-use of that information. All data will have relevant metadata that is standardized across the Department, and proper context and use instructions will be given to HUD's data consumers and customers in order to provide guidelines on what are the proper and improper ways to utilize each dataset.

HUD realizes that a potentially significant impediment to the collection and use of information or data received through open government is the public's worry that privacy information may somehow be collected. HUD currently has clear policies for collecting and managing personally identifiable information (PII), and what solicitation mediums or activities allow this collection. These policies will be modified as necessary to fit with HUD's open government needs.

HUD will modify and update its existing policies to enable open government initiatives to incentivize the public and other stakeholders via monetary and non-monetary prizes and competitions. These will be vital to increasing the public's participation in HUD's open government activities. Non-monetary prizes may include meetings with senior leaders to present novel ideas or other such opportunities for recognizing those with the best feedback and ideas.

HUD will continue to ensure its IT security policy is compliant with the Federal Information Security Management Act (FISMA) and National Institute of Standards and Technology (NIST) standards. As previously stated under ‘Privacy' above, a situation may arise where a HUD dataset merged with another Agency's dataset could reveal privacy or security issues. HUD will deal with any such issues on a case-by-case basis, and set policy for any recurring scenarios that may arise from such analysis.

Terms of Service/Terms of Use
Terms of Service (TOS) and Terms of Use (TOU) establish the agreement between the provider and the Government for use of, for example, social media tools such as Facebook. Many provider TOS agreements are not acceptable for Government use unless modified. Even when common terms have been negotiated, legal and CIO review must be obtained prior to use to ensure HUD policies and guidelines are not nullified or superseded by the TOS or TOU.

Any information posted on the Web must align with HUD's web policy, and all data presented will be Section 508 compliant. This may include the use of captions in videos for the hearing impaired, or any number of solutions to address accessibility issues on the Internet.

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