June 3, 2014
Open Government Plan
This document sets forth the Millennium Challenge Corporation’s (MCC) 2014 plan for promoting transparency, participation and collaboration in all aspects of its work to reduce poverty through economic growth. MCC’s Open Government Plan (OGP) has been developed in accordance with the Open Government Plan memorandum issued by the Executive Office of the President, Office of Science and Technology Policy, on February 24, 2014.
MCC has advanced its mission—to reduce poverty through investments promoting economic growth in developing countries with sound policy environments—by signing large-scale grant agreements, called Millennium Challenge compacts, with 25 countries totaling approximately $9.2 billion since its creation in 2004. MCC also has signed 24 threshold programs, which are smaller grants focused on policy reform with countries that do not yet qualify for compact funding. MCC-funded projects produce sustainable and quantifiable results that improve the lives of the poor in practical and meaningful ways.
Since its inception, MCC has been at the forefront of making foreign assistance transparent and open. MCC provides the public with data and insights on MCC’s decision-making, program management and policy assessments through posting criteria for country selection, economic analysis and project evaluation information on its public website; participation in the U.S. Government’s Foreign Assistance Dashboard; public events; press interactions; and participation in the global development initiatives of the Obama Administration and the global development community.
MCC’s 2014 OGP builds upon efforts, accomplishments and lessons learned from two prior plans. Significant progress has been made on all three of the flagship initiatives in MCC’s 2012 OGP:
- Leadership on reporting to the Foreign Assistance dashboard: MCC has led U.S. Government (USG) agencies in reporting to the dashboard, being among the first to submit regular quarterly reports. In recognition of MCC’s transparent reporting, the agency was ranked first out of 67 donors worldwide in the 2013 Aid Transparency Index.
- Release of survey datasets from independent evaluations: MCC is on target to meet its goal of releasing 10 to 20 survey data sets by the end of this fiscal year. We have put standard procedures in place to facilitate timely public release of data from all future evaluations. We have also institutionalized the process of reviewing survey data sets to ensure all legal and ethical standards are upheld as we make data freely available to the public. Released data can be viewed and downloaded at data.mcc.gov/evaluations/index.php/catalog
- Enhanced online presence: MCC has completed a strategic review of desired enhancements and has been working on development of a new website that continues MCC’s commitment to making our content and data easy to discover, understand and use. This work will continue, with enhanced capacity for participation and collaboration built into future efforts.
MCC’s 2014 OGP reflects input from MCC senior leadership, staff, interested stakeholders, and members of the public. Recognizing the importance of open government and the value that transparency, participation and collaboration bring to MCC’s work, the MCC staff working group that developed this plan hosted consultations and numerous conversations with external stakeholders, surveyed and hosted a focus group with MCC staff and presented stakeholder ideas to MCC senior staff for consideration and decision.
New and Expanded Initiatives
To comply with the May 9, 2013 Executive Order on Open Data, and the resulting Open Data Policy Memorandum (M-13-13), MCC continues to develop an “enterprise data inventory” of all data resources across the agency for release of data in open, machine-readable formats on the www.mcc.gov/data website. One way in which MCC is making public data assets available for download and use is through an application programming interface (API), encouraging public use of already released datasets in order to promote public knowledge and foster innovation.
To date, the MCC Departments of Policy and Evaluation (DPE) and Administration and Finance (A&F) have abided by a Memorandum of Understanding (MOU) for a data transfer and verification process that includes data quality assurance, notification of source system changes that affect the data, approval of data definitions, disclaimers and visualizations, form authorizations of data and values to be released, and automation of data transfer, generation and publication in support of MCC’s open data website. Data approved for release include indicator tracking tables, selection indicators, financial, and key performance indicators. The Disclosure Review Board, chaired by MCC’s vice president for the Department of Policy and Evaluation, clears the survey data associated with independent evaluations for public release.
Processes, to include one for identifying data assets not yet publicly available and establishing specific timelines for online publication in open formats, are under review and will continue to reflect changes as part of MCC’s robust implementation of the Executive Order on Open Data. Changes in business, data and technical contacts are communicated to authorizing parties.
MCC is publishing data and using information resources to increase agency accountability and responsiveness and improve public knowledge of MCC. To further the agency’s core mission, create economic opportunity and respond to feedback received through public consultation, MCC dialogues regularly with various stakeholders in many venues to develop strategies for effective international development, international aid transparency, evaluation, and private sector engagement and investment.
MCC shares a wealth of data and information to allow the public to understand not only how we invest taxpayer dollars, but also how we make decisions as an agency. On a quarterly basis—and in open, accessible and machine-readable formats—MCC posts complete financial and program performance information. MCC’s monitoring and evaluation data, independent evaluations, economic analysis and country selection information is available on our website. We also publish all procurement information to the public. As we review all the data and information produced at MCC, we continually identify new sources that could be made available to the public and add to the content available.
In 2014, MCC also developed a Policy on Access to Information and Materials that provides internal guidance to MCC staff on how to proactively disclose information.
Per OMB guidance and in accordance with the Federal Information Security Management Act (FISMA), MCC provides the Senior Agency Official for Privacy (SAOP) report to the Department of Homeland Security (DHS), Cyberscope. The URL of the webpage where the public can access this report is cyberscope.dhs.gov/ReporterHome.aspx. This list of all required privacy compliance reports is also submitted to firstname.lastname@example.org.
The following reports are not applicable to MCC and are not scheduled to be provided as part of MCC’s 2014 OGP:
- The Federal Agency Data Mining Report, described in 42 U.S. Code § 2000ee–3 - Federal agency data mining reporting, requires federal agencies to report on their data mining activities relating to criminal or terrorist activities. MCC does not data mine on these activities; and
- MCC does not have a system of records and does not have a system that would meet the criteria for the biennial computer matching activity report.
MCC will participate in the Office of Special Counsel’s (OSC) 2302(c) Certification Program to ensure MCC meets its statutory obligation to inform our workforce about the rights and remedies available to them under the Whistleblower Protection Enhancement Act of 2012 (WPEA) and related civil service laws. As of June 2014, MCC has completed four of the five requirements to achieve certification. Specifically,
- MCC has posted informational posters on “Prohibited Personnel Practices” (PPPs), “Whistleblowing,” Whistleblower Retaliation,” and “The Hatch Act and Federal Employees” in a common area on every floor of the agency offices in Washington, D.C. and on MCC’s internal website available to all U.S. and overseas-based employees;
- New employees will receive information about PPPs and the WPEA in their new employee orientation packets;
- All MCC employees received updated written materials via email in May 2014. This information is also available on MCC’s internal website; and
- Users can link from MCC’s No FEAR Act page to OSC’s website.
MCC currently offers Refresher Supervisory Skills Training twice a year; however, only managers who have not received training within three years are required to attend. MCC is considering other training options, such as inviting MCC’s WPEA Ombudsman or an OSC attorney to speak, in order to satisfy the final requirement of the 2302(c) Certification.
MCC is committed to the transparency promoted through government initiatives, like:
- Open Government, including this Open Government Plan, www.mcc.gov/open;
- Digital Strategy, www.mcc.gov/digitalstrategy; and
- Open Data, www.mcc.gov/data.
MCC continues its long-term flagship effort to make its content and data on the website easy to discover, understand and use. In doing so, MCC continuously assesses ways to improve the site’s usability through improvements to navigation and content organization.
Additionally, MCC’s myriad reports will be not only easier to find but also published as HTML to make for a better experience regardless of the type of device used. Those reports include:
- Copies of signed compacts;
- Quarterly status reports;
- Information on program-related procurement and investment opportunities;
- Informational publications such as annual reports; and
- Reports and notifications to Congress.
MCC also maintains a comprehensive approach to Information Resource Management (IRM) which comprises a knowledge management strategy and action plan. The FY 2014 Action Plan addresses a number of information technology requirements and behavioral changes to improve IRM. The IT Investment Review Board provides executive decision-making on and oversight of MCC IT investment planning and management.
Participation in Transparency Initiatives
In support of the Digital Accountability and Transparency Act (DATA ACT), Public Law 113-101, MCC participates in USAspending.gov. MCC reports in near-real time all of its contract data by transaction via the Federal Procurement Data System (FPDS). FPDS data feeds into and is reflected in USASpending.gov. MCC has an agency profile in SAM.gov, which is used in accordance with the FAR to do pre-award verification on all of our awardees except for credit-card purchases under $3,000.00. MCC also posts grant opportunities on Grants.gov.
MCC does not participate in Recovery.gov, which was targeted for agency reporting on stimulus money that MCC did not receive. MCC does not participate in the Catalog of Federal Domestic Assistance (CFDA.gov) as our programs are internationally focused rather than domestic assistance focused. The Government Accountability Office (GAO) has articulated to MCC a requirement to post compact spending in USASpending.gov, which requires a CFDA entry. However, CFDA applies to domestic assistance as opposed to foreign assistance, as MCC has pointed out to the General Services Administration (GSA) and the Office of Management and Budget (OMB). MCC does not participate in FSRS.gov, and MCC is not a rulemaking agency; however, we will explore using eRulemaking to the extent we publish in the Federal Register. MCC expects to increase participation in data.gov to include publication of additional data sets.
MCC has also been a leading agency in reporting to the Foreign Assistance Dashboard (www.foreignassistance.gov) and has recently become the first USG agency to submit data in extensible markup language (XML) format. MCC has developed a standard, sustainable business process for production of the data submitted to the dashboard that ensures continuous improvements to the quality, quantity and automation of data submitted each quarter.
MCC has a strong public engagement and information strategy which is carried out through monthly, quarterly and annual events with the general public and stakeholders. These events include digital strategies, such as social media chats and town halls. MCC’s Facebook page continues to grow, having attracted more than 6,900 “likes” through the third quarter of FY 2014. The agency’s Twitter account, @MCCtweets, has amassed well over 11,000 followers and has boosted the number of “re-tweets” with increased use of photos and videos, more than 60 since the second quarter of FY 2014. Having launched the first of its Twitter town hall meetings in 2011, MCC holds approximately four per year, with individual event participation that has reached well beyond 200 participants and attracted dozens of additional followers. These events also serve to build stronger relationships with external stakeholders through collaboration and shared values.
MCC also conducts email outreach campaigns with a compilation of MCC activities, announcements and significant actions. Public town hall meetings, which are carried out four times a year following each of MCC’s scheduled Board of Directors meetings, draw an average audience of more than 200 people. MCC participates about six times a year in public and industry-sponsored exhibits relevant to MCC’s mission to distribute informational material and enhance awareness of the agency.
MCC also uses traditional tools such as press releases to announce milestones, agency actions, significant personnel changes, and announcements surrounding the results of quarterly meetings of the agency’s Board of Directors. MCC identifies targeted media outlets for articles, interviews or op-eds, radio and TV appearances and podcasts. MCC’s story is also told through blogs, country dispatches and success stories, videos, photos and published booklets, reports and informational brochures, many of which are published in hard copies as well as published on the agency’s public website.
MCC continues to demonstrate compliance with Federal Records Management Statutes and Regulations. MCC has designated the vice president of the Department of Administration and Finance as the Record Management Senior Agency Official (SAO) tasked with overseeing MCC’s Records Information Management (RIM) program and electronic records requirements. To date, MCC has met all mandatory reporting requirements, including completing the National Archives and Records Administration (NARA) annual records management self-assessment (RMSA) and submitting the SAO’s annual report describing MCC’s plan to meet electronic records and cloud computing requirements. Because MCC was established 10 years ago in 2004, MCC did not have permanent records that had been in existence for more than 30 years to transfer and report to NARA by December 31, 2013. In 2011, NARA approved MCC’s comprehensive records retention and disposition schedule wherein MCC has identified permanent records to be transferred to NARA beginning in 2015. Finally, in MCC’s Fiscal Year 2014 strategic plan, the agency identified and trained records liaisons known as Division Records Managers (DRM) and added classroom RIM training for all new employees. MCC completed NARA’s 6-part federal records management certification process in 2006.
In order to better inform and communicate MCC’s RIM program and best practices, the MCC records program plans to provide RIM policies and procedures and goals and objectives on MCC’s public website by the end of the second quarter of FY 2015. To address more recent records management requirements, including the President’s November 28, 2011 Memorandum on Managing Government Records and the accompanying August 24, 2012 Managing Government Records Directive (M-12-18), MCC will also provide program records retention schedules and records management contact information in conjunction with NARA .
MCC is also improving guidance, including a document retention schedule, for the accountable entities that implement compact programs in countries selected for investment (Millennium Challenge Accounts or MCAs) for the retention of their own compact related records. MCC’s existing guidance will be updated by the end of FY 2014 to require that MCAs maintain, at a minimum, the standard retention schedule. This will assist MCAs with structuring their own records and information policies and improve accessibility to compact records, particularly after a compact program is completed.
Freedom of Information Act (FOIA) Requests
MCC prides itself on the transparency of its programs. Not only are all of our compacts and threshold programs listed on our public website, but we include the core program documentation and the results of those programs as they progress. MCC pursues a policy of proactive disclosure to ensure information is generally accessible to the public without the need to submit a Freedom of Information Act (FOIA) request.
MCC responds promptly to all FOIA requests and closed Fiscal Years 2011, 2012 and 2013 with no backlog of requests or administrative appeals.
Due to the small number of FOIA requests received by MCC (less than 30 requests per fiscal year), the agency has a small FOIA office in which each member has been trained on the President’s FOIA memorandum and the U.S. attorney general’s FOIA Guidelines in order to ensure a presumption of openness. MCC’s Office of General Counsel (OGC) manages the agency’s FOIA program. An OGC attorney acts as the chief FOIA officer and a second attorney serves as the FOIA appeal authority. An administrative staff member provides support.
FOIA requests can be sent to MCC’s chief FOIA officer at: Millennium Challenge Corporation, Attn: Chief FOIA Officer John Mantini, 875 Fifteenth Street, N.W., Washington, D.C. 20005, or electronically via email to email@example.com. Upon receipt and review of a FOIA request, staff in MCC’s Office of General Counsel prepares the agency response by gathering information and input from other MCC departments. MCC’s chief FOIA officer reviews and approves all responses prior to their release. MCC’s average number of days to process non-expedited requests is fewer than the 20 business day statutory response requirement.
MCC’s FOIA webpage www.mcc.gov/foia includes links for all FOIA reporting, including information on how to submit a FOIA request and electronic access to the Annual FOIA Report in HTML and XML, the Chief FOIA Officer Report, the Department of Justice’s FOIA Act Guide, and an “electronic reading room” where the public can access certain previously released documents. Because MCC is required by law to withhold the release of certain information related to government contracts, including bid and business proprietary information, some documents or parts of documents cannot be released to the public. MCC’s electronic reading room currently includes policies, procurement guideline documents and selection criteria and methodology reports.
Congressional requests for information, briefings or meetings are handled by MCC’s Department of Congressional and Public Affairs, which is MCC’s primary liaison with Congress. The five-member Congressional Affairs (CA) team is responsible for development of MCC’s congressional priorities and strategy, as well as keeping MCC senior staff and key internal and stakeholders informed of congressional developments. The CA team coordinates the dissemination of existing informational material or writes material in response to specific requests from lawmakers, their staff and committee staff; prepares required documentation of MCC activities such as congressional notifications; prepares testimony, congressional budget justifications and responses to questions for the record; prepares and handles correspondence to and from MCC’s chief executive officer; maintains relationships with members of Congress and staff and committee staff; schedules and attends congressional meetings along with appropriate MCC sector or regional staff; and ensures all required materials are posted to MCC.gov at www.mcc.gov/pages/about/reports#reports-cbj.
MCC approved a declassification program in 2011. The public can learn about MCC’s program and how to access declassified materials at, http://www.mcc.gov/pages/foia/declassification.
The public is given opportunities to participate by utilizing feedback forms available on MCC’s public website. For example, individuals may submit a Request for Correction if they believe that MCC has disseminated information that does not comply with the Office of Management and Budget Information Quality Guidelines and they are directly affected by this information. In addition, town hall meetings are open to the public; and MCC receives feedback through Twitter, Facebook, phone and email messages. Opportunities for public participation will be refreshed in the continuing redesign of MCC.gov with enhanced feedback tools throughout the website’s pages and platforms. MCC staff also regularly take part in public events at which they engage in discussions through question and answer periods.
MCC actively pursues collaboration with donors, academics, non-governmental organizations, philanthropies, and other institutions that share the agency’s values or have an interest in observing, analyzing and contributing to MCC’s activities. The agency has rich working relationships with its partner countries and encourages full collaboration with civil society, political, business, and other stakeholders in the implementation of MCC compacts and threshold programs.
It is standard practice at MCC to consult with internal and external stakeholders on changes to policies and procedures that would constitute a significant change in the way the agency makes decisions and pursues its mission. MCC also works with country partners to ensure broad consultation and input to the analysis of constraints to economic growth that is carried out in each country to select investments that promise the greatest impact.
In addition to collaboration with outside entities, MCC is focused on enhancing collaboration between the MCAs, MCC’s partner accountable entities in compact countries. MCC is building an online platform to allow MCAs to conduct discussions and share knowledge in core MCC process and business areas. Different subject areas are being introduced to MCAs on a rolling basis beginning in the summer of 2014 and continuing throughout FY 2015.
MCC has identified two Flagship Initiatives for the 2014 OGP:
1. MCC’s commitment to building an enhanced public website will continue to be a flagship initiative as part of the agency’s 2014 OGP, building on a new architectural framework and a new approach to visualizing data. Steady progress has been made in understanding how to best present MCC’s data and pair that with the best user experience possible. The new website design will allow the agency to maximize opportunities for public participation and collaboration through improved web feedback features, and offer multiple points of entry that will make the agency’s data more clear and accessible. The enhanced design will be coupled with a new web governance plan that allows the editorial process to include direct participation by more stakeholders from across the agency. Traffic to the new MCC website will be more vigorously measured with a plan to regularly assess metrics on the variety of data and other written products. The plan calls for measuring not only the number of visits to the site, but also the time spent on each page or product. Over a period of time, this will allow MCC to adjust its outreach in other areas such as Twitter, e-newsletters and email campaigns, in order to drive more traffic to the website and increase first-time and repeat visitors.
2. MCC recognizes that the nature of our work with partner countries offers unique opportunities to support governments and citizens in those countries in their own Open Government Partnership (OGP) commitments, as well as in adopting best practices in transparency, traceability and open data. Prior to the implementation of an MCC compact program, the host government designates an accountable entity (called an MCA) that is responsible for implementing the compact projects. MCC has been piloting a management information system for the MCAs to provide a more efficient tool to manage their core data and business processes. While MCC has always set high standards for transparency in our partnerships with MCAs, over the course of the next two years MCC aims to more systematically analyze the results of these efforts and to identify opportunities, leveraging the systems and applications being introduced to MCAs, to further facilitate MCA efforts to share information and data with the public in the countries where MCC invests.
Public and Agency Ideas
MCC’s 2014 OGP reflects input from MCC senior leadership, staff, interested stakeholders, and members of the public. Recognizing the importance of open government and the value that transparency, participation and collaboration bring to MCC’s work, the MCC staff working group that developed this plan hosted consultations and numerous conversations with external stakeholders, surveyed and hosted a focus group with MCC staff and presented stakeholder ideas to MCC senior staff for consideration and decision. Through our website, public town hall meetings and continued consultations with stakeholders, MCC is committed to considering and responding to public feedback. Our open government website has space for public comment, and MCC will respond to all comments and inquiries within two weeks.