Plain Writing Act Annual Compliance Report for 2015
PLAIN WRITING ACT
ANNUAL COMPLIANCE REPORT FOR 2015
In the past year, the Department’s disparate components have again continued their efforts to implement the requirements of the Plain Writing Act by writing and revising documents intended for the public to be more clear, concise, meaningful and well-organized.
The Department’s law enforcement bureaus and offices, boards and divisions vary considerably in their missions and structures, and therefore the Department has continued to rely on each component’s leadership to determine which of their documents comply with the Act, or need to be revised, as well as which employees need Plain Language training.
In a continued reflection of the diverse and decentralized process being employed by the Department in implementing the Act, we list here a sampling of Plain Writing activities of a number of components.
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
In 2014, ATF held several working sessions related to Plain Language, which built on the 10-session Effective Writing Workshops held in 2013, as well as 2012’s course on Acquiring Plain Language Writing Skills. The 2014 program was organized and hosted by the Enforcement Programs and Services Directorate (EPS)’s Office of Regulatory Affairs. Session descriptions were as follows.
Session #1:
All are welcome to this hands-on workshop that shows how to take that crucial first step in plain writing—sitting in your reader’s chair before hitting the “send” button for e-mails, memos, reports, oral presentations, and more. George F., regulations writer in the Office of Regulatory Affairs, EPS, hosts this session using actual ATF writing examples to show how to get and keep your reader’s attention. Free to you at no charge whatsoever—tips on how getting your reader’s attention is critical to delivering your message.
Session #2:
All are welcome to this hands-on workshop that builds on the “Plain Writing Tips – By George” series presented by George F., Regulations Writer, Office of Regulatory Affairs, EPS. This new workshop reviews a full array of online sites that guide you through editing techniques and suggestions that help you make your reports, memos, and e-mails as effective as you can make them. George F. presents this session and uses actual ATF writing examples to highlight commonly-used word choice patterns that bore your readers and cost you effectiveness and impact. Mark your calendar now to get easy-to-remember tips on making your writing concise, to-the-point, and powerful.
Audience Participation:
Special Invitation: Pick one of your writing tasks—any task will do—and email George a copy. He will review the task with you first, and then consider discussing it during the workshop. No surprises—just sound advice on preparing for accuracy. (For the record, no attendee submitted any material to analyze. Therefore, he went with generic samples that he selected from his own ATF experience.)
George F. made himself available to work with anyone who wanted to adapt, adopt or refine these ideas for use in other environments.
Antitrust Division
Progress on Internal Division Documents
To help promote a culture of Plain Writing, we are continuing to review frequently used Division Directives, memos and announcements for conversion to a plain language format. The following Division documents have been revised and posted internally to familiarize staff with the plain language form of writing:
Examples of 2014 Daily Intranet announcements in Plain Language
Procedures for Joining the Voluntary Leave Bank Program
Best Places to Work Results
Urgent System Messages
Security and Computer Alerts
Computer Tips of the Week
Use or Lose Leave Instructions
Federal Benefits Open Season
Progress on Internet Website Compliance
The following public documents that are widely used are continuously reviewed and adjusted with updates, as needed, to a plain language format:
Division Staff Training
The Division will identify and provide training on Plain Language principles and practices in FY2015.
Civil Rights Division (CRT)
In 2014, the Professional Development Office created a Plain Language folder on its SharePoint site, which is available to all CRT staff. The site includes some key Plain Language documents and resources. In addition, we drafted some FAQs for CRT personnel, which are also posted on the SharePoint site. During 2014, the Civil Rights Division continued to provide writing training during the attorney orientation program, which incorporated plain writing principles.
Office of Community Oriented Policing Services (COPS)
Designated Plain Writing contact: LaShawn Montgomery
Progress on Internal Documents:
We have completed the COPS Office Editorial and Graphics Style Manual: Third Edition. We are continuing to update and review COPS products, including our Problem-Oriented Policing (POP) Guides, Grant Owner’s Manuals (GOMs), Director Decision Memos, and other general announcements for conversion to a plain language format.
Examples of 2014 Intranet announcements in Plain Language:
Kudos for COPS – Recognize a Colleague for a Job Well Done
Idea Station – Post and Vote on New Ideas for the Office
Announcement of the Monthly Issue of Community Policing Dispatch
Progress on Internet Website Compliance:
The following public documents that are widely used are continuously reviewed and adjusted with updates, as needed, to a plain language format:
Division Staff Training:
In 2013, the COPS Office required staff members to complete Principles of Plain Language Parts I and II, online through LearnDOJ, to fulfill the Plain Writing Act requirement. The training was completed by 62 COPS employees, who included senior leadership and managers as well as those responsible for publications available to law enforcement, community members and the public at large. We will be reissuing the Plain Writing Act training to capture the staff that did not complete the training in 2013.
Community Relations Service (CRS)
Agency Website: In the summer of 2014, CRS designated a website working group, composed of staff members from both Headquarters and regional offices, to evaluated the CRS website and determine ways to make it more accessible to the public. The working group has been actively rewriting the website pages to remove extraneous or convoluted text and to ensure that passages are written for a public lens rather than the perspective of CRS staff.
In that vein, CRS has, and is still in the process of, rephrasing the services it provides to communities to remove terms that are confusing, vague or unnecessarily complex to the public; condensing and simplifying bullet points describing CRS’s work; and rewriting case summaries from the viewpoint of the communities the Agency serves.
New Web Pages and Photos: Because the website is viewed by many different audiences, CRS is creating additional web pages, encompassing jurisdictional areas and communities the Agency works with, in order to address the specific needs and concerns of the different communities it serves. In addition, CRS is replacing its current photographs to be more representative of the work CRS does, rather than showing locations of CRS offices. The working group believes the updated photographs will contribute additional clarity to the types of services the Agency provides and the conflicts in which it may assist communities.
Annual Reports: CRS also implemented Plain Writing recommendations in its 2013 Annual Report to Congress. During the drafting of the Annual Report, CRS ensured that the information about the Agency, as well as the review of its casework, was clear, concise and well-organized. In addition, the Agency ensured it used short, simple words when writing, and omitted unnecessary words. CRS avoided using legal and technical jargon when not necessary, and maintained consistency of terms throughout the report. In addition, CRS provided examples of its work and used illustrations when possible, to add clarity to the writing.
Drug Enforcement Administration (DEA)
The Office of Acquisition and Relocation Management (FA): FA has instituted an informal initiative to review solicitation and proposal documents, including Statements of Work, Requests for Proposals and Requests for Quotes, in an effort to comply with the Plain Writing Act of 2010. Additionally, FA reviews other acquisition communications, such as Acquisition Policy Letters and DEA clauses which will also facilitate more streamlined and clearer communications with government contractors.
Improved interaction will result in a more vigorous response from the small business community, which enhances DEA’s ability to achieve small business contracting objectives. The guidelines of the Plain Writing Act have provided invaluable assistance in the formation of federal government solicitations and contracts, resulting in less ambiguity, and therefore better agreements.
Also, FA has started tracking vendor questions in response to requests for information in order to determine whether FA is in compliance with the Plain Writing Act, with specific emphasis on the active voice in solicitations, minimizing government abbreviations and using shorter, simpler words. FA also continues to monitor documents presented during the Contract Review Board process for Plain Language compliance.
The Office of Operations Management (OM): OM was recently notified by the Office of Chief Counsel Forfeiture Attorneys (CCF) that there was a change in the federal forfeiture regulations regarding Claims. CCF attorneys revised the claim letter, confirming that it continued to be written in Plain Language, and would be easily understood by the public. This claim letter has complied with the Plain Language Act since the start of the initiative; however, as changes are made, reviews of the document for compliance will continue.
The Office of Diversion Control (OD): OD indicated there were no new manuals, brochures, pamphlets, etc., posted on the Diversion website in 2014; therefore, no Plain Language updating has occurred. However, minor changes and corrections have been made to the Narcotic Treatment Manual and the revised Practitioner’s Manual, which remain in compliance with the Plain Writing Act.
Environment and Natural Resources Division (ENRD)
ENRD provides Plain Writing Act training for all new Division employees. We additionally offer PWA training to all ENRD employees, which can be taken on an as-needed and/or as-desired basis from the convenience of the employee’s desktop via learnDOJ.
ENRD continues to provide and maintain a Plain Writing Act-compliant template for composing Federal Register Notices on the Division’s intranet. The template was created to ensure such Notices were specifically compatible with the goals of the PWA. Federal Register Notices drafted by ENRD (which are most often intended to publish notices of the lodging of proposed consent decrees for public consumption) are reviewed by Division managers before they are finalized, and PWA is one of the elements of the review.
Executive Office for U.S. Attorneys (EOUSA)
The development of EOUSA’s central web platform for U.S. Attorneys’ Offices’ press releases, which would create a single point of entry for public information about the work of the U.S. Attorneys’ Community, has been substantially completed. EOUSA anticipates this platform will be live in approximately June 2015.
Office of Attorney Recruitment and Management (OARM)
Throughout the year, we prepared our electronic and paper documents (aimed to both internal and external audiences) in concise and clear language. We believe our OARM documents are well-organized, understandable by the public, and in compliance with the Plain Writing Act. Over the past year we did not conduct any training, although an office-wide reminder was circulated regarding the Act, and a copy of the “how to” guide was also distributed office-wide.
Office of the Inspector General (OIG)
The majority of OIG divisions use items referring to Plain Language in position descriptions or personnel performance goals. Most divisions also address Plain Language principles in their performance or strategic plans. The OIG is in the process of reviewing its vacancy announcement templates and making some additional changes to streamline the language in them, in accordance with the Plain Writing Act guidelines.
For other types of written material going to the public, such as reports, testimony and letters, divisions are responsible for ensuring that final products materially comply with relevant OIG standards, including the OIG Style Guide, which specifies the use of plain and concise language. Almost all of the OIG’s publicly-disseminated documents go through a rigorous editing process to ensure that plain, concise and understandable language is used in the final product.
This past year, report review staff from all of the reporting divisions participated in Plain Language training offered by the Council of the Inspectors General on Integrity and Efficiency, including seminars on Writing Effective Reports; Writing Better, Writing Smarter; Writing Fundamentals; and Coaching Effective Writing. One division also provided training for using Word software that generates a readability measurement roughly equivalent to U.S. grade levels.
Divisions also continue to review templates for memoranda and letters used for various correspondence. For example, the OIG’s Office of General Counsel regularly assesses standard form documents, such as Freedom of Information Act and Giglio response letters, to improve them from a Plain Language perspective. (“Giglio” refers to the issue of law enforcement officer credibility in court.) Overall, report reviewers and writer-editors have been trained to use Plain Language to the fullest extent possible – a challenge, given the often technical and legal nature of the OIG’s work.
This past year the OIG implemented report standardization efforts to establish more consistency among its reporting divisions and improve the readability of its publicly-issued products. These efforts included the use of uniform report covers with design elements mirroring the OIG’s public website; a uniform report numbering system within the reporting divisions; the use of a reader-friendly standardized font; the creation of a report template with standard report elements; and the development of formatting requirements to be applied consistently across the OIG. To launch this initiative, the OIG held division-wide information sessions, followed by specific training according to the needs of each division.
The OIG also continues to use its biweekly employee bulletin and its internally shared website to raise awareness of the Plain Writing Act and to provide related tools and tips. There are also plans to use SharePoint for communicating effective writing guidance that includes Plain Language techniques.
Office of Justice Programs
In previous years, OJP trained all Office of Communications staff and Office of the General Counsel staff. These individuals were trained according to the frequency of their written communications with the public. After this effort was completed, OJP has continued to provide plain language training to all employees by highlighting the Plain Language training modules within LearnDOJ. In addition, materials provided by the Center for Plain Language have been made available to all staff through the internal OJP U, an online resource for employee training needs. We also use this collaborative resource for employees to share best practices and post information regarding plain language.
Our Office of the General Counsel and Office of Communications continue to review all external releases, as appropriate and necessary, to ensure compliance with the Plain Writing Act. Within the Office of Communications, specific examples of implementation of the Plain Writing Act include (but are not limited to):
- Adhering to Associated Press style on all external releases. This is a widely accepted and understood style (state and title abbreviations for instance). This avoids making writing more difficult to understand because of style and usage of certain references. The style of OJP communications mirror articles that might appear in USAToday or The Atlantic.
- The review process including first-line editing for syntax, grammar and plainness of language.
- Standardized office guidelines that dictate the elimination of passive language and continued use of active voice. Active voice more clearly defines subject and action.
- Summarizing complex reports. In some cases, material has been condensed into “Top 5 things to know about…” which has proven popular to our social media audiences.
- Investing in support that can provide infographics – visual representations of information that quickly helps the viewer understand complex statistics.
Office of Privacy and Civil Liberties (OPCL)
The following OPCL documents are covered by the Plain Writing Act:
- Privacy Act (of 1974) System of Records Notices (SORNs), published in the Federal Register, that provide information regarding how individuals may obtain access to, and amendment of, records contained in the system;
- Privacy Impact Assessments (PIAs), as required by Section 208 of the E-Government Act of 2002, that provide information on Department systems that collect information in identifiable form on individuals;
- Certain correspondence and email in response to Privacy Act amendment appeals and public inquiries, when the response requires that we provide additional procedures or steps that the appellant or inquirer may wish to take; and
- Annual reports as required by Section 1174 of the Violence Against Women and Department of Justice Reauthorization Act of 2005, 28 U.S.C. § 509 (note) (2012); and Semi-Annual reports as required by Section 803 of the Implementing Recommendations of the 9/11 Commission Act of 2007, 42 U.S.C. § 2000ee-1(f) (2012).
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These documents have consistently been prepared with Plain Language to ensure clear communication to the intended audience and recipients. A thorough review process is undertaken by OPCL to ensure that such documents are written in clear, concise, well-organized and consistent language. In addition, copies of SORNs, PIAs and other reports cited above are placed on OCPL's website.
OPCL and Department employees are encouraged to write these documents in clear and concise fashion. In addition, OPCL employees are encouraged to take advantage of Plain Writing Act training offered by the Department.
Office of Professional Responsibility (OPR)
OPR continually reviews its documents that fall under the requirements of the Act to ensure that they comply with the Plain Writing provisions. Most of OPR’s written products are not intended for public distribution and, therefore, are not covered by the Act.
OPR’s website, annual reports and letters to the public, however, do fall under the Act’s requirements. OPR reviewed its website and determined that it complies with the Act. The website clearly describes how a member of the public can file a complaint about a Department attorney, and provides information in plain language about the OPR process. OPR reviews its annual reports for clear language and determines that its reports also comply with the Act. Letters to individual members of the public similarly comply with the Act.
All new employees are given a copy of the Federal Plain Writing Act Guidelines 2011 for their review. In addition, OPR developed a writing style manual that is distributed to all employees. All documents that are subject to the Plain Writing Act are thoroughly reviewed for clarity, punctuation, grammar and spelling before they are finalized.
Office on Violence against Women (OVW)
The Office on Violence Against Women has engaged in extensive efforts to revise our publicly available background materials about OVW and the implementation of federal grant programs authorized under the Violence Against Women Act and to review the OVW website. The goal is to make the materials more user-friendly and accessible and to ensure that information about our office, grant programs and other activities is accurate, clear, and concise.
OVW supervisors encourage all OVW staff members to review online resources designed to enhance their ability to communicate in a clear and straightforward manner. OVW is also hoping to schedule training on Plain Writing at an upcoming mandatory staff meeting. In addition, we are considering requiring OVW staff to participate in online trainings.
Tax Division
The Tax Division’s principal covered document is its public website. The Division recognizes the importance of clear communication in promoting tax compliance, and has taken steps to ensure that its website meets the Plain Language standard. Writing that is concise, thorough, well-organized and effective remains a priority for Division managers.
Moreover, the Division has taken steps to communicate the message about writing in Plain Language to its employees. As part of the Division’s training program, employees have access to training intended to help improve and clarify their writing. And, through the Division’s intranet website, all employees have access to the Plain Language website and resources.
United States Marshals Service (USMS)
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The USMS Office of Congressional and Public Affairs is hiring a web content manager in the third quarter of FY 2015 to improve both the USMS Internet and Intranet sites. Enhanced graphics, easier-to-read formatting, and updated content will be provided.
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The USMS Human Resources Division is in the process of standardizing position descriptions for commonly filled administrative positions in the agency. Currently, administrative position descriptions (PD’s) are written for specific headquarters or division offices. This has created a large number of unique PD’s that require significant updates by Human Resources specialists, as well as administrative officers in the field, whenever jobs must be backfilled. In the future, the standard PD will be used as the basis for job announcements so the USMS can fill vacancies faster. Operational positions already use standardized PD’s.
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The Management Support Division conducts annual policy recertification and requires each headquarters component to update each USMS policy. To increase the speed of policy certification, the USMS is conducting a business process analysis (BPA) to ensure bottlenecks in the review process are eliminated. Timely dissemination ensures that the USMS is operating with the most current policies.
United States Trustee Program (USTP)
At the U.S. Trustee Program we maintain a Plain Writing Act SharePoint page that includes PowerPoint slides from the Program’s Plain Writing training, FAQs, and other Plain Writing related documents. We also continue to have Plain Writing coordinators in each of the Program’s 21 regions and the Executive Office (there are two experts at the EOUST, including our Public Information Officer) who are responsible for ensuring that newly created documents subject to the Act are written in plain language.