Section 3: Management Controls

A: QUARTERLY CONTENT CERTIFICATIONS

HUD's quarterly certification process helps us ensure that all content is current and accurate and in compliance with laws, regulations, and policies. While managers are responsible for the certifications, the Web Managers should assist managers to coordinate the process and to make any changes that are needed.

About the Certification Policy

• In 2001, the Deputy Secretary issued the policy requiring each organization head to certify, in writing, each quarter that the web content for which that organization is responsible is both current and accurate. Certifications for are due:
  • January 1,
  • April 1,
  • July 1, and
  • October 1.
• This certification requirement applies only to all web content, including content on www.hud.gov, hud@work, and the HUD content on kiosks. Managers should establish procedures to ensure that all web content is reviewed and updated routinely, to avoid delays just before certifications are due.
• Certifications should include:
  • Navigational pages
  • Documents
  • Data available without password protection
  • Discussions and real-time chats (only need to certify that they are being used and maintained by the owner)
  • Webcasts (only need to certify that they should continue to be on the website)
  • Mailing lists (only need to certify that they are still being used and maintained by the list owner)
  • Calendars (only need to certify that they are still being used and maintained by the owner)
  • Links (must be working, must go to the site intended)

Process

• Most organization heads hold their subordinate managers responsible for the web content they generate.
• At least one month prior to the end of the quarter, prepare an email from the organization head to subordinate managers reminding them that certifications are due. Establish a deadline - normally at least one week before the end of the quarter - for the subordinate managers to submit their own certifications to the organization head. Since you must do both internet and intranet, you may want to stagger the deadlines, doing the reviews of the intranet the first month and the reviews of the internet the second month. That way, you can complete all changes in plenty of time for the certification deadline.
• Collect the certifications from the subordinate managers, and prepare the certification memo "http://hudatwork.hud.gov/po/odoc/webinc/policies/sample.pdf" for the organization head so that it can be submitted by the due date. If subordinate managers do not meet the deadline, follow up and/or raise the problem to the attention of the organization head.
• Certifications must be submitted to the Deputy Secretary, through the Director of ODOC. You may fax the certifications to the Director of ODOC at (202) 401-8848. Be sure to fax a copy of the signed certification memo to the Departmental Web Team at: (202) 708-1090.
• The Departmental Web Team will monitor certifications and report any outstanding certifications to the Director of ODOC.
• If, during the course of QC reviews, web pages are identified that are not current and accurate - after they have been certified - the Departmental Web Team may raise that issue with the organization Web Manager and/or the Director of ODOC.

B: POSTING RIGHTS

The Departmental Web Team is responsible for granting and managing posting rights for HUD's web pages in a manner that protects the security of the websites.

Posting Rights in Headquarters

For the Internet website, each of the program offices and major support offices may request one posting right per major organizational unit (Deputy Assistant Secretary level). Thus, the allocation for Headquarters organizations are as follows:

• Housing: 6
• PIH: 5
• CPD: 4
• FHEO, Administration, CIO, CPO, CFO, CIR, EEO, OGC, OIG, Lead Hazard Control, ODOC: 2 each
• ALJ, Board of Contract Appeals, Faith Based and Neighborhood Partnerships, OSDBU, FPM, and PDR will get support from the Departmental Web Team technical support contractor.

For hud@work, organizations may have twice the number of posting rights that they have on www.hud.gov.

Posting Rights in the Field

Regional Web Managers use contract support for most posting. Regional Web Managers do have a limited content management system that they can use to create and post features on the front pages of their Internet state pages and to add and update links on their topic level pages.

Each Regional Web Manager has an official back-up among the other Regional Web Managers. That back-up has rights to post content on behalf of the primary Web Manager. No one except the Regional Web Managers, the Departmental Web Managers, and the technical support contractor may have rights to or post content on the State pages.

Official back-ups for posting purposes are:

For espanol.hud.gov and for hud@work, Regional Web Managers are supported by the Departmental Web Team's technical support contractor. In that case, Regional Web Managers submit requests through the Fieldtrak system.

General Rules about Posting Rights

• Posting rights are issued to individuals and may not be shared for any purpose.
• Any posting activity that results in losing files, making changes in directories other than those authorized, security violations, legal violations, rendering the websites or part of the websites unworkable, or any other result that has a negative impact on the operation of HUD's websites will be dealt with promptly by the Departmental Web Managers and, as appropriate, the CIO, in consultation with the organization manager. Remedies may include required training, temporary suspension of posting rights, or permanent suspension of posting rights.
• All Web Managers are expected to know and abide by the policies and procedures for HUD's websites.

C: CONTENT QUALITY CONTROL

HUD's Departmental Web Team manages the Content Quality Control process, which ensures that HUD's web pages are reviewed routinely to ensure that they meet HUD's writing standards. Web Managers and others who develop web content and web pages should use the Quality Control rating form to review their pages before they post them.

Background

HUD is using its website to complete its mission and goals and serve the public; and it is important to have a process to ensure that the content is well-written, well-organized, and in compliance with Departmental web policies and publication standards. The Deputy Secretary already has established a quarterly certification process that requires HUD managers to certify that content is current and accurate. We also need to have a process that monitors the quality of the content, including compliance with Departmental requirements.

Overview of Process

The quality control process has five objectives:

• Be as objective as possible
• Be as helpful and constructive as possible
• Be routine
• Be carried out without new or additional resources
• Contain ramifications sufficient to ensure sustained, high quality web content throughout HUD's website

While the substance of the content (the "what") of HUD's website is "owned" by HUD managers, the presentation of the content (the "how") is the responsibility of Web Managers. Therefore, the quality control process will depend on "peer reviews," with Web Managers and web coordinators reviewing the pages of other Web Managers and web coordinators.

All reviewers will be trained by the Departmental Web Team, prior to conducting any reviews.

What Will Be Reviewed?

At the beginning of each year, the Departmental Web Team will establish a significant number of web pages to review.

Content to be reviewed will be identified in 3 ways:

• An established percentage will be the most visited pages for that organization. Some of these pages will be the same from review to review; but since these are the most visited pages, it is important that they be top quality.
• An established percentage of the pages reviewed each year will be selected at random from all the pages for that organization.
• An established percentage of the pages will be suggested by the Web Manager for that organization.

Review Teams

• Review teams will be 3-person teams drawn from all officially designated Web Managers throughout the Department
• Teams will include representation both from the Field and from HQ.
• Reviewers will never be assigned to review their own pages.
• The two Departmental Web Managers will not participate in routine reviews. They will handle disputes and appeals.

Review Process

• The Departmental Web Team will establish an annual review schedule, identifying review teams and review deadlines for each team. Deadlines will be staggered throughout the year.
• Each member of the team will review the same content so that there will be 3 different evaluations of the content.
• Each team member will complete an automated review form for each page reviewed. Reviewers will be encouraged to include specific comments and suggestions for ways to improve the content, particularly on ratings of 3 or less. QC reviews will focus both on compliance with HUD web policies and publication standards and on compliance with HUD's standards for writing for the web.
• The three evaluations of each page will be averaged to come up with an overall "score" for each page. The Departmental Web Team will review evaluations, identifying trends and anomalies.
• The Web Manager for the organization also will review the evaluations of the content for his/her organization, sharing the results with managers within the organization as appropriate.
• Deficiencies should be remedied within 1 month. A follow-up team, comprised of Web Managers, will spot check pages that score 44 (80%) or lower.
• Failure to correct deficiencies within one month will be reported to the organization head and the Deputy Secretary. Remedies could include temporary suspension of posting rights.
• A sample rating form is available in Appendix K.

D: OPERATING IN EMERGENCIES

HUD's websites could play a critical role in emergency situations, getting information out to citizens, business partners, and employees about operations and procedures. Every Web Manager needs to know what he/she is expected to do within the organization, in case of emergencies. Every Web Manager needs to suggest possible impacts on, and uses of, the web in emergencies, to his/her organization head, to help ensure that his/her organization's emergency plans address web operations.

• Terror Alert Level - The terror alert level will be posted only on the front page of the national hud@work website. If specific regions or cities are at a different alert level, we will note it in that box. Employees only have to check one place - the front page of hud@work - to find out the alert level. The Departmental Web Managers will update the terror alert level based on a) notification from the Office of Security and Emergency Planning, b) notification from the White House or on the White House website, or c) notification from the Department of Homeland Security or on the Homeland Security website, whichever comes first. If the alert level is changed after normal working hours, the status will be updated on hud@work as early in the morning as possible, the next working day.
  
  
• Departmental Information and Guidance on Security and Emergencies - Important information about security and emergencies will be posted on HUD's Intranet (hud@work) by the Office of Security and Emergency Planning (OSEP). It will appear under the topic: "Emergencies and Security." That will serve as the primary information source for HUD employees about security and emergency procedures and protective measures. Any local emergency and security information posted onregional hud@work pages will be linked to the national Emergencies and Security page, so that all employees have just one place to look for this kind of information.
  
  
• Local Information and Guidance on Security and Emergencies - Regional Web Managers may create local Emergencies and Security pages on their Regionalhud@work pages, provided that they coordinate all content with OSEP in advance and that all content is approved by the Regional Director, in advance. They must ensure that local information is linked to the Emergencies and Security page on the Departmental hud@work site. Content onlocal hud@work pages must be strictly local and must not duplicate information already on or appropriate for the national site.

Specific Duties of Web Managers

• Be familiar with the Department's procedures for posting content during emergencies,
  
  
• Work with your COOP representative and others in your organization to make sure they are aware of emergency posting procedures and that any other web aspects are addressed.
  
  
• Maintain a current list of phone numbers, home email addresses, and other contact information for key managers in your organization, Web Coordinators, fellow Web Managers, Public Affairs Officers or Coordinators, and any others who you might need to contact in an emergency.
  
  
• Inform/train Web Coordinators in your organization on procedures for posting information and other emergency plans related to the web.

Posting in Emergencies

In the case of a major emergency, information related to the emergency can be posted to HUD's website remotely.

1. HUD's Web Team may post information on the front page of HUD's website or - in the case of local emergencies - on the front page of the "state" pages to inform employees, business partners, and/or the public about changes in the Department's operations. The following policies and procedures will be used in emergency situations.
   
   For Level 1, 2, 3, or 4 emergencies in Headquarters and Level 4 emergencies in the Field:
   
   
   • Information to be posted should be submitted for approval by telephone, in person, or in the most expeditious way possible to the Secretary, the Deputy Secretary, the Chief of Staff, or - if none of those officials is available - to the top official specified in the succession plan documented in the COOP. A concurrent alert should be sent to the Assistant Secretary for Public Affairs or his/her designee.
     
     
   • If the emergency affects one or more Field offices, information should be coordinated with the Assistant Deputy Secretary for Field Policy and Management or his/her designee before it is submitted for approval.
     
     
   • Once approved by the Secretary, Deputy Secretary, Chief of Staff, or top HUD official designated in the COOP, the information will be submitted to the Office of Public Affairs for content clearance. The Assistant Secretary for Public Affairs will designate - in advance - specific staff that may authorize this clearance.
     
     
   • The Assistant Secretary for Public Affairs or designee may post the information on the website him/herself or telephone one of the two Departmental Web Managers to alert him/her that information is being sent for posting. The Assistant Secretary or designee will email the information to be posted to the Departmental Web Manager, and the Departmental Web Manager will post the information as soon as possible.
     
     
   • Only the Assistant Secretary for Public Affairs and/or designee and the two Departmental Web Managers have the authority to post emergency updates. The Departmental Web Managers will post information only with the authorization of the Assistant Secretary for Public Affairs (or designee) or, if the Public Affairs staff is not available, with the personal approval of the Secretary, Deputy Secretary, Chief of Staff, or top HUD official according to the COOP. The Departmental Web Managers will not post information provided through third parties.
     
     
   • The Assistant Secretary for Public Affairs and/or designee and the Departmental Web Managers can post from anywhere in the country, as long as they have access to a computer with Internet access and as long as HUD's web servers are operational at the primary or secondary locations.
     
     
   For Level 1, 2, and 3 emergencies in the Field:
   
   
   • The Regional Web Managers may post information for employees, partners, and/or the public about the status of operations or actions to take related to local emergencies on hud.gov. Information to be posted on hud@work may be submitted through Fieldtrak as a "Now" priority.
     
     
   The following approvals and notifications are required:
   
   
   • For Level 1, Level 2, or Level 3 events, the Regional Director (RD) must approve the information before the Regional Web Manager can post it. The RD must inform the Assistant Deputy Secretary for Field Policy and Management, the Assistant Secretary for Public Affairs, and the Director of the Office of Security and Emergency Planning about the posting. For Level 1, 2, or 3 events, if the Regional Director is unable to reach the Regional Web Manager or his/her designated back-up, the RD may contact either of the Departmental Web Managers directly.
     
     
   • For Level 4 events in the Field, approvals will be the same as for Headquarters emergencies, outlined above and documented in the COOP.

E: CONTENT COORDINATION

Web Managers need to ensure that the content they post has gone through all required clearances. Web Managers should work with their organization heads to establish clearance processes, and Web Managers should train their Web Coordinators to ensure that all clearance processes are implemented.

Required Coordination

• Assistant Secretaries and Regional Directors are responsible for establishing and communicating procedures within their organizations to ensure that all content submitted to the Web Manager has been properly coordinated and approved.
  • Web Managers should meet with their organization heads to develop and document these procedures and should assist their organization heads in communicating the procedures to all involved.
• All website content of a political or policy nature must be coordinated through the Office of Public Affairs before it is posted. It is the responsibility of the appropriate Principal Staff member or Regional Director to ensure that this occurs.
  • Web Managers should meet with their organization heads to develop and document procedures and should assist their organization heads in communicating the procedures to all involved.
  • Web Managers should be on the lookout for new or revised content that may be of a political or policy nature and ensure that it has been vetted appropriately before posting.
• Organizations who want to create content that crosses program or organizational jurisdiction must be coordinated with the other organization(s).
  • Web Managers should be assertive in identifying content that may cross jurisdictions and in coordinating with - or at least informing - the Web Managers of those jurisdictions about potential overlap, before the content is posted.
• Organizations involved in cross-agency efforts must coordinate with the Departmental Web Team.
• Organizations creating new web-based applications must coordinate with the CIO (including the Test Center) and with the Departmental Web Team.

F: BRAND INFRINGEMENT AND FRAUD

Once in awhile, we become aware of a website that appears to be a HUD website - by its content or by its look and feel or by its URL. Though we may wish these websites wouldn't exist, they are perfectly legal...as long as they do not represent themselves as being an official HUD website. If another website appears to represent as an official HUD website, you should alert the Departmental Web Team. The Web Team will review the site and, if they agree, forward it to the General Counsel for action.

What to Look For

• No organization, outside of HUD, can use the official HUD seal. If the HUD seal appears on another website and the seal seems to be used to indicate HUD sponsorship, report it.
  
  
• If a website looks like a HUD website - maybe it has a URL with "HUD" in it or it talks about a HUD program, check to see if there is a disclaimer somewhere on the front page. Normally, they are at the bottom. As long as there is a disclaimer that says the website or organization is not officially affiliated with HUD, it is OK. However, if it appears to be a HUD site and has no obvious disclaimer, then refer it to the Departmental Web Team.
  
  
• There is growing concern about the new technical trick called "phishing" - where a website is made to look like an official website for the purpose of defrauding people (collecting personal information, etc.). Be on the lookout for any websites that might be trying to use phishing; report them immediately.

G: DATA ACCURACY

Requirement: Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 and guidance from OMB requires agencies "to ensure and maximize the quality, objectivity, utility, and integrity of information disseminated by Federal agencies." OMB policy memo M-05-04 says that agencies should take reasonable steps to ensure the quality of information by:

• "Clearly identifying the limitations inherent in the information dissemination product (e.g., possibility of errors, degree of reliability, and validity) so users are fully aware of the quality and integrity of the information or service,
• Taking reasonable steps to remove the limitations inherent in the information, and
• Reconsidering delivery of the information or services.

This applies to content, data, and links.

What Web Managers Must Do

• If inaccurate data is found on the website, the Web Manager need to work with the appropriate office to correct the data as soon as possible.
• If people who use HUD's website report potential inaccuracies in data that is presented on the website, via the webmail system, forward the message to the designated email box maintained by the Office of Administration, for processing: quality_info@hud.gov.
• When putting up new web content - especially content that presents or includes data - make the manager aware of the OMB requirements and include appropriate clarification or disclaimers.
• When evaluating new links or reviewing existing links to outside websites, consider the requirements of the OMB policies and include appropriate clarification or disclaimers.

H: KIOSK PERFORMANCE STANDARDS

Kiosk Management Controls

Web Managers and the Departmental Web Team are to monitor monthly kiosk statistics. When a kiosk has fewer than 250 visitors per month for 3 consecutive months, the Web Manager will alert the Field Office Director and - together - they will decide whether to promote the kiosk or move it to a more favorable location. Kiosks failing to meet the average of 250 visitors per month for 6 months must be moved.

Procedures for moving kiosks are identified in Appendix B.

I: QUALITY MANAGEMENT REVIEWS (QMRs)

Each year, the Office of Departmental Operations and Coordination, in cooperation with the Office of Field Policy and Management, develops a schedule of offices that will receive Quality Management Reviews.

Part of ODOC's responsibility during the QMRs is to look at web management operations in the office. We have developed very specific standards, measures, methodologies, and interview questions in four basic web management areas, to determine how effectively web management - and in particular, all the essential coordination - is being handled in the office being reviewed (see Appendix J).

• Web Content Management
• Promoting HUD's Web Products
• Web Training
• Managing Web-Generated Email

Departmental Web Team's Role

• The Departmental Web Team updates the QMR standards, measures, methodologies, and interview questions annually, prior to the start of QMRs.
• The Departmental Web Managers determine which QMRs need an indepth look at web management and, if necessary, assign a Web Team member to serve on the QMR team. For other QMRs, the Departmental Web Managers provide any appropriate background information and/or issues to examine to the ODOC team leader, prior to the review.
• The Departmental Web Manager for Field Operations responds to any questions from the ODOC team leader during the QMR, providing recommended actions as appropriate.
• The Departmental Web Manager for Field Operations follows up with the Regional Web Manager on any issues, ensuring actions for which the Web Manager or Web Coordinator are responsible are being taken.
• On occasion, the Departmental Web Managers may be asked to determine when an observation or issue should be closed.

Regional Web Managers' Roles

• Regional Web Managers should use the QMR process as an opportunity to educate Field Office Directors and other staff on the important roles and coordination necessary for effective web management.
• Get on the agenda of a Regional staff meeting early in the year to go over the web management QMR criteria and answer questions
• Train the Web Coordinators in your region on the QMR standards, and offer suggestions for ways to address all the standards.
• Before the review, contact the FOD and Web Coordinator to go over the web management QMR criteria again and provide suggestions on how web management could be improved. Offer to assist in conducting staff training.
• Follow up with the FOD and Web Coordinator after the review, offering appropriate assistance in addressing any observations or issues.
• Regional Web Managers may be interviewed during the review process, as defined in the ODOC standards and methodology for reviewing web management (Appendix J)

10: USING WEB ANALYTICAL TOOLS

The Departmental Web Team has developed a number of tools to help Web Managers and Web Coordinators improve the website.

• Statistical reports (Webtrends): Statistics for HUD's websites are published monthly, normally by the middle of the month. Statistics can be very useful in
  • Promoting the website with both internal and external audiences (Did you know that HUD's website had more than 1 million unique visitors last month? Did you know that the "homebuying" page was the most used page this month?)
  • Identifying navigation problems - if you think a page should be getting more use than it is, then maybe you need to change the navigation to that page, so it's more prominent
    
    
• 404 error reports: These reports help you spot bad links - links to pages no longer available. See Appendix L for instructions on its use.
  
  
• File management reports - these reports help Web Managers identify files currently on the production server. You can use this report to find files that should be removed or archived.
  
  
• Linkbot reports: Linkbot reports help identify broken links.
  
  
• American Customer Satisfaction Inventory (ASCI): The ACSI helps us get feedback from citizens and partners who use our Internet websites, about their perception of the sites. Customer satisfaction scores help us know our audiences' perceptions about our sites. They may or may not actually reflect how well audiences can use our sites.
  
  
• Usability tests: usability testing helps us know what our audiences actually do on our sites. These tests can help us determine where we've got navigation problems or wording problems.