NFATCA Report: V18N4
By John Brown
“If you like your old plan, you keep it. Nobody’s going to take it away from you.” Does this sound familiar? It should because a government plan to fix what many in government widely perceived as a broken system was implemented with the proviso that you absolutely could keep what you were already comfortable with using to take care of “business.” Except that all of the new stuff that was put in place to make the new system work actually did have a negative effect upon the old plans. Many of the old plans did not meet the requirements of new rules and regulations. Not all of the old plans were quite up to snuff and even though the President said that you could keep them, that pledge turned out to be ever so much political speak for, “you’re gonna do it our way.” Pay no attention to the fact that “our way” involves a system that was poorly constructed by contractors who failed to utilize expected norms of modern technology and techniques, operation, security and usability. Ignore the fact that “our way” is regularly unavailable for even routine use. Walk past the ongoing issues of the system regularly being unable to access needed information or display it for proper use. Discount the fact that only a small fraction of the user base is able to consistently use the system for its intended purpose. Now add in the instructions from the Fed that you are encouraged to use the system, as is, and submit your information with known errors and then submit a written request to have the already overburdened staffers go back and correct mistakes after the fact. And to add to the delicious cauldron of government goodness, you are informed that all submissions to the new system absolutely will receive preferential treatment as compared to “your old plan.” The infrastructure system of ObamaCare known as www.HealthCare.gov sounds pretty shaky, as does the government’s insistence on sticking with it, no matter what.
Except that we are not discussing www.HealthCare.gov or ObamaCare. We are talking about the Department of Justice - Bureau of Alcohol Tobacco Firearms and Explosives’ contribution toward government efficiency and progress that is better known as eForms. Sadly, the parallels that can be drawn between eForms and HealthCare.gov are eerily similar:
The eForms system design was created by a contractor organization that:
- Did not implement current technology
- Did not understand the scope of the project
- Did not complete the initial project
The eForms system was not thoroughly tested before launch to:
- Validate access compatibility with current, commonly used browsers (recommended browsers are not current or even shipped with current computers)
- Verify stability under load Confirm functionality of registration process
- Assure accurate data integration
- Provide reasonable error correction
- The eForms system must be taken down and restarted most every day; some restarts taking longer than others
- The eForms system is subject to intermittent stalls
- The eForms system frequently fails to load system sub-components, even after successful log on
- The eForms system requires that users force the propagation of known descriptive errors (manufacturer, model, serial, etc.)
- The eForms system does not support the attachment of fingerprints or photographs (rendering the ability to tackle the largest backlog of NFA Form approvals moot)
- The eForms system does not clearly explain what the approval process will look like and does not inform the user of the validity and acceptability of the “new stamp” process
- The eForms system does not have plans or budget in place to address the known issues
- The eForms system is faced with additional issues that are labeled as “we don’t know why this is happening”
- The replacement contractor has finished their work under the current contract and there is no additional contract being bid at this time
- The NFA Branch is informing users, when asked, that eForms applications absolutely will be given priority over traditional paper or facsimile submissions, despite the known issues
- NFA Branch has been made aware of the fact that the eForms system does not accurately reflect dashes and spaces in serial numbers, as required by ATF communication to industry via written communication and Webinars. This has the potential to cause problems during compliance inspections when an IOI does not fully understand the system limitations
To recap, the firearms community is being rather demandingly herded into using a system that is incomplete, inaccurate and just plain not ready for prime time. And even though all of the involved parties are painfully aware of the shortcomings of the preferred system, there is no plan or budget for the foreseeable future to address those shortcomings. Despite all of this, our community is trying its best to accommodate what most would consider to be a less than stellar situation.
According to the 2013 Firearms Commerce in the United States Annual Statistical Update (published by BATF), the NFA community, which is the primary target audience for eForms, has swollen the government coffers in terms of monies paid over the past decade. Total annual revenue collected by NFA Branch in terms of Occupational Tax paid and Transfer and Making tax paid has swollen nearly 300% from approximately $5.6mm in 2006 to approximately $15.5mm. The increase from 2011 to 2012 (the most current data published in the Update) is nearly 25% and there is no reason to expect anything but another huge jump in revenue from 2012 to 2013. If there are currently 21 agency folks assigned to pushing NFA “paper” (12 Examiners, 7 Specialists and 2 Supervisors), the allocated rate of cash intake per assigned personnel comes in at almost three quarters of a million dollars per desk. A glaring question comes to mind: At this income level, why can’t we get more personnel and a functioning electronic system that will actually support their efforts? There is more than enough money to fund the enterprise to the point where it could effectively and efficiently tackle the current work load and accommodate increases for many years to come. People are willing to pay for reasonable service People are not willing to embrace ever-increasing wait times, balky systems and processes that perpetuate errors and mistakes. Yet that is exactly what we have in the form of www.HealthCare.gov 2.0... otherwise known as eForms.
Those of us who submit official forms to ATF that are included in the eForms system must embrace the new reality in a manner similar to those seeking health care coverage under the government’s mandated system. Yes, you can use the old paper system if you are more comfortable with it. But your old system has changed in that it is absolutely going to take a back seat to the new eForms systems – the eForms system that is acknowledged by ATF officials as substandard. The eForms system that may or may not be available when you need it, that may or may not allow you to access it with your own current computer hardware and software technology, that may or may not be able to accurately reflect items that you are trying to transfer and that may or may not display or print information correctly. If you choose to use the eForms system, make sure that you have a healthy serving of patience by your side. If the system “insists” that you complete a form that you know has errors on it, please forward a copy of the approved form, a detailed explanation of the error and a request for acknowledgement to:
NFA Branch Chief
244 Needy Rd
Martinsburg WV 25405
You are absolutely encouraged to begin using the eForms system right now so that you can become familiar with its functionality and abilities. ATF sends out a helpful hints guide after you register, but you may wish to review the guide before you register. An electronic copy can be found at www.nfatca.org/pubs/eFormsHints.pdf. If you have specific questions regarding the eForms program you may contact Gary Schaible (firstname.lastname@example.org, 202.648.7165) or Lee Alston-Williams (email@example.com, 202.648.7166).
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