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Secretary of Labor Thomas E. Perez
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DOL's Strategic Plan - Live Q&A Session with OLMS - Static Page

This chat about the DOL Strategic Plan was held on Tuesday, April 6 at 3:30 p.m. EDT with OLMS.

3:24 Moderator: Welcome! The live, text-only chat will begin at 3:30 EDT, but you can submit your questions at any time and they will go into the queue.

3:31 Director John Lund: This is OLMS Director John Lund. Welcome to the OLMS Web chat on its strategic plan. This exercise is part of a larger strategic planning exercise that the Department of Labor is involved in. Our purpose today is to discuss our proposed goals and outcomes at OLMS and we would like to hear from you as to whether or not these are the right goals and outcomes; if they aren’t what should they be? We look forward to your participation in this process. For more information about OLMS and our programs please visit www.olms.dol.gov.

3:35 Comment From Elaine Reese: Included in the strategies to achieve the goals internal controls are listed. Has the department considered providing guidelines on how to develop Internal Controls?

3:35 John: Thanks for your question Elaine. We are planning on issuing a series of "Compliance Tips" on our Web site.

3:35 Comment From David Broderdorf: Is the DOL/OLMS aligning its NPRM on the LM-20/LM-21 with the pending regulations on Executive Order 13494 on "unallowable costs" for certain persuader activities by federal contractors?

3:36 John: David: Thank you for your question. The Executive Order (EO) that you refer to disallows federal contractors from passing costs to the federal government for expenses related to activities to persuade employees with regard to their rights to organize and bargain collectively. OLMS's NPRM is intended to clarify aspects of the forms requiring disclosure of similar persuader activities. The EO and the OLMS regulation all work together and combine to create and maintain a level playing field.

3:36 Comment From John: When do you plan to issue the Request for Information on electronic balloting, and how long will you accept input? How long do you expect the entire process to take?

3:36 John: Thanks for the question, John. OLMS plans to issue the Request for Information (RFI) on electronic balloting in the fall of 2010. We have not yet drafted the RFI, but anticipate accepting input for at least a thirty day period. It is hard to predict how long the entire rule making process will take.

3:38 Comment From Elaine Reese: The department is considering increasing the number of disclosure reports filed electronically. Will a fee be required to secure an electronic signature?

3:38 John: Thanks again Elaine. There will be no fee for electronic signature in our soon to be released electronic file software (EFS).

3:39 Comment From Gerard DeWolf: When does the OLMS expect to roll out information or guidance concerning LMRDA compliant internet voting processes? Thank you for any information which you are able to share.

3:39 John: Gerard, see my response to John at 3:36.

3:45 Comment From Elaine Reese: In measuring success the LM-10 and LM-20 reports filed were listed. Was the LM-30 not considered as necessary to this list?

3:45 John: I appreciate your question Elaine. Rulemaking is planned for the Form LM30 as well as for the Form LM10 and Form LM20. All of the public disclosure reporting forms are important in achieving the objectives of the law. We can consider a goal related to Form LM30 reporting. If you have particular suggestions please feel free to forward them to OLMS. You may use OLMS-Public@dol.gov for that purpose.

3:49 Comment From Elaine Reese: Does the department have any recommendations to a National Division attempting to secure delinquent LM Reports?

3:49 John: Elaine, actually we have had some very interesting results reported to us by several international unions. First of all, we suggest you obtain monthly lists of delinquent reports from OLMS. Secondly, each month assign a followup contact person in the national office to speak with each delinquent filer; make sure this contact person stresses the importance of filing on time; and, at the same time, offer any assistance they may need in completing their form. Thirdly, if the same delinquent local shows up in succeeding months, have a higher level union official contact the local with the same message. The key to success is repeated contact with the delinquent filer combined with an offer of assistance. Please feel free to contact me if you would like to discuss this further.

3:51 Comment From Elaine Reese: Thank you those are good suggestions.

3:52 Comment From JC: Are there any plans to enable or facilitate filing an LM30 electronically?

3:52 John: Hello, JC, thank you for your question. It is the long range goal of OLMS to enable the electronic filing of all required forms.

3:55 Comment From Kurt Richwerger, AUD: If we wish to submit a comment by email, on the plan, when is the deadline? And tell us again the proper email address. Thanks

3:55 John: Thanks Kurt, we are working on the deadline. For the time being, all comments, suggestions and questions can be submitted to strategic-plan@dol.gov. Please put the name of the agency, OLMS, in the subject field of the E-mail.

3:55 Comment From David Dorsey: When do you anticipate that the Department issue the next Notice of Proposed Rulemaking for Form LM-30 and/or Form LM-10?

3:55 John: Thanks, David for that question. The plans to be announced in the Department of Labor's Spring Regulatory Agenda will propose a notice a notice of proposed rulemaking for Form LM30 in August 2010 and a notice of proposed rulemaking for persuader reporting on the Form LM10 and the Form LM20 in November 2010.

3:56 Moderator: John is working his way through the questions, so we can use some more. Don't be shy!

3:57 Comment From JC: When the LM4 can be filed electronically, do you anticipate a reduction in fees for the electronic signature?

3:57 John: JC: There will be no charge for the electronic signature with the soon to be released electronic filing software (EFS).

3:58 Comment From JC: Thank you. That is fantastic news for the smaller local unions.

4:00 Comment From Paul: Will there be a fee for any required digital signatures (Lm2)? Will the digital signature be secure similar to the current ones?

4:00 John: Paul, more good news. There will be no fee for the electronic signature for the LM-2. There will be no fee for the electronic signature for the LM-3 or -4. Security will be assured through a pin and password system.

4:03 Comment From Elaine Reese: When a criminal investigation is conducted how many years will the investigator examine?

4:03 John: Hello, Elaine. In a criminal investigation, the number of years of financial activity examined will depend on the period of alleged or suspected financial impropriety.

4:06 Comment From JC: What percentage of LM3s submitted to the OLMS are checked for mathematical errors?

4:06 John: Hello, JC. All LM-3 reports submitted to OLMS are checked for mathematical errors as well as standards of acceptability through an electronic screening process.

4:06 Moderator: This chat ends at 4:15. If you have any more questions, please send them now.

4:07 Comment From David Broderdorf: Thanks for the response to my earlier question. Under OLMS' strategic plan and goals, is there a timeline for finalizing the regulations to implement Exec. Order 13494 on unallowable costs for persuader activities?

4:07 John: David, thanks again for your question. The Executive Order 13494 is being implemented by the Federal Acquisition Regulatory Council, which is a multi-agency council outside of the Department of Labor. Please contact the FAR Council for additional information on timelines for the promulgation of the regulation.

4:07 Comment From Elaine Reese: Thank you for taking this time to answer questions.

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4:11 Moderator: That's a photo of John working on an answer to a question.

4:11 Comment From JC: Is it the policy of OLMS to notify the union lodge when errors are discovered?

4:11 John: JC, in most cases, unions are sent advisory letters of reporting deficiencies. In some instances, amended reports may be requested.

4:13 John: Thank you for taking the time to participate in today's Web chat. Your ideas and suggestions are important to us as we finalize our goals and outcomes as part of our own agency’s and DOL’s overall strategic planning process. If you have any other ideas, comments or questions, please feel free to submit them by e-mailing them to strategic-plan@dol.gov. Also, a transcript of today’s chat will be made available at http://www.dol.gov/_sec/stratplan/ .

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