Project Management and the Do Not Call Registry: The Government's Big IT Success
Tue, June 01, 2004
CIO — It was a quintessential D.C. summer morning, hot, humid, sticky. But among the small crowd assembled in the Rose Garden, no one had more reason to sweat than Stephen Warren. As President Bush stepped through the Oval Office doors just after 8:30 a.m. on June 27, 2003, to announce the official launch of the Do Not Call (DNC) Registry, the CIO of the Federal Trade Commission was listening anxiously to the earpiece of his cell phone. Warren needed to make sure that the system, which had launched at 12:01 that morning, didn’t crash while handling the surge of early bird requests. It’s not a good career move, after all, to make a liar of the president. The sweat trickled slowly down Warren’s back as the number of registrants kept climbing, but the system held steady as the commander in chief reached the podium.
"Unwanted telemarketing calls are intrusive, they are annoying, and they’re all too common. When Americans are sitting down to dinner, or a parent is reading to his or her child, the last thing they need is a call from a stranger with a sales pitch," said Bush, whose words aired live on Today and The Early Show.
Spurred on by the publicity, consumers began flocking to www.donotcall.gov and calling the toll-free number to place their phone numbers on the Do Not Call list. Within 72 hours, consumers signed up more than 10 million phone numbers, making it a federal offense for telemarketers to disrupt their dinner hour, or indeed call at any hour of the day or night.
Not many IT projects are tackled at lightning speed under the glare of national media attention. Fewer still involve a courtroom drama that shuts them down three months after going live. Yet, despite these challenges, the Do Not Call registry delivered on its ultimate goal: giving consumers a painless way of preventing unwanted phone calls. This is the story of how the FTC pulled off one of the most successful IT projects in the history of government. Using such strategies as splitting the project into manageable phases, creating a performance-based contract and lining up a vendor before Congress came through with funding, Warren and his staff got the consumer registry up and running in fewer than 100 days.
"We view the Do Not Call Registry as one of the most successful privacy protections in the United States," says Chris Hoofnagle, associate director of the Electronic Privacy Information Center in Washington, D.C.
Planning for a Green Light
In 1994, Congress passed a law directing the FTC to come up with a way to prohibit deceptive or abusive telemarketing practices. A year later, the FTC’s Telemarketing Sales Rule prohibited telemarketers from making repeat calls to consumers who’ve asked them not to call again. In 2000, when the FTC conducted a yearlong review to examine the impact of the Do Not Call provision, it became clear that it wasn’t strong enough. Consumers were getting so fed up with unwanted telemarketing calls that many states had established their own Do Not Call lists. In January 2002, the FTC proposed a regulation requiring telemarketers to subscribe to a national Do Not Call Registry and prohibiting them from calling consumers on that list.
Warren joined the FTC in December 2001?just as the agency began investigating how it could create such a registry. FTC Chairman Timothy Muris had tapped Lois Greisman, associate director of the Division of Planning and Information in the FTC’s Bureau of Consumer Protection, to represent the business side of the project. He also wanted Warren?the new guy?in on the process from the outset.
"Usually the policy and legal people decide ’This is what I want’ with no thought to feasibility, cost or alternatives," says Greisman. "For the first time, IT people sat down with policy and legal folks in the planning stage." Warren, who had previously been CIO for the Department of Energy’s bureau responsible for cleaning up nuclear weapons production sites, helped the task force consider the feasibility of various technical options as it hashed out the details of how to build a list and get it in the hands of telemarketers.
The group identified five key components that the system should have: the consumer registry, telemarketer access to the list, a complaint system for consumers to report telemarketers who ignored the list, access to complaints and the list database for law enforcement agencies, and an interface to enable data sharing between the federal and state lists.
Warren quickly realized that the FTC didn’t have the resources to build a DNC system internally. So he decided to line up a vendor in advance to give the project a running start as soon as it got the green light. With so much demand from consumers for the registry?the agency had received 64,000 responses to its call for public comment, and most were vehemently in favor?the FTC was under enormous pressure to make the system work flawlessly. So the task force agreed with Warren’s recommendation to share risk with the chosen vendor by setting up a performance-based contract.
While Warren and his team evaluated vendors, political momentum for the project grew. Chairman Muris went before Congress in January 2003, asking for funding and permission to charge telemarketers for list access. Muris urged Congress to act quickly to get the list up and running in fiscal 2003, which ended Sept. 30. He outlined an aggressive time line, based on Warren’s recommendation to split the project into chunks and roll it out in phases: build and launch the consumer registry in fewer than 100 days, launch the telemarketer registration and offer the list download two months later, and begin enforcement one month after that.
Meanwhile, the FTC awarded the DNC project contract to AT&T, contingent upon receipt of funding. The performance-based contract aligned incentives with the FTC’s goals. The FTC wanted easy registration?and so did AT&T, since its fees would be based in part on the number of successful registrations.
In February 2003, Congress appropriated $18.1 million to launch and enforce the DNC Registry?including $3.5 million earmarked for the contractor in 2003, and approximately $2.5 million to cover internal IT costs to upgrade infrastructure systems and redesign the FTC’s website. On March 11, President Bush signed the Do-Not-Call Implementation Act. By the end of March, the final legislative hurdles had been cleared, releasing the funds to start the project.
