FOIA Ombuds Observer, No. 2023-01

The Office of Government Information Services (OGIS) offers dispute resolution services to Freedom of Information Act (FOIA) requesters and agencies. This function allows OGIS to observe and examine the interactions between requesters and agencies across the Federal government, and note common questions and issues that arise in the FOIA process. The FOIA Ombuds Observer addresses questions and issues frequently seen in our individual cases. Our goal is to increase efficiency and transparency in the FOIA process.

Decommissioning of FOIAonline

May 19, 2023
No. 2023-01

Since the Environmental Protection Agency (EPA) announced in November 2021 the decommissioning of FOIAonline effective September 30, 2023, the Office of Government Information Services (OGIS) has heard a number of comments and inquiries regarding this change. Questions have centered around  what system or systems will replace FOIAonline for accepting and tracking Freedom of Information Act (FOIA) and Privacy Act requests and appeals, and providing a centralized FOIA repository for released records. (Federal procurement rules strictly prohibit communicating about that process until a contract has been awarded to a particular vendor.)

History of FOIAonline

Originally conceived in 2010 and built on the regulations.gov platform by EPA, FOIAonline was launched in 2012 with the goal of improving the requester experience and saving taxpayers money by sharing agency resources. Initially, six federal agencies — EPA, the National Archives and Records Administration; the Departments of Commerce and the Treasury; the Federal Labor Relations Authority; and the Merit Systems Protection Board, and later, the Department of Justice — came together to develop a multi-agency web-application system. The system allowed the public to make electronic requests for records from the multiple participating federal agencies. For many partner agencies, FOIAonline was a case management system. At the time of its development, FOIAonline filled a void in the public and private sectors.

Participation grew to 22 large and medium-sized federal agencies that used FOIAonline as a platform for requesting records and managing the processing of those records. By fiscal year (FY) 2021, there were 20 agencies using FOIAonline; those 20 agencies together processed more than 162,000 FOIA requests, or 19.4 percent of all FOIA requests processed by federal agencies that year. Since five agencies have left FOIAonline, the remaining 15FOIAonline agencies processed nearly 47,000 FOIA requests in FY 2022, or 5.3 percent of the all requests processed governmentwide. 

For over a decade, EPA managed the system for its partner agencies; however, agencies began to ask for more and more customizations to the platform, which caused EPA to focus on updates rather than upgrades to the system. FOIAonline customizations for individual partner agencies  led to technical challenges for EPA. What began as a single integrated and shared system became, at its peak, 22 different systems, each with its own maintenance challenges. Because of these changes, the system lacked a universal workflow, and the costs of maintenance for EPA increased all while creating glitches that affect performance. The FOIAonline application, from EPA’s perspective, turned into a situation in which everyone owned it and no one owned it. At the same time, over the past decade, significant growth has occurred in the private sector, with multiple software vendors now offering robust off-the-shelf FOIA case management systems. Those systems did not exist in FOIAonline’s early days. 

Given the expense of maintaining FOIAonline, and the current availability of commercial off-the-shelf and customizable software, EPA determined that maintaining FOIAonline was no longer a justifiable use of government resources. Therefore, EPA, in consultation with the Federal Chief Information Officers Council, decided to decommission the web application as of September 30, 2023, and announced that decision to partner agencies in November 2021.

Next Steps 

EPA is helping  the remaining agency partners in sunsetting their use of FOIAonline and is offering continuous support as partners transition away from FOIAonline to new case management systems. The last day FOIAonline can be accessed by the public is September 30, 2023. Partner agencies with active requests as of that date will have access to FOIAonline until the requests are migrated to new platforms or are closed. 

For agency FOIAonline partners, the EPA has held ongoing meetings detailing the decommissioning process so agencies could identify a replacement case management system. Partner agencies highlighted areas where support was needed, and the EPA has hosted vendor demonstrations, held one-on-one meetings with partners, and responded to ongoing communications to aid in the transition process. For FOIAonline partners that have not yet transitioned to a new platform, the data in FOIAonline will still be accessible until it is migrated to the partner agency’s new case management system. Agencies must grant authority to FOIAonline’s engineers to migrate the data, including open cases. Any remaining data is protected and secure until the technological dismantling of FOIAonline ends. 

As of May 3, 2023, 14 agency partners are still using FOIAonline. As of March 30, 2023, 10 of the 20 partners had awarded contracts to new vendors to begin the process of migrating their case management systems by September 30, 2023. The remaining partner agencies are in the procurement and acquisition phase of identifying a new case management system.