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Executive Summary


The Departments of Commerce and Homeland Security worked jointly on this effort through three approaches by hosting two workshops, publishing two requests for comment, and initiating initiating starting an inquiry through the President's National Security Telecommunications Advisory Committee (NSTAC) with the objective of gathering with the objective of gathering to gather a broad range of input from experts and stakeholders, including private industry, academia, and civil society. These activities all contributed to the information-gathering process for the agencies developing the recommendations in this report.


Automated, distributed attacks are a global problem. The majority of the The majority of the Most of the compromised devices in recent noteworthy botnets have been geographically located outside the United States. In order to In order to To increase the resilience of the Internet and communications ecosystem against these threats, many of which originate outside the United States, we must continue to work together together with international partners.


Effective tools exist but are not widely used. While there remains room for improvement, the tools, processes, and practices required to significantly enhance the resilience of the Internet and communications ecosystem are widely available and are routinely applied in selected market sectors. However, they are not part of common practices for product development and deployment in many other sectors for a variety of reasonsa variety of reasonsmany reasons, including (but not limited to) lack of awareness, cost avoidance, insufficient technical expertiseexpertiseknowledge, and lack of market incentives.


Products should be secured during all stages of the lifecycle. Devices that are that are vulnerable at time of deployment lack facilities to patch vulnerabilities after discovery or remain in service after vendor support ends, make assembling automated and making distributed threats far too easy.


Home users and some enterprise customers are often unaware of the role their devices could play in a botnet attack and may not fully understand the merits of available available technical controls. Product developers, manufacturers, and infrastructure operators often lack the knowledge and skills necessary to deploy tools, processes, and practices that would make the ecosystem more resilient.


Market incentives should be more effectively more effectively aligned. Market incentives do not currently appear to appear to seem to align with the goal of "dramatically reducing threats perpetrated by automated and distributed attacks." Product developers, manufacturers, and vendors are more highly motivated to minimize minimize reduce cost and time to market rather than to build in security or offer efficient security updates. Market incentives must be realigned to promote a better balance between security and convenience when developing products.


Automated, distributed attacks are an ecosystem-wide challenge. No single stakeholder community can address the problem alone.


The recommended actions include activities that should be continued or expanded, in addition to new initiatives. No single investment or activity can mitigate all threats, but organized discussions and stakeholder feedback will allow us to further evaluate allow us to further evaluate let us further evaluate and prioritize prioritize focus on these activities based on their expected return on investment and ability to measurably impact measurably impact measurably affect ecosystem resilience.


There is much work left to do. However, we do not expect all actions to occur simultaneously, due to considerations such as resource constraints in the relevant stakeholder communities. In addition, some actions are already in progress, while others are dependent on are dependent on depend on outside factors. While some actions directly related to the federal government are clearly clearly appropriate for the government to lead, this model provides a way for stakeholders to collaborate with government as they move forward on those actions that are best accomplished are best accomplished are best done through private-sector leadership.


On May 11, 2017, the President issued an executive order calling for "resilience against botnets and other automated, distributed threats." These types of types of attacks have been a concern since the early days of the Internet and were a regular occurrence by the early 2000s. Automated and distributed attacks form a threat that reaches beyond any single company or sector. These threats are used for a variety of malicious activitiesa variety of malicious activitiesmany malicious activities, including distributed denial of service (DDoS) attacks that overwhelm networked resources, sending massive quantities of spam, disseminating disseminating distributing keylogger and other malware; ransomware attacks distributed by botnets that hold systems and data hostage; and computational propaganda campaigns that manipulate and intimidate communities through social media. Traditional DDoS mitigation techniques, such as network providers building in excess capacity to absorb the effects of botnets, are designed to protect against botnets of an anticipated anticipated expected size. With new botnets that capitalize on the sheer number of "Internet of Things" (IoT) devices, DDoS attacks have grown in size to more than one terabit per second, far outstripping expected size and excess capacity. As a result, recovery As a result, recovery Recovery time from these types of types of attacks may be too slow, particularly when mission-critical services are involved.


The DDoS attacks launched from the Mirai botnet in the fall of 2016, for example, reached a level of sustained traffic that overwhelmed many common DDoS mitigation tools and services, and even disrupted a Domain Name System (DNS) service that was a commonly used component component part in many DDoS mitigation strategies.13 This attack also highlighted the growing insecurities in-and threats from- consumer-grade IoT devices. As a new technology, IoT devices are often built and deployed without important security features and practices in place. While the original Mirai variant was relatively simple in that it exploited in that it exploited because it exploited weak device passwords, more sophisticated botnets have followed. For example, the Reaper botnet uses known code vulnerabilities to exploit a long list of devices, and one of the largest DDoS attacks seen to date recently exploited a newly discovered vulnerability in the relatively obscure MemCacheD software. These examples clearly clearly demonstrate demonstrate show the risks posed by botnets of this size and scope, as well as the expected innovation and increased scale and complexity of future attacks.


Approach


The Departments of Commerce and Homeland Security worked together on this effort through three approaches that had the that had the with the objective of gathering a broad range of input from experts and stakeholders, including private industry, academia, and civil society.


In July 2017, Commerce's National Institute of Standards and Technology (NIST) hosted a workshop on "Enhancing Resilience of the Internet and Communications Ecosystem." The workshop encouraged stakeholders to explore current and emerging solutions addressing automated, distributed threats in an open and transparent mannerin an open and transparent manneropenly and transparently. It attracted 150 participants from diverse stakeholder communities, who identified a broad range of coordinated actions by all stakeholders to address these threats.


As directed in Executive Order 13800, a draft report was published in January 2018, followed by a second RFC and workshop, at which time stakeholders discussed substantive public comments and next steps. These activities contributed to the information-gathering process for agencies developing the recommendations in this final report. The comments and workshop discussions will also inform many of the of the actions that will take place after this report is published.


While developing its report, the President's National Security Telecommunications Advisory Committee's (NSTAC) studied botnets, as well as forms of attacks that may be facilitated by botnets, such as DDoS attacks and vectors that could be used to create botnets (i.e., end user devices and IoT). Through its study, the NSTAC concluded that automated and distributed attacks performed using botnets threaten the security and resilience of the Internet and communications ecosystem, and in turn, in turn, the nation's critical infrastructure.



Technical Domains


Infrastructure: Current State


In the face of In the face of Faced with automated, distributed attacks, the current infrastructure underlying the digital ecosystem has demonstrated has demonstrated has shown remarkable resilience, but the increasing size and scope of attacks appear to be testing appear to be testing appear to test the limits of that resilience.


Filtering traffic as it enters and exits a network-the technique known as ingress and egress filtering-is one such tool. IP-spoofing is a common technique employed in employed in used in DDoS attacks, where the attacker fabricates the source IP address to prevent the victim from filtering bad traffic by the traffic's origin. Network providers can limit spoofing by restricting incoming traffic to that which is actually from its stated network, filtering out traffic that claims to come from outside its expected network space. Ingress filtering is acknowledged to be a longstanding best practice by the Internet Engineering Task Force (IETF) and other infrastructure-focused organizations. It can be complemented by egress filtering, in which an organization or network operator deploys filters at the edge of its network to prevent traffic that does not appear to appear to seem to originate from inside the network from exiting onto the global Internet.


Major domestic carriers implement the ingress filtering standards in at least some portion portion of their networks. However, these standards are not universally supported worldwide, or by smaller domestic infrastructure providers. Many technical and business experts have objected to proposals to apply ingress filtering higher at the level of international backbones because it would be more likely to block legitimate traffic. Egress filtering is advocated as a common security practice for enterprises but is still uncommon uncommon rare for small and medium-sized enterprises. Although not universally implemented, network ingress/egress filtering, where implemented, is effective at mitigating the class of DDoS attacks that leverage IP-source address spoofing.


Infrastructure providers and other companies offer commercial anti-DDoS services, which can play a key role in limiting the impacts of attacks against specific targets. However, not all enterprise customers purchase purchase buy the full slate of anti-DDoS services due to the expense and the complexity of integrating those services into the other components components parts of the enterprise's network. Meanwhile, attackers quickly learn to exploit holes in existing services. When confronted by attacks that rely on the sheer volume of traffic, off-premise DDoS mitigation solutions either proffer more proffer more offer more network capacity or use the shape of the network itself to limit the volume of traffic that reaches the target.


The current best practices involve employing a employing a using a hybrid approach that uses both local filtering and DDoS defense tools that increase off-premise capacity. However, implementing best practices can be expensive and difficult to manage; they also require skilled staff. These best practices are also typically built around past crises, making it difficult, for example, to argue for a large amount of a large amount of a lot of excess capacity until under attack.


Responding in a timely fashion in a timely fashion promptly requires preparation and knowledge. Given the large set of security controls needed in the modern Internet, not all staff at smaller infrastructure providers or key enterprises are aware of the benefits of filtering and other tools. Many infrastructure providers offer warnings about compromises and ongoing attacks, but if enterprises ignore those warnings, then the infrastructure provider is less likely to follow up with further warnings. Victims often struggle when encountering their first substantial attack without a response plan in place, because they depend on the very very network under attack to understand it and contact service providers for aid.


Vision for the Future of Infrastructure


Infrastructure providers of all types must develop a broad understanding of the benefits of shared defense approaches, and communities should work together to drive best-practice adoption. This work includes ubiquitous adoption of filtering at the interface with customer networks, including multi-tenant infrastructures such as cloud providers. Ideally, infrastructure providers should understand the current levels of attacks, maintain sufficient maintain sufficient maintain enough capacity to absorb realistically expected levels of malicious traffic, and communicate those capabilities to their customers. Infrastructure-provider services for DDoS mitigation should integrate with customers' existing network solutions irrespective of irrespective of despite the level of service a customer has chosen.


As new products and tools become available, players across the ecosystem should understand how their behavior can help (or hinder) their efficacy. An increasingly smart network can segment different types of traffic automatically in order in order to isolate or mitigate applications or devices that are sources and targets of attacks. Enterprises are increasingly able to are increasingly able to can increasingly address application-level attacks with appropriate appropriate tools, and the vendors of these tools should work with both customers and the relevant application vendors to make security decisions easier and more efficient.


Increased implementation of a number of a number of several existing technologies will help mitigate these attacks. At the core of the infrastructure, key players already share information about the evolving nature of threats. Many of these organizations employ experts employ experts use experts who coordinate with their peers around the globe; , in the future, , in the future, however, information sharing must expand to include smaller, less well-funded, or niche players through new automated tools and practices. Incentives could promote investment in better, more efficient detection of malicious traffic, as well as more public commitments to avoid carrying malicious traffic.



Promote global participation through enhanced stakeholder and U.S. government engagement on international policy and standards development.


The global nature of distributed threats was frequently frequently often highlighted during the process executed by Commerce and Homeland Security. Stakeholders highlighted the importance of international standards, policies, and best practices in promoting international participation and collaboration. By continuing to advocate for industry-led approaches and by actively actively participating in development of voluntary, consensus-based international standards, the federal government can contribute to pragmatic and effective outcome-based standards that meet the needs of all stakeholders. The federal government is also uniquely positioned to lead the international engagement required to establish broadly accepted policies and best practices and will enhance coordination with stakeholders on these efforts.

RESULTS

After the first decade of the FTF initiative, we estimate that, in areas where FTF worked, the prevalence of extreme poverty decreased by an average of 19 percent, the proportion of households experiencing hunger decreased by an average of 21 percent, and the prevalence of stunting among children under five decreased by an average of 26 percent. Furthermore, women Furthermore, women Women and women-owned businesses have achieved access to more than $975 million in agriculture-related financing since 2011 as a direct result of as a direct result of because of FTF's work globally. However, the combined impacts of Russia's invasion of Ukraine, COVID-19, climate change, and other conflicts are reversing many of these gains. At the time that this At the time that this When this report was drafted, FTF was continuing its work with both internal task forces and external research institutions to better understand these long-term effects.


In the interimIn the interimMeanwhile, results from FTF interagency analyses at the time highlighted a number of a number of several salient lessons to inform future FTF programming.


FTF is well positioned to counter shocks, stressors, and volatility from the COVID-19 pandemic: Annual reporting data from FY 2020 and FY 2021 demonstrates demonstrates shows FTF's ability to reach and benefit FTF benefit FTF help FTF target populations, even in the face of COVID-19 and without additional financial resources.


Investing in agriculture research yields sizable economic impacts: A meta-analysis of impact case studies of U.S. investment in international agriculture-related research demonstrates demonstrates shows the median value of economic impacts is estimated at $8.4 billion compared to a cumulative nvestment of $1.24 billion. About four-fifths of these economic benefits accrued to individuals with incomes under $5.50/day, and about 29 percent to those in extreme poverty, with incomes under $2.15/day.


Investing in capacity-building activities yields results, as in Ghana poultry farms program led by USDA: A USDA-funded impact evaluation on the poultry sector in Ghana reflects the work of two Food for Progress (FFP) projects and provides evidence of what works in capacity-building activities with farms of varying sizes and across differing components components parts of the poultry sector.


Extension services to women reduces the negative impacts of climate change on agricultural performance: The Gender Climate and Nutrition Integration Initiative (GCAN) conducted research in Tanzania, Uganda, Malawi, and Nigeria. Their results demonstrated that demonstrated that showed providing extension services to women reduces the negative impacts of climate change on agricultural performance. The study also found that securing women with either access to advisory services or control over land significantly increases agricultural income. Specifically, it concluded that: 1) if women are added as extension recipients, agricultural performance is 13 percent higher than in case of men-only beneficiaries and 2) when extension-recipient women also contribute to decision making, the negative impact of floods on crop income is reduced by 19 is reduced by 19 goes down by 19 percent. These findings add to the growing evidence on the gendered dimensions of resilience.


Continuing Impact of COVID-19 and Response Strategy

Over the course of the reporting periodOver the course of the reporting periodDuring the reporting period, as COVID-19 continued to threaten global public health, countries shifted their approach to confronting a disease that has become increasingly endemic. Just as countries were rolling back their pandemic-imposed restrictions to reduce and hopefully reverse some of the negative impacts, the Russian invasion of Ukraine limited chances of a rapid recovery, with the invasion's consequences on fertilizer availability, fuel prices, and food availability further driving food insecurity, malnutrition, and poverty globally. According to the UN's 2022 State of Food Insecurity in the World (SOFI), 828 million people were affected by hunger in 2021, which is an increase of 46 million from 2020 and an increase of 150 million from prior to prior to before the pandemic.


Additional Additional More waves of the pandemic significantly hurt USAID's ability to implement planned FTF activities, resulting in significant delays or even cancellation of planned interventions due to shifting government priorities and areas of investment. FTF responded to the COVID-19 outbreak by reprogramming and pivoting ongoing activities, embracing a significant increase in the use of in the use of in using digital platforms and tools to address COVID-19- induced restrictions on in-person gatherings.


The Agency continued to adjust programming both to expand ongoing activities and to add additional additional more services and interventions that offset the secondary effects of COVID-19. Efforts were focused on improving food security, providing agricultural subsidies, and strengthening targeted supply chains. Agriculture-led growth activities in particular in particular responded to the pandemic by pivoting around several key areas, including market expansion and diversification strategies, leveraging ICT and digital platforms to overcome movement restrictions, collaborating with local and national governments to develop COVID-19 protocols, offer guidelines, and clarify rules and regulations, and integrating programming with COVID-19 training.


FTF continued to learn from the COVID-19 response, both regarding its impacts on FTF initiatives as well as initiatives as well as initiatives and the effectiveness of programmatic pivots and reprogramming. These new global challenges further highlighted the importance of the initiative's flexibility, adaptability, and responsiveness to meet the needs of the most vulnerable populations.


ADDRESSING CLIMATE CHANGE

Beyond the Russian invasion of Ukraine and ongoing impacts of COVID-19, the world is confronting the increasingly grave challenges posed by climate change. Climate change is driving higher rates of food and water insecurity, as well as of conflict and displacement. Climate stressors, including increasing temperatures, shifting rainfall patterns, and rising sea levels, affect the livelihoods and income of farmers, herders, and smallholder producers. In turn, these In turn, these These climate stressors intensify other crises, exacerbating the effects of COVID-19 and conflict on increasing food insecurity, poverty, and malnutrition. Developing countries are experiencing a disproportionate burden of extreme weather and climate events despite having produced fewer emissions. Climate change disproportionately affects women and girls, who are often responsible for the increasingly difficult tasks of gathering and producing food, collecting water, and sourcing fuel for heating and cooking.


Recognizing the impact climate change is having on food security and the urgent need to address climate change to maintain development goals, President Joseph R. Biden announced the President's Emergency Plan for Adaptation and Resilience (PREPARE) on Nov. 1, 2021, at COP26. PREPARE activated a coordinated, whole-of-government approach, bringing together the diplomatic, development, and technical expertise expertise knowledge of the United States to help more than half a billion people in developing countries adapt to and manage the impacts of climate change by 2030.


Moving forward, helping Moving forward, helping Helping farmers adapt to climate change will continue to be central to FTF programming. In addition to the vision provided by the vision provided by the vision from the GFSS, FTF's response will be shaped by the various interagency climate strategies, including the U.S. International Climate Finance Plan and individual strategies such as USAID's Climate Strategy and MCC's Climate Commitment.


FTF COUNTRY EXPANSION

Following the updating of the GFSS in late 2021, the FTF interagency embarked upon embarked upon started a rigorous review and selection process to expand the number of FTF target countries. This process was driven by level of need, potential for agricultural-led growth, opportunities for partnership, opportunities for regional economic integration, U.S. government resource availability, and government commitment to food security investment and policy reform.


Taking these criteria into accountTaking these criteria into accountConsidering these criteria, FTF expanded its global footprint from 12 to 20 target countries. The eight new countries are: the Democratic Republic of the Congo, Liberia, Madagascar, Malawi, Mozambique, Rwanda, Tanzania, and Zambia. The next step will be for FTF target countries to develop their GFSS Country Plans. USAID developed a framework for the planning process and provided guidance to provided guidance to guided posts near the end of FY 2022. These are five- year Interagency Plans, developed and owned by interagency teams at post and coordinated by the USAID/FTF Coordinator at post. Country Plans are high-level documents that lay out programmatic priorities for FTF programming in the country.


COUNTRY OWNERSHIP

Under this renewed and expanded support, FTF continues its commitment to country ownership - that is, country governments achieving locally sustained results, mobilizing public and private investments, strengthening local capacities, and accelerating enterprise-driven development. In line with this driving philosophy, FTF supports national policy reform and implementation and partners with country governments to set their own policy and funding priorities for food security and nutrition. Areas of engagement include helping countries to adopt policies that will sustainably increase productivity and mitigate risk from emerging threats to agriculture; investing in policy research; and developing the capacity of local governments and grassroots organizations to engage in multi-sectoral "systems" analysis of key challenges in the realms of agriculture, resilience, food security, and nutrition.


In 2018, the FTF interagency developed a policy and review process for graduating target countries from "target-country status" to fulfill Section 5 (a)(16) of the GFSA. The annual review process uses quantitative and qualitative data to evaluate a target country's readiness to graduate from target-country status into a different, less resource-intensive form of partnership with the U.S. government. While FTF piloted the project in 2019, FTF suspended the process in 2020 due to the COVID-19 pandemic. The interagency will continue to monitor monitor track both the global and individual contexts of GFSS target countries to determine the appropriate the appropriate the proper time to resume target-country graduation reviews.

In January 2021, the President issued Executive Order 14005 stating that agencies should maximize the use of goods, products, and materials produced in, and services offered in, the U.S. Furthermore, agencies should promote an accountable and transparent procurement policy. However, agencies may use applicable waivers when they are unable to are unable to cannot meet this directive for reasons like nonavailability, unreasonable cost, and public interest, or if there is an urgent need in an unforeseen and exigent circumstance.

As part of an effort to update and centralize the federal government's waiver process, the executive order directed the Office of Management and Budget (OMB) to establish MIAO. Prior to Prior to Before an agency granting a waiver from domestic preference laws, in general, , in general, MIAO must review the waiver to ensure that ensure that make sure it is consistent with is consistent with follows applicable law and policy. Additionally, the executive order, among other things, , among other things, directed the General Services Administration (GSA) to develop a public website that allows interested parties to easily identify that allows interested parties to easily identify that lets interested parties easily identify proposed and approved waivers, as well as to provide contact information for each granting agency. One of MIAO's goals is to bring increased transparency to waivers to send clear demand signals to domestic producers.

The act requires agencies to submit a request to invoke a waiver to these laws to the GSA and that the GSA make the request available on or through the public website for public comment for not less than 15 days. This would give industry officials an opportunity to notify an agency that notify an agency that tell an agency their product may meet the agency's needs. The act further establishes that establishes that shows that no domestic preference waiver for the purposes of awarding for the purposes of awarding to award a contract may be granted if information about the waiver was not made available made available provided on the website or no opportunity for public comment concerning concerning about the request was granted.

The OMB requested that the GSA develop requested that the GSA develop asked for the GSA to develop the capability for agencies to report on seven types of procurement and federal financial assistance waivers to domestic preference laws.

As of June 2023, 17 of 26 agencies had active links on the madeinamerica.gov website. OMB officials stated that they expect agencies to provide a link to provide a link to give a link to the GSA once they issue a federal financial assistance waiver. Nevertheless, Nevertheless, Still, including active links to all agency websites on the madeinamerica.gov website, regardless of whether regardless of whether even if an agency has issued a waiver, would help promote the transparent reporting of federal financial assistance waivers. In the absence of In the absence of Absent active agency links, website users do not know if an agency has zero federal financial assistance waivers or if the agency is not reporting them on the website.

We also found that some agencies that reported federal financial assistance waivers on their websites had not cross-posted all the waivers on the madeinamerica.gov website. For example, the Department of Veterans Affairs had not posted two federal financial assistance waivers related to the construction of to the construction of to constructing two nursing home facilities and veteran burial needs.

GSA officials agreed that not all federal financial assistance waivers are included on madeinamerica.gov. The officials hypothesized that agencies may be unaware of their obligation obligation duty to submit them or that they feel overburdened in having to provide the information twice. Action by the OMB to provide an updated date to agencies for cross-posting all their federal financial assistance waivers to the madeinamerica.gov website would help ensure that ensure that make sure all waiver information is in one location. Without doing so, the burden is on website users to visit multiple websites to identify waiver information.

We found that the GSA used an incremental approach for providing agencies with providing agencies with giving agencies the capability to report waivers on the website. As of June 2023, agencies were able to report were able to report reported on six of the seven types of waivers identified by the OMB: three of the four types of procurement waivers and all three types of the federal financial assistance waivers.

Agencies used waivers on a range of products. More than 50 More than 50 Over 50 percent of the reported waivers were for laboratory equipment and supplies. The other waivers were for items such as medical and surgical equipment; freight containers; weapon componentscomponentsparts; and electrical components components parts such as circuit breakers. For example, Defense Logistics Agency officials said they use waivers to procure procure get shipping containers because they found that available available domestic sources are offered for an unreasonable cost.

The GSA has not yet provided agencies with has not yet provided agencies with has not yet given agencies the capability to report on the remaining waiver type the OMB identified-unreasonable cost for a procurement. According to GSA officials, the GSA has already already developed the capability and the OMB is reviewing the form that contracting officials will have to will have to must submit when reporting this type of type of waiver. The officials also stated that the OMB has not established a date established a date set a date by which this capability will be provided. Establishing a date Establishing a date Setting a date for providing agencies with providing agencies with giving agencies the capability to report on unreasonable cost for procurement waivers will help ensure that ensure that make sure the OMB prioritizes prioritizes focuses on the completion of its review. Without this capability, federal agencies cannot be transparent about their use of this type of type of waiver.

In interviews, we identified one federal financial assistance waiver from the Department of the Interior that was recorded twice on the madeinamerica.gov website. Interior officials told us that the waiver was inadvertently duplicated on the website when a grants officer received an error message while uploading the original waiver and then submitted it a second time. Department of the Interior officials notified the OMB of notified the OMB of told the OMB about the issue, but the duplicate waiver remains, and Interior officials are unable to are unable to cannot remove it. GSA officials told us that agencies do not have the capability to remove do not have the capability to remove cannot remove waivers from the site, but OMB does.

According to the Infrastructure Investment and Jobs Act, the website is required to include is required to include must include information on all waivers of and exceptions to what the statue refers to as refers to as calls "Buy American" laws. While agencies are reporting waiver information on the website, the OMB has not developed procedures to correct reporting errors.

In August 2023, OMB officials notified us that notified us that told us their actions related to the errors we found were appropriate as either the waivers that we detected were not reviewed by the OMB before they were issued-and therefore should not be included on the website-or, alternatively, , alternatively, agency officials could have made the correction themselves. The OMB has since confirmed that agencies do not have the ability to edit do not have the ability to edit cannot edit reported waivers. Furthermore, the Furthermore, the The OMB provided that OMB provided that OMB stated that the duplicate waiver we identified has been removed from the website and the process for addressing duplicate waivers has been improved. However, the OMB did not explain or provide evidence of how the process has been improved. Without procedures for correcting reporting errors, agencies' use of waivers will likely will likely will probably not be accurately represented on the website.

The Infrastructure Investment and Jobs Act requires agencies to submit a request to invoke what the statute refers to as refers to as calls a "Buy American" waiver to the GSA and that the GSA make the request available on or through the public website for public comment for not less than 15 days. The act states that no waiver for the purposes of awarding for the purposes of awarding to award a contract may be granted if information about the waiver was not made available made available provided on the website or no opportunity for public comment concerning concerning about the request was granted.

The public can provide comments on procurement waiver requests through links on the madeinamerica.gov website and on federal financial assistance waivers through links to the appropriate the appropriate the proper federal agency's website. GSA officials informed us that these waivers are posted for public comment for 15 days.

We did not identify any additional actions that need to be taken to implement this requirementimplement this requirementput this requirement into practice.

To grow and innovate, organizations have to come have to come must come up with creative ideas. At the employee level, creativity results from a combination of a combination of expertise, motivation, and thinking skills. At the team level, it results from synergy between team members, which allows the group to produce which allows the group to produce which lets the group produce something greater than the sum of its parts.


The most widely used method to spark group creativity is brainstorming, a technique ?rst introduced by Alex Osborn, a real life "Mad Man," in the 1950s. Brainstorming, which is the term that that this article will use to refer to working in a group to come up with new ideas, is based on four rules: (a) generate as many ideas as possibleas many ideas as possibleideas; (b) prioritize prioritize focus on unusual or original ideas; (c) combine and re?ne the ideas generated; and (d) abstain from criticism during the exercise. The process, which should be informal and unstructured, is based upon based upon based on two old psychological premises. First, that the mere presence of others can have motivating e?ects on an individual's performance. Second, that quantity (eventually) leads to quality.


Osborn famously submitted that submitted that argued that that brainstorming should enhance creative performance by almost 50% when compared to the performance of individuals working on their own. Yet, after six decades of scienti?c research, there is very very little evidence that group brainstorming produces more or better ideas than the same number of individuals would produce working independently. In fact, a In fact, a A great deal of evidence indicates that group brainstorming frequently that group brainstorming frequently that group brainstorming often harms creative performance, resulting in a collective performance loss that is the very very opposite of synergy.


A meta-analysis of over 800 teams demonstrated that demonstrated that showed individuals are more likely to generate original ideas if do not interact with other people during the brainstorming process. Brainstorming is particularly particularly likely to harm productivity in large teams, when teams are closely supervised, and when performance is oral rather than written. Another problem is that teams tend to give tend to give usually give up when they notice that their e?orts aren't producing very much.


But why doesn't brainstorming work? There are four explanations:


Social loa?ng: There's a tendency - also known as free riding - for people to make less of an e?ort when they are they are working in teams than alone. As with the bystander e?ect, we feel less propelled to do something when we know other people might do it.


Social anxiety: People worry about other team members' views of their ideas. This is also referred to as referred to as called evaluation apprehension. Similarly, when team members perceive that others have more expertiseexpertiseknowledge, their performance declines. This is especially problematic for introverted and less con?dent individuals.


Regression to the mean: This is the process of downward adjustment downward adjustment decrease whereby the most talented group members end up matching end up matching match the performance of their less talented counterparts. This e?ect is well known in sports - if you practice with someone less competent than you, your competence level decreases, and you sink to the mediocrity of your opponent.


Production blocking: No matter how large the group, individuals can only express a single idea at one time if they want other group members to hear them. Studies have found that the number of suggestions plateaus with more than six more than six over six or seven group members, and that the number of ideas per person declines as group size increases.


Given brainstorming's ?aws, why is the practice so widely adopted?


There are two main reasons. First, with the increased specialization of labor, organizations see that expertise expertise knowledge is distributed among their employees. If problem solving bene?ts from di?erent types of knowledge, assembling the right combination of people should, in theory, increase the amount of expertise expertise knowledge in the room and result in better solutions being proposed. In practice, howeverIn practice, howeverHowever, this approach would require careful selection selection choice of individuals and painstaking coordination of their e?orts. Second, even though groups don't generate more or better ideas, brainstorming is arguably more democratic than the alternatives, so it can enhance buy-in buy-in support and subsequent implementation of the ideas generated, no matter how good those ideas are.


Ultimately, brainstorming continues to be used because it feels intuitively advantageous advantageous useful to do so as a means of improving as a means of improving to improve creativity or output. As such, it As such, it It is one more placebo in the talent management cabinet - something that is believed to work in spite of in spite of despite the clear absence of evidence. So go ahead, schedule that brainstorming meeting. Just don't expect to accomplish very much other than making your team feel good.

WordRake is available for Word on Mac and Windows. WordRake is also available for Outlook on Windows.

WordRake System Requirements
Mac System Requirements(WordRake for Word)
  • Operating Systems: Monterey, Ventura, Sonoma, and Sequoia 
  • Applications: Microsoft/Office 365*, MS Word 2024, 2021, 2019, or 2016
Not compatible with web-only versions of Word
Windows System Requirements(WordRake for Word and/or Outlook)
  • Operating Systems: Windows 11, 10, 8, 7, Server 2022, Server 2019, Server 2016
  • Applications: Microsoft/Office 365*, MS Word and/or Outlook 2024, 2021, 2019, 2016, and 2013 
*Not compatible with web-only versions of Microsoft/Office 365

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