Before commenting on the CCAC Blueprint Report, I would like to note that the report has not been formally published by the U.S. Mint. It appears that the report was sent via email to a number of people who requested a copy. When I received a copy, I posted it here for the public to see. It appears as if the U.S. Mint takes an arms-length approach to the CCAC with regard to its support which shows in the lack of public information disseminated about the CCAC. While I appreciate the U.S. Mint Public Affairs Office sending a copy of this report, they should be more proactive in providing information about the CCAC to the public.

Also, it is not known whether the CCAC is accepting comments about the report. Page iii indicates that this is a final report and was transmitted to the Secretary of the Treasury. This is a shame since the document should clearly have been reviewed by others before its transmittal. While they could reject comments, accepting reviews from another perspective may have been helpful to tighten their sound recommendations.

Since they have not indicated whether they are accepting public comment, I am providing my commentary in this blog post. I will be contacting those CCAC members whose email address I know and point them to this commentary. I ask that they share this with the other CCAC members. They are invited to provide commentary to this blog post or contact me privately for further clarification. I am willing to help in anyway I can.

As with all my blog posts, comments from my readers are always appreciated!

In 2007, speaking before the delegates at the International Art Medal Federation (Fédération Internationale de la Médaille d’Art or FIDEM) in Colorado Springs, then U.S. Mint Director Edmund Moy announced his vision “to spark a neo-renaissance for coin design and achieve a new level of design excellence.” But during design reviews by the United States Commission of Fine Arts and Citizens Coinage Advisory Committee during 2010, it was noted that the U.S. Mint was falling short of Director Moy’s goals.

In response, the CCAC formed the Subcommittee on Design Excellence to address the design quality issues. The subcommittee was chaired by CCAC Chairman and included CCAC members Roger W. Burdette, Mitch Sanders, Donald Scarinci, and Heidi Wastweet.

The subcommittee’s work is document in the report, A Blueprint for Advancing Artistic Creativity and Excellence in United States Coins and Medals that was approved by the CCAC as their official position on January 19, 2011. This 62-page report, of which the first 22-pages is the report with the balanced supporting Appendices, describes the reason the CCAC felt it needed to write this report, their findings investigating the issues, and recommendations for improvement.

While reading the documented investigation into the process’s of the U.S. Mint, it reads like the U.S. Mint is a typical federal government agency whose entrenched processes created many years ago are continued today because “that’s the way we’ve always done it.” The biggest flaw is that the Sales and Marketing Department is in charge of the coin design process. While this might have made sense many years ago, as the report points out, there is a conflict between the goals of the Sales and Marketing Department and the artistic nature of the coins produced by the U.S. Mint. Further complicating the situation is that the Sales and Marketing Department does not include someone with an artistic background overseeing the decisions.

Another part of the U.S. Mint bureaucracy is the Design Working Group (DWG) whose function was to coordinate manufacturing time tables and interface with stakeholder groups. Since the creation of the Artistic Infusion Program (AIP), the DWG has managed those artists and coordinating with the U.S. Mint Sculptor-Engravers. However, the report notes that the DWG does not include anyone with an artistic background.

CCAC’s Recommendation #1
The CCAC’s first recommendation is to remove the Sales and Marketing Department from the design process and abolish the DWG. Rather than these groups controlling the artistic design process, the report recommends that the U.S. Mint forms an Coin and Medal Design Department (CMDD) whose Division Chief has an artistic and management background. The CMDD would include all artists and include the management of AIP artists, management of stakeholder relations, and management of the die creating functions (Dies, Tools and Digital Control). While some may see this as the proverbial “shuffling of deck chairs,” it makes sense for the U.S. Mint to combine these functions under one manager and eliminate potential interdepartmental issues that occur within government agencies.

Although this is a sound recommendation, it appears that the recommendation continues to promote a bureaucratic approach for this new organization by creating three Associate Division Chiefs (ADC) to manage each of the major functions. While the ADC of Designing and Engraving should be the “Chief Engraver of the United States Mint” and the ADC of Dies, Tools and Digital Control should be a technical oriented person, it is questionable that the ADC for Stakeholder Relations is necessary. All the report says about the current stakeholder relations is that it is part of the Sales and Marketing Department without describing the basic job function and the level of effort to perform that job. Unless the CCAC and U.S. Mint can justify that the level of effort would require a full-time ADC, it would seem that the external contact and the person best suited to for this function would be the CMDD Division Chief. In fact, it should be recommended that this function be taken on by the CMDD Division Chief until such time as the level of effort is too great for this person to handle.

The report recommends that the DWC be replace by an interdisciplinary group to coordinate artistic and manufacturing schedules, a group referred to as the Timetable Task Force (TTF). According to the report, the TTP would be made up of representatives of Office of Chief Counsel, Sales and Marketing Department, and the Manufacturing Department and “should perform the scheduling function and advise the Art Director on historical, legal and technical matters.” This is absolutely the wrong approach to “fixing” what is wrong with the design issues. The design process already has too many inputs into the process. In order to provide more artistic freedom for the artists to create good designs, it is highly advisable to remove as many obstacles as possible. All design decisions including consulting with outside stakeholders (including the Office of Chief Counsel) should remain within the CMDD and managed by the Division Chief and Chief Engraver. The TTF should only concern itself with the timetable necessary to that will take the law passed by congress and have it manufactured, marketed, and sold to the public. The TTF should be limited to one representative of each department with the authority to speak for that department. Having worked in a federal government environment, having a large group of stakeholders meet is unwieldily and leads to a bad decision making process.

CCAC’s Recommendation #2
The CCAC’s recommendation to provide more artistic freedom for the U.S. Mint Sculpture-Engravers and improve the requests for proposals (RFP, the “call for artists”) for the Artistic Infusion Program is a necessary change the U.S. Mint needs to implement. The report rightly calls for the end of the practice U.S. Mint artists call “trace and bake” where artists are given materials to reproduce rather than rely on the artists talents.

It was surprising to learn that the U.S. Mint artists are not offered addition professional training, the opportunity to attend seminars or workshops, and are not allowed to attend artistic exhibits of coin and medallic art. The CCAC recommends that this change to allow U.S. Mint artists to advance themselves and promote their fine work. Funding must be set aside to support continuing education and promotion of the U.S. Mint’s talented artists. However, the recommendation does not include members of the AIP. Although the AIP artists are technically contract workers to the U.S. Mint, they should be afforded some opportunities to attend seminars and workshops that would benefit their work as part of the Artistic Infusion Program. While these opportunities would be offered on a lower scale than those offered to the full-time Sculpture-Engravers, it would benefit the U.S. Mint for these artists to be able to participate.

Although left out of the Summary section (Section 5), the recommendation for changes in working conditions in Section 4.3 is a key issue for artistic creativity. While the U.S. Mint should provide better working conditions by removing the cubicle farm and creating a studio-like design, the CCAC should have recommended that artists be given the opportunity to participate in a telework program. Missing from the report’s recommendation is how the U.S. Mint would implement “Telework Enhancement Act of 2010” (Public Law 111-292; 124 STAT. 3165) the could help improve the working environment of the U.S. Mint’s artists. Signed by President Obama on December 9, 2010—prior to the publishing of this report—the law calls for agency to “establish a policy under which eligible employees of the agency may be authorized to telework” within 180 days of enactment. The CCAC’s report should recommend that the U.S. Mint Sculptor-Engravers be allowed to telework in their own studios away from their current office at the Philadelphia Mint with a requirement to work at the Philadelphia facility for a certain amount of time to ensure appropriate collaboration. Not only would this provide the artists an opportunity to work comfortably, but it would help the U.S. Mint comply with the new law and begin compliance with the Presidential Memorandum “Accountable Government Initiative” of September 14, 2010.

CCAC’s Recommendation #3
The CCAC recommends that they and the CFA be more integral in the design and review process. After commenting on reducing the bureaucracy in Recommendation #1 (above), this recommendation by the CCAC will only increase it in the name of alleged oversight. First, the CCAC does not say how it will change its process in order to work within the schedule the U.S. Mint might require. Instead, the CCAC recommends that “[production] timelines should be designed to recognize the role of these groups.” Unfortunately, the CCAC does not recognize the will of congress that could force a change in normal scheduling practices by passing a coin-related bill the same year as the coin is produced. While this situation does not effect current production, it has happened in the past and is not recognized by the CCAC.

Routinely, the CCAC decries the U.S. Mint’s scheduling and how designs are thrusted upon them for their approval in order to meet production requirements. What the CCAC has not considered is that their own schedule of monthly meetings that may not fit an active manufacturing process. While all the employees are working daily to manufacture the coins and medals, the CCAC meets once per month in a scheduled three-hour morning session to conduct its business. Waiting for the CCAC to meet in order to gain their concurrence has to wreak havoc with production scheduling. It places the CCAC on the schedule’s critical path of the U.S. Mint’s design and manufacturing process. The CCAC should not be on the critical path. If the report is to hold the U.S. Mint accountable for improving its process, the CCAC must consider their own process improvement to support the changes. As part of these reforms, the CCAC should support Telework Enhancement Act of 2010 and consider holding virtual meetings as necessary to aid the U.S. Mint in its production process. In fact, as a public committee, the CCAC should extend their use of this technology to make the meetings and discussions more accessible to the public rather than requiring interested parties to travel the the U.S. Mint’s headquarters in Washington, D.C.

Further, the CCAC does not include verification from the CFA that they would be willing to participate in this process or has the flexibility to work within the U.S. Mint’s schedule for manufacturing the coin or medal. It should not the CCAC’s place to volunteer the CFA’s time and effort without their concurrence.

Second, the CCAC recommendation asserts itself too far into the design process. For most of the commemorative and bullion designs, the narrative is provided in the law passed by congress. Thus, there is no reason for the CCAC or CFA to be involved in those discussion. Where a narrative is necessary, it should be held with the stakeholders are previously recommended. Inserting the CCAC and CFA will add to bureaucratic process. Once the narrative is created, having the designs reviewed by the CCAC and CFA should remain part of the process. Reviews should be in the form of recommendations and not mandates. Artists should have the ability to reject recommendations for artistic (fitting the narrative) or technical reasons (ability to strike the coin properly) remembering that the law says the final decision rests with the Secretary of the Treasury—and by extension the Director of the U.S. Mint. However, as it was stated above, the CCAC and CFA must become more flexible in their scheduling so as to support the timeline requirements of the U.S. Mint.

The goal of this recommendation is to reduce the bureaucracy giving the artists freedom to be creative and not change the bureaucratic structure.

Additional Recommendation
It is unfortunate the the CCAC report does not properly address the bureaucratic nature of the design process and seek to reduce it or its impact on coin designs. While the above commentary attempts to reduce the bureaucracy there is one aspect of the coin design process that the CCAC does not discuss: why does it require two external committees to review coin and metal designs?

The CFA was established in 1910 to give expert advice to the “Federal and District of Columbia governments on matters of design and aesthetics, as they affect the Federal interest and preserve the dignity of the nation’s capital.” Their work consists of monitoring architectural development to historic buildings, statues, monuments, memorials, and other artwork in the public spaces in and around Washington, D.C. They also provide “advice to the U.S. Mint on the design of coins and medals.” In fact, their review of the coin and medal design is their only review that does not include physical development in Washington, D.C.

The CCAC was established in 2003 to provide a dedicated committee review all coin and medal designs replacing the Citizens Commemorative Coinage Advisory Committee, which only reviewed commemorative coins.

It seems that if both committees are doing the same work, it makes sense to consolidate the work into one committee. Since the CCAC is dedicated to advising the Secretary of the Treasury on coin and medal design and is only a part of what the CFA does, it makes sense to eliminate the review of coin and medal design from the CFA’s jurisdiction. This consolidation would also comply with the president’s Accountable Government Initiative.

Eliminating the CFA’s role in coin and medal design should not require an act of congress. The law that governs the CFA (40 U.S.C. §§ 9101–9104) does not mention coin and medal design as part of its jurisdiction. However, the Code of Federal Regulations (CFR) does include coin and medal design under the section for Statutory and Executive Order Authority (45 C.F.R. § 2101.1(d)). Since coin and medal design review is not a statutory requirement for the CFA, it should be recommended that the Secretary of the Treasury request that the President issue an Executive Order to remove this requirement from the CFR as part of the Accountable Government Initiative and reduce the bureaucracy.

A Final Thought
I have never hidden the fact that my professional experiences involve working with the federal government. Although I have never worked with the U.S. Mint, I am familiar with the bureaucracy of other bureaus within the Department of the Treasury. Using my understanding of the bureaucratic nature of these agencies and my background in public policy, I hope the CCAC will consider my recommendations to help improve the subcommittee’s report so that they reach their goal of improving coin and medal design at the U.S. Mint.

Pin It on Pinterest

%d bloggers like this: