Alan Balutis is a distinguished fellow and senior director, U. S. Public Sector, Cisco Systems.
I’ve seen a number of articles over the past few weeks on implementation of the recently-enacted Federal Information Technology and Acquisition Reform Act (FITARA). With few exceptions, the articles have contained phrases like “…start planning,” “…poised to usher in some big changes,” “waiting for guidance on how to implement,” and so on.
One CIO, speaking at an industry association event, indicated that while he’d like to have FITARA provisions in place at his department by the end of the fiscal year – or even the calendar year – “that may be too optimistic.”
So I’d like to offer some thoughts to help, before September 30 or December 31 come and go:
- FITARA was passed by both houses of Congress and signed into law by the president in December as part of the National Defense Authorization Act (PL113-291). It did not contain provisions that said it would take effect in 90-120 days, or when the Office of Management and Budget issued guidance, or when department Chief Financial Officers and/or Chief Acquisition Officers woke up and decided it would be okay to play nicely and share;
- It’s not likely to be declared unconstitutional because it affects CFO and/or CAO authorities;
- It’s mid-March. Whilst awaiting OMB guidance, it would be good to put some basics, some essentials, in place in every department and agency subject to the Act. Those “basics” might include giving the CIOs an enhanced role or greater authority in budgeting for IT, review and approval of contracts, and the selection and appraisal of component level CIOs.
- While Rep. Darrell Issa, R-Calif., has moved on due to term limitations from being Chairman of the House Oversight and Government Reform Committee, his FITARA co-sponsor, Rep. Gerald Connolly, D-Va., remains, and has pledged to be dogged in his oversight of the law’s implementation. It’s not likely that “we’re awaiting guidance from OMB” is going to be seen as a good answer at a spring oversight hearing.
- Appropriations hearings are starting in the House and the Senate on the President’s FY 2016 budget request. How will your secretary or agency head respond when asked any of the following questions: Describe the role of your CIO in the development and oversight of the IT budget for your department/agency. Describe the existing authorities, organizational structure, and reporting relationship of the CIO. Note and explain any variance from that prescribed in PL 113-291. How does your governance process allow your department/agency to terminate IT investments that are over budget, behind schedule, or failing to deliver the promised functionality? See bullet immediately before the above for an unsatisfactory response.
- Finally, I’ve seen complaints along the lines of “that would be a whole lots of contracts for the CIO to review; what a bottleneck.” How many is the CIO seeing now? What visibility exists into who is buying what, whether it’s supportive of an enterprise architecture or taking advantage of strategic sourcing opportunities, etc. If one sets a dollar threshold for the review (e.g., $500,000), expect to see lots of RFP’s or awards at $475,000. The CIO cited above suggested interesting criteria – “newer and riskier.” Good idea! How would one operationalize that?
The time to start is now. Better to seek forgiveness….
