The Federal Information Technology Acquisition Reform Act (FITARA) is getting a lot of attention since OMB’s implementation guidance was released for public comment. OMB set a deadline of May 30, 2015 for comments, but strongly encouraged interested parties who believe they have substantive comments to get them in by this Friday – May 15.
So is FITARA worth all the hype? Will it make a difference? If so, why? After all, the Clinger-Cohen Act was passed in 1996 and many would argue it did not have the impact its supporters envisioned.
FITARA is different and I believe it has the potential to fundamentally change how IT is bought and used in government. It will change the role of the Chief Information Officer and the Chief Financial Officer and may improve partnering between those two and the Chief Human Capital and Chief Acquisition Officers. The Office of Management and Budget learned a lot from the government’s experience since Clinger-Cohen was passed. Let’s be honest – Clinger-Cohen was implemented in the standard bureaucratic way with no teeth. It made changes, but fell far short of what was needed. OMB clearly was determined to implement FITARA in a new and far more effective manner.
They started by listening to experts in government and industry. They sought out people who knew what happened with Clinger-Cohen and other reform efforts. They asked what worked and what did not work, and why. Then they crafted draft guidance that was anything but wishy-washy. It set clear requirements that agencies could not dance around. They defined a clear and unambiguous role for the CIO in the IT budget and program planning processes, including a requirement that the agency certify the CIO reviewed and approves the major IT investments portion of budget requests. They clearly state “The CIO defines the development processes, milestones, review gates, and the overall policies for all capital planning and project management and reporting for IT resources.” They carved out a role for the CIO in IT acquisition as well, saying “Agencies shall not approve an acquisition strategy or acquisition plan (as described in FAR Part 7)21 or interagency agreement (such as those used to support purchases through another agency) that includes IT without review and approval by the agency CIO.”
They did not stop there. The draft guidance includes a substantial role for Departmental CIOs in the selection of bureau/component CIOs, saying “The CIO shall be involved in the recruitment and shall approve the selection of any new bureau CIO.” Once bureau CIOs are on board, the guidance requires that “The CHCO and CIO shall jointly establish an agency-wide critical element (or elements) included in all bureau CIOs’ performance evaluations” and “The [agency] CIO must identify “key bureau CIOs” and provide input to the rating official for this critical element(s) for at least all “key bureau CIOs” at the time of the initial summary rating and for any required progress reviews. The rating official will consider the input from the [agency] CIO when determining the initial summary rating and discusses it with the bureau CIO during progress reviews.”
Recognizing the critical role of talent management in any organization and the challenges the government faces in maintaining a skilled IT workforce, OMB included a section on the IT workforce. They say “The CIO and CHCO will develop a set of competency requirements for IT staff, including IT leadership positions, and develop and maintain a current workforce planning process to ensure the department/agency can (a) anticipate and respond to changing mission requirements. (b) maintain workforce skills in a rapidly developing IT environment, and (c) recruit and retain the IT talent needed to accomplish the mission.” They go on to require that “the CIO shall have direct access to the agency head (i.e., the Secretary, or Deputy Secretary serving on the Secretary’s behalf) regarding programs that include information technology.”
OMB’s initial draft of FITARA guidance survived the interagency review process remarkably intact. The version that is out for comments now is in many respects a model for how policy guidance should be developed. OMB Deputy Director for Management Beth Cobert, CIO Tony Scott, and E-Government chief Lisa Schlosser should be commended for producing a public policy document that will make a difference rather than just answering the mail.
How big a difference will it make? Given the authority it gives to CIOs, the difference may be surprising to a lot of people. It clearly defines the role of the CIO and assures s/he will have the authority to do the job. Whether you think biblically (“For unto whomsoever much is given, of him shall be much required”) or like Spiderman (“With great power comes great responsibility”), the authority granted to CIOs by FITARA and OMB could be a game-changer for many CIOs.
CIOs who are highly capable, but may have been struggling with the bureaucracy and its unwillingness to change, may find they have new weapons and tools to get their jobs done. They can drive budgets (the mother’s milk of Washington, DC), force changes in under-performing programs, hire the right leaders for bureau/component CIO roles, and if necessary, kill programs. CIOs who are less capable may find themselves exposed. Rather than being able to blame others for their shortcomings, they may find themselves with no excuse for their performance. They will have the tools, but if they do not know how to use them, they may fail quickly.
That is not a bad thing. FITARA may very well generate some turnover in CIO roles and allow Departments to get the right talent in the jobs. OMB’s guidance, wisely developed with the intent of making a real and lasting difference, is a great start that should have a lasting impact. This is definitely no snooze – it is a big deal.