If there are any questions about the Office of Management and Budget’s commitment to implementing the Data Accountability and Transparency Act (DATA Act), then you haven’t read the proposed updates to Circular A-11 guidance.
I know what an exciting life I lead to have the joy of reading financial management regulations.
But OMB’s plans for major changes to A-11 based on requirements in the month-old law will impact everyone from financial managers to acquisition workers to IT staff.
In a CFO Council management alert outlining the requirements under the DATA Act and a draft document detailing A-11 changes obtained by Federal News Radio, OMB lays out a timeline that focuses on a series of steps that will get agencies toward full implementation.
First off, Congress readily admits it’s asking the administration to implement a complex set of changes without any new funding. That’s why lawmakers gave civilian agencies three years and the Defense Department five years to implement the DATA Act. So OMB’s plans for A-11 recognizes the law’s challenges.
“Carrying out the DATA Act’s program activity reporting requires participation among accounting, budget formulation, and budget execution experts at the agencies; OMB examining divisions and other parts of OMB; and the Treasury Department, which will ultimately post these data on the USA Spending website,” the draft A-11 guidance stated. “This paper will use OMB’s SF 133 Report on Budget Execution and Budgetary Resources as a common starting point for discussion. The SF 133 provides a solid foundation to respond to two requirements in the DATA Act: Reporting all data, governmentwide, and reporting accurate data.”
A couple of things jump out to me about the proposed A-11 changes starting with OMB’s recommendation not to immediately implement a key section of the DATA Act.
OMB has recommended postponing the requirement to report programs by object class. In the current A-11 guidance, OMB defines object classes as categories in a classification system that presents obligations by the items or services purchased by the federal government. These are the major object classes: Personnel compensation and benefits; Contractual services and supplies; Acquisition of assets; Grants and fixed charges; Other.
OMB stated that past efforts to report programs by object class haven’t been successful.
“The legal and policy framework underlying object class data is scant by comparison. For instance, OMB guidance on funds control does not apply to object class,” the document stated. “The rule (Federal Financial Management Improvement Act) that agency systems adhere to the United States Standard General Ledger at the transaction level does not apply to object class. Internal control processes at agencies may cover object class data but would not be applied with the same scrutiny as they are to the data that underlie DATA Act programs. Object class data are only reported to OMB once a year by budget account, which is aggregated, while data underlying DATA Act programs are reported through highly structured systems seven (or more) times a year. Further, OMB uses a limited number of edit checks to validate the consistency of object class data even though OMB and Treasury use scores of edit checks to validate accuracy and consistency of data that underlie DATA Act programs.”
OMB’s chief concern is around the infrastructure to support consistent and accurate reporting of object class data. These include agency financial management software, internal controls and even a central collection system to ensure data consistency and quality.
“While the DATA Act requires reporting by both DATA Act programs and object class, at the outset (several years) we expect a significant potential for quality differences between the data sets,” the A-11 paper stated. “As combining the higher quality data (DATA Act program) and the lesser quality (object class) may lead stakeholders to challenge the quality of both data sets, we conclude that postponing collection and reporting of program data by object class is the most prudent course to follow at this time.”
But OMB is more confident agencies can post to USASpending.gov object class data by outlays and obligations-meaning money in and money out.
“In fulfilling this requirement, OMB plans to leverage existing guidance and reporting processes to the maximum degree practical,” the draft A-11 changes document stated. “As different agencies will face different implementation challenges, OMB will use a phased implementation strategy and will for a limited time allow agencies to use one of two reporting formats (the easier format cannot be quality checked as well as the other format). The duration of using the easier format will be evaluated on a case-by-case basis.”
The first major deadline is March 2015 when agencies must provide OMB with a plan describing how they will report object class obligations in October 2015, and how they will report both obligations and disbursements by object class in October 2016.
Other dates agencies need to look out for:
By July 1 — OMB will issue detailed guidance for agencies to use in preparing a proposed list of DATA Act programs. The guidance will include a template that shows each agency’s unexpired Treasury Appropriation Fund Symbols (TAFSs), Category B projects and program reporting categories. Agencies will use the template to identify proposed DATA Act programs.
By Aug. 1 — Agencies will complete and return to OMB the templates for 10-20 of their TAFS’s as a “trial run” before completing the templates for at least one-third of their TAFS’s no later than Aug. 15.
Summer 2015 — MB will issue guidance on how agencies will report information on DATA Act programs in 2016. The guidance will cover apportionments, particularly program reporting categories, and agency reporting to the Treasury Governmentwide Treasury Account Symbol (GTAS) system.
August 2015-September 2016 — Agencies (and OMB) will follow new guidance for reporting DATA Act programs to GTAS starting in January 2016. “We expect operational issues will arise, and that agencies, OMB and Treasury will need to develop and implement solutions to resolve these issues.”
Summer 2016 — OMB revises guidance from summer 2015 on how agencies will report information on DATA Act programs in 2017. The new guidance will be informed by lessons learned from reporting that takes place starting in January 2016.
IT, acquisition A-11 changes
There are a couple of other interesting non-DATA Act related changes in the proposed A- 11 updates.
First off, OMB seems to be getting rid of the “Exhibit 53 and 300″ monikers for federal IT spending.
This change isn’t a huge deal in the overall scheme of things, but it does signal a change in the way the federal community commonly refers to these important information sources. 53s and 300s were numbers with meaning similar to the way baseball fanatics refer to ERA or OBP or slugging average with reverence.
The more important potential change comes from the requirement for agencies to provide details on the amounts and types of contract support anticipated for each IT investment supported by a major IT investment business case for 2016.
“The forecast will help to increase the management and efficiency of agency programs and should include: A description of the amount and type of anticipated contractor support and identify any new agency contracts anticipated that may potentially duplicate the scope of existing Federal Strategic Sourcing Initiative solutions or efforts underway by the Strategic Sourcing Leadership Council,” the document stated.
This clearly shows OMB is not letting up on strategic sourcing despite repeated challenges in court and with the Government Accountability Office. It also signals a strategic sourcing move into IT services — think of how the new OASIS contracts the General Services Administration recently awarded will come into play. If GSA saw a battle from office supplies contractors, the IT community is much better organized and lobbied up for a fight so it will be an interesting year to see how far OMB goes with this concept.
Finally, the draft A-11 addressed sequestration and how agencies should plan for it in 2016 and beyond.
“[T]he new section provides specific guidance for a variety of account types, including those with changes to mandatory programs in appropriations bills, those funded by fees, and those with legislation that affects the amount of resources after a sequestration occurs,” the draft document stated. “While sequestration permanently cancels most budgetary resources, the new section also provides guidance on the subset of amounts that are temporarily reduced and explains what happens to those resources in the year after the sequestration. Lastly, the chapter directs agencies to record their decisions to assist in future planning and execution.”
IT reform bill to get day in Senate, finally
After several hearings, the Senate Homeland Security and Governmental Affairs Committee finally is weighing on federal IT reform. Sens. Tom Carper (D-Del.) and Tom Coburn (R-Okla.), chairman and ranking member of the committee, respectively, are scheduled to mark up several bills on Wednesday, including the House version of the Federal IT Reform Act (FITARA).
So what will the Senate’s version of FITARA look like? How will it compare to the House’s? As of now, your guess is as good as mine. But I think there are a few items we can deduce from the recent hearings.
Senate lawmakers are expected to offer up an amendment in the nature of a substitute or some other arcane procedural motion to take the House bill and put their own stamp on it.
Senate committee members have focused their hearings on the IT workforce and IT project management as well as CIO authorities, the IT Dashboard and data centers consolidation have come up repeatedly.
In fact, a committee aide said those areas will be a part of the bill. The aide said the version of FITARA also likely will seek to institutionalize the PortfolioStat process and bring parts of the data center consolidation bill the committee passed last year.
The Senate’s decision to markup FITARA comes just days after Federal CIO Steve VanRoekel said he didn’t think IT reform bill was necessarily needed.
In a Federal News Radio online chat on Thursday, VanRoekel said the current version of FITARA has the right themes, but more is needed.
“[W]e need an approach that encompasses good management, good incentives, works with both the appropriations side as well as the authorizing side of the work we do and involves all the offices in the C- suite, not just the CIO, to focus on mission outcomes,” he wrote during the Q&A. “As I said in the interview, I look forward to working with Congress on this very important issue.”
Aside from FITARA, the committee also will introduce and mark up an update to the Federal Information Security Management Act (FISMA).
The committee initially started to consider a FISMA update as far back as 2008 when Carper introduced a revised bill. That didn’t get any traction and tried again in 2011, but got too made little progress as the focus was on a more comprehensive cybersecurity bill.
The House passed its version of a FISMA update April 2013. Among the areas the Federal Information Security Amendments Act of 2012 did was to reestablish OMB’s role — as opposed to the Homeland Security Department’s — in developing and overseeing agency cybersecurity guidance.
The committee plans to mark up several other bills, including the National Cybersecurity and Communication Integration Center Act of 2014, the Conference Accountability Act of 2014 and the Preventing Conflicts of Interest with Contractors Act, which focuses almost solely on vendors’ role with security clearances.
CIOs go to camp
While there was no swimming, camp fires with S’Mores or Color War, senior IT managers from large and small agencies alike did enjoy two days of collegial education at the Transportation Department headquarters in Washington.
Participants in the two-day event tell me the goal of OMB and the CIO Council was to reemphasize priorities and the second term management agenda as well as hear from CIOs and their staffs about challenges and concerns.
OMB leaders such as Beth Cobert, the deputy director for Management, highlighted the key parts of the management agenda, while Michael Daniel, the White House cybersecurity coordinator, offered the latest on the cross-agency cyber goals and GSA administrator Dan Tangherlini and DHS’ Andy Ozment brought their unique perspectives on change and cybersecurity, respectively.
One CIO tells me there was a lot of emphasis on PortfolioStat and controlling out- of-control spending.
“The big takeaway was for CIOs to take smart risks, and if you are going to fail, fail fast and small,” said the CIO, who requested anonymity in order to speak more candidly about the event. “They also emphasized that we can deliver effective systems and we can surprise our customers.”
Another attendee said it was good to bring everyone together, but there wasn’t really anything new from the speakers.
A third attendee had a similar take that there wasn’t a lot of new information but it was good to bring everyone together.
The third government source said the breakout session led by GSA CIO Sonny Hashmi was one of the better ones, because it provided the type of best practices that need to be shared more widely and duplicated across government.
“At the end of the day, I wanted to get that tool GSA was using,” the executive said. “I went up to another CIO and asked him to talk to our folks, especially at the bureau levels, about their experiences and challenges.”
Overall, the source said the two-day event had more of an academic feel rather than one where the emphasis was on getting things done.
“My biggest takeaway was you have to have working partnerships with the other CXOs because absent that, you will have uphill challenge to get anything done,” the source said.
“Takeaway for the day “don’t play with dead snakes” via Karen Evans #AcceptDecisions #CIOBootCamp,” from Greg Doan of the Energy Department.
“The #CIO role should be CIO*2. Chief Information Officer and Collaborate & Innovate Officer. #collaboration is the final topic #CIOBootCamp,” from Richard Young of DHS.
“@WhiteHouse New Media Director: Engage stakeholders to make sure they know that new technologies warrant new process changes. #CIOBootCamp,” from Alissa Johnson, White House deputy CIO.
Continuous evaluation timeline
There was a lot of focus this week on the size of the contractor workforce in the intelligence community. But this little newsworthy tidbit seemed to slip out during the Senate Homeland Security and Governmental Affairs Committee hearing Wednesday.
Stephanie O’Sullivan, the principal deputy director of National Intelligence, told committee members the continuous evaluation program of employees with secret or top secret clearances should reach initial operating capability by the end of this year.
She continued she expects “5 percent of our TS/SCI employees cleared covered by continuous evaluation looks going into 2016.”
The Obama administration has called on the Office of the Director of National Intelligence to expand the initial continuous-evaluation capabilities developed by DoD to 100,000 of the “most sensitive” top-secret clearance holders across government by this September. The administration aims to continue expanding coverage over the next few years until it reaches all 1 million top-secret clearance holders. But that’s not scheduled to happen until 2017.
It’s unclear when the system could be implemented for all 5 million clearance holders.
The move to continuous evaluation comes after high-profile incidents such as the Edward Snowden leak and the Navy Yard shootings.
O’Sullivan said the Director of National Intelligence James Clapper sent out a letter in October telling managers to take a “risk-based approach to the reinvestigation, so that we make sure that those at highest risk or who have the most sensitive access are investigated more frequently.”
She also confirmed the intelligence community is doing random audits of employees on their IT systems. But O’Sullivan didn’t offer any details about what that means, and the committee members didn’t follow up in the open session asking for more details.
IT Job of the Week:
Do you want to take over one of the problem-child IT programs in government? Well, the DHS Immigration and Customs Enforcement has the job for you. ICE is hiring a new CIO where for no more than $181,000 a year you could be in charge of the TECS modernization program.
ICE decided in February that a central element of its approach to TECS over the last six years was unworkable. The agency spent $64 million on developing a custom-built system.
This job posting also begs the question what happened to Kevin Kern, which the agency announced as its next CIO in May. Kern still is listed on the ICE website as its CIO.
Emails to ICE seeking comment or explanation were not immediately returned.