Comment from email: Comments on draft Report to the President on Federal IT Modernization

To Whom It May Concern:

Thank you for the opportunity to provide feedback on the draft Report to the President on Federal IT Modernization. I have broad and varied experience in the government IT policy arena, having served in past roles during my career in positions that include a Senior Policy Analyst for IT at the White House Office of Science and Technology Policy, as well as having served as the CIO of the National Institute of Standards and Technology and then at the U.S. Department of Commerce.

Below are a few comments on the draft Plan which I hope will be of value:

· There is a very strong emphasis on modernizing network architectures. But for many systems that are difficult to secure and expensive to maintain, the root of the problem is often not simply one of network architecture, it’s one of system architecture. There is no question that networks are important, but in many cases the shortcomings can't be addressed simply by rearchitecting networks… the applications themselves need to be rearchitected, migrated to modern technology stacks, and transitioned to run on modern infrastructure. Indeed, in many cases with legacy IT systems you can’t bring the government to the cloud without doing this. The system-level modernization focus is very much absent from this report.

· The action on page 16 regarding contracts for small agencies is very important. I’m not sure if the authors of the report are aware, but ACT-IAC has a project underway right now on this topic, and the issue of acquisitions for small agencies is one of the key points in the draft report from that project. My one comment here is that there’s a bit of a missed opportunity resulting from the IT Modernization Plan’s focus on GSA and EIS. The issue of improving shared services and economies of scale through acquisitions targeting small agencies in particular is a general problem, so there is a need to address this issue more broadly than just EIS, i.e., a recommendation that cuts across GSA schedules/GWACs to address small agency needs would provide greater benefit.

· Page 4 of the plan says that agencies “should consider ‘cut and invest’ strategies that reallocate funding from obsolete legacy systems to modern [ones]…”. Back in 2012 under then-Federal-CIO Steve VanRoekel, OMB mandated via the annual budget formulation process that agencies cut and reinvest IT spending. One can debate how much impact that ultimately had, but to the extent it did have impact, it’s because it was mandated by OMB through the annual budget process. Agencies are notoriously resistant to changing what and how they do things. Accomplishing meaningful change may take a heavier hand than just suggesting what agencies should consider doing. OMB has historically been reluctant to use budget control to drive management initiatives, despite management and budget both being part of the OMB name. OMB controls the purse strings and can be much more influential in directing how funds are spent and what they are spent on, in order accomplish the White House’s IT modernization objectives. If the authors of the report are not prepared to deliver stronger direction at this time, I think at the very least it would be worthwhile to include messaging about what will be coming down the line, by signaling intentions to be more prescriptive in direction to agencies via the 2019 budget formulation process that be kicked off in the relatively near future.

· Pages 46-51 of the report provide a summary of 44 different recommendations. A majority of them refer to

o Creating (or updating or releasing) reports/strategies/roadmaps/plans/frameworks

o Developing or revising policies and guidance

o Issuing, responding to and reviewing data calls, and

o Updating and collecting metrics.

Those things may all be important, but given how slow things have historically been to evolve in the government IT world, I think that issuing strategies/policies, sending out data calls, and collecting data is a very indirect path to real progress. It may at some point become necessary to take a heavier hand and provide stronger direction to achieve the desired results, and a set of more firmly worded and action-oriented recommendations could help set the stage for that meaningful change.

Thanks for your consideration.

Regards,

- Simon

Simon Szykman

Managing Director and Chief Technology Officer

Federal Services Division

Attain