OMB HOME • ABOUT THE WHITE HOUSE
OFFICE
OF MANAGEMENT AND BUDGET
Management
of Federal Information Resources
AGENCY:
Office of Management and Budget, Executive Office of the President
ACTION:
Revision of OMB Circular No. A-130, Transmittal No. 4.
SUMMARY:
The Office of Management and Budget issues a revision to Circular
No. A-130, "Management of Federal Information Resources," to implement
provisions of the Clinger-Cohen Act (also known as AInformation
Technology Management Reform Act of 1996" and for other purposes.
The revision modifies sections of the Circular concerning information
systems and information technology management to follow more closely
provisions of the Clinger-Cohen Act and OMB Circular A-11. These
sections involve the acquisition, use, and disposal of information
technology as a capital asset by the Federal government to improve
the productivity, efficiency, and effectiveness of Federal programs.
OMB
has issued previous guidance regarding the Clinger-Cohen Act implementation,
including OMB Memoranda M-96-20, "Implementation of the Information
Technology Management Reform Act of 1996;" M-97-02, "Funding Information
Systems Investments;" M-97-09, "Interagency Support for Information
Technology;"M-97-15, "Local Telecommunications Services Policy;"
and M-97-16, "Information Technology Architectures." As a convenience
to readers, these Memoranda are rescinded and their content incorporated
into this Circular.
This
revision also incorporates the content of three other OMB Memoranda.
The guidance in Memorandum M-98-09, on the handbook requirement
of the 1996 Electronic FOIA Amendments, has been incorporated into
Appendix IV. The guidance on "Implementing the Government Paperwork
Elimination Act" (OMB Memorandum M-00-10) has been inserted in Appendix
II, and the principles on "Incorporating and Funding Security in
Information Systems Investments" (OMB Memorandum M-00-07) have been
incorporated into Section 8b(4). Appendix IV has been expanded to
reflect these changes. With its incorporation into the Circular,
Memoranda M-98-09 is rescinded.
OMB
intends to review this Circular in 2001 for other revisions including
Information Policy, Security and Privacy. At that time, we will
review the Circular generally and update it to reflect plain language
principles.
AVAILABILITY:
You can find a full recompiled version of Circular A-130, including
the changes made here along with the existing sections that have
not changed on the Internet at the OMB web site,
http://www.whitehouse.gov/OMB/circulars/index.html
and at the CIO Council home page at http://www.cio.gov.
You can also obtain a copy of OMB Circular No. A-11, including
the supplement to Part 3, "The Programming Guide," at the OMB web
site and the CIO Council web site, or by calling the Budget Review
and Concepts Division at OMB at 202-395-3172.
FOR
FURTHER INFORMATION CONTACT: Tony Frater, Information
Policy and Technology Branch, Office of Information and Regulatory
Affairs, Office of Management and Budget, Room 10236, New Executive
Office Building, Washington, D.C. 20503. Telephone: (202) 395-3785.
SUPPLEMENTARY
INFORMATION:
Background:
The Clinger-Cohen Act (also known as "Information Technology
Management Reform Act of 1996") (Pub. L. 104-106, Division E,
codified at 40 U.S.C. Chapter 25) grants to the Director of the
Office of Management and Budget (OMB) authority to oversee the
acquisition, use, and disposal of information technology by the
Federal government, so as to improve the productivity, efficiency,
and effectiveness of Federal programs. It supplements the information
resources management (IRM) policies contained in the Paperwork
Reduction Act (PRA) (44 U.S.C. Chapter 35) by establishing a comprehensive
approach to improving the acquisition and management of agency
information systems through work process redesign, and by linking
planning and investment strategies to the budget process.
The
Clinger-Cohen Act establishes clear accountability for IRM activities
by creating agency Chief Information Officers (CIOs) with the authority
and management responsibility necessary to advise agency heads on
budget, program, and implementation issues concerning information
technology. Among other responsibilities, CIOs oversee the design,
development, and implementation of information systems. CIOs also
monitor and evaluate system performance and advise agency heads
whether to modify or terminate those systems. The Clinger-Cohen
Act directs agencies to work together towards the common goal of
using information technology to improve the productivity, effectiveness,
and efficiency of Federal programs and to promote an interoperable,
secure, and shared government-wide information resources infrastructure.
OMB
Circular No. A-130, "Management of Federal Information Resources,"
contains the policy framework for the management of Federal information
resources. OMB last revised Circular A-130 on February 20, 1996
(61 FR 6428). To provide agencies with additional guidance on implementing
the Clinger-Cohen Act, and for other purposes, OMB on April 13,
2000 (65 FR 19933) requested public comment on a proposed revision
to this Circular. In addition to publishing the proposed revision
in the Federal Register, OMB posted it on its public web site and
sent copies of the proposal directly to Federal agencies.
Comments
on the Proposed Revision to Circular A-130
In
response to the request for public comment, OMB received specific
comments from thirty four organizations and individuals. Federal
agencies submitted the majority of comments, but non-profit organizations
and concerned citizens also responded. Most comments proposed changes
in clarity and detail. Where these comments added clarity and did
not conflict with the substance of the provision in question, OMB
incorporated them. Several organizations suggested changes to parts
of the Circular that are not within the scope of this update of
the Circular. OMB intends to review Circular No. A-130 for other
revisions in 2001.
We
describe below the principal substantive issues raised in the comments
and our responses to them.
1.
Comments regarding the IT Capital Plan
A
number of agencies wanted greater clarification regarding the distinction
between the Information Technology (IT) Capital Plan and the Information
Resources Management (IRM) Strategic Plan. We have updated the section
outlining the IT Capital Plan and the IRM Strategic Plans. The new
section describes in much greater detail, and in so doing clarifies,
the different objectives of the two plans: the IT Capital Plan is
operational in nature while the IRM Strategic Plan is a long range
planning document.
The
IRM Strategic Plan is the agency's IT vision or roadmap that will
align its information resources with its business strategies and
investment decisions. As an example, the IRM Strategic Plan might
include the mission of the agency, key business processes, IT challenges,
and guiding principles.
Conversely,
the IT Capital Plan provides the justification for individual assets.
A sample IT Capital Plan would include: the business case, expected
benefits and costs, schedule, return on investment analysis, performance
measures to evaluate the effectiveness of the investment, an examination
of the alternative solutions, an acquisition strategy, and a discussion
of how that system comports with IT security and privacy guidance.
The
Government Performance and Results Act requires agencies to develop
and submit to OMB agency Strategic Plans. Each agency submits this
information annually along with its Performance Plans, as part of
its budget submission to OMB. IRM Strategic Plans should support
the Agency Strategic Plans, describing how information resources
will help accomplish agency missions and ensuring that IRM decisions
are integrated with organizational planning, budget, financial management,
procurement, human resources management, and program decisions.
The IT Capital Plan, on the other hand, supports the goals and missions
identified in the IRM Strategic Plan, is an operational document,
and is updated twice yearly. The IT Capital Plan is largely comprised
of existing documents that accompany the agency budget submission,
as updated to reflect the Presidential budget request to Congress.
The updated IT Capital Plan becomes the implementation plan for
the budget year.
2.
Comments on the relationship between the agency Enterprise Architecture
and the agency capital planning and investment control process
Several
agencies wanted further elaboration on how the Enterprise Architecture
(EA) and the capital planning and investment control (CPIC) process
should work together. To address these comments, we include information
on the EA within the body of Section 8b and elaborate on its relationship
with the capital planning and investment control process. In doing
so, information contained in the proposed Appendix II regarding
the EA (April 13, 2000 (65 FR 19933)) has been incorporated into
Section 8b(2). Appendix II is now dedicated to information on implementing
the Government Paperwork Elimination Act.
We
also add a discussion that describes how the EA documents linkages
between mission needs, information sources and content, and information
technology capabilities. The EA should inform the CPIC process by
defining the technologies and information critical to operating
an agency's business, and by creating a roadmap which enables the
agency to transition from its current to its targeted state. The
EA helps the agency respond to changing business needs, and ensures
that potential solutions support the agency's targeted state. A
proposed IT solution that does not comply with the EA should not
be considered as a possible investment, and should not enter the
CPIC process. The CPIC process helps select, control and evaluate
investments that conform with the EA.
For
example, during the select stage of capital planning an agency identifies
and investigates different potential solutions for an investment.
An agency then selects the option with the best business case. If
any of these alternatives does not conform with the EA, the agency
should drop it from consideration.
Another
example might include an agency considering a new financial management
system. The new system will require users to have a certain computing
environment in order to operate the proposed system. During the
select stage of capital planning, the agency should review the EA
to determine if that proposed system design is appropriate for all
of the necessary users in the organization. Users in field offices,
for example, may not have the computing resources to use the system.
The agency must consider the costs of upgrading these users' computing
resources in the evaluation of this alternative. If the system is
selected, the agency must incorporate, into the EA, its impact on
business processes, data, security, etc.
There
were also comments regarding how the Federal Enterprise Architecture
(FEA) framework relates to the agency Enterprise Architecture. The
Chief Information Officers Council created and currently maintains
the FEA. We discuss the FEA in Appendix IV; agencies should address
the Federal framework when developing the agency-specific EA. Collaboration
among agencies who share a common business function promotes information
sharing and is critical for the creation of a responsive, customer-focused
electronic government.
3.
Comments on the threshold for a major information system
A
few agencies wanted OMB to create a dollar threshold for major information
systems. We did not adopt this recommendation.
Since
1985, OMB has included in Circular A-130 a definition for what is
a "major information system" (50 FR 52730, 52735; December 24, 1985.)
Since its revision in 1994, the Circular has defined "major information
system" as follows: "an information system that requires special
management attention because of its importance to an agency mission;
its high development, operating, or maintenance costs; or its significant
role in the administration of agency programs, finances, property,
or other resources" (59 FR 37906, 37909; July 25, 1994.) As this
definition indicates, whether an information system qualifies as
"major" depends on the particular circumstances of that system and
its context within the agency's operations. Therefore, an information
system that is "major" for one agency may not necessarily be "major"
for another agency. This determination is to be made by the respective
agency, and this determination necessarily involves an exercise
of judgment.
Because
there is significant variance among agency information technology
budgets, we think it is inadvisable to establish a uniform, one-size-fits-all
dollar threshold across all agencies, and therefore we have not
done so.
4.
Comments on Data Quality concerns
A
few organizations inquired about the quality of Federal data. Ensuring
the quality of the information that the Federal Government disseminates
to the public is very important. Federal agencies must take seriously
their responsibility to ensure the quality of their data. OMB works
with the agencies to ensure the quality of Federally disseminated
information in several ways, including the review of collections
of information under the Paperwork Reduction Act (to ensure that
collections "maximize usefulness"), statistical coordination and
review, and the establishment in this Circular of general policies
for information dissemination. The current Analysis of Key Sections
in Appendix IV stresses the importance of data quality protections.
OMB intends to review data quality policies in 2001 and to issue
new guidance as appropriate.
5.
Comments on Computer Security
Several
agencies inquired about changes regarding computer security and
privacy. OMB Memorandum M-00-07 "Incorporating and Funding Security
in Information Systems Investments" (February 28, 2000) is incorporated
into Section 8b(3).
Of
special note, Title X, Subtitle G, "Government Information Security
Reform" of the FY 2001 Defense Authorization Act (P.L. 106-398),
was enacted during the final stages of revision to this Circular.
In order to include these reforms, and other important computer
security modifications, we plan more substantive changes when we
revise Circular A-130 in 2001. During the upcoming revision process,
we will take into consideration the comments that we have received
on computer security.
6.
Comments on information dissemination and information resources
management
One
organization suggested we add to Section 9 "Assignment of Responsibilities"
a provision to reflect Section 5403 of the Clinger Cohen Act (40
U.S.C. 1503). Section 5403 requires agencies, in the designing of
IT systems for disseminating information to the public, to reasonably
ensure that an index of information disseminated by the system is
included in the directory, created by the Superintendent of Documents
pursuant to 44 U.S.C. 4101. OMB has included a new Section 9a(14)
to reiterate Section 5403.
One
organization expressed concern that language in Appendix IV (Sections
8a(5) and 8a(6)) describing agency requirements for the Government
Information Locator Services (GILS) could lead to agency non-compliance
with those requirements. OMB expects all agencies to comply with
the information dissemination provisions of the PRA and of the E-FOIA
Amendments to the Freedom of Information Act. In this regard, in
accordance with the PRA (44 U.S.C. 3511) and the FOIA (5 U.S.C.
552(g)), each agency must develop and make available to the public
(including through the Government Information Locator Service) an
inventory that includes the agency's major information systems.
In
addition, with respect to the "information resources management"
responsibilities of each agency under the PRA (44 U.S.C. 3506(b)),
OMB continues to believe that an agency needs to focus its management
attention on its "major" information systems. For this reason, an
agency's management of its information resources is best improved
by having the agency maintain an inventory of its "information resources"
that includes those major information systems (rather than all of
the agency's information systems).
In
sum, in addition to reflecting the passage of the E-FOIA Amendments,
the revisions to Section 9 also clarify the agency obligations under
the PRA and FOIA. These revisions reiterate that each agency must
maintain and disseminate an inventory of its major information systems
(these systems may be electronic or paper -- the Circular's definition
of "major information systems" is format neutral). The revisions
also clarify that, under the "information resources management"
responsibilities in Section 3506(b)(4) of the PRA, each agency needs
to maintain an inventory of its other "information resources" (such
as personnel and funding) at the level of detail that the agency's
managers believe is most appropriate for use in the agency's management
of its information resources.
Because
this revised Circular A-130 is not being reprinted here in its entirety,
changes from the previous version are provided below. A copy of
the recompiled Circular (consisting of the February 1996 Circular
and the amendments in this notice) is available on OMB's web site
(see "Availability" above).
Section
3.
Authorities. This section is amended to cite and
to incorporate changes necessitated by the Clinger-Cohen Act, the
Government Performance and Results Act (GPRA), and Executive Order
13011.
Section
5.
Background. A discussion of the basic principles
and goals of the Clinger-Cohen Act is added.
Section
6.
Definitions. The terms "Chief Information Officers
Council" and "Information Technology Resources Board" are introduced
to reflect the interagency support structures established by Executive
Order 13011. The terms "executive agency" and "national security
system" are introduced to reflect the definitions found in the Clinger-Cohen
Act. The term "information technology" is amended to reflect definitional
changes made by the Clinger-Cohen Act, and is supplemented by the
limiting term "national security system" to clearly identify those
systems to which the Circular applies. The term "capital planning
and investment control process" is introduced to assist agencies
in the reporting requirements of the Clinger-Cohen Act.
Section
7. Basic Considerations and Assumptions. The existing
basic considerations and assumptions are supplemented with a modified
subsection (i) and new subsection (r) to reflect the relevant goals
and purposes of the Clinger-Cohen Act and Executive Order 13011.
Section
8b. Policy. Information Systems and Information Technology
Management. This section is substantially revised to implement
the policies of the Clinger-Cohen Act and the principles of Executive
Order 13011. Previous subsections (8b(1)-8b(5)) have been merged
and revised to integrate requirements under Clinger-Cohen Act, the
Government Performance and Results Act (Pub. L. 103-62), and revisions
to OMB Circular A-11.
Section
9a, All Federal Agencies, is changed to reflect
the new Chief Information Officer (CIO) position created by the
Clinger-Cohen Act, and reflects developments since the Circular
was last revised in February 1996
Section
9b, Section 9c, Section 9e, Section 9h, are revised to reflect responsibilities
described in the Clinger-Cohen Act and Executive Order 13011.
Accordingly,
OMB revises Circular A-130 as set forth below, and rescinds OMB
Memoranda M-96-20, M-97-02, M-97-09, M-97-15, M-97-16, and M-98-09.
Jacob
J. Lew
Director
1.
Section 3, "Authorities," is revised to read as follows:
3.
Authorities: OMB issues this Circular pursuant to the Paperwork
Reduction Act (PRA) of 1980, as amended by the Paperwork Reduction
Act of 1995 (44 U.S.C. Chapter 35); the Clinger-Cohen Act (also
known as "Information Technology Management Reform Act of 1996")
(Pub. L. 104-106, Division E); the Privacy Act, as amended (5 U.S.C.
552a); the Chief Financial Officers Act (31 U.S.C. 3512 et seq.);
the Federal Property and Administrative Services Act, as amended
(40 U.S.C. 487); the Computer Security Act of 1987 (Pub. L. 100-235);
the Budget and Accounting Act, as amended (31 U.S.C. Chapter 11);
the Government Performance and Results Act of 1993(GPRA); the Office
of Federal Procurement Policy Act (41 U.S.C. Chapter 7); the Government
Paperwork Elimination Act of 1998 (Pub. L. 105-277, Title XVII),
Executive Order No. 12046 of March 27, 1978; Executive Order No.
12472 of April 3, 1984;and Executive Order No. 13011 of July 17,
1996.
2.
Section 5, "Background," is revised to read as follows:
5.
Background: The Clinger-Cohen Act supplements the information resources
management policies contained in the PRA by establishing a comprehensive
approach for executive agencies to improve the acquisition and management
of their information resources, by:
- focusing
information resource planning to support their strategic missions;
- implementing
a capital planning and investment control process that links
to budget formulation and execution; and
- rethinking
and restructuring the way they do their work before investing
in information systems.
The
PRA establishes a broad mandate for agencies to perform their information
resources management activities in an efficient, effective, and
economical manner. To assist agencies in an integrated approach
to information resources management, the PRA requires that the Director
of OMB develop and implement uniform and consistent information
resources management policies; oversee the development and promote
the use of information management principles, standards, and guidelines;
evaluate agency information resources management practices in order
to determine their adequacy and efficiency; and determine compliance
of such practices with the policies, principles, standards, and
guidelines promulgated by the Director.
3.
Section 6, "Definitions," is revised by adding five new definitions
(c,d,f,t, and v, below); revising the definition of "information
technology"; and redesignating the remaining definitions accordingly:
c.
The term "capital planning and investment control process " means
a management process for ongoing identification, selection, control,
and evaluation of investments in information resources. The process
links budget formulation and execution, and is focused on agency
missions and achieving specific program outcomes.
d.
The term "Chief Information Officers Council" (CIO Council) means
the Council established in Section 3 of Executive Order 13011.
f.
The term "executive agency" has the meaning defined in section 4(1)
of the Office of Federal Procurement Policy Act (41 U.S.C. 403(1)).
s.
The term "information technology" means any equipment or interconnected
system or subsystem of equipment, that is used in the automatic
acquisition, storage, manipulation, management, movement, control,
display, switching, interchange, transmission, or reception of data
or information by an executive agency. For purposes of the preceding
sentence, equipment is used by an executive agency if the equipment
is used by the executive agency directly or is used by a contractor
under a contract with the executive agency which (i) requires the
use of such equipment, or (ii) requires the use, to a significant
extent, of such equipment in the performance of a service or the
furnishing of a product. The term "information technology" includes
computers, ancillary equipment, software, firmware and similar procedures,
services (including support services), and related resources. The
term "information technology" does not include any equipment that
is acquired by a Federal contractor incidental to a Federal contract.
The term "information technology" does not include national security
systems as defined in the Clinger-Cohen Act of 1996 (40 U.S.C. 1452).
t.
The term "Information Technology Resources Board" (Resources Board)
means the board established by Section 5 of Executive Order 13011.
v.
The term "national security system" means any telecommunications
or information system operated by the United States Government,
the function, operation, or use of which (1) involves intelligence
activities; (2) involves cryptologic activities related to national
security; (3) involves command and control of military forces; (4)
involves equipment that is an integral part of a weapon or weapons
system; or (5) is critical to the direct fulfillment of military
or intelligence missions, but excluding any system that is to be
administrative and business applications (including payroll, finance,
logistics, and personnel management applications). The policies
and procedures established in this Circular will apply to national
security systems in a manner consistent with the applicability and
related limitations regarding such systems set out in Section 5141
of the Clinger-Cohen Act (Pub. L. 104-106, 40 U.S.C. 1451). Applicability
of Clinger-Cohen Act to national security systems shall include
budget document preparation requirements set forth in OMB Circular
A-11. The resultant budget document may be classified in accordance
with the provisions of Executive Order 12958.
4.
Section 7, "Basic Considerations and Assumptions," is amended
by revising Section 7i, and by adding Section 7r, as follows:
i.
Strategic planning improves the operation of government programs.
The agency strategic plan will shape the redesign of work processes
and guide the development and maintenance of an Enterprise Architecture
and a capital planning and investment control process. This management
approach promotes the appropriate application of Federal information
resources.
r.
The Chief Information Officers Council and the Information Technology
Resources Board will help in the development and operation of interagency
and interoperable shared information resources to support the performance
of government missions.
5.
Section 8b is revised to read as follows:
b.
How Will Agencies Manage Information Systems and Information Technology?
(1)
How will agencies use capital planning and investment control process?
Agencies
must establish and maintain a capital planning and investment control
process that links mission needs, information, and information technology
in an effective and efficient manner. The process will guide both
strategic and operational IRM, IT planning, and the Enterprise Architecture
by integrating the agency's IRM plans, strategic and performance
plans prepared pursuant to the Government Performance and Results
Act of 1993, financial management plans prepared pursuant to the
Chief Financial Officer Act of 1990 (31 U.S.C. 902a5), acquisition
under the Federal Acquisition Streamlining Act of 1994, and the
agency's budget formulation and execution processes. The capital
planning and investment control process includes all stages of capital
programming, including planning, budgeting, procurement, management,
and assessment.
As
outlined below, the capital planning and investment control process
has three components: selection, control, and evaluation. The process
must be iterative, with inputs coming from all of the agency plans
and the outputs feeding into the budget and investment control processes.
The goal is to link resources to results (for further guidance on
Capital Planning refer to OMB Circular A-11). The agency's capital
planning and investment control process must build from the agency's
current Enterprise Architecture (EA) and its transition from current
architecture to target architecture. The Capital Planning and Investment
Control processes must be documented, and provided to OMB consistent
with the budget process. The Enterprise Architecture must be documented
and provided to OMB as significant changes are incorporated.
(a)
What plans are associated with the capital planning and investment
control process?
In
the capital planning and investment control process, there are two
separate and distinct plans that address IRM and IT planning requirements
for the agency. The IRM Strategic Plan is strategic in nature and
addresses all information resources management of the agency. Agencies
must develop and maintain the agency Information Resource Management
Strategic Plan (IRM) as required by 44 U.S.C. 3506 (b) (2). IRM
Strategic Plans should support the agency Strategic Plan required
in OMB Circular A-11, provide a description of how information resources
management activities help accomplish agency missions, and ensure
that IRM decisions are integrated with organizational planning,
budget, procurement, financial management, human resources management,
and program decisions.
The
IT Capital Plan is operational in nature, supports the goals and
missions identified in the IRM Strategic Plan, is a living document,
and must be updated twice yearly. This IT Capital Plan is the implementation
plan for the budget year. The IT Capital Plan should also reflect
the goals of the agency's Annual Performance Plan, the agency's
Government Paperwork Elimination Act (GPEA) Plan, the agency's EA,
and agency's business planning processes. The IT Capital Plan must
be submitted annually to OMB with the agency budget submission.
annually. The IT Capital Plan must include the following components:
(i)
A component, derived from the agency's capital planning and investment
control process under OMB Circular A-11, Section 300 and the OMB
Capital Programming Guide, that specifically includes all IT Capital
Asset Plans for major information systems or projects. This component
must also demonstrate how the agency manages its other IT investments,
as required by the Clinger-Cohen Act.
(ii)
A component that addresses two other sections of OMB Circular
A-11: a section for Information on Financial Management, including
the Report on Financial Management Activities and the Agency's
Financial Management Plan, and a section entitled Information
Technology, including the Agency IT Investment Portfolio.
(iii)
A component, derived from the agency's capital planning and
investment control process, that demonstrates the criteria it
will use to select the investments into the portfolio, how it
will control and manage the investments, and how it will evaluate
the investments based on planned performance versus actual accomplishments.
(iv)
A component that includes a summary of the security plan from
the agency's five-year plan as required by the PRA and Appendix
III of this Circular. The plan must demonstrate that IT projects
and the EA include security controls for components, applications,
and systems that are consistent with the agency's Enterprise
Architecture; include a plan to manage risk; protect privacy
and confidentiality; and explain any planned or actual variance
from National Institute of Standards and Technology (NIST) security
guidance.
(b)
What must an agency do as part of the selection component of the
capital planning process?
It
must:
(i)
Evaluate each investment in information resources to determine
whether the investment will support core mission functions that
must be performed by the Federal government;
(ii)
Ensure that decisions to improve existing information systems
or develop new information systems are initiated only when no
alternative private sector or governmental source can efficiently
meet the need;
(iii)
Support work processes that it has simplified or otherwise redesigned
to reduce costs, improve effectiveness, and make maximum use
of commercial, off-the-shelf technology;
(iv)
Reduce risk by avoiding or isolating custom designed components,
using components that can be fully tested or prototyped prior
to production, and ensuring involvement and support of users;
(v)
Demonstrate a projected return on the investment that is clearly
equal to or better than alternative uses of available public
resources. The return may include improved mission performance
in accordance with GPRA measures, reduced cost, increased quality,
speed, or flexibility; as well as increased customer and employee
satisfaction. The return should reflect such risk factors as
the project's technical complexity, the agency's management
capacity, the likelihood of cost overruns, and the consequences
of under- or non-performance. Return on investment should, where
appropriate, reflect actual returns observed through pilot projects
and prototypes;
(vi)
Prepare and update a benefit-cost analysis (BCA) for each information
system throughout its life cycle. A BCA will provide a level
of detail proportionate to the size of the investment, rely
on systematic measures of mission performance, and be consistent
with the methodology described in OMB Circular No. A-94, "Guidelines
and Discount Rates for Benefit-Cost Analysis of Federal Programs";
(vii)
Prepare and maintain a portfolio of major information systems
that monitors investments and prevents redundancy of existing
or shared IT capabilities. The portfolio will provide information
demonstrating the impact of alternative IT investment strategies
and funding levels, identify opportunities for sharing resources,
and consider the agency's inventory of information resources;
(viii)
Ensure consistency with Federal, agency, and bureau Enterprise
architectures, demonstrating such consistency through compliance
with agency business requirements and standards, as well as
identification of milestones, as defined in the EA;
(ix)
Ensure that improvements to existing information systems and
the development of planned information systems do not unnecessarily
duplicate IT capabilities within the same agency, from other
agencies, or from the private sector;
(x)
Ensure that the selected system or process maximizes the usefulness
of information, minimizes the burden on the public, and preserves
the appropriate integrity, usability, availability, and confidentiality
of information throughout the life cycle of the information,
as determined in accordance with the PRA and the Federal Records
Act. This portion must specifically address the planning and
budgeting for the information collection burden imposed on the
public as defined by 5 CFR 1320;
(xi)
Establish oversight mechanisms, consistent with Appendix III
of this Circular, to evaluate systematically and ensure the
continuing security, interoperability, and availability of systems
and their data;
(xii)
Ensure that Federal information system requirements do not unnecessarily
restrict the prerogatives of state, local and tribal governments;
(xiii)
Ensure that the selected system or process facilitates accessibility
under the Rehabilitation Act of 1973, as amended.
(c)
What must an agency do as part of the control component of the
capital planning process?
It
must:
(i)
Institute performance measures and management processes that
monitor actual performance compared to expected results. Agencies
must use a performance based management system that provides
timely information regarding the progress of an information
technology investment. The system must also measure progress
towards milestones in an independently verifiable basis, in
terms of cost, capability of the investment to meet specified
requirements, timeliness, and quality;
(ii)
Establish oversight mechanisms that require periodic review
of information systems to determine how mission requirements
might have changed, and whether the information system continues
to fulfill ongoing and anticipated mission requirements. These
mechanisms must also require information regarding the future
levels of performance, interoperability, and maintenance necessary
to ensure the information system meets mission requirements
cost effectively;
(iii)
Ensure that major information systems proceed in a timely fashion
towards agreed-upon milestones in an information system life
cycle. Information systems must also continue to deliver intended
benefits to the agency and customers, meet user requirements,
and identify and offer security protections;
(iv)
Prepare and update a strategy that identifies and mitigates
risks associated with each information system;
(iv)
Ensure that financial management systems conform to the requirements
of OMB Circular No. A-127, "Financial Management Systems;"
(v)
Provide for the appropriate management and disposition of records
in accordance with the Federal Records Act.
(vi)
Ensure that agency EA procedures are being followed. This includes
ensuring that EA milestones are reached and documentation is
updated as needed.
(d)
What must an agency do as part of the evaluation component of
the capital planning process?
It
must:
(i)
Conduct post-implementation reviews of information systems and
information resource management processes to validate estimated
benefits and costs, and document effective management practices
for broader use;
(ii)
Evaluate systems to ensure positive return on investment and
decide whether continuation, modification, or termination of
the systems is necessary to meet agency mission requirements.
(iii)
Document lessons learned from the post-implementation reviews.
Redesign oversight mechanisms and performance levels to incorporate
acquired knowledge.
(iv)
Re-assess an investment's business case, technical compliance,
and compliance against the EA.
(v)
Update the EA and IT capital planning processes as needed.
(2)
The Enterprise Architecture
Agencies
must document and submit their initial EA to OMB. Agencies must
submit updates when significant changes to the Enterprise Architecture
occur.
(a)
What is the Enterprise Architecture?
An
EA is the explicit description and documentation of the current
and desired relationships among business and management processes
and information technology. It describes the "current architecture"
and "target architecture" to include the rules and standards and
systems life cycle information to optimize and maintain the environment
which the agency wishes to create and maintain by managing its IT
portfolio. The EA must also provide a strategy that will enable
the agency to support its current state and also act as the roadmap
for transition to its target environment. These transition processes
will include an agency's capital planning and investment control
processes, agency EA planning processes, and agency systems life
cycle methodologies. The EA will define principles and goals and
set direction on such issues as the promotion of interoperability,
open systems, public access, compliance with GPEA, end user satisfaction,
and IT security. The agency must support the EA with a complete
inventory of agency information resources, including personnel,
equipment, and funds devoted to information resources management
and information technology, at an appropriate level of detail. Agencies
must implement the EA consistent with following principles:
(i)
Develop information systems that facilitate interoperability,
application portability, and scalability of electronic applications
across networks of heterogeneous hardware, software, and telecommunications
platforms;
(ii)
Meet information technology needs through cost effective intra-agency
and interagency sharing, before acquiring new information technology
resources; and
(iii)
Establish a level of security for all information systems that
is commensurate to the risk and magnitude of the harm resulting
from the loss, misuse, unauthorized access to, or modification
of the information stored or flowing through these systems.
(b)
How do agencies create and maintain the EA?
As
part of the EA effort, agencies must use or create an Enterprise
Architecture Framework. The Framework must document linkages between
mission needs, information content, and information technology capabilities.
The Framework must also guide both strategic and operational IRM
planning.
Once
a framework is established, an agency must create the EA. In the
creation of an EA, agencies must identify and document:
(i)
Business Processes - Agencies must identify the work performed
to support its mission, vision and performance goals. Agencies
must also document change agents, such as legislation or new technologies
that will drive changes in the EA.
(ii)
Information Flow and Relationships - Agencies must analyze the
information utilized by the agency in its business processes,
identifying the information used and the movement of the information.
These information flows indicate where the information is needed
and how the information is shared to support mission functions.
(iii)
Applications - Agencies must identify, define, and organize
the activities that capture, manipulate, and manage the business
information to support business processes. The EA also describes
the logical dependencies and relationships among business activities.
(iv)
Data Descriptions and Relationships - Agencies must identify
how data is created, maintained, accessed, and used. At a high
level, agencies must define the data and describe the relationships
among data elements used in the agency's information systems.
(v)
Technology Infrastructure - Agencies must describe and identify
the functional characteristics, capabilities, and interconnections
of the hardware, software, and telecommunications.
(c)
What are the Technical Reference Model and Standards Profile?
The
EA must also include a Technical Reference Model (TRM) and Standards
Profile.
(i)
The TRM identifies and describes the information services (such
as database, communications, intranet, etc.) used throughout the
agency.
(ii)
The Standards Profile defines the set of IT standards that support
the services articulated in the TRM. Agencies are expected to
adopt standards necessary to support the entire EA, which must
be enforced consistently throughout the agency.
(iii)
As part of the Standards Profile, agencies must create a Security
Standards Profile that is specific to the security services
specified in the EA and covers such services as identification,
authentication, and non-repudiation; audit trail creation and
analysis; access controls; cryptography management; virus protection;
fraud prevention; detection and mitigation; and intrusion prevention
and detection.
(3)
How Will Agencies Ensure Security in Information Systems?
Agencies
must incorporate security into the architecture of their information
and systems to ensure that security supports agency business operations
and that plans to fund and manage security are built into life-cycle
budgets for information systems.
(a)
To support more effective agency implementation of both agency
computer security and critical infrastructure protection programs,
agencies must implement the following:
(i)
Prioritize key systems (including those that are most critical
to agency operations);
(ii)
Apply OMB policies and, for non-national security applications,
NIST guidance to achieve adequate security commensurate with
the level of risk and magnitude of harm;
(b)
Agencies must make security's role explicit in information technology
investments and capital programming. Investments in the development
of new or the continued operation of existing information systems,
both general support systems and major applications must:
(i)
Demonstrate that the security controls for components, applications,
and systems are consistent with, and an integral part of, the
EA of the agency;
(ii)
Demonstrate that the costs of security controls are understood
and are explicitly incorporated into the life-cycle planning
of the overall system in a manner consistent with OMB guidance
for capital programming;
(iii)
Incorporate a security plan that complies with Appendix III
of this Circular and in a manner that is consistent with NIST
guidance on security planning;
(iv)
Demonstrate specific methods used to ensure that risks and
the potential for loss are understood and continually assessed,
that steps are taken to maintain risk at an acceptable level,
and that procedures are in place to ensure that controls are
implemented effectively and remain effective over time;
(v)
Demonstrate specific methods used to ensure that the security
controls are commensurate with the risk and magnitude of harm
that may result from the loss, misuse, or unauthorized access
to or modification of the system itself or the information
it manages;
(vi)
Identify additional security controls that are necessary to
minimize risk to and potential loss from those systems that
promote or permit public access, other externally accessible
systems, and those systems that are interconnected with systems
over which program officials have little or no control;
(vii)
Deploy effective security controls and authentication tools
consistent with the protection of privacy, such as public-key
based digital signatures, for those systems that promote or
permit public access;
(viii)
Ensure that the handling of personal information is consistent
with relevant government-wide and agency policies;
(ix)
Describe each occasion the agency decides to employ standards
and guidance that are more stringent than those promulgated
by NIST to ensure the use of risk-based cost-effective security
controls for non-national security applications;
(c)
OMB will consider for new or continued funding only those system
investments that satisfy these criteria. New information technology
investments must demonstrate that existing agency systems also
meet these criteria in order to qualify for funding.
(4)
How Will Agencies Acquire Information Technology?
Agencies
must:
(a)
Make use of adequate competition, allocate risk between government
and contractor, and maximize return on investment when acquiring
information technology;
(b)
Structure major information systems into useful segments with
a narrow scope and brief duration. This should reduce risk,
promote flexibility and interoperability, increase accountability,
and better match mission need with current technology and market
conditions;
(c)
Acquire off-the-shelf software from commercial sources, unless
the cost effectiveness of developing custom software is clear
and has been documented through pilot projects or prototypes;
and
(d)
Ensure accessibility of acquired information technology pursuant
to the Rehabilitation Act of 1973, as amended (Pub. Law 105-220,
29 U.S.C.794d).
6.
Section 9a is revised to read as follows:
a.
All Federal Agencies. The head of each agency must:
- Have
primary responsibility for managing agency information resources;
- Ensure
that the agency implements appropriately all of the information
policies, principles, standards, guidelines, rules, and regulations
prescribed by OMB;
- Appoint
a Chief Information Officer, as required by 44 U.S.C. 3506(a),
who must report directly to the agency head to carry out the
responsibilities of the agencies listed in the Paperwork Reduction
Act (44 U.S.C. 3506), the Clinger Cohen Act (40 U.S.C. 1425(b)
& (c)), as well as Executive Order 13011. The head of the
agency must consult with the Director of OMB prior to appointing
a Chief Information Officer, and will advise the Director on
matters regarding the authority, responsibilities, and organizational
resources of the Chief Information Officer. For purposes of
this paragraph, military departments and the Office of the Secretary
of Defense may each appoint one official. The Chief Information
Officer must, among other things:
(a)
Be an active participant during all agency strategic management
activities, including the development, implementation, and maintenance
of agency strategic and operational plans;
(b)
Advise the agency head on information resource implications
of strategic planning decisions;
(c)
Advise the agency head on the design, development, and implementation
of information resources.
(i)
Monitor and evaluate the performance of information resource
investments through a capital planning and investment control
process, and advise the agency head on whether to continue,
modify, or terminate a program or project;
(ii)
Advise the agency head on budgetary implications of information
resource decisions; and
(d)
Be an active participant throughout the annual agency budget
process in establishing investment priorities for agency information
resources;
- Direct
the Chief Information Officer to monitor agency compliance with
the policies, procedures, and guidance in this Circular. Acting
as an ombudsman, the Chief Information Officer must consider
alleged instances of agency failure to comply with this Circular,
and recommend or take appropriate corrective action. The Chief
Information Officer will report instances of alleged failure
and their resolution annually to the Director of OMB, by February 1st
of each year.
- Develop
internal agency information policies and procedures and oversee,
evaluate, and otherwise periodically review agency information
resources management activities for conformity with the policies
set forth in this Circular;
- Develop
agency policies and procedures that provide for timely acquisition
of required information technology;
- Maintain
the following, as required by the Paperwork Reduction Act (44
U.S.C. 3506(b)(4) and 3511) and the Freedom of Information Act
(5 U.S.C. 552(g)): an inventory of the agency's major information
systems, holdings, and dissemination products; an agency information
locator service; a description of the agency's major information
and record locator systems; an inventory of the agency's other
information resources, such as personnel and funding (at the
level of detail that the agency determines is most appropriate
for its use in managing the agency's information resources);
and a handbook for persons to obtain public information from
the agency pursuant to these Acts.
- Implement
and enforce applicable records management policies and procedures,
including requirements for archiving information maintained
in electronic format, particularly in the planning, design and
operation of information systems.
- Identify
to the Director of OMB any statutory, regulatory, and other
impediments to efficient management of Federal information resources,
and recommend to the Director legislation, policies, procedures,
and other guidance to improve such management;
- Assist
OMB in the performance of its functions under the PRA, including
making services, personnel, and facilities available to OMB
for this purpose to the extent practicable;
- Ensure
that the agency:
(a)
cooperates with other agencies in the use of information technology
to improve the productivity, effectiveness, and efficiency of
Federal programs;
(b)
promotes a coordinated, interoperable, secure, and shared government
wide infrastructure that is provided and supported by a diversity
of private sector suppliers; and
(c)
develops a well-trained corps of information resource professionals.
- Use
the guidance provided in OMB Circular A-11, "Planning, Budgeting,
and Acquisition of Fixed Assets," to promote effective and efficient
capital planning within the organization;
- Ensure
that the agency provides budget data pertaining to information
resources to OMB, consistent with the requirements of OMB Circular
A-11,
- Ensure,
to the extent reasonable, that in the design of information
systems with the purpose of disseminating information to the
public, an index of information disseminated by the system will
be included in the directory created by the Superintendent of
Documents pursuant to 41 U.S.C. 4101. (Nothing in this paragraph
authorizes the dissemination of information to the public unless
otherwise authorized.)
- 15.
Permit, to the extent practicable, the use of one agency's contract
by another agency or the award of multi-agency contracts, provided
the action is within the scope of the contract and consistent
with OMB guidance;
- 16.
As designated by the Director of OMB, act as executive agent
for the government-wide acquisition of information technology.
7.
Section 9b is revised to read as follows:
b.
Department of State. The Secretary of State must:
1.
Advise the Director of OMB on the development of United States positions
and policies on international information policy and technology
issues affecting Federal government activities and the development
of international information technology standards; and
2.
Be responsible for liaison, consultation, and negotiation with foreign
governments and intergovernmental organizations on all matters related
to information resources management, including federal information
technology. The Secretary must also ensure, in consultation with
the Secretary of Commerce, that the United States is represented
in the development of international standards and recommendations
affecting information technology. These responsibilities may also
require the Secretary to consult, as appropriate, with affected
domestic agencies, organizations, and other members of the public.
8.
Section 9c is revised by revising subparagraph 1, as follows:
c.
Department of Commerce. The Secretary of Commerce must:
- Develop
and issue Federal Information Processing Standards and guidelines
necessary to ensure the efficient and effective acquisition,
management, security, and use of information technology, while
taking into consideration the recommendations of the agencies
and the CIO Council;
9.
Section 9e is revised to read as follows:
e.
General Services Administration. The Administrator of General Services
must:
- Continue
to manage the FTS2001 program and coordinate the follow-up to
that program, on behalf of and with the advice of agencies;
- Develop,
maintain, and disseminate for the use of the Federal community
(as requested by OMB or the agencies) recommended methods and
strategies for the development and acquisition of information
technology;
- Conduct
and manage outreach programs in cooperation with agency managers;
- Be
a liaison on information resources management (including Federal
information technology) with State and local governments. GSA
must also be a liaison with non-governmental international organizations,
subject to prior consultation with the Secretary of State to
ensure consistency with the overall United States foreign policy
objectives;
- Support
the activities of the Secretary of State for liaison, consultation,
and negotiation with intergovernmental organizations on information
resource management matters;
- Provide
support and assistance to the CIO Council and the Information
Technology Resources Board.
- Manage
the Information Technology Fund in accordance with the Federal
Property and Administrative Services Act, as amended;
10.
Section 9h is revised by deleting subparagraph (10), renumbering
subparagraphs (11) and (12) as (10) and (11), and adding the following
new subparagraphs:
h.
Office of Management and Budget. The Director of the Office of Management
and Budget will:
- Evaluate
agency information resources management practices and programs
and, as part of the budget process, oversee agency capital planning
and investment control processes to analyze, track, and evaluate
the risks and results of major capital investments in information
systems;
-
Notify an agency if OMB believes that a major information system
project requires outside assistance;
- Provide
guidance on the implementation of the Clinger-Cohen Act and
on the management of information resources to the executive
agencies, to the CIO Council and to the Information
Technology Resources Board; and
- Designate
one or more heads of executive agencies as executive agent for
government-wide acquisitions of information technology.
11.
Appendix II to Circular A-130, which was formerly reserved, now
incorporates OMB's guidance on the Government Paperwork Elimination
Act (OMB Memorandum M-00-10; April 25, 2000); published at 65
FR 25508-21 (May 2, 2000).
In
addition to referencing 65 FR 25508-21, readers may also find a
full text of the GPEA guidance on the Internet at the OMB web site,
http://www.whitehouse.gov/OMB/memoranda/index.html
and at the CIO Council home page at http://cio.gov.
12.
Appendix IV of Circular A-130, is revised by revising section
1 and 2, and by adding supplemental discussions regarding Section
8(a)(5), 8(b), 9(a)(3), and 9(a)(4) of the Circular, as follows:
1.
Purpose
The
purpose of this Appendix is to provide a general context and explanation
for the contents of the key Sections of the Circular.
2.
Background
The
Clinger-Cohen Act (also known as "Information Technology Management
Reform Act of 1996" (Pub. L. 104-106, Division E, codified at 40
U.S.C. Chapter 25) grants to the Director of the Office of Management
and Budget (OMB) various authorities for overseeing the acquisition,
use, and disposal of information technology by the Federal government,
so as to improve the productivity, efficiency, and effectiveness
of Federal programs. It supplements the information resources management
(IRM) policies contained in the Paperwork Reduction Act (PRA) (44
U.S.C. Chapter 35).
The
Paperwork Reduction Act (PRA) of 1980, Public Law 96-511, as amended
by the Paperwork Reduction Act of 1995, Public Law 104-13, codified
at Chapter 35 of Title 44 of the United States Code, establishes
a broad mandate for agencies to perform their information activities
in an efficient, effective, and economical manner. Section 3504
authorizes the Director of OMB to develop and implement uniform
and consistent information resources management policies; oversee
the development and promote the use of information management principles,
standards, and guidelines; evaluate agency information management
practices in order to determine their adequacy and efficiency; and
determine compliance of such practices with the policies, principles,
standards, and guidelines promulgated by the Director.
The
Circular implements OMB authority under the PRA with respect to
Section 3504(b), general information resources management policy,
Section 3504(d), information dissemination, Section 3504(f), records
management, Section 3504(g), privacy and security, and Section 3504(h),
information technology. The Circular also implements certain provisions
of the Privacy Act of 1974 (5 U.S.C. 552a); the Government Paperwork
Elimination Act. (Pub. L. 105-277, Title XVII); the Chief Financial
Officers Act (31 U.S.C. 3512 et seq.); Sections 111 and 206 of the
Federal Property and Administrative Services Act of 1949, as amended
(40 U.S.C. 759 and 487, respectively); the Computer Security Act
(40 U.S.C. 759 note); the Budget and Accounting Act of 1921 (31
U.S.C. 1 et seq.); and Executive Order No. 12046 of March 27, 1978,
and Executive Order No. 12472 of April 3, 1984, Assignment of National
Security and Emergency Telecommunications Functions. The Circular
complements 5 CFR Part 1320, Controlling Paperwork Burden on the
Public, which implements other Sections of the PRA dealing with
controlling the reporting and recordkeeping burden placed on the
public.
3.
Analysis
Sections
8a(5) and 8a(6). Information Dissemination Policy.
Section
8a(5). As described in Section 11 of the "Electronic Freedom of
Information Act Amendments of 1996" (Pub. L. 104-231), 5 U.S.C.
552(g), an agency must place its index and description of major
information and record locator systems in its reference material
or guide. We expect that this index and description would include
an agency's Government Information Locator Service (GILS) presence
as well as any other major information and record locator systems
the agency has identified.
In
addition, each agency should prepare a handbook that describes in
one place the various ways by which a person can obtain public information
from the agency, as well as the types and categories of information
available. In preparing the handbook, each agency should review
the dissemination policies contained in this Circular. The handbook
should be in plain English and user-friendly. Where applicable,
it should indicate that the public is encouraged to access information
electronically via the agency's home page or to search in its reading
room, and that the public may also submit a request to the agency
under the Freedom of Information Act. "Types and categories" of
available information will vary from agency to agency, and agencies
should describe their information resources in whatever manner seems
most appropriate.
Although
the law does not require that the handbook be available on-line,
OMB encourages agencies to do so as a matter of policy. The handbook
should include the following elements:
- The
location of reading rooms within the agency and within its major
field offices, as well as a brief description of the types and
categories of information available.
- The
location of the agency's World Wide Web home page.
- A
reference to the agency's FOIA regulations and how to get a
copy.
- A
reference to the agency's FOIA annual report and how to get
a copy.
- The
location of the agency's GILS page.
- A
brief description of the types and categories of information
generally available from the agency.
In
addition, if there is an on-line version, it should have electronic
links to these elements wherever they exist.
Every
agency has a responsibility to inform the public within the context
of its mission. This responsibility requires that agencies distribute
information at the agency's initiative, rather than merely responding
when the public requests information.
Section
8b. Information Systems and Information Technology Management
Section
8b(1). Capital planning and investment control.
What
is the capital planning and investment control process?
The
capital planning and investment control process is a systematic
approach to managing the risks and returns of IT investments. The
process has three phases: select, control and evaluate. The process
covers all stages of capital programming, including planning, budgeting
and procurement. For additional information describing capital planning,
please consult Circular A-11.
What
will happen if I don't maintain an IT Capital Plan?
The
IT Capital Plan is the document that demonstrates to the agency
Investment Review Board and to OMB officials, that a project deserves
Federal funds. If the agency does not provide this information,
merits of the project can not be determined.
As
part of the agency IT Capital Plan, do I need to report on both
development, modernization and enhancement (DME) as well as Steady
State investments?
Yes.
Additional information is provided in Part 3 of OMB Circular No.
A-11, "Planning, Budgeting, and Acquisition of Capital Assets."
As
part of the portfolio view of the agency IT Capital Plan, do I
only need to report on major investments?
In
accordance with the Clinger-Cohen Act and Circular A-11, agencies
are required to manage all investments. They must also provide OMB
with individual IT Capital Plans for major projects, as well as
significant projects at the request of OMB.
Where
can I get more information about return on investment (ROI)?
Agencies
that would like to learn more about compiling and demonstrating
projected return on investments (ROI) are encouraged to consult
the Federal CIO Council document "ROI and the Value Puzzle". This
document may be obtained at the CIO Council's web page (www.cio.gov).
Why
do agencies need to conduct a Benefit-Cost Analysis?
Benefit-cost
analyses provide vital management information on the most efficient
allocation of human, financial, and information resources to support
agency missions. Agencies should conduct a benefit-cost analysis
for each information system to support management decision making
to ensure: (a) alignment of the planned information system with
the agency's mission needs; (b) acceptability of information system
implementation to users inside the Government; (c) accessibility
to clientele outside the Government; and (d) realization of projected
benefits. When preparing benefit-cost analyses to support investments
in information technology, agencies should seek to quantify the
improvements in agency performance results through the measurement
of program outputs.
The
requirement to conduct a benefit-cost analysis need not become a
burdensome activity for agencies. The level of detail necessary
for such analyses varies greatly and depends on the nature of the
proposed investment. Proposed investments in "major information
systems" as defined in this Circular require detailed and rigorous
analysis. This analysis should not merely serve as budget justification
material, but should be part of the ongoing management oversight
process to ensure prudent allocation of scarce resources. Proposed
investments for information systems that are not considered "major
information systems" can be analyzed more informally.
While
it is not necessary to create a new benefit-cost analysis at each
stage of the information system life cycle, it is useful to refresh
these analyses with up-to-date information to ensure the continued
viability of an information system prior to and during implementation.
Reasons for updating a benefit-cost analysis may include such factors
as significant changes in projected costs and benefits, significant
changes in information technology capabilities, major changes in
requirements (including legislative or regulatory changes), or empirical
data based on performance measurement gained through prototype results
or pilot experience.
How
will portfolio management aid in the selection of investments?
Agencies
must also weigh the relative benefits of proposed investments in
information technology across the agency. Given the fiscal constraints
facing the Federal government, agencies should fund a portfolio
of investments across the agency that maximizes return on investment
for the agency as a whole. Agencies should also emphasize those
proposed investments that show the greatest probability (i.e., display
the lowest financial and operational risk) of achieving anticipated
benefits for the organization.
Is
there a preferred model for information life cycles?
The
policy statements in this Circular describe an information system
life cycle. It does not, however, make a definitive statement that
there must be, for example, four versus five phases of a life cycle
because the life cycle varies by the nature of the information system.
Only two phases are common to all information systems - a beginning
and an end.
While
each phase of an information system life cycle may have unique characteristics,
the dividing line between the phases may not always be distinct.
For instance, both planning and evaluation must continue throughout
the information system life cycle. In fact, during any phase, it
may be necessary to revisit the previous stages based on new information
or changes in the environment in which the system is being developed.
Why
are post-implementation reviews necessary?
Agencies
will complete a retrospective evaluation of information systems
once operational to validate projected savings, changes in practices,
and effectiveness in serving stakeholders. These post-implementation
reviews may also serve as the basis for agency-wide learning about
effective management practices.
Section
8b(2). Enterprise Architectures.
How
will the EA guide the agency?
An
EA should guide the agency's management of information resources
for agency-wide information and information technology needs consistent
with Section 8b(2) of this Circular. The EA will help the agency
cope with technology and business change by serving as a reference
for updates to existing and new information systems. The EA will
also assure interoperability of business processes, data, applications
and technology as agencies integrate proposed information systems
projects with one another and with existing legacy systems.
Where
can I get more information describing the EA?
Agencies
that require additional information on developing or maintaining
an EA are encouraged to consult the Federal CIO Council document
entitled, "The Federal Enterprise Architecture (FEA) Framework,"
which is available on the CIO Council's web site (http://cio.gov).
The Architecture Plus web site (http://www.itpolicy.gsa.gov/mke/archplus/archhome.htm>)
also has a number of useful documents.
What
is an open systems environment?
An
open system should be based on an architecture with published or
documented interface specifications that have been adopted by a
standards settings body.
What
Enterprise Architecture issues must an agency consider that have
government-wide or multiple agency implications?
The
CIO Council has begun to address this issue in its "Federal Enterprise
Architecture Framework (FEAF), Version 1.0," and subsequent versions.
The FEAF was created to promote shared development for common Federal
processes, interoperability, and sharing of information among the
agencies of the Federal government and other governmental entities,
as required by the Clinger-Cohen Act. The FEAF is recommend for
use in (1) Federal government-wide efforts, (2) multi-Federal agency
(2 or more agencies) efforts and, (3) whenever Federal business-areas
and substantial Federal investment are involved with international,
state, or local governments. The Federal Enterprise Architecture
Framework, Version 1.0, which is a conceptual model, begins the
process of defining a better documented and coordinated structure
for cross-cutting businesses and technology developments in the
government. Collaboration among agencies who share a common business
function promotes information sharing and is a prerequisite for
the creation of a responsive electronic government.
Where
can I get more information on Federal EA efforts?
Some
other examples of ongoing Federal government efforts in this arena
are Treasury Enterprise Architecture Framework (TEAF) and Command,
Control, Communications, Intelligence, Surveillance, and Reconnaissance
(C4ISR).
Section
8b(3) Securing Agency Information Systems
How
should agencies incorporate security into management of information
resources?
Effective
security is an essential element of all information systems. A process
assuring adequate security must be integrated into the agency's
management of information resources. This process should be a component
of the both capital planning process and the EA. A system's security
requirements must be supported by the agency EA in order for it
to be considered during the select phase of the capital planning
process. Agencies will use the control and evaluate phases of capital
planning to ensure these security requirements are met throughout
the system's life cycle. For more information on computer security
please read Appendix III of this Circular.
Ultimately,
who determines the acceptable level of security for a system?
Each
agency program official must understand the risk to systems under
their control. They are also responsible for determining the acceptable
level of risk, ensuring adequate security is maintained to support
and assist the programs under their control, ensuring that security
controls comport with program needs and appropriately accommodate
operational necessities. In addition, program officials should work
in conjunction with Chief Information Officers and other appropriate
agency officials so that security measures support agency information
architectures.
Section
8b(4) Acquiring Information Technology
What
should agencies consider before acquiring a COTS solution?
Commercial-off-the-shelf
(COTS) products can provide agencies a cost effective and efficient
solution. However, often COTS products require customization for
seamless use. Therefore agencies must still thoroughly examine the
impact of a COTS product selection. A lessons-learned guide describing
the risks of COTS products has been published by the Information
Technology Resources Board (ITRB). The guide, entitled "Assessing
the Risks of Commercial-Off-The-Shelf (COTS) Applications," is available
on the ITRB web site (http://www.itrb.gov).
Section
9a(3). Chief Information Officer (CIO).
To
whom does the CIO report?
Each
agency must appoint a Chief Information Officer, as required by
44 U.S.C. 3506(a), who will report directly to the agency's head
to carry out the responsibilities of the agency under the PRA.
What
is the CIO's role in the capital planning process?
The
CIO will ensure that a capital planning process is established and
rigorously used to define and validate all information resource
investments. Through this process, the CIO will monitor and evaluate
the performance of the information technology portfolio of the agency
and advise the agency head on key budget, program, and implementation
issues concerning information technology.
Additionally,
the CIO will help establish a board composed of senior level managers,
including the Chief Financial Officer and Chief Procurement Executive,
who will have the responsibility of making key business recommendations
on information resource investments, and who will be continuously
involved. Many agencies will institute a second board, composed
of program or project level managers, with more detailed business
and information resource knowledge. They will be able to provide
technical support to the senior level board in proposing, evaluating,
and recommending information resource investments.
What
is the CIO's role in the annual budget process?
The
CIO will be an active participant during all agency annual budget
processes and strategic planning activities, including the development,
implementation, and maintenance of agency strategic plans. The CIO's
role is to provide leadership and a strategic vision for using information
technology to transform the agency. CIO's must also ensure that
all information resource investments deliver a substantial mission
benefit to the agency and/or a substantial return on investment
(ROI) to the taxpayer.
Additionally,
the CIO will ensure integration of information resource planning
processes and documentation with the agency's strategic, performance
and budget process, in coordination with the CFO and Procurement
Executive.
Section
9a(4).
Why
is the CIO considered an Ombudsman?
The
CIO designated by the head of each agency under 44 U.S.C. 3506(a)
is charged with carrying out the responsibilities of the agency
under the PRA. Agency CIOs are responsible for ensuring that their
agency practices are in compliance with OMB policies. It is envisioned
that the CIO will work as an ombudsman to investigate alleged instances
of agency failures to adhere to the policies set forth in the Circular
and to recommend or take corrective action as appropriate. Agency
heads should continue to use existing mechanisms to ensure compliance
with laws and policies.