Comment from email: Comments of Tom Schatz, President, Citizens Against Government Waste

[Inlining a best-effort version of the attached comment below. If there were links in the original, they are not maintained in the below version. Download the original attachment in the issue above to see the original comment.]

                             Thomas A. Schatz, President
                             1100 Connecticut Ave., N.W., Suite 650
                             Washington, D.C. 20036
                             cagw.org

September 19, 2017

Christopher Liddell Director American Technology Council The White House 1600 Pennsylvania Avenue, N.W. Washington, D.C. 20500

Dear Director Liddell,

Citizens Against Government Waste (CAGW) is a private, nonpartisan, nonprofit organization representing more than one million members and supporters nationwide, dedicated to educating the American public about waste, mismanagement, and inefficiency in the federal government. We are pleased to have the opportunity to provide comments on the administration’s draft plan to modernize federal information technology (IT).

We commend the efforts by the American Technology Council (ATC) to work toward developing a path forward to consolidate services, where appropriate; protect critical and sensitive data stored by the government; and strengthen the security and functionality of federal IT systems. As documented by numerous Government Accountability Office (GAO) reports and agency inspectors general, the road to modernizing federal IT has a bumpy history, including the listing of federal IT in the GAO’s past two High Risk reports. CAGW recommends that in addition to assessments already cited in the ATC draft report that GAO audits relating to IT also be included.

Among the recommendations in the draft ATC report is the accelerated adoption of cloud email and collaboration tools by federal agencies. One of the benefits of the use of cloud services, such as email, is the ability to scale the products based on need. By scaling these services as necessary, cost savings can be achieved. We are also pleased that the report encourages greater collaboration among agencies when acquiring IT assets, rather than building duplicative, stove- piped systems that lack interoperability.

However, we are concerned that the report will lead to further waste of taxpayer resources by proposing the expenditure of funds to duplicate IT tools that are currently available through the private sector. There are many examples of wasteful spending when a federal agency decided to create or develop a new software program that already exists and works well in the private sector. It is not the mission of the federal government to create software; it should instead maximize the use of available resources to improve services to the taxpayers, and there is nothing in the report that would prevent this mission creep from occurring. The federal government should not attempt to emulate the fast-paced innovation of the private sector, but should instead leverage readily available and time-tested resources that will improve services to the taxpayer. In addition, we would caution against using any language that might be construed as mandating a technology preference, including either vendor-specific or open source.

Like all procurement decisions, the best policy on the use of software is to place all products on equal footing so that taxpayers receive the best quality programs at the least cost. While open source may have its benefits in certain applications, it may increase the risk of cyberthreats by opening up government systems to intrusions once the source code is released, particularly for systems that require strong cybersecurity from outside, nation-state threats. A prime example of this is the recent Equifax data breach. The Equifax system was in the Apache Struts web- application software, an open source program that was exploited by hackers. Rather than specify open source as a preferred or mandated technology, it should be allowed to compete against other technologies, with a contract award given to the technology that best meets the needs of the agency.

CAGW is very concerned about the heavy reliance within the report on the U.S. Digital Services (USDS). The USDS is an Obama administration creation that is staffed with term-limited, full- time, private sector individuals who serve between 3 to 12 months. These individuals may or may not fully understand the requirements and restrictions of the Federal Acquisition Regulation (FAR), which is critical to federal IT procurement. In addition, because the Office of Management and Budget (OMB) is the primary agency controlling this staff, it is superfluous to designate USDS as a support office within the report. CAGW recommends that any direct reference to USDS be stricken from the draft report. In addition, much of the work being designated as being performed by the USDS in the draft report may be better suited to the acquisition/migration cadres that will be created by OMB as noted on page 24 of the report.

Overall, the report appears to favor increasing the bureaucracy surrounding IT procurement and modernization, while relying too heavily on creation of an open source environment, rather than seeking to streamline the process and enhance competition. None of these features will help modernize federal IT or save taxpayer resources.

Thank you for the opportunity to weigh in on the report before it is finalized. If you have any questions, please feel free to contact either myself or Deborah Collier at (202) 467-5300.

Sincerely,

Thomas A. Schatz President

GSA / modernization

Comment from email: Comments of Tom Schatz, President, Citizens Against Government Waste #69