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Public comment from NetApp #32

Open OMBPublicComments opened 5 years ago

OMBPublicComments commented 5 years ago

www.netapp.com www.cloud.netapp.com NetApp, U.S. Public Sector, Inc. 1921 Gallows Road Suite 600 Vienna, VA 22182

October 24, 2018

Ms. Suzette Kent Federal Chief Information Officer Office of Management and Budget Executive Office of the President 1650 Pennsylvania Avenue, N.W. Washington, D.C. 20502

Dear Ms. Kent, Thank you for providing industry the opportunity to comment on the 9/24/2018 update to the Federal Cloud Computing Strategy (“Cloud Smart”). NetApp, Inc., is the data authority for the hybrid cloud. We provide a full range of hybrid cloud data services that simplify management of applications and data across cloud and on-premises environments. Together with our partners, we empower global organizations to unleash the full potential of their data. We were incorporated in 1992 and are headquartered in Sunnyvale, California. NetApp, U.S. Public Sector, Inc. is a leading provider of data management and data storage solutions to the U.S. Federal Government. While NetApp has been known as an enterprise data storage provider, today NetApp’s portfolio includes software and cloud services that either run in or complement leading cloud service provider offerings. Because of our presence in traditional Government datacenters and focus on data management, NetApp has been in the middle of some of the challenges of migrating data and workloads from agency datacenters to one or more cloud service providers. NetApp applauds the fact that, going forward, the federal Government wants to see measurable results from its move to cloud services. Both private sector and public sector entities, alike, struggle with how to measure success when moving workloads from a traditional datacenter to a cloud service. NetApp’s experience in its commercial business is that while there is no one way or standard of measurement for “cloud success”, enterprises are turning more to digital key performance indicators (KPIs) to evaluate the success of their digital transformation investments. Digital KPIs are classified by Gartner as falling into two categories: (1) how well an organization is digitizing or transforming its business model and (2) how much additional revenue, margin, etc. is being generated via the digital change. See CIO Magazine, “Digital KPIs: Your Keys to Measuring Digital Transformation Success”, September 10, 2018. Examples of KPIs that measure digital transformation are (1) using a mobile application to complete a transaction as opposed to visiting a brick-and-mortar store, (2) measuring the reduction in use of call centers when digital assistants are provided, (3) measuring the utilization and reduced wait times using an online scheduling application. One can easily imagine how KPIs can be adapted to measure the success of federal agency initiatives for citizen facing services. NetApp has its own experience in measure the success of internal efforts to digitize and transform our internal processes. We believe that future procurements should include a pre-procurement planning phase where KPIs are defined by the procuring agency. Such KPIs would be useful to communicate to prospective contractors, but we also believe that they should not be part of the actual solicitation evaluation criteria, nor a deliverable under a procurement. Analogizing to the commercial use of KPIs, while project KPIs are a frequent component of commercial enterprise strategies to measure return on investment and make strategic operation plans, they are rarely deliverables that are expected of commercial vendors. Additionally, post-implementation KPIs should be measured and reported out so that agencies can make smart decisions about where to deploy cloud services and can learn from projects where KPIs have not been met. In the area of Cloud Smart Procurement, the Cloud Smart policy acknowledges gaps in government-wide guidance and buying practices. NetApp has seen that when agencies are focused on acquisition of cloud services, they are not necessarily fully appreciating the complexity of the marketplace for cloud services. For example, many cloud IaaS/PaaS/SaaS (XaaS) products are built up on the back-bones of the major cloud service providers. In the commercial market place, such services can be sold directly by the product publisher/manufacturer or they can be sold as part of a cloud service provider’s online marketplace. We have seen acquisition strategies for cloud services that completely ignore how a marketplace will be set up or how an agency could bring additional functionality into a cloud environment with subsequent purchases from a XaaS provider with complementary services. This decreases competition in the government purchasing sphere relative to what is available commercially. It would be best if acquisition strategies were open to both to provide the best and broad access to cloud services including native cloud services as well as these complementary services. This would maximize competition for commercially offered solutions. Once again, we thank you for your consideration of our comments. We welcome discussion of these comments with your team. Regards, Mary Jean (MJ) Schmitt Business Development Manager NetApp U.S. Public Sector