USDA's FITARA Implementation Plan: Highlights and Contractor Implications

The U.S. Department of Agriculture publicly released its Federal Information Technology Acquisition Reform Act (FITARA) Common Baseline and Implementation Plan shortly before the Thanksgiving holiday. That the USDA was the first major government agency to publish its implementation plan comes as no surprise because of a reformed IT oversight and guidance organization instituted by the Office of the Chief Information Officer several years ago. The CIO meets regularly with key stakeholders in department components to determine investment priorities and strategies for the USDA as a whole. This organizational structure is something of a forerunner to the common baseline reforms called for in FITARA, meaning that the USDA was prepared to address FITARA’s provisions more rapidly than many other federal agencies.

This said, with the implementation of FITARA, the USDA is now ready to take its governance of IT acquisition and management to a new level. Here are some of the important points from the USDA’s plan, as well as a discussion of some of the implications for government contractors.

IT Governance and Leadership

USDA’s common baseline guidance is called the Integrated Information Technology Governance Framework. The IITGF is “a holistic set of processes, procedures, and guidelines [including budget formulation/execution, enterprise architecture, capital planning, IT security, Section 508, Records Management, and portfolio/project management] that assists the OCIO’s customers improve mission delivery.” The IITGF establishes a new, integrated process for coordinating IT investment and acquisition efforts between departmental leadership and program managers.

At the highest organizational level is the Executive Information Technology Investment Review Board. The E-Board, as it’s called, is “composed of the Department’s senior leaders [who] ensure that proposed investments contribute to the Secretary's strategic vision and mission requirements, employ sound IT investment methodologies, comply with Departmental enterprise architecture, employ sound security measures, and provide the highest return on the investment or acceptable project risk.”

Below the E-Board is the Integrated Advisory Board (IAB), comprised of the Enterprise Architecture Advisory Council, Capital Planning Advisory Council, Enterprise Security Governance Council, and the Critical Partners Advisory Group. The IAB aligns all technology decisions with “Department and Agency/Staff Office level goals, strategies, objectives, and mission needs.” Approved IAB decisions are then kicked upstairs to the E-Board for final approval.

At the agency level, Investment Review Boards (IRBs) and Integrated Project Teams (IPTs) provide technical reviews and governance to proposed system development efforts. “Any agency-level proposed or existing initiatives that are or become an enterprise, shared service, or major IT investment … proceed through the governance boards, including the IAB and E-Board,” before being sent to the CIO for approval.

Implications for Contractors

The consolidation of IT governance and leadership will put greater emphasis on efficiency measures already in place at the USDA and it is here that contractors will feel the legislation’s effect the most.

Performance Reviews – Programs at USDA are directed to continue using TechStat and/or other performance review processes to identify non-performing programs. Those programs failing in performance will be scrutinized for alternative paths forward, including sunsetting and budget reallocation. The bottom line for vendors is that they will face greater pressure to meet performance metrics.

Strategic Sourcing – Enhanced coordination between the OCIO, the CFO, and key component stakeholders is intended to uncover additional areas for strategic sourcing. As the guidance notes, “the USDA is strongly encouraging leveraging Federal and Department-wide procurement vehicles.” This is nothing new for the USDA, which is among the heaviest users of GSA’s Schedule IT 70, Alliant Small Business, STARS II, and multiple generations of NASA’s SEWP vehicles. The bottom line for contractors is that open market competition at the USDA will continue to shrink.

Fewer New Programs – A greater need to justify funding and IT requirements will result from increased scrutiny of the USDA’s IT budget, potentially resulting in the initiation of fewer new programs. Shared services will be closely examined as alternatives. The bottom line for vendors is that closer budget scrutiny and the use of shared services could result in fewer new investments and thus fewer business opportunities.